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Although the EBF welcomes the European Commission’s current proposals, members however have a number of important additional amendment suggestions.
EBF, for example, suggest however that it should also be explicitly stated in that paragraph that the requirement to publish a prospectus in the case of re-sales of a security does not apply if a prospectus has already been issued.
With regard to the Key Investor Information introduced for UCITS funds, the EBF notes that the Prospectus Directive covers a larger range of more diverse products, of which a significant amount is also suitable for many retail investors. However, many securities offered under the Prospectus Directive are primarily designed for the wholesale market and it is likely that many professional investors are also making use of the summary prospectus, EBF notes. EBF has therefore initiated a discussion on a possible standard template for point of sale disclosures to retail investors, which should however include a larger range of products including some that are not subject to the Prospectus Directive.
Further concerns relate in particular to authorities’ review of prospectus supplements; liability issues; the concept of incorporation by reference; and the notification process for the use of the passport.
The full response can be downloaded below.