draft PD Law. 3 EU legislation only applies to issuers with securities admitted to trading on an RM. IOSCO Principles also apply to issuers that have made a public offer of securities. 4 Except for financial institutions and companies with state ownership interest of at least 25 percent. III. Issuer Disclosure Requirements A. Issuer Initial Disclosure Requirements Findings 10. The current initial disclosure requirements do not comply with IOSCO Principle 16 or the key provisions of the PD . IOSCO Principle 16 requires full
effect, including costs, of proposed rules (as currently required by Article 8 of the Law on State Regulatory Policy). Removal of an obligation to conduct an analysis of regulatory effect may raise questions about compliance with IOSCO Principles for regulatory processes (see IOSCO Principle 4, and especially Key Question 2(c) of the Assessment Methodology), if the NSSMC does not have a legal obligation to carry out such an analysis, or does not adopt a policy of doing so as a matter of practice. 24. Supervision of the NSSMC’s rulemaking by the SRS does not raise