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Market Abuse Regulation 2020? A forward looking perspective on the implementation of the
2014 Market Abuse Regulation
Thanks and Disclaimer
I would like to thank the conference organisers for inviting me to come and speak to you today. They
have asked me to try to look at what the full regime will look like. I will begin by saying at the outset
that I will make my remarks on an individual basis rather than seeking to represent the position of the
Central Bank of Ireland.
Introduction
The Market Abuse Regulation entered into force on the 2nd of July 2014. This event “starts the
clock” on the development and implementation of the Level II legislative measures whether, in the
form of Delegated Acts by the European Commission or in the form of Regulatory and
Implementing Technical Standards by ESMA. The Market Abuse Regulation seeks to improve
market integrity by, amongst other things, providing for an extension of scope to new markets and
new trading strategies as well as adopting measures aimed at enhancing the transparency architecture
provided for under the 2003 MAD.
Winston Churchill once said ‘It is always wise to look ahead, but difficult to look further than you
can see.’ It is difficult to know, at this point in time, how far we can see with any assurance. But let
us at least look with some confidence forward to how the regime will look after the level 2 measures
are complete and more tentatively explore what market abuse regulation might look like in Europe,
five years after the implementation of the 2014 Regulation.
I propose to do this under three headings.
 I will highlight for you first the new developments in the text of the Market Abuse
Regulation itself;
 Then I will address the sizable Level II legislative agenda under MAR; and
 Finally I will explore with you what, perhaps in an ideal world, market abuse
regulation will look like in Europe when all of these regulatory measures are in place.

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Market Abuse Regulation – new proposals
As with its predecessors, the 1989 Insider Dealing Directive and the 2003 MAD, the objective of the
Market Abuse Regulation is to prohibit market abuse because of the harm it causes to the integrity of
financial markets. In an effort to keep pace with the legislative, market and technological advances
that have considerably changed the financial landscape since 2003, the European Commission in
2011 proposed the Market Abuse Regulation and the Criminal Sanctions Directive for Market
Abuse. It is fair to say that the final texts represent the most far reaching legislative provisions in the
25 year history of market abuse prohibition in Europe as they impose a significant number of
requirements on all participants in securities markets.
One of the first developments to note is that the new legislation takes the form of a Regulation. It is
important to focus on the distinctive effects of a Regulation. Principal among these is because there
is little transposition being required into the national law of each Member State; the Regulation
should create more uniform rules and increased clarity of concepts and definitions across the Union.
This maximum harmonization approach will go some considerable distance to ensuring a single
rulebook as advocated by the High Level Group on Financial Supervision and should result in
reduced administrative costs for issuers and investment firms, with likely convergence of compliance
systems and controls across Member States. Further, such an approach arguably seeks to ensure that
the Market Abuse Regulation is an instrument that is fit for purpose by National Competent
Authorities, in exercising their extra-territorial jurisdiction.
By contrast, the European Commission also proposed the Criminal Sanctions Directive for Market
Abuse using Article 83(2) of the Treaty as a legislative basis for the first time. The Criminal
Sanctions Directive seeks, albeit on a minimum harmonisation basis, to ensure that all Member
States have a criminal sanctions regime for insider dealing, market manipulation and unlawful
disclosure of inside information, as well as for any attempt to commit these offences.
A point to note in this regard is that the specification of a dual sanctioning regime was a source of
much discussion during the MAR negotiations. Much of the debate centred on the issue of whether
market abuse should be an administrative or criminal matter. These discussions stemmed from the
widely held understanding of the difficulties with investigating market abuse and the rather counter-
intuitive response to that difficulty which is to advocate the introduction of criminal sanctions
regimes, although doing so raises the standard of proof required of the National Competent
Authority. Once the required standard of proof has been raised, this paradoxically increases the legal
protection for insider dealers and market manipulators, if you only have a criminal option.

