The organization requests modifications to the proposed research unbundling exemptions, including narrowing geographic scope to EU-listed issuers only and making the regime optional for both buy-side and sell-side firms. They want simpler definitions for SME issuers using annual assessment dates rather than rolling 12-month periods. For fixed income markets, they seek comprehensive consultation before any changes. This would reduce compliance complexity and system change costs while preserving US regulatory relief.
Non-EU issuers lose potential research coverage improvements from the exemption.