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Regulatory policy


May 2013
LSEG Response to the IOSCO Consultation report on Principles for Financial Benchmarks
The London Stock Exchange Group has provided a response to the IOSCO consultation report on principles for financial benchmarks.

March 2013
LSEG Budget Submission for 2013/14
The London Stock Exchange Group has made a submission to UK Government ahead of the Budget announcement for tax year 2013/14.

February 2013
LSEG Response to the EBA/ESMA Consultation: Principles for Benchmarks-Setting Processes in the EU
The London Stock Exchange Group has provided a response to the ESMA-EBA consultation on principles for the benchmark-setting process in the EU.

LSEG Response to the IOSCO Consultation report on Financial Benchmarks
The London Stock Exchange Group has provided a response to the IOSCO consultation report on financial benchmarks.

January 2013
LSEG response to ESMA’s consultation paper on ‘Guidelines for establishing consistent, efficient and effective assessments of interoperability arrangements’
The London Stock Exchange Group has provided a response to ESMA’s consultation paper on ‘Guidelines for establishing consistent, efficient and effective assessments of interoperability arrangements’

December 2012
LSEG Response to EC Consultation on Recovery and Resolution for Financial Institutions other than Banks
The London Stock Exchange Group has provided a response to the EC's consultation on recovery and resolution of financial institutions other than banks.

LSEG Response to HM Treasury’s Consultation on Implementing the Wheatley Review: Draft Secondary Legislation
The London Stock Exchange Group has provided a response to HM Treasury’s consultation on the implementation of the recommendations in the Wheatley Review of LIBOR.
 
November 2012
LSEG Respose to the EU Commission Consultation on the Regulation of Indices 
The London Stock Exchange Group has responded to the EC consultation on a possible framework for the regulation of the production and use of indices serving as benchmarks in financial and other contracts.

October 2012
LSEG response to HMT consultation 'Financial Sector Resolution: broadening the regime'
The London Stock Exchange Group has responded to the HMT consultation on a possible recovery and resolution framework for financial market infrastructures.

May 2012
LSEG Response to the European Commission’s Consultation on Gender Imbalance in Corporate Boards in the EU
The London Stock Exchange Group has responded to the consultation issued by the European Commission (DG Justice) on gender imbalance in European corporate boards

March 2012
LSEG Response to ESMA Consultation Paper - guidelines on ETFs and other UCITS issues
The London Stock Exchange Group has provided a response to ESMA’s consultation (2012/44) on the guidelines on ETFs and other UCITS issues.

LSEG Response to ESMA Consultation on possible Delegated Acts in the EU Regulation on short selling and certain aspects of credit default swaps
The London Stock Exchange Group has provided a response to ESMA’s consultation (2012/98) on possible Delegated Acts in the EU Regulation on short selling and certain aspects of credit default swaps.

February 2012
LSEG Response to ESMA Consultation on draft technical standards in the EU Regulation on short selling and certain aspects of credit default swaps
The London Stock Exchange Group has provided a response to ESMA’s consultation (2012/30) on the EU Regulation on short selling and certain aspects of credit default swaps.

January 2012
LSEG response to MiFID/MiFIR questionnaire by Markus Ferber MEP
The London Stock Exchange Group has submitted a response to the questionnaire on MiFID/MiFIR by Markus Ferber MEP

LSEG response to FSA Consultation regarding Financial Resources Requirements for Recognised Bodies
The London Stock Exchange Group has provided a response to the FSA’s consultation on Financial Resources Requirements for Recognised bodies

November 2011
LSEG Response to BIS Consultation on Narrative Reports
LSEG has provided a response to the BIS Consultation on “Executive Remuneration and the Future of Narrative Reporting by Companies”

October 2011
LSEG Response to ESMA Consultation on Systems and Controls
LSEG has provided a response to the ESMA Consultation: "Guidelines on systems and controls in a highly automated trading environment for trading platforms, investment firms and competent authorities"

September 2011
LSEG Response to HM Treasury White Paper
LSEG has provided a full response to the Government's White Paper on the reform of the UK's financial regulatory structure.

