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March 2007


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.

However, we do have some concerns over CESRs proposals on "what constitutes a transaction", namely that the guidelines do not help firms to fully understand their responsibilities and do not promote supervisory convergence amongst regulators.

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