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transparency of comments on proposed regulation April 24, 2008

Posted by Bradley in : Uncategorized , trackback

On reading the LIBA-SIFMA response to the FSA’s January 2008 Discussion Paper on a Review of the Structure of the Listing Regime I thought it would be interesting to see what other organizations had expressed views on the DP and what those views were. If this were a regulatory proposal published by the SEC I’d be able to look on the SEC’s website for comments. For example, here are comments on the recent naked short selling anti-fraud proposal. But the FSA produces response papers analysing the various responses rather than publishing them itself. Trade associations do publish their responses on their own websites, so it is possible to find them, at least in some cases, but relying on commenters to make their comments available produces a less transparent process than if the regulator makes all comments on a particular proposal available in one place.

I often think the FSA makes more effort to consider the interests of financial services consumers than CESR, but here is one example where that is not the case as CESR does itself publish the comments it receives on its own initiatives. In some ways, having the FSA analyse and summarise the responses is helpful (see for example this document on responses relating to private equity) but it would be nice for transparency to have easy and immediate access to comments as they are being made (as is the case with the SEC) as well.


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