LSEG Response to FSB Consultation on SIFIs
LSEG has provided a response to the Financial Stability Board’s consultation on the effective resolution of systemically important financial institutions

August 2011
LSEG Response to IOSCO Consultation
LSEG has provided a response to IOSCO's consultation report on the regulatory issues raised by the impact of technological changes on market integrity and efficiency

July 2011
LSEG has provided a full response to the European Commission's Green Paper on the corporate governance regime in the European Union

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"

June 2011
LSEG Response to early implementation of amendments to the Prospectus Directive
LSEG has provided a response to HM Treasury's Consultation on early implementation of amendments to the Prospectus Directive

April 2011
LSEG response to DG Taxud's public consultation
LSEG has provided a response to DG Taxud's public consultation on the taxation of the financial services sector

LSEG response to HM Treasury’s public consultation: “A new approach to financial regulation: building a stronger system”
LSEG has provided a response to HM Treasury’s public consultation: “A new approach to financial regulation: building a stronger system”

March 2011
LSEG Response to DG Internal Market and Services working document on Technical Details of a Possible EU Framework for Bank Recovery and Resolution.
 The London Stock Exchange Group has responded to some aspects of the working document of DG Internal Market and Services: “Technical Details of a Possible EU Framework for Bank Recovery and Resolution”.

LSEG Response to European Commission Consultation on Central Securities Depositories (CSDs) and the Harmonisation of Certain Aspects of Securities Settlement in the European Union.
The London Stock Exchange Group has submitted a response to the European Commission’s public consultation: “Central Securities Depositories and the harmonisation of certain aspects of securities settlement in the European Union".

February 2011
LSEG Response to ESMA's request for technical advice concerning the Prospectus Directive
The London Stock Exchange Group has submitted a response to ESMA's request for technical advice on possible delegated acts concerning the Prospectus Directive.

LSEG Response to Commission Communication: “Reinforcing sanctioning regimes in the financial services sector”
The London Stock Exchange has submitted a response to the European Commission's Communication: "Reinforcing sanctioning regimes in the financial services sector"

LSEG Response to European Commission Consultation on the Review of MiFID
The London Stock Exchange Group has submitted a full response to the European Commission’s public consultation: “Review of the Markets in Financial Instruments Directive (MiFID)”.

LSEG Budget Submission - 2011
The London Stock Exchange Group has made a submission ahead of the Government's Budget for the tax year 2011/12 with recommendations on improving SME access to equity finance, boosting UK corporate access to fixed income finance and using the UK capital markets as effective policy tools.

October 2010
LSEG Response to HMT Consultation: “A new approach to financial regulation: judgement, focus and stability”
The London Stock Exchange Group has provided a full response to the Government’s Consultation Document: “A new approach to financial regulation: judgement, focus and stability”

September 2010
LSEG Response to the Government's Green Paper on Financing a Private Sector Recovery
The London Stock Exchange Group has responded to the Government's consultation on how to improve access to finance for UK SMEs.

August 2010
LSEG Response to the European Commission's Consultation Paper on the Modernisation of the Transparency Directive
The London Stock Exchange Group has provided a response to the European Commission's Consultation Paper on the Modernisation of the Transparency Directive. 

Response to CESR's Consultation Paper on Standardisation and Exchange Trading of OTC Derivatives
The London Stock Exchange Group has provided a response to CESR's Consultation on Standardisation and Exchange Trading of OTC Derivatives.

Response to CESR's Consultation on Transaction Reporting of OTC Derivatives and Extension of the Scope of Transaction Reporting Obligations
The London Stock Exchange Group has provided a response to CESR's Consultation on Transaction Reporting of OTC Derivatives and Extension of the Scope of Transaction Reporting Obligations.

July 2010
LSEG Response to Commission CP on the Market Abuse Directive
The London Stock Exchange Group has responded the European Commission’s Consultation on a revision of the Market Abuse Directive (MAD). 

LSEG Response to the European Commission’s Consultation on Short Selling
The London Stock Exchange Group has responded the European Commission’s Consultation on Short Selling. Short selling is deeply embedded in all financial markets and is intrinsic to their efficiency.

Response to European Commission's consultation on Derivatives and Market Infrastructures
The London Stock Exchange Group has provided a full response to the European Commission's consultation on Derivatives and Market Infrastructures.

June 2010
LSEG Response to CESR MiFID Consultation Paper 10/510 - Non-Equity Markets Transparency
The London Stock Exchange Group has provided a response to CESR’s consultation on non-equity markets transparency.

