Ms Helen Mahony:

Briefly, section 88 as a preamble is absolutely crucial. It says that the prospectus regulation must be in accordance with the Charter of Fundamental Rights.

That is not optional. It is absolutely essential. The prospectus is seriously incomplete. It amounts to the withholding of risk-related information from investors. There are a couple of relevant sections in the prospectus regulation, including recital 54 and Article 16. Both of those require the issuer to provide complete information, especially in respect of risk. It does not.