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Critical to combatting market abuse is the likelihood of detection and successful prosecution. The
intensity of the penalty could almost be considered a secondary matter. Criminology studies place
considerable emphasis on the impact of a credible threat of detection and enforcement rather than the
potential levels of sanctions available under statute.
Clarity of concepts and definitions
Moving on, one of the significant clarifications contained in the MAR, is the alignment of the
definition of financial instruments with that contained in the proposed Markets in Financial
Instruments Directive and Regulation, thus rectifying the anomalous misalignment that has been a
feature of the 2003 MAD and MIFID I.
The inclusion of a definition of benchmarks and a prohibition of market abuse using benchmarks, as
well as the incorporation of a regime for market soundings detailing harmonized conditions which a
market sounding must comply with in order to avoid an automatic presumption of unlawful
disclosure of inside information; these are also to be welcomed as progressive.
The judgments of the Court of Justice of the European Union on arguably the two most significant
cases under the 2003 MAD have also been reflected in the MAR. Namely, in the Spector Photo Case
whether possession of inside information could give rise to a rebuttable presumption of and in the
Markus Geltl Case whether, an intermediate step in a protracted process may in itself constitute
inside information. This clarity will increase the certainty of the offence of insider dealing and will
be to the benefit of all market participants and to competent authorities in their efforts to bring
effective enforcement actions for market abuse.
Scope –Uniform Rules across venues (RM/MTF/OTF/OTC)
One of the limitations of the 2003 MAD was that its scope was limited to financial instruments
traded on a regulated market or for which admission to trade on a regulated market had been sought.
The MAR by contrast, includes within its scope financial instruments traded on regulated markets,
multilateral trading facilities (MTFs), organised trading facilities (OTFs), over the counter (OTC)
and any conduct or action which can have an effect on such financial instruments. This is a
significant broadening of the scope of application and indeed the degree of responsibility for issuers,
trading venues, financial and credit institutions from the 2003 MAD. This should significantly
reduce risks of regulatory arbitrage throughout the Union.

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Reporting: Suspicious Transaction and Order reports – Transparency Architecture
The harmonisation of the content and form of Suspicious Transaction Reports, the trading disclosure
notifications by Persons Discharging Managerial Responsibilities and indeed Insider Lists will
increase regulatory convergence which is a considerable advancement in the context of an integrated
European financial services market. These enhanced provisions will also be beneficial to competent
authorities seeking to enforce effectively the provisions of the legislation, because crucial
information, whether from insider lists or suspicious transaction reports will be maintained and
reported in an equivalent manner across the Union.
Let me add a particular point about Suspicious Transaction Reports: the Market Abuse Regulation
makes it clear that the obligation to make a suspicious transaction report extends to suspicious
transactions, orders and behaviours that take place outside the trading venue as well as on the trading
venue. This is a significant extension, particularly on investment firms, of the existing requirements
under the 2003 MAD
Sanctions
Finally, it is worth my speaking a little bit about the sanctions that are envisaged under the Market
Abuse Regulation. MAR sets minimum levels to apply in all Member States for what the maximum
administrative pecuniary fines can be. These are €5 million for natural persons and €15 million or
15% of annual turnover for legal persons. Other administrative sanctions of note include the
disgorgement of profits made or losses avoided and a permanent ban from exercising management
functions in investment firms for repeated offences of insider dealing or market manipulation.
As certain Member States faced difficulties with the level of sanctions being set at such a level that
would be deemed criminal in effect, in their country, the compromise is that the level of the
minimum fine has been raised, but the apparent discretion for Member States has been broadened
Another feature of interest in the area of sanctions is that failure to cooperate or to comply with an
inspection, investigation or request by the competent authority is also subject to sanctions. However,
the applicable sanctions are not specified in Article 30 of MAR. They are ostensibly the subject of
Member State discretion in transposition. It is my hope is that Member States will not exercise their
discretions in ways which will make it as hard to penalise non-cooperation as it is to penalise the
matter being investigated.

