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The majority of its members question, however, the timing of ESMA's intervention and hope, therefore, that the high level nature of the proposed guidelines will reduce the likelihood of significant new requirements arising in relation to the points covered in the draft guidelines, following the MiFID and MAD reviews. The EBF urges ESMA to coordinate closely with the European Commission to limit the need for further such modification.
The Federation notes that the draft guidelines will set out significant compliance and operational costs for many firms where existing policies, procedures, trading systems and controls do not meet all aspects of the guidelines. The EBF highlights the need to provide the industry with a reasonable timescale to carry out the necessary revision and implement the requirements in full.
Furthermore, the EBF is concerned with the practical implementation of some of the proposed guidelines. For example, investment firms operating electronic trading systems cannot be asked to check whether their clients are in a position to complete the transaction.