The document outlines some considerations for the penalty framework and application from both a secondary and primary market perspective.
ICMA has submitted its formal feedback for the European Commission’s proposed amendments to CSDR. ICMA’s
members provide three main recommendations to enhance the effectiveness
of the proposed revisions, along with some more technical refinements,
such as amending the regulatory text to address the asymmetry in the
cash compensation payment. The document also outlines some
considerations for the penalty framework and application from both a
secondary and primary market perspective.
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