May 2010
Markets Position Paper
The London Stock Exchange Group has submitted a Markets Position Paper to the European Commission, setting out its views on the key areas we believe the MiFID Review should address (post-trade data and pre-trade transparency waivers) and a broader vision of the approach to regulation of markets, the need for improvement in the post-trade space (clearing and counterparty risk) and the need for support for SMEs

LSEG Response to CESR MiFID Consultation Paper 10/394 - Equity Markets
The London Stock Exchange Group has provided a full response to CESR’s consultation on equity markets.

LSEG Response to CESR MiFID Consultation Paper CP10/292 - Transaction Reporting
The London Stock Exchange Group (LSEG) has provided a full response to CESR’s consultation on Transaction Reporting.

LSEG Response to CESR Consultation Paper CP10/417 - Investor protection and Intermediaries
The London Stock Exchange Group (LSEG) has provided a full response to CESR’s consultation on Investor protection and Intermediaries.

April 2010
Response to CESR's Call For Evidence on micro-structural issues of the European Equity Markets
The Exchange has responded to CESR's Call For Evidence on micro-structural issues.  This covers the areas of high frequency trading, sponsored access, co-location, tick sizes, fee structures and IOIs.

November 2009
Response to CESR's consultation on trade repositories in the European Union
The Group agrees that the establishment of trade repositories could be an important step in the development of tools that allow regulators to have access to more information regarding trading in derivatives markets. In particular we understand their need to be able to obtain a clear understanding of the size of the market, the number of transactions, the size and risk profile of outstanding positions and their potential impact in the event of a default or systemic failure. However, we believe that for any system of trade repositories to be fully effective, a critical part of the exercise will be determining the requirements for the system and processes to be applied in collecting and analysing the information. Material submitted to a TR must be in a standard, consistent format, capable of being interrogated and delivering meaningful and comprehensive reports and analysis. Without this, the ability of regulators to build their understanding of the market will be compromised.  

October 2009
Response to HM Treasury’s consultation on notifying trading suspensions in the market
The Exchange has responded to HM Treasury’s consultation on notifying trading suspensions in the market. Broadly, we are supportive of HM Treasury’s proposed use of RISs to disseminate information on the suspension of financial instruments from trading, as this would facilitate the suspension of OTC trading, which is not currently possible for practicable reasons.

August 2009
Response to the European Commission's consultation on possible initiatives to enhance the resilience of OTC derivatives markets
The London Stock Exchange Group has responded to the European Commission's consultation on possible initiatives to enhance the resilience of OTC derivatives markets. We agree with the Commission's objective of seeking to strengthen the safety of derivatives markets and assess how risks can be reduced. We believe that transparent markets facilitate the achievement of this objective as well as assisting in price determination and improving market efficiency. The trading of derivatives via public order books should be encouraged, however we recognise that not all products are suitable for exchange trading and there will continue to be a need for an OTC derivatives market, albeit subject to appropriate levels of transparency and controls. We also note that the Commission needs to be mindful of the potential systemic risks arising from seeking to bring some of the more complex products (notably Credit Default Swaps) on to CCPs and, in particular, the resulting concentration of risk in key market infrastructure providers.

July 2009
Response to the Rowlands Growth Capital Review
The Exchange has responded to the Rowlands Growth Capital Review from the Department for Business, Innovation and Skills. In our response we highlight the role of AIM in providing finance for UK SMEs, but explain that financing gaps still exist, many of them exacerbated by the current recession. Finally, we set out the policy measures that could be taken by government to improve access to finance for SMEs. This largely comprises changes to the Venture Capital Trust regime in the UK.

May 2009
Response to the FRC's Review of the Effectiveness of the Combined Code: Call for Evidence
Reflecting feedback from a variety of Primary Listed, Main Market companies and their advisers, the London Stock Exchange has responded to the FRC's call for evidence as part of their review of the effectiveness of the Combined Code,  in which we reinforce the success of the principles-based, 'comply or explain' approach and stress that the Code has a direct bearing on our markets as all UK-domiciled, Primary Listed Main Market companies are required to report on their application of the Code. 

Response to IOSCO’s Consultation on Direct Electronic Access (“DEA”)
The LSE Group has responded to IOSCO’s consultation, in which it outlines possible principles for DEA. We broadly agree with IOSCO’s proposed principles, which are in line with the principles underpinning Order Routing and MAC.

Response to the FSA's consultation on short selling
The Exchange has responded to the FSA's Discussion Paper 09/1 on the regulation of short selling. We are pleased that the FSA recognises the benefits of short selling to market efficiency and does not seek a ban or other structural changes to constrain the activity. While supporting greater transparency around short selling in principle, the Exchange does not necessarily support the FSA's proposal for a regime requiring public disclosure of individual net short positions. We ask for more information about the FSA's policy objectives to be able to comment in more detail on any transparency regime.

