12 December 2003

FBE Response on working document on Prospectus Directive

In its response to the Commissions working document on the Prospectus Directive the European Banking Federation (FBE) is concerned about the remaining lack of clarity in certain areas such as the road map, the definition of debt, and the scope of the bank disclosure. The Federation also sees a need to further streamline the base prospectus.

Other points of concern relate to the degree of detail in the annexes, and the inclusion of the financial disclosure in Annex 1 Appendix A even though CESR has not yet finished its work on this subject.

FBE believes that the process could be still further improved in an important aspect by providing a brief explanatory memorandum or statement by the Commission giving the reasons for the policy choices made.

Full paper

© FBE