EuropeanIssuers response to CESR consultation on a pan-European short selling disclosure regime

01 October 2009



EuropeanIssuers applauds the initiative to regulate short selling but says that the proposal needs to be completed and amended as follows:

 

- short selling should be addressed also from a corporate governance and market abuse perspective;

- naked short selling should be banned;

- the threshold for public and private disclosure should be aligned;
 
- short positions should be reported on a gross basis;

- flagging allows for disclosure of total short positions per share and should be further studied as a means of disclosure;

- the disclosure exemption for market makers should be carefully drafted to avoid loopholes.
 
EuropeanIssuers response
 

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