Response to IOSCO consultation on short selling:
The Exchange has responded to the consultation by IOSCO which outlines 4 principles for the effective regulation of short selling. The Exchange is supportive of the proposed principles and IOSCO's efforts to develop a more consistent international approach.

April 2009
IOSCO Hedge Fund Oversight Consultation Report
The Exchange has responded to IOSCO's consultation report examining regulatory approaches to hedge funds. In our response, we acknowledge the need to examine vulnerabilities in the global financial system, but stress the need to avoid inappropriate or excessive regulation where there is little evidence of market failure. We suggest that in line with the G20 requirements, any analysis should focus on issues of systemic importance as the priority. Finally, we note that London is the second largest global centre for hedge fund managers and as such the development of industry best practices should take particular note of the views of the major trade bodies located here as well as the Financial Services Authority. 

March 2009
HMT consultation on the legislative framework for the regulation of alternative finance investment bonds (sukuk)
The Exchange welcomes the opportunity to respond to this joint consultation between HM Treasury and the FSA.  The Exchange has played a pivotal role in establishing the UK as a gateway for global Islamic finance and promoting London’s international competitiveness.   

We agree with the move to align the regulatory treatment of alternative finance investments bonds with conventional debt securities and support the proposal for AFIBs to be subject to a mandatory listing requirement.

Response to the European Commission’s consultation on the review of the Prospectus Directive (Directive 2003/71/EC)
The Exchange has responded to the European Commission’s consultation on the review of the Prospectus Directive (PD). The Exchange welcomes the work undertaken by the Commission to reduce administrative burdens on issuers but thinks a number of improvements can still be made to simplify the application of the PD, particularly for small companies and pre-emptive offers.

Response to FSA’s Consultation Paper on the Structure of the Listing Regime
The Exchange has responded to the FSA’s Consultation Paper CP 08/21 “Consultation on Amendments to the Listing Rules and Feedback on DP08/1 (A Review of the Structure of the Listing Regime)".

February 2009
Response to UK Debt Management Office Consultation on Supplementary Methods for Distributing Gilts 
The London Stock Exchange has responded to the DMO's proposals regarding the potential introduction of additional distribution methods to supplement gilt auctions.

Response to BERR's consultation on the implementation of the Shareholder Rights Directive
The Exchange has responded to BERR's consultation on the exercise of certain rights of shareholders in listed companies. We support BERR's proposals and the work that has been conducted to incorporate our feedback from earlier negotiations regarding the Directive's implementation. We comment on the notice period for EGMs and the need for clarity on the definition of electronic voting. 

Response to the European Commission consultation on hedge funds
The Exchange has responded to the European Commission consultation on hedge funds. Whilst recognising that there is a need to examine vulnerabilities in the global financial system, there is also the need to avoid the temptation to over-regulate specific areas of the financial markets where there is little material evidence of market failure but where inappropriate and hurried regulatory intervention may damage the long term efficacy of public capital markets.

 

January 2009
Response to the FSA's consultation on rights issue subscription periods
The Exchange has responded to the FSA's consultation on shortening rights issue subscription periods.

Response to FSA’s Consultation Paper on Disclosure of Contracts for Difference
The London Stock Exchange has responded to the FSA’s consultation on a disclosure regime for Contracts for Difference (CFDs).

We generally support the FSA’s proposals to increase transparency on CFDs and we agree the scope of the regime should be extended to similar economic interests. However, we encourage the FSA to consider the Transparency Directive approach of disclosure of full notional exposure for countering anti-avoidance issues. 

Response to CESR’s call for evidence on the regulation of short selling
The LSE Group has responded to CESR’s call for evidence on the regulation of short selling. We strongly support CESR in working to achieving greater convergence between CESR Members in the short-selling space.

We believe that bans on short selling are both ineffective in countering concerns about market volatility, and damaging to the wider interests of market participants. However, we recognise that other measures may be desirable, such as increased disclosure.

