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FESE supports a fully internet-based system for storage of regulated information. The availability of the information via the internet will allow investors (regardless of their location) to easily and quickly gain access to such information. FESE advocates the use of electronic means to the maximum extent possible; the processing of the information by electronic means allows for automated workflow and avoids unnecessary costs. FESE believes that the open e-filing architecture should support a limited number of format standards and that no prescribed format should be required.
Our members believe that any translation – potentially provided by the storage - of the regulated information received from the issuers falls into the category of value-added service and welcome the Commission’s clarification that the language regime minimum standards should not be construed as imposing on the Storage mechanism an obligation to translate the information filed.
It is FESE's belief that the minimum condition required for the effective functioning of a pan-European network of national central storage mechanisms would be a central application server and a central database containing a list of all the EU listed companies. Therefore we support the so-called Model C, as presented by CESR in its June 2006 final advice to the Commission. We think that such a model could be assessed after a sufficient period following its implementation with a survey taking into account costs and benefits and the Commission could decide, on the basis of this assessment, if there is a need and an advantage for proceeding with more integrated solutions such as the BRITE Project.
FESE Technical drafting comments_v0402_Commission's working document on storage_02APR07.pdf
