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Executive summary
The SMSG welcomes the proposed RTS under the new Prospectus Regulation. We strongly believe that a successful review of the Prospectus rules should result in an increased level of investor protection and a true reduction of costs for issuers, without additional burdens imposed.
We believe that issuers should be given flexibility with regard to the number and format of the KFI to be included in the summary, e.g. flexibility to decide to include KFI extracted from the cash flow statement or not. The limit on the number of pages will already prevent unnecessary information being included in the summary.
Lastly, we recommend finding a balance between the technological evolution and state of the art solutions that could ease disclosure of information for investors and potential related issues in terms of security and liability for issuers.
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