Reply to ESMA on its technical advice on possible delegated acts concerning the Prospectus Directive

EuroFinuse welcomes the consultation from ESMA on technical advice on acts concerning the Prospectus Directive. However, this is a very specific consultation concentrating on very legal matters. We would like ESMA to focus also on other key disclosure issues raised by the implementation of the Prospectus Directive and Regulation, in particular the very poor quality of the Summary Prospectuses, for debt securities as explained in more detail in EuroFinuse’s position papers on the PRIPs initiatives.
We strongly regret the exclusion of securities from the scope of the PRIPs Regulation proposal, and we urge ESMA to ensure that the disclosure requirements for securities are at par with those for other “substitute” investment products accessible to individual investors.

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