The EACB welcomes the opportunity to actively contribute to the discussion review of the Prospectus Directive (PD) and to transmit its views regarding possible amendments in that regard with a view to making it easier for companies (including SMEs) to raise capital throughout the EU while ensuring effective investor protection.
We share the Commissions view on the overall positive functioning of the PD but would like to highlight that certain parts of it create high administrative burdens and costs for our members. The complexity, considerable time and significant costs involved in the production of a prospectus has affected the volumes of bond issuance of our co-operative banks – especially some smaller ones-. At the same time, the fact that several regulations have developed since the entry into force of the PD (MiFID, PRIIPs, TD etc.) concerning the disclosure regime for issuers and investment products calls for a reconsideration of the cases in which the Prospectus is still necessary. Therefore, we totally agree with the assessment of the European Commission that certain elements of the prospectus regime merit a review.
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