EAPB position paper on CESR consultation on Prospectus Directive

05 February 2003

The European Association of Public Banks (EAPB) released a position paper on CESR’s consultation paper on possible implementing measures for the Prospectus Directive. The EAPB is most concerned about the finalisation of the consultation process. The association regards it as vital to start a second consultation process, even if this would extend the planned end of the consultation process from March to probably May or June 2003. With regard to the base prospectus, the EAPB considers it as crucial to develop valid disclosure requirements and to give the market participants enough time to contribute during the consultation process.

Among others, the association proposes that the obligation to disclose the actual solvency ratio should be waived. Actually, there are two solvency ratios, at least for the international banks, EAPB argues. The actual solvency ratios are changing permanently and the disclosed figures would be incorrect after a short time.

Position paper

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