EACB response to CESR Consultation on “Possible Implementing Measures on Prospectuses”

26 July 2002

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The European Association of Cooperative Banks, EACB, responded to Consultation paper subject to the three items of:

Minimum Information (Article 6 (1) of the proposed Directive)
With reference to the building block approach, developed in a FESCO working document last year, the EACB fears that the process of documentation will be heavily overloaded by the mass of information to be provided.
The extended documentation process may also seriously hinder SMEs and their banks from accessing financial markets via stock exchanges. The process of due diligence will need more time. Hence, this will automatically raise the threshold for accessing capital markets.

Incorporation by Reference (Articles 10 (1) and (3) of the proposed Directive)
The EACB states that the incorporation of documents by reference should be supervised by the competent authority only in a formal manner. There should be no analysis of the contents because this would mean a further delay on the way to the European Passport.

Availability of the prospectus (Article 12 (7) of the proposed Directive)
The EACB supports the idea of the proposed directive to establish the web page of the competent authority as the forum information the public. There or in suited news-papers can also be a link/information on where to get a hard copy of the prospectus at a bank for free.

EACB document

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