Response to CESR’s call for evidence on the impact of MiFID on the functioning of equity secondary markets
The Exchange has responded to CESR's call for evidence on the impact of MiFID on the functioning of equity secondary markets. CESR is gathering views in anticipation of a formal European Commission Review – the findings of which will be published in 2010. The Exchange has been active in the formation of MiFID since the process first began over eight years ago. The review of how well MiFID is functioning is naturally an area of considerable interest to us. We believe the key question behind the reviews should be whether the market since MiFID’s introduction is fundamentally a better one. In our response, we highlight a number of issues such as the lack of a level playing field between venues: especially in relation to pre-trade transparency requirements. 

Response to FSA consultation on temporary short selling measures
The Exchange has responded to the FSA's consultation on temporary short selling measures. We welcome the decision to lift the Ban on short-selling and we support the decision to retain the Disclosure Obligation in the short term. We look forward to contributing more fully to the debate on the detail of any long term disclosure regime in the forthcoming comprehensive review.
 
The Effect of Short-selling Restrictions on Liquidity: Evidence from the London Stock Exchange
The London Stock Exchange commissioned research by Capital Markets CRC Limited on the effect of FSA's short selling prohibition on market quality. The research compared those FTSE 100 companies that are subject to the prohibition, against a control sample of those FTSE 100 securities that are not within the scope of the prohibition. The research indicated that market quality (defined as price volatility and liquidity) was reduced in the affected stocks in the period following the ban.

October 2008
Response to HM Treasury's consultation on amendments to Part 7 of the Companies Act 1989
We support the changes proposed in this consultation. We agree that the measures proposed to enhance and support central counterparty clearing, which is a key element of Part 7, are crucial for what is recognised as a vital element of market infrastructure; helping to guarantee transactions and produce efficiencies of risk management. We encourage Treasury to implement these changes as soon as possible, but we also make the point that Treasury's changes do not go far enough. Recent experience suggests that a fundamental review of default arrangements for the UK markets in all instruments is required.

Response to HM Treasury's consultation on the extension of the statutory regime for issuer liability
The Exchange has responded to this consultation. We welcome the review of the UK liability regime and the work that is being undertaken by the Government to shape and direct UK law. We support the proposals to include issuers of all securities admitted to trading on a UK Regulated Market or MTF. However, we seek some clarity on the scope of disclosure that is covered by the regime.

September 2008
Response to CESR call for evidence on post-trading infrastructures
The Exchange has responded to CESR’s call for evidence on identification of regulatory arrangements for post-trading infrastructures and advice on possible solutions in terms of bridging any potential differences in these arrangements.

The Exchange has responded to this consultation. We support the FSA's objective to modernise the sponsor regime for the Exchange’s Main Market and in so doing, move it to a more principles-based regime that is practical and reflects good market practice. However, we query the proposals that could result in a significant level of responsibility and liability being placed on issuers for the identification and management of conflicts of interest within its sponsor firm.

Response to the FRC's consultation on proposals for future arrangements for funding the FRC's activities in relation to accounting, auditing and corporate governance.
The Exchange has responded to this consultation. Whilst we support the work of the FRC, we raise concerns about the scale of the increases in the business levy and the consequent impact on quoted companies (particularly in terms of the potential for triple-charging and the effect on the overall cost of raising capital). We also query the basis for the proposals to replace income lost by dint of the removal of Government funding. Consequently, we request a wholesale review of the funding arrangements to create a level playing field for charging purposes.

May 2008
Response to HM Treasury review of sunset clauses under the market abuse regime
The Exchange has responded to HM Treasury review of sunset clauses relating to superequivalent provisions under the UK civil market abuse regime.

We support the proposal to retain the current UK superequivalent provisions for a further limited period, pending the EU review of the Directive. It would seem unnecessary and disruptive to change the regime now, only to potentially have to change it again in a couple of years’ time.

April 2008
Response to CESR consultation on the equivalence of Canadian and South Korean GAAP
The Exchange has responded to CESR’s consultation on the equivalence of Canadian and South Korean GAAP.

We are supportive of the conclusions reached by CESR and the resultant advice that the Commission should accept both Canadian and South Korean GAAP.

Response to the Financial Reporting Council's levy proposals for 2008/9
The Exchange has responded to the Financial Reporting Council's consultation regarding their levy proposals for 2008/9. In our response, we support the work of the Council, but raise concerns regarding the level, scope and apportionment of the business levy. However, we also acknowledge that the Council intends to consult more widely on their core funding requirements during 2008 and we signal our intention to contribute to that debate.

Response to FSA’s Discussion Paper on the Structure of the Listing Regime
The Exchange has responded to the FSA’s Discussion Paper 08/1 “A Review of the Structure of the Listing Regime”.

