Prospectus Regulation - Recommendations to put good ideas into practice

The position paper comments on the draft of the EU Commission, published on the 11/30/2015. Deutsches Aktieninstitut opposes the idea of allocating risk factors into categories and restricting their number in the summary since this approach would give especially retail investors a false sense of security. The abolishment of the 100k bond exemption and facilitations is grounded on wrong assumptions. Moreover, 32 empowerments of the EU Commission and ESMA make it uncertain, if the new prospectus regime will really lead to facilitations. Therefore, this number has to be reduced.