ICMA notes that during the period of absence of a unified approach of competent authorities to complex financial histories/significant financial commitments, the disclosure of identical or similar situations may differ in different Member States. The Member States should be reminded to accept this divergence.
Currently, some Member States for example resist or complicate passporting prospectuses from other Member States if they take a different view on a particular item of the disclosure. The divergent approaches to complex financial histories/significant financial commitments should not exacerbate this problem.
As most concerns expressed in relation to the Working Document have already been addressed, the comments are limited and of a technical nature.
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