Mr. Gerry Cross:

I do not believe it is accurate at all to describe it as a box-ticking exercise, nor is it the same as what we have in relation to investment funds, for example. Where investment funds are concerned, we have an authorisation regime and a supervision regime. In the context of investment funds, it is our job to implement the legislation, which is about determining whether the standards required in issuing, managing and administering funds are met. In this context, it is a set of regulated entities and products that we are responsible for, but that is not the case with prospectuses. The prospectus regulation is not about regulated entities but about the simple task of asking whether a document or set of documents is consistent with the requirements in the regulation. It is a very clean, straightforward process. It is not setting up a regulated framework, and it is not about our being expected to follow what is going on in the many thousands of corporates and sovereigns. That is not the task assigned to us to do. To say that there is box-ticking is not quite correct either because we see our role as playing the very important role of the gate. In the context of the latter, I am referring to asking the question at the moment an issuance comes into the market. If you look at the guidance of the European Securities and Markets Authority, ESMA, on this, the word you will see all the time is "challenge". It is about challenge.

At the end of the day, as regulators in this space, we ultimately cannot determine the accuracy of all of the corporates and sovereign issuers' documentation. There is no way to determine the accuracy of everything that is said. However, we can challenge them and ask whether they have disclosed what they need to disclose in given spaces as regards the financial risks and so on. That is what I would say. It is not box ticking. It is a challenge exercise. However, it also absolutely is not a regulatory issue as we would see in, for example, the funds sector.