5.3 CONTENIDOS ACTITUDINALES.

6.3.1 A number of the options identified in Section 5 can be discounted at this stage on the basis that they clearly do not meet one or more of the requirements. The discounted options and reasons for disqualification are listed below.

Option 4: OAM web-ring

6.3.2 This option proposes that the data storage standards and search tools are harmonised across all current OAMs to allow users to easily conduct searches across all OAM databases from any national OAM portal.

6.3.3 It is discounted at this stage because the EC requirements specify that a single, central search tool is required, that allows users to conduct pan-European searches from a single, central point. This option does not meet that requirement as no additional portals are created – users would be able to use any of the existing OAM portals rather than being directed to a single, central portal. Option 6: Central search and index engine

6.3.4 This option proposes to implement an intelligent search tool within a central portal that can automatically search and index all data held in OAM databases. This indexed data can then be searched by users to effectively conduct a pan-European search.

6.3.5 The option is discounted at this stage because use of an intelligent tool to index the data is seen as interpretation and carries a risk that data could be incorrectly or inappropriately indexed. Users conducting a search of information indexed in this fashion could therefore be presented

Page 42 Actica/PB318D004 1.3 with incorrect or inaccurate results which could be seen as the responsibility of the owner and supplier of the search tool. This could lead to complaints or more serious action being taken against the EC (or other central body that is responsible for the central search tool) to recover monies lost as a result of incorrect data being supplied.

Option 7: Combine current OAM operations with national business registers

6.3.6 This option involves creating a single database by combining the information contained in the current OAM databases with that contained in the national business registers. This would make best use of the existing European linkages between national business registers.

6.3.7 This option is discounted at this stage for the following reasons:

a. The effort required to integrate OAM databases with the Business Registers at a national level to enable the existing international linkages to be used to share OAM information is likely to be prolonged. This extra effort is not likely to deliver additional benefits over the previous options;

b. The option does not increase the efficiency of the two separate databases due to a lack of synergy between them. The information held in the national business registers is different to that held in the OAMs, the only point of commonality is financial reports. It is therefore unlikely that a combined database would deliver any tangible savings and it is also unlikely that the combined database would be able to make use of the existing international linkages to search OAM data as these exist to share business register data rather than the different OAM data.

Option 8: Maintain status quo

6.3.8 This option does not involve making any changes to the current situation. The national OAMs will continue to provide national databases and facilitate national searches, and will continue to make slow progress in forging European linkages to share regulated information.

6.3.9 This situation allows all member states to manage their OAM operations separately, and to coordinate OAM operations with national regulators as needed. This has resulted in a large number of different approaches to the storage of regulated information and many areas where this data is duplicated across a number of systems to fit with existing national processes.

6.3.10 Maintaining the sataus quo means that users will continue to rely on commercial data providers to provide consolidated, cross-European access to regulated information in addition to analysis and non-regulated information about issuers of securities. This will mean that central organisations such as Eurostat and the European Central Bank will have to continue to pay for all the information that they need, and individual users will also continue to pay for their information due to the lack of understanding about what is available from OAMs as well as the lack of analysis available from the OAMs.

6.3.11 This option would be the easiest to implement as it does not involve making any changes, however it would not meet the requirements of the Transparency Directive, or the other requirements as stated in Appendix A.

6.3.12 This option is discounted as it does not meet the requirement for a single European access point and does not enable a pan-European search.

Actica/PB318D004 1.3 Page 43 6.4 Further analysis methodology

6.4.1 A set of criteria by which the four options taken forward (Options 1,2,3 and 5) can be assessed has been developed based on assessing the overall suitability of each option to fulfil the requirement of enabling users to conduct pan-European searches of regulated information held on issuers of securities. These criteria are listed below:

a. ability to meet the EC requirements as described in the ITT (Annex A);

b. deliverability – how easy is it to move from the current situation to that proposed by the option;

c. ability to address concerns identified in previous reports;

d. timescale – how long is the option likely to take to be fully implemented; e. Cost;

f. governance and resourcing – How much will current governance and resourcing arrangements need to change to implement the option;

g. standardisation – to what level will the current national arrangements need to be standardised to implement the option;

h. flexibility - how easily can the proposed system be changed to include new data, storage arrangements or processes (such as moving to XBRL);

i. benefits and user experience – what are the quantifiable and unquantifiable benefits of the option, including any improvements to the user experience;

j. impact on other organisations, including 3rd party providers; k. impact on other government services such as information registers; l. risk – the likely risk of implementing the option.

6.4.2 Each option is then assessed against these criteria individually in order to understand how well that option is likely to meet the overall need.

6.4.3 Table 6-1 summarises how each option performs against these criteria, in comparison with the current situation (Option 8).

Page 44 Actica/PB318D004 1.3

Current Situation Option 1: Central

everything

Option 2: Central copy of