Dear Mr. Commissioner,
First of all, we should like to express our gratitude for the flexibility that your services have been kind enough to allow us to take more time to prepare FESE views at this stage of the review of the Investment Services Directive. As you are aware many crucial elements of the Investment Services Directive are of the greatest possible strategic and substantive importance to Europe's regulated markets and associated organisations.
At the latest General Assembly of the Members of the Federation of European Securities Exchanges a small Task Force was charged to prepare in detail FESE comments on some of the most pressing issues under the ISD. The Working Group chaired by Dr. Wieslaw Rozlucki, Chief Executive Officer of the Warsaw Stock Exchange has delivered its report to the FESE Membership, which has indicated its approval. The Working Group did not have the charge to come to a consensus on each and every issue and you will find traces of less than full consensus on a number of items in our attached report.
We would stress however, that on some of the most pressing issues the Members of the Federation came to views that we feel should allow the Commission services to work further and to come up with text proposals that could allow and facilitate the European financial markets to continue to develop in the innovative ways we have seen over the last number of years.
The FESE Paper does in no way wish to indicate that individual points of views by specific Exchanges or affiliated organisations have lost their value: quite on the contrary, they should be seen as contributions to further lively and intensive debate and should contribute to the ultimate outcome a revised ISD.
Soon after you have received this paper we plan to post this on the FESE website (www.fese.org) [also available in PDF format here] in line with the transparency requirements of the post-Lamfalussy consultation processes. We do not at this stage plan to host a press conference or draft specific press releases on the subject.
We stand of course ready and available to discuss the issues involved with you and your services.
Yours sincerely,
George Möller
President
Paul Arlman
Secretary General
