ESBG position paper on commission communication

28 March 2001

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This paper stresses that the commission should not totally change the basis of the ISD which proved since its implementation in EU to be a reliable instrument, but should clarify and adjust it in order to create and ensure a level playing field for investment firms and to foster public confidence in the financial services. Also the ESBG sees a possible risk of uncoordinated duplication of work between the European Commission and FESCO that may finally lead to the adverse effect that investment firms have to face new sets of regulations from different legal sources with incoherent contents within short intervals.

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