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Public consultation on minimum requirements in the transmission of information for the exercise of shareholders rights

Consumers, Employment and social affairs, Justice and fundamental rights

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Public consultation

ID: 1695

Lobbying Activity

30 responses

Consultation response

Confederation of Swedish Enterprise, 7 May 2018

Please, find the comments by the Confederation of Swedish Enterprise in the attached file.

Consultation response

Confederation of Danish Industry, 9 May 2018

Please see the consultation response from the Confederation of Danish Industry in the attached document. Best regards Lars Frolov-Hammer Leading Senior Advisor

Financial industry urges deadline flexibility in shareholder rights rules

Association for Financial Markets in Europe, 9 May 2018

AFME requests flexible 'without undue delay' language instead of same-day transmission requirements, and opposes extremely tight deadlines for information transfer. They seek alignment with existing market standards and opt-out provisions for shareholders not wishing to receive notifications.
This would reduce operational complexity and allow time for manual processing requirements.
Shareholders lose faster notification of corporate events and voting opportunities.

European Banking Federation seeks flexible shareholder rights implementation timelines

European Banking Federation, 9 May 2018

The EBF requests flexible timelines for information transmission, exemptions from same-day requirements for paper-based communications, and alignment with existing market standards. They emphasize the need to avoid prescriptive formats that contradict ISO standards and warn that the proposed deadlines create unnecessary operational risk.
This would reduce compliance costs and allow banks to maintain existing efficient processes.
Shareholders may experience delays in exercising voting rights if flexibility reduces information flow speed.

Consultation response

Bundesverband deutscher Banken e.V., 8 May 2018

Please find enclosed the Comments of the Bundesverband deutscher Banken (Association of German Banks). It represents more than 200 private commercial banks in Germany.

Consultation response

Associazione Bancaria Italiana, 9 May 2018

Please, refer to the attached response to the consultation.

Consultation response

Citigroup Inc., 9 May 2018

Please refer to the attached document.

Consultation response

Asociación Española de Banca, 9 May 2018

The Spanish Banking Association welcomes the opportunity to share our views on the draft Implementing Regulation laying down minimum requirements as regards shareholder identification, transmission of information and facilitation of the exercise of shareholders rights, issued by the European…

Consultation response

London Stock Exchange Group, 9 May 2018

Article 8, Paragraph 2 We seek confirmation of our interpretation that this is not intended to impact upon the current practice for UK Rights Issues and Open Offers where the event record date usually precedes the event announcement date. We believe that the market claims process for the…

Consultation response

BVI Bundesverband Investment und Asset Management e.V., 9 May 2018

BVI’s position on Commission‘s proposal regarding implementing measures of the revised Shareholders’ Rights Directive. Since shareholder engagement is a cornerstone of sustainable finance, the fund management industry has a strong interest in improving the communication between shareholders and…

Consultation response

Association Française de la Gestion financière, 8 May 2018

The Association Française de la Gestion financière (AFG) is grateful to have the opportunity to make the following comments on the Draft Implementing Regulation laying down minimum requirements as regards shareholder identification, the transmission of information and the facilitation of the…

Consultation response

Deutsches Aktieninstitut, 9 May 2018

Deutsches Aktieninstitut welcomes the opportunity to comment on the draft level II Regulation on the SRD II which will help to further improve and harmonise information flows between companies, intermediaries and shareholders and, in turn, will ease to practice shareholders’ rights cross border…

Consultation response

European Fund and Asset Management Association, 8 May 2018

EFAMA welcomes the new chapter in the Revision of the Shareholder Rights Directive regarding shareholder identification, transmission of information and facilitation of the exercise of shareholder rights. We are generally encouraged by the Commission’s objective in this Draft Implementing…

Consultation response

Deutscher Anwaltverein (German Bar Association), 9 May 2018

Sehr geehrte Damen und Herren, anbei finden Sie die Stellungnahme 18/2018 des Deutschen Anwaltvereins. Aus Sicht des Deutschen Anwaltvereins ist der Entwurf der Durchführungsverordnung zur Umsetzung der Aktionärsrechte-Richtlinie mit seiner Zielsetzung der Verbesserung der grenzüberschreitenden…

