ESBG Position Paper on ISD

21 February 2003

The internalisation of order-flows by large authorised intermediaries is of particular concern to the European Savings Banks Group (ESBG), largely because of its impact on the liquidity of the markets. The current approach of the European Commission, based on extensive pre-trade and post-trade transparency, is only partly convincing.

Further key issues for European savings banks operating in retail banking are the restructuring of operational and organisational procedures as well as the conduct of business obligations of investment firms. Having regard to these issues, the ESBG is of the opinion that the proposal of the Commission is too far-reaching and overly detailed in its requirements. Consequently, the principles of subsidiarity and of proportionality have not been sufficiently taken into account.

Position Paper

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