We very much support the purpose of the Listing Review that you are undertaking and are pleased to be able to contribute to this project. We are in agreement with the overall objectives of simplifying and modernizing the listing regime and accommodating the effects of European regulation, whilst at the same time not detracting from the reputation of the London markets through diluting the effectiveness of regulation here.
Given the background and nature of the ACT we have not thought it appropriate to respond to every question you posed in the consultation but rather have approached it selectively so as to concentrate on the subject areas of particular relevance to our members. The Chapter 6 on debt prompts some very much wider questions as to the structure of the debt market as between specialist and non-specialist issues and the relationship with the PD definitions of wholesale debt. We note in our answer to question 11 that this is an area which would benefit from further consideration and review amongst those involved in this market.