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One of the difficulties with investigating market abuse, experienced across many Member States is
that regulators are often unable to prove the ‘person connection’ between the inside information and
a particular trade. Under MAR and the new MIFID, Investment firms now will be required to record
telephone land lines and Competent Authorities have the power to request existing telephone
recordings from investment firms, credit institutions or other financial institutions. This is a clear
improvement from the status quo. MAR also goes further in addressing the somewhat controversial
question as to whether competent authorities are able to require existing recordings of telephone
conversations, electronic communications and data traffic records held by telecommunications
operators. This particular power, I believe is a crucial power for the detection of market abuse,
because it allows the competent authority to establish the identity of a person responsible for the
dissemination of inside or indeed false or misleading information. It also provides evidence that
particular persons were contacted at particular times by certain other parties, therefore going quite
some way to establishing that there was a relationship between the parties in question.
Market Abuse Regulation – Level II ESMA
I will turn now to the sizable Level II legislative agenda under MAR, and in particular the portion of
that that has been assigned to the European Securities and Markets Authority.
ESMA received two formal mandates from the Commission for technical advice on possible
delegated acts under MAR. The first mandate was published on the 21st of October 2013, and the
second on the 2nd of June 2014. The latter refers only to the “specification of procedures to enable
reporting of actual or potential infringements of MAR”, while all the other topics sought as technical
advice are covered in the first mandate. These include:
 The specification of the indicators of Market Manipulation;
 The specification of the competent authority for the notification with respect to the
public disclosure of inside information;
 The specification of the circumstances under which trading during a closed period
may be permitted by the issuer; and
 The specification of the characteristics of a manager’s transaction which trigger the
notification duty, and the specification of the circumstances under which trading
during a closed period may be permitted by the issuer.

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Accordingly, ESMA has published two separate consultation papers on the 15th
of July 2014. One on
the draft advice to the European Commission and the other on the draft technical standards which I
will return to discuss in more detail later. These consultation papers are a necessary part in the
fulfilment of ESMA’s legal responsibilities under Articles 290 and 291 of the TFEU and Regulation
(EU) 1095/2010.1
To speak briefly of the timeline on the delivery of the Level II measures, both
consultation papers are based on the MAR text published in the Official Journal2
on the 12th
of June
2014 and which subsequently entered into force on the 2nd
of July, 2014 to enter into application 24
months later. This time line necessitates that ESMA finalise the draft technical advice for submission
to the European Commission within 8 months and the draft technical standards within 12 months
Draft Technical Advice to the European Commission – summary
Let me walk through each of the main items.
Specification of the indicators of market manipulation included in Annex I of MAR
A list of indicators of market manipulation and a list of the types of manipulation practices have
previously been identified and compiled in CESR Guidance, the predecessor to ESMA. In its advice
to the Commission, ESMA has built on the indicators previously identified in order to encapsulate
the increased scope of the Market Abuse Regulation. Consequently, developments such as automated
trading and benchmarks have been considered in the draft advice to the Commission.
Managers’ Transactions
The European Commission required technical advice under two headings in the area of managers’
transactions under MAR. The first relates to the, types of transactions that trigger notification and
disclosure reports the second is on the specification of circumstances under which the trading during
a close period may be allowed by an issuer. Article 19(12)(a) provides for an exception being made
on a case by case basis where exceptional circumstances are deemed to be in play and Article
19(12)(b) provides for transactions made relating to employee share savings schemes, qualification
or entitlements of shares and transactions without a change in the beneficial ownership of the shares.
A development from the 2003 MAD is the insertion of the de minimus cumulative threshold of
€5,000 (or €20,000 – if provided for in national law) for these disclosures and once that threshold has
been reached any subsequent acquisition, disposal, regardless of significance to the market need to
1
Articles 10(1) and 15(1) in particular require ESMA to conduct open consultations on draft regulatory standards and to
analyse the potential related costs and benefits before submitting such draft technical standards to the Commission.
2
OJ L 173 12.06.2014, p.1

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be notified. The notification requirement also applies to persons closely associated with persons
discharging managerial responsibilities and to third parties exercising full discretion over the account
of a PDMR.
In terms of trading in the closed period, ESMA have suggested that for permission to be granted to a
PDMR, the PDMR must be able to show that the proposed transaction cannot be executed at any
other moment other than during the close period. ESMA have provided guidance on how an issuer
should assess whether the circumstances put forward by the manager in question are in fact
exceptional. ESMA’s proposed technical advice also sets out what transactions could potentially be
permitted during a close period.
A topic that was a matter of some considerable debate during the MAR Level I negotiations was that
of the reporting of violations or whistle blowing as it is more commonly known. The whistleblowing
provision is an innovation in the context of the regulation of Market Abuse and ESMA have
provided particular advice on the procedures that competent authorities should have in place for the
receipt of such reports and the protection of both the persons reporting and reported as a result of
these provisions. This is clearly an area where data protection will be central as well as employment
and privacy rights of all persons involved.
Regulatory Technical Standards
The MAR Level 1 text specifically charges ESMA with the development of regulatory and
implementing technical standards in relation to several provisions. These are as follows:
 Article 5(6) of MAR requires ESMA to develop draft regulatory technical standards to
specify the conditions that buy-back programmes and stabilisation measures must meet
 In relation to market soundings, Article 11(9) of MAR requires ESMA to develop draft
regulatory technical standards to determine appropriate arrangements, procedures and record
keeping requirements for persons to comply with the new market soundings requirements.
ESMA is also empowered by Article 11(10) of MAR to develop implementing technical
standards to specify the systems and notification templates to be used by persons to comply
with some specific market sounding’s requirements.