Consultation response

EuropeanIssuers, 9 May 2018

We very much welcome the opportunity to provide feedback on draft Commission Implementing Regulation laying down minimum requirements implementing the provisions of Directive 2007/36. We would like to mention though that for the future we would appreciate a longer deadline and less constrained…

Consultation response

European Federation of Investors and Financial Services Users, 8 May 2018

BETTER FINANCE welcomes this opportunity to comment on this draft implementing regulation laying down minimum requirements implementing the Shareholders Rights Directive II as regards, shareholders identification, the transmission of information and the facilitation of the exercise of shareholders…

Consultation response

Finland Chamber of Commerce (Keskuskauppakamari), 9 May 2018

Please find the response of Finland Chamber of Commerce attached. Regards, Antti Turunen Legal Counsel Finland Chamber of Commerce

Consultation response

The Investment Association, 9 May 2018

The Investment Association welcomes the opportunity to provide feedback on the Commission's proposed Implementing Regulation concerning shareholder identification and the transmission of information to facilitate the exercise of shareholders’ rights under the amended Shareholders Rights Directive…

Consultation response

The Bank of New York Mellon, 9 May 2018

BNY Mellon welcomes the approach of Commission in proposing an Implementing Regulation (IR). We believe that such a Regulation will help facilitate the objective of a harmonized pan-European operational process that allows all end investors in voting shares of European companies to exercise the…

Consultation response

Związek Banków Polskich, 9 May 2018

Dear EC, Please find attached position of Custodian Banks Board within Polsih Bank Association . Kind regards, Jacek Mierzejewski Chairman Custodian Banks Board

Consultation response

Swedish Securities Markets Association (Swedish: Föreningen Svensk Värdepappersmarknad), 9 May 2018

Please see enclosed file

Consultation response

Die Deutsche Kreditwirtschaft, 9 May 2018

The German Banking Industry Committee (GBIC) welcomes the opportunity to comment on the Draft Commission Implementing Regulation laying down minimum requirements implementing the provisions of Directive 2007/36/EC of the European Parliament and the Council as regards shareholders identification,…

Consultation response

The Association of General Counsel and Company Secretaries working in FTSE 100 Companies, 9 May 2018

Please see the file attached.

Consultation response

Computershare Limited, 9 May 2018

ARTICLE 1 corporate event: Replace ‘affects’ with ‘involves’ record date: ‘record date’ for events and ‘reference date’ for shareholder ID should be unbundled for clarity of these distinct concepts first intermediary: Purpose requires clarification. Content needs to be amended: it should not be…

Consultation response

European Central Securities Depositories Association, 9 May 2018

PLEASE READ THE FULL RESPONSE ATTACHED 1. ECSDA appreciates the draft regulation to be broadly supportive of the market standards. We would ask to make an explicit reference to the CSD Regulation (CSDR, (EU) 909/2014). 2. We encourage the Commission to collaborate with other authorities globally…

Consultation response

Dutch Advisory Committee Securities Industry, 9 May 2018

DACSI strongly supports the chosen legal form - with a strong drive for harmonisation of processes and information flows - , the emphasis on digital info flows and straight-through processing and the "adoption" of the Market Standards for Corporate Actions Processing. In our position paper we…

Consultation response

The Association of Investment Companies, 8 May 2018

See attached file.

Consultation response

Eumedion, 8 May 2018

Eumedion, representing the interests of 65 Dutch and non-Dutch institutional investors who have more than € 5 trillion AuM, welcomes the opportunity to give feedback. The poor performance of the chain of intermediaries makes it very difficult and often very costly for shareholders to exercise…

Consultation response

BorderXingInfo, 7 May 2018

REACTION from BorderXingInfo (“bordercrossinginformation”, “bXi”, website under construction www.info-bxi.com ; EU Transparency Register number: 820757127925-21) to the consultation regarding. General remarks 1. Paragraph (4) of the preamble of the IR refers to the encouragement to use…

Consultation response

Association Française des Professionnels des Titres, 7 May 2018

AFTI welcomes the opportunity to share our views on the draft Implementing Regulation (IR) issued by the European Commission on shareholder identification, the transmission of information and the facilitation of the exercise of shareholders rights published on 11 April 2018. AFTI is the leading…