July 2011

LSEG has provided a response to ESMA's consultation on "Technical advice on possible delegated acts concerning the Prospectus Directive as amended by the Directive 2010/73/EU".

Our response outlines our views on the proposed technical advice on the following delegated acts:

• The format of the final terms to the base prospectus;
• The format of the summary of the prospectus and detailed content and the format of the specific form of the key information to be included in the summary; and
• Proportionate disclosure regime regarding Rights Issues, SMEs and issuers with reduced market capitalisation, Credit Institutions and other issuers.

• We support the efforts of ESMA to introduce measures that will help facilitate access for smaller companies, though we are concerned that these changes alone do not tackle the core issue of extending the base of investors that are readily able and willing to invest in SMEs.
• On the format of the Final Terms, we agree that ESMA's approach to developing a fixed format/list of items to be included in the Prospectus, is very helpful as it will help to set the parameters for scrutiny by competent authorities
• On the Summary, we support the principle of greater comparability between prospectus summaries 
• On Proportionate Disclosure regimes, we welcome the proposals in principle, but make the point that these should be on a per market basis and not part of a tiered regime within markets.

LSEG Response to ESMA Consultation on delegated acts concerning the Prospectus Directive(file pdf - 140 KB)