March 2012

LSEG Response to ESMA Consultation Paper - guidelines on ETFs and other UCITS issues

The London Stock Exchange has provided a response to ESMA’s consultation (2012/44) on the guidelines on ETFs and other UCITS issues.

In our submission we highlight the following points:

• We support ESMA’s conclusion that products with broadly similar characteristics should be subject to the same level of regulatory requirements
  
  
• Though we can agree with ESMA’s proposed definition of ETFs, we would suggest that this wording is amended, as the reference to “market maker” in the definition could be misleading.
  
  
• We do not agree that there should be a further identifier to distinguish between synthetic and physical ETFs. Our view is that a simple distinction purely on this basis may be overly simplistic and could lead some less sophisticated investors to rely solely on these identifiers for their understanding of the products.

LSEG Response to ESMA Consultation Paper - guidelines on ETFs and other UCITS issues (file pdf - 226 KB)