We support the FSA’s desire to ensure clearer labelling and to improve the general understanding amongst market participants of the terminology used to describe the listing regime. However, we believe that Option 1 of the FSA's proposals is a disproportionate response that may adversely affect existing and prospective issuers and investors and damage the UK’s competitive position. Under Option 2, the tiered structure of the Main Market would be retained and unintended adverse consequences for issuers and investors would thus be avoided.
 
March 2008
Response to FSA’s Consultation on the implementation of the Statutory Audit Directive (SAD) and the Company Reporting Directive (CRD) in the UK
The Exchange has responded to FSA’s consultation on the implementation of the Statutory Audit Directive (SAD) and the Company Reporting Directive (CRD) in the UK.

We support the majority of the FSA proposals regarding the implementation of the requirements on audit committees and corporate governance statements.

Response to the Financial Reporting Council's consultation on amending the Combined Code
The Exchange has responded to the Financial Reporting Council's consultation on potential revisions to the Combined Code. In our response, we welcome the Council's intention to focus on improving the practical application of the Combined Code and support the proposed amendments to allow an individual to chair more than one FTSE 100 company board and to also allow a Chairman to sit on the audit committee.
 
February 2008
Response to FSA's Consultation on amending Chapter 18 of the Listing Rules for investment entities
The Exchange has responded to the FSA's Consultation Paper CP08/1 in which they propose amending the Listing Rules where investment entities are considering listing depositary receipts.

Response to FSA’s Consultation on Disclosure of Contracts for Difference.
The Exchange has responded to FSA’s consultation on a possible disclosure regime for Contracts for Difference. We agree that some form of action needs to be taken. However, we believe that additional work needs to be undertaken before conclusions on the design of such a regime can be reached.

Response to CESR’s Consultation on the equivalence of Chinese, Japanese and US GAAP.
The Exchange has responded to CESR’s consultation on the equivalence of Chinese, Japanese and US GAAP. We are very supportive of the approach that CESR sets out in this consultation paper and we were encouraged by the similar support voiced at the recent open hearing on this subject.

October 2007
Response to the European Commission's communication on a simplified business environment for companies in the areas of company law, accounting and auditing
The Exchange has responded to the European Commission's communication on a simplified business environment for companies in the areas of company law, accounting and auditing.

Our response focuses on one aspect – the potential repeal of the second company law directive and the impact upon pre-emption rights. Pre-emption rights are highly valued by investors and we believe there is a strong case for retaining the requirement at EU level.

Response to BERR's consultation on UK implementation of the Directive on Statutory Audit (Policy Conclusions and Draft Regulations)
The Exchange has responded to BERR's consultation on UK implementation of the Directive on Statutory Audit (Directive 2006/43/EC).

Our response focuses on the provisions relating to audit committees and third country auditors, and we are broadly supportive of BERR's proposals.

Response to HM Treasury/FSA Consultation Paper on proposals for a UK recognised covered bonds legislative framework
The Exchange has responded to the joint consultation from HM Treasury and the FSA on proposals to develop a legislative framework for the issuance of covered bonds in the UK.

The consultation paper discusses the rationale and outline of the proposed legislative framework and how the FSA would go about implementing it. The consultation also sets out a regulatory impact assessment for the proposals and the draft Statutory Instrument. The Exchange supports the broad proposals and believes they would be of value to both issuers and investors. In addition, the Exchange provides views and makes recommendations on a number of points raised in the consultation.
 
September 2007
Response to FSA Discussion Paper on trading in MTF shares: impact of proposed stamp duty changes
The Exchange has responded to FSA Discussion Paper DP07/3 on trading of multilateral trading facility ("MTF") shares and the impact of proposed stamp duty changes.

DP07/3 discusses how the markets in MTF shares might be regulated if HM Treasury takes forward its plans to extend stamp duty intermediary relief to trading in MTF shares that takes place away from the systems of an MTF (i.e. OTC). The Exchange recognises the FSA has undertaken important and positive work with respect to the regulatory structure between organised venues. DP07/3 also reflects the Treasury’s aim of facilitating further competition in the market for MTF shares, and we welcome this in what is already a highly-competitive environment. However, the Exchange raises in its response a number of important issues that require careful consideration before the proposals are taken further.

