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The FBE stresses that many further official steps still need to be taken before the Directive is adopted and implemented. Key third countries also need to approve the EU proposal and translate it into bilateral conventions. Furthermore, considering the changes made to the original proposal, the European Parliament and the European Economic and Social Committee may have to be consulted again.
FBE warns that banks will be unable to make important decisions and design system requirements until the required legislation is passed. Furthermore, a minimum of 12 months will be necessary to develop, test and implement IT systems and procedures. The FBE therefore urges the ECOFIN Council to defer implementation of the Directive to 1 January 2005.