CESR Level 3 Work on the Transparency Directive

SIFMA and the International Capital Market Association (ICMA) provide comments to the Committee of European Securities Regulators (CESR) on possible CESR Level 3 work on the Transparency Directive, Ref. 07-487.  The groups believe that the inconsistent application, lack of clarity and regulatory gaps in the new transparency regime as well as other factors raise a significant number of important issues that could be appropriately addressed through Level 3 measures. For this reason, the groups support the CESR in beginning work in its Level 3 capacity to promote a consistent application of the new regime.  They groups do not believe the CESR can or should do anything further to facilitate the establishment of the EU network of national storage mechanisms until the European Commission produces a legislative measure which selects a network model and requires storage mechanisms to comply with an interoperability agreement.