The Federation of European Securities Exchanges (FESE) released its response to the 
CESR  Consultation paper on Implementation Measures for the Transparency Directive. 
FESE  supports the general line to approach the regulatory issues surrounding the dissemination and storage of regulated information. Also, 
FESE  generally approves the proposal to introduce and define the category of “operators” as intermediaries between issuers and recipients of regulated information. However, an issue of major concern to a considerable number of our Member Exchanges is the timing of the information flow from issuers to Regulated Markets (and regulators) in the case of price-sensitive information.
FESE  also emphasises that the Transparency Directive and its implementing measures must in no way rule out (additional) ongoing information arrangements between issuers and Regulated Markets on the basis of the market’s admission rules. Such rules may of course not be designed, administered, and commercially exploited in a way that creates competitive advantages for Exchanges in their competition with (other) operators.
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