EAPB position paper on second call for evidence on prospectus

03 April 2003

The European Association of Public Banks (EAPB) issued a position paper on CESR’s second call for evidence on the Prospectuses mandate. EAPB is concerned about the finalisation of the consultation and the fulfilling of CESR’s mandate.

Among others, EAPB welcomes the building block approach proposed by CESR. Nevertheless, the association fears that this will result in a high degree of inflexibility. Furthermore, and with regard to the large number of building blocks to be expected, there should be a clear ranking between the different registration documents to make the shelf registration system workable.

EAPB also stressed difficulties with CESR adopting the IOSCO standards verbatim as minimum requirements. Numerous requirements only appear to make sense for debt securities and derivative products to a limited extent. According to the association, using the IOSCO standards as minimum requirements puts a heavy burden especially on smaller issuers, and prevents them from issuing securities.

Position paper

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