Dato: 06.09.2024 Svartype: Med merknad Dears, Proxymity is an investor communication platform and we run shareholder identification requests under SRDII on behalf of European Issuers, including Norwegian Issuers. While the process is fairly stable it is not widely used yet because of several barriers. Kindly find our feedback on the performation of the Norwegian market and the barriers, which new legislation can alleviate. SRDII only applies to listed companies on a regulated exchange. While the existing Norwegian law is extended to all issuers, Proxymity has performed some disclosures on non-listed, and while some intermediaries reply, some do not consider unlisted, and listed on MTF exhanges (such as Euronext Growth) eligible for identification under SRDII. It would be beneificial if any new legislation includes specific wording which clearly and explicitly extends the scope of securities to include all asset types (detailing each type), similar was applied in France, who also extended the securities in scope. The current Issuer CSD in Norway (Euronext Oslo) is charging issuers NOK 15.000 to initiate a shareholder identification request. These fees are limited to the Nordic Markets. Outside of the Nordics the Issuer CSDs charge no fees to process the Shareholder Identification request. The issuer CSD is just another intermediary, albeit, the first intermediary and their fees are not proportionate to the cost of processing a request, as can be seen by the other CSDs who charge no fees. The Issuer CSD also doesn’t support the common method of requesting such data under SRDII, restricting access to only a handful of parties. Issuers only option is to pay the fees demanded by the local issuer agents who have access to the Issuer CSDs online platform to initiate requests. The Issuer CSD should be compliant with SRDII and develop a solution to supporting incoming requests by ISO20022. The Issuer CSD also doesn’t support the common method of responding such data under SRDII. Instead they provide a legacy csv file only available to the local issuer agents who have access to the Issuer CSDs online platform to initiate requests. The Issuer CSD should be compliant with SRDII and develop a solution to supporting disclosure responses by ISO20022. It should be noted the Issuer CSD does at least forward the requests to the direct participants of the Issuer CSD by ISO20022. But, as mentioned they charge NOK15,000 just for this process. A minority of foreign responding intermediaries are charging issuers fees for providing data. In the region of €200 - €50,000 per response depending on volumes. Norwegian law should address this and say no fees can be charged to a party wishing to identify the underlying shareholders. Some other markets, such as Germany, through a consultation by the Ministry of Justice are proposing a maximum fee a responding intermediary can charge, with €5 the suggested rate. This could also be fair compromise for all parties. Thresholds are barriers to identifying the majority of shareholders. Several markets have introduce a 0.5% threshold and issuers therefore see little value in using Shareholder Identification as they can only identify the large institutional investors who are already known to them. If the underlying benefits are to improve shareholder engagement and foster stewardship between issuer and its shareholders, having no threshold makes sense. Kind regards, Nigel Little (n.little@proxymity.io) Proxymity Limited Nærings- og fiskeridepartementet Til høringen Til toppen <div class="page-survey" data-page-survey="133" data-page-survey-api="/api/survey/SubmitPageSurveyAnswer" data-text-hidden-title="Tilbakemeldingsskjema" data-text-question="Fant du det du lette etter?"