August 2007
Response to FSA Consultation on Consequential Handbook Amendments: Post-Trade Transparency and Trade Data Monitors
The Exchange has responded to FSA's CP07/16 (Chapter 6) on Consequential Handbook Amendments: Post-Trade Transparency and Trade Data Monitors (TDMs).
 
The Exchange fully supports the proposal for a TDM regime, which we believe has the potential to address the market data needs of both market participants and regulators. However, we suggest amendments to some of the guidelines, where we do not believe that the current wording will achieve the desired outcome.

July 2007
Response to the European Commission's third consultation document on fostering an appropriate regime for shareholders' rights
The Exchange has responded to the European Commission's consultation on a possible Recommendation for fostering an appropriate regime for shareholders’ rights. Such a Recommendation would supplement the recently adopted Directive.

We support the Commission’s efforts to promote shareholders’ rights. However, we believe that some of the measures outlined in the consultation may not need to be addressed at the EU level, but should instead be left to the market to develop best practice or should be left to private contractual arrangements.

Response to FSA's Consultation Paper 07/10 - Notification Obligations under the Investment Exchanges and Clearing Houses Act 2006
The Exchange has responded to FSA's Consultation Paper 07/10 which details the proposed implementation of the Investment Exchange and Clearing Houses Act 2006 ("the Act") via FSA's Handbook.

The Consultation Paper seeks to codify within the Handbook the terms of the Act relating to those "regulatory provisions" made by Recognised Bodies which are notifiable to the FSA and which FSA may then subsequently decide to "call-in" for further market-wide consultation. The Exchange has a limited number of comments as CP 07/10 seeks merely to codify the current position under the Act. Our main concern however is the potentially lengthy consultation timetable available once FSA has decided to call-in a "regulatory provision". The Exchange has requested that the need for market certainty be considered within the circumstances of the specific "regulatory provision" in question and that working to the maximum available consultation timetable be avoided.

June 2007
Response to the European Commission's Call for Evidence regarding private placement regimes in the EU
The Exchange has responded to the European Commission's Call for Evidence regarding private placement regimes in the EU.

 
Our main concern is that any regime should not impinge on securities markets which are already functioning efficiently under the Prospectus Directive.
 
May 2007
Response to CESR's consultation on technical advice regarding equivalence of Third Country GAAP
The Exchange has responded to CESR’s technical advice regarding a mechanism for determining the equivalence of the generally accepted accounting principles (GAAP) of third countries.

We urge CESR to take a pragmatic, flexible approach that takes account of the quality of the financial reports produced under local GAAPs, and provides an incentive for third countries to move towards convergence. 
 
March 2007
Response to CESR's consultation on Best Execution under MiFID
The Exchange has responded to CESR's consultation on Best Execution under MiFID, which covers issues such as the contents of an execution policy, client consent, and relationships between firms in chains of execution. CESR also asks for evidence with respect to the execution quality data that is available commercially. In general, we agree with CESR's views, and have provided input into the call for evidence.

Response to CESR's consultation on the Level 3 Guidelines on MiFID Transaction reporting
The Exchange has responded to CESR's consultation on Level 3 guidelines for Transaction reporting. In general, we agree with CESR’s proposed guidelines. In particular, we support the proposal that CESR members take account of any prior approval by another CESR member for reporting channels, as the process should be streamlined as much as possible to avoid unnecessary duplication of work,

Response to CESR's call for evidence on non-equities market transparency
The Exchange has responded to CESR's call for evidence on non-equities market transparency. Whilst we are not aware of conclusive evidence of market failure, we believe that if the Commission does decide to take action, it should be limited to the specific area of retail participation in the most liquid bonds.

Response to the European Commission's consultation on implementation of articles 45-47 of the Directive on Statutory Audit
The Exchange has responded to the European Commission's consultation on implementation of articles 45-47 of the Directive on Statutory Audit. We fully support the consultation, which proposes equivalence provisions and transitional arrangements for (non-EU) auditors of third country issuers.


January 2007
Response to the FSA consultation paper CP 06/17 - Amendments to the Prospectus and Listing Rules
The Exchange has responded to this consultation paper in which we are broadly supportive of the proposed amendments. However, we also raise queries regarding certain proposals concerning an issuer's ongoing control of assets, the definition of a threshold for certain 'related party' rules, the extension of the RICS standard for property valuations to companies incorporated in the Channel Islands and the Isle of Man and the imposition of a minimum reporting period for wholesale issuers filing a voluntary annual information update. 

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