We responded to the European Commission's Call for Evidence on the EU Regulatory Framework for Financial Services. We welcomed the European Commission’s decision to conduct this review of the EU regulatory framework for financial services in the context of the Capital Markets Union initiative. Notwithstanding, we stressed that the Commission should conduct a thorough impact assessment on the interaction of the regulatory framework as a whole to ensure a coherent interplay of rules for a smooth functioning of the single market for finance.
We identified several examples where better regulatory coordination would be necessary in order to remedy current overlaps and inconsistencies of the EU Regulatory Framework for Financial Services, or where better regulation would benefit a more proportionate application of the EU rules to small and mid-size companies.
We noted that, for example, the changes introduced by MiFID II Level 2 could impair the ability of small and mid-size quoted companies to have research produced on them, decreasing their visibility and potentially limiting their investment. We encouraged the Commission to introduce proportionate requirements for firms specialising in SMEs stocks' research, as well as a more flexible clients' agreement on cost allocation.
Regarding the Market Abuse Regulation, we highlighted, for example, that the information required on firms to keep insider lists is far too detailed and will be burdensome for issuers to provide. We urged the Commission to ensure that the contents of insider lists are proportionate for all issuers. Whilst we welcome the exemptions for producing insider lists for companies on 'SME Growth Markets' in MAR, we highlighted that, as requirements in MAR are introduced before MiFID II comes into force, companies on growth markets will then be required to produce full insider lists. We urged the Commission to assess how this issue can be solved through an exceptional derogation.