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 Article 13(7) of MAR requires ESMA to develop draft regulatory technical standards
specifying the criteria, the procedure and the requirements for establishing an accepted
market practice,
 In relation to the prevention and detection of market abuse, ESMA is empowered by Article
16(5) to develop draft regulatory technical standards to determine appropriate arrangements,
systems and procedures to comply with Article 16,
 Article 17(10) of MAR requires ESMA to develop draft implementing technical standards to
determine both the technical means for appropriate public disclosure of inside information,
and the technical means for delaying the public disclosure of inside information.
 Article 18(9) of MAR requires ESMA to develop draft implementing technical standards to
determine the precise format of insider lists and the format for updating the same.
 Article 19(15) requires ESMA to develop draft implementing technical standards concerning
the format and template in which the information related to managers’ transactions is to be
notified and made public.
 Article 20(3) requires ESMA to develop draft regulatory technical standards to determine the
technical arrangements for objective presentation of investment recommendations or other
information recommending or suggesting an investment strategy and for disclosure of
particular interests or indications of conflicts of interest.
Draft Consultation Paper on MAR draft Technical Standards
In ESMA’s CP, the technical standards are grouped together in three sections. Finally, those
referring to certain behaviours that may be legitimate under certain conditions or exempted from the
prohibition of market abuse, secondly, the technical standards related to “transparency”
requirements, and thirdly, the draft TS on market soundings, suspicious transaction and order
reporting, and investment recommendations. Let me highlight some of the more important of these
technical standards to you now.

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Buyback and stabilisation measures
To turn first to buyback and stabilisation measures. As a general comment I will say to you that in
the development of the draft technical standards under MAR the existing Level 2 texts and the CESR
guidance have been used as a basis, to which new elements have been added.
For example, in relation to the specification of the competent authority to be notified of the buy-back
and stabilisation transactions, the draft CP proposes that transactions carried out on a trading venue
are to be reported to the competent authority of that particular trading venue. This implies that if the
buyback or stabilisation is carried out in multiple trading venues, there will be a requirement for
multiple reporting, as each competent authority should be informed of the transactions that took
place in the trading venue it supervises.
Further, in relation to buyback programmes, the draft CP also clarifies that OTC transactions are not
covered by the exemption, the advice goes on to specify the particular price conditions to apply
during auction phases and seeks to simplify the volume condition, as it exists under the status quo by
no longer offering to extend, in case of extreme low liquidity, the average daily volume threshold
below which buyback transactions could benefit from the exemption.
In relation to stabilisation measures, the draft CP clarifies that “refreshing the Greenshoe” and
“block-trades” are not covered by the exemption.
Market soundings
As I mentioned earlier, this is the first time market soundings have been addressed in the context of
MAR Level 1 and ESMA is consequently required to develop both RTS and ITS on the subject.
The draft RTS proposes arrangements, procedures and record keeping requirements for market
soundings. These refer only to requirements that the “disclosing market participant” (DMP) must
respect, they do not cover the market participant receiving the disclosure. The RTS sets out particular
procedures that are to be followed ahead of the sounding activity in question. In particular the RTS
looks at the type of information being communicated by the disclosing market participant, ensuring
that recipients are informed as to whether the sounding will involve inside information and a
consideration of the implications attached to such communications.
Disclosing market participants are also required to maintain accurate records in relation to each
market sounding conducted (regardless of whether there is a disclosure of inside information),

