FBE response to revised CP on 1st set of mandates for MiFID

22 December 2004

FBE criticizes that the revised CP covers only a portion of the subjects included in the 1st set of mandates and questions how CESR plans to proceed with the other issues that are subject to the January 31 deadline, but not included in this new CP.

With regard to the subjects that are covered by the 2nd CP, we find it hard to respond in greater detail in those areas where no precise Level 2 text is provided.

The degree of detail in some areas is still not optimal. The degree of detail intended by CESR is far from clear. We do not have a clear indication as to the detail of the technical advice to be submitted to the Commission.

Finally, FBE strongly supports the introduction of transitional arrangements, and in particular an extension of the MiFID implementation deadline. The deadline of implementation should be extended until the end of 2007 as a minimum.

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