FESE response to CESR Paper on implementing measures of FIMD/ISD2

15 April 2004

The Federation of European Securities Exchanges (FESE) published its response to the CESR paper on implementing measures of FIMD. On the methods and arrangements for reporting financial transactions FESE members are of the opinion that it is to early to make any judgement of the extent of commonalities between post-trade transparency requirements and transaction reporting requirements and the possibilities to exploit them. When drafting an inventory of minimum conditions of reporting systems, FESE urges CESR also to provide a level playing field for all transaction reporting solutions

FESE also repeats its concern about the level 1 concept of forwarding transaction information to the competent authority “of the most relevant market”. The Federation rejects all concepts that artificially reinforce the stickiness of liquidity and may thus be seen as influencing competition.

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