[17867]
August 5, 2004
TO: INTERNATIONAL MEMBERS No. 46-04
INTERNATIONAL OPERATIONS ADVISORY COMMITTEE No. 32-04
OPERATIONS COMMITTEE No. 17-04
RE: INSTITUTE COMMENT LETTER ON CLEARING AND SETTLEMENT IN THE
EUROPEAN UNION
On July 30, 2004, the Institute submitted a comment letter to the European Commission
on its communication to the Council and the European Parliament entitled Clearing and
Settlement in the European Union – The way forward.1 A copy of the Institute’s comment letter
is attached.
The Institute’s letter strongly supports the goal of the Commission, which is to create EU
securities clearing and settlement systems that are efficient and safe and ensure a level playing
field among the different providers of clearing and settlement services. The letter notes that,
although the term “securities” is not defined in the communication, it is our understanding that
the Commission’s current work will not address the clearance and settlement of capital shares
of investment funds.
The Institute’s letter points out that cross-border processing of fund units is a key issue
for the asset management industry and expresses the belief that standardizing operational
protocols and increasing efficiencies for fund processing could bring significant benefits to
shareholders. The letter states that clearance and settlement of investment fund shares should
be addressed separately because of the unique characteristics of investment fund capital shares.
Mary S. Podesta
Senior Counsel
Attachment (in .pdf format)
Note: Not all recipients receive the attachment. To obtain a copy of the attachment, please visit our members website
(http://members.ici.org) and search for memo 17867, or call the ICI Library at (202) 326-8304 and request the
attachment for memo 17867.
1 The Communication is available at http://europa.eu.int/comm/internal_market/financial-
markets/clearing/index_en.htm#com.