©2005 Investment Company Institute. All rights reserved. Information may be abridged and therefore incomplete.
Communications from the Institute do not constitute, and should not be considered a substitute for, legal advice.
URGENT/ACTION REQUESTED
[18868]
May 18, 2005
TO: INTERNATIONAL COMMITTEE No. 9-05
RE: DRAFT ICI COMMENT LETTER TO CESR REGARDING SIGNIFICANT OWNERSHIP
DISCLOSURE
Recently, the Committee of European Securities Regulators (CESR) issued its final
consultation paper on possible implementing measures of the Transparency Directive.1 The
Institute has drafted a comment letter in response to the consultation paper, a copy of which is
attached for your review.
Generally, the draft letter is very supportive of CESR’s revised draft advice, especially
with respect to the conditions for exempting parents of non-EU management companies and
investment firms from the requirement to aggregate their holdings with those of their
subsidiaries. The letter also states that the Institute appreciates CESR providing some
additional clarifications in the revised draft in response to comments, including those of the
Institute.
Comments to the consultation paper must be received by CESR no later than May 27. If
you have any comments or concerns about the letter, please contact me at (202) 326-5810 or
jchoi@ici.org by Tuesday, May 24, 2005.
Jennifer S. Choi
Associate Counsel
Attachment (in .pdf format)
1 A copy of the consultation paper is available at, http://www.cesr-eu.org (CESR’s Revised Draft Technical Advice
on Possible Implementing Measures of the Transparency Directive).