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The rapporteur identified a number of subjects the Commission should take into account including among others the treatment of block trades and large transactions. The rapporteur calls to exclude some secondary market transactions from transaction and trade reporting obligations. With regard to client identifiers as part of the transaction report Mrs Kauppi calls for a standstill clause, to the effect that Member States where it is not currently enforced could not adopt it.
Other points include:
Furthermore, the rapporteur identified a number of conflicts of interest that need to be clarified. These include among others the best execution on an order-by-order basis and the inclusion of derivatives in non-complex products.
In a first short response the Commission already denied the inclusion of derivatives in non-complex products.