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The Deutsche Aktien Institut (DAI) states that the quality of the legislation should not take a back seat to the ambitious planning schedules of the Commission and lawmakers. The present Consultation Paper is evidence of that danger. The task assigned to CESR on 27 March 2002 for a Level 2 regulation is still based on an outdated text version of the Directive. Thus the present consultation is neither complete nor conclusive.
According to the DAI, this can lead to misunderstandings and confusion. In addition, there is no example of transparent, consistent legislation. Precisely this, however, is what would go a long way towards enhancing the acceptance of the European financial center and a positive perception of Brussels activities in the public eye.
For this reason, some of the DAI's comments in this position paper go beyond the points addressed by CESR and make suggestions on aspects that will be a subject of the Level 2 regulation in an extended consultation.