-Among others the International Primary Market Association (IPMA) agrees with CESR’s approach of establishing straightforward requirements at Level 2 relating to time limits and price, and dealing with other relevant issues at Level 3, but not as a condition to the safe harbour. 
It is important, however, that Member States cannot impose more restrictive requirements to obtain the benefit of the safe harbour through Level 3 measures than are contemplated in the Market Abuse Directive and in Level 2 implementing measures.
 IPMA response to CESR  consultation on Market Abuse
      
      
      
      
        © IPMA - International Primary Market Association
    
      
      
      
      
      
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