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including any document and material provided by the disclosing market participant to a potential
investor. Such records should be made available to the competent authority upon request.
The draft ITS include a template for a single script of market sounding communication to be used by
disclosing market participants in their communication with potential investors; it also details the
format of the records to be kept and on the communication in relation to the information that has
been disclosed in the course of the market sounding and more specifically on whether it has ceased
to be inside information.
Suspicious transaction and order reporting
As I mentioned earlier, MAR requires ESMA to develop RTS on the arrangements, systems and
procedures that operators of trading venues and persons professionally arranging or executing
transactions have to put in place in order to report suspicious transactions or orders. Although
ESMA, in its previous incarnation as CESR had addressed this issue, the widening of the scope of
MAR to OTC derivatives and to unexecuted orders has necessitated revisiting the content and format
of the STR form, with a view to developing a new harmonised template in an electronic format.
In relation to the detection of suspicious transactions and orders, the CP proposes the setting up of
appropriate automated surveillance systems as well as the provision of proper training and the
development of a detection culture within organisations.
Finally, and what I think is a very useful innovation, the draft RTS introduce a requirement to keep
records of “near-misses STRs” (i.e. suspicions examined but not reported to the NCA). These
proposals coupled with the provisions in MAR Level 1 should increase the volume and usefulness of
STR’s to NCAs, this would be a most welcome development as to date STR’s have not been
received by NCA’s in the volume that was anticipated, which can result in delayed and indeed
missed investigations of behaviour which could amount to market abuse.
As I briefly mentioned at the outset ESMA are charged with drafting an ITS relating to the form and
content of insider lists. As such the CP contains proposals on the design of a document which will
facilitate issuers and persons acting on their behalf or on their account to create, update, store and
submit insider lists. Taking into account the responses to the DP, the draft CP proposes more
flexibility in the design of its document. Although the issuer is fully responsible for the complete and
comprehensive list of insiders, there are two different approaches that could be used:

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1) General lists per issuer, consolidating all the projects or events which have triggered the
duty to draw up and maintain an insider list and including all insiders for each specific
inside information; or
2) Deal-specific/event based insider lists, relating to a unique inside information and
including all the insiders in respect to that particular inside information.
The proposed content of the insider list has been amended only marginally despite the concerns
voiced in response to the proposed approach in the DP, which was primarily that the content of the
proposed insider list was too detailed and that excessive amounts of personal information were
required. ESMA remains globally convinced that the granularity of the information to be included in
the insider list is necessary for the proper and efficient fulfilment of their supervisory and
investigatory missions.
In order for SME Growth Market issuers to benefit from the exemption to draw up and maintain
insider lists as a way to reduce their administrative burden, the draft CP is only requiring that these
issuers are able to provide an insider list containing the appropriate information and to submit it in
the proper format. The draft CP is no longer requiring the establishment of internal systems and
processes for SME Growth Market issuers, as originally proposed in the DP.
Turning to managers transactions, ESMA is mandated to draft implementing ITS concerning the
format and the template to be used for the notification and publication of the transactions of “persons
discharging managerial responsibilities” (PDMRs) within an issuer, an EAMP, an auction platform,
an auctioneer or the auction monitor, as well as of persons closely associated to them.
The draft CP proposes to have a single template for notification, which will contain two sections.
The first section should contain information on a transaction per transaction basis (i.e. non
aggregation), to specifically allow the competent authority to fulfil its monitoring and supervisory
tasks. The second section should be used by PDMRs and closely associated persons to notify
transactions in an aggregated form. The issuer, EAMP, auction platform, auctioneer or the auction
monitor will in turn then proceed with the publication of the information in the second section. In
accordance with the 3rd paragraph of Article 19(3), national law may provide for a competent
authority to make public the information notified. If this is the case, the relevant competent authority
should make public the aggregated information provided in section two of the template. The specific
template and the list of information to be provided within it are detailed in Annex II of the draft ITS
presented in Annex VII of the draft CP.

