FBE response to CESR's work on the Provisional Mandate for the ISD

12 March 2004

In a letter to Mr Demarigny the European Banking Federation (FBE) replys to the CESR call for evidence on the provisional mandates for the Investment Services Directive implementing measures.

FBE announced its concern that the Commission want to make more use of regulations for those forthcoming provisions that will directly regulate relations between an investment firm and its clients or employees. However, directives taking into account national jurisdictions and the highly heterogeneous structures in the member states, would be more feasible.

Working on Level 2 measures while the Level 1 legislation is incomplete poses certain problems. In full accordance with the IIMG principle FBE recommends CESR to postpone its work on the measures for the “best execution” part of the provisional mandate until after the Directive is adopted.

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