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III. Market Abuse Regulation – 2020?
My concluding remarks to you today, as I indicated at the outset are concerned with an exploration
of what market abuse regulation will look like in Europe when all of the measures that I have
outlined to you are in place and indeed are operationalized by market participants and National
Competent Authorities.
My observations can be grouped into three headings, namely the disclosure environment and the
transparency architecture, enhanced pan-European detection of Market Abuse, reduction of
regulatory arbitrage by the application of similar sanctions across the European Union.
Disclosure environment and transparency architecture
With improved specification and clarity on information required to be disclosed, both to the Market
and to National Competent Authorities in the Level I coupled with increased convergence on the
mechanics of such disclosures under the Level II particularly in the area of PDMR disclosures, the
reporting of suspicious transactions and orders and insider lists will increase the quality of
information being made available both to investors and to competent authorities, which should in
turn lead to improved information quality which should enable investors to make improved
investment decisions.
The approach that was adopted during the Level 1 negotiations and that is also reflected in ESMA's
approach to the design and development of Level II instruments was one that sought to capitalise on
the experience for over 11 years of the 2003 MAD. This is exemplified by the incorporation of
previous Level II instruments that have been adopted and implemented by the majority of Member
States in the European Union into the Level I text of MAR, thus ensuring effective maximum
harmonisation, because it is built on a foundation of actual implementation across the Union. The
MAR text also reflects those elements of the transparency architecture enacted by the 2003 Directive
that have not been so successfully implemented or indeed that have been implemented in diverging
ways across Member States. Where the Court of Justice or indeed the supervisory convergence work
of ESMA provided clarity on these matters, these were included in the Level I text, such as the
examples I provided earlier in relation to the Car-phone Warehouse case and indeed the classification
of information on interim stages in a protracted process as inside information and perhaps more
practically the enhanced Level I and Level II requirements for the provision of Suspicious
Transaction Reports to Competent Authorities.

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I would anticipate, that by enhancing the regulatory architecture that currently exists by seeking
information that heretofore has been lacking and by addressing a number of anomalies that came to
light with the implementation of the 2003 Directive as well as improving the consistency of reporting
by using convergence tools in the Level II provisions, which should incidentally reduce the
compliance costs of participants in cross border securities markets, that a more effective transparency
architecture should result in Europe, in the field of market abuse in any event!
Enhanced pan-European detection of Market Abuse
Such improved disclosure frameworks, in terms of both information quality and what should
materialise as an increased frequency of reporting should also improve the detection capabilities of
the National Competent Authorities within their home jurisdiction and harmonisation of forms
should facilitate increased efficiency and effectiveness in the context of cross border market abuse
investigations.
I would also suggest to you that although the MAR Level 1 provision that deals with the reporting of
violations had to be drafted in a manner which is more consistent with the minimum harmonization
approach to legislation, the facility for persons to make reports of suspected violations of market
abuse law in a way that affords them considerable protections should result in enhanced notifications
of contraventions of market abuse law reaching National Competent Authorities in a time frame that
might even facilitate a proactive interventionist approach, which could ostensibly halt the
misconduct before investors suffer detriment. Too often market abuse law can only be utililzed when
the harm is done, as it were, rather than being an effective legislative instrument that could halt the
consequent harm that stems from offences under the Market Abuse Regulation.
Reduction of regulatory arbitrage across the European Union
In addressing matters such as market soundings, the indicators of market manipulation across all
venues, in using maximum harmonisation tools to improve the regulation of buy-backs and
stabilisation measures and accepted market practices, the Market Abuse Regulation is engaging with
complex strategies in a way that is reflective of the 'real world' context over which the Regulation
seeks to exercise control. It would have been very easy to suggest that the regulation of market
soundings, for example is a matter for national law to address because the manner in which such
soundings are conducted is very dependent on securities markets within your jurisdiction. The same
could also be said of buy-backs and stabilisation measures, for it could be argued that it was far safer
from a regulators point of view, to ban the practice or indeed to 'pretend that these are not multi-

14. 14
jurisdictional purchase programmes. The reality is that both of these practices are good examples of
the grey areas within which market abuse is very likely to lurk, but they can also be legitimate and
beneficial exercises. It is my hope that the regulatory engagement currently envisaged in these areas
will at the very least provide a common regulatory framework throughout Europe, whereby an
informed decision can be made as to what side of the bright red line of legality transactions carried
out during such activities reside.
In summary then, compliance costs for industry will have risen in 5 years, the precision of data held
by industry will have improved, the dividing line between what is permitted and what is not, will be
clearer, the professionalism of market abuse compliance functions will have risen with more internal
checks, the extent of dialogue with regulators will have risen both because of the increased STRs and
because data analysis within regulators will throw up more questions than in the past.
What I do not know is whether the provisions on criminality will have a significant effect. What I am
not sure of is whether, despite the sense of having made progress, we will feel that we have cracked
this one and that the regulatory framework is about right. For that regulators will have to have been
able to bring cases to a successful conclusion at a proportionate cost, and that remains to be seen.
Thank you
[ENDS]