BBA has responded to CESR’s short selling consultation. Its response stresses the benefits of short selling, and says any solution must allow markets to operate with proportionate disclosure requirements. It supported IOSCO’s short selling principles. It thinks the scope of the regime suggested by CESR is reasonable and agrees it should be pan-European and fully harmonised. It does not support the suggestion of two-tier disclosure and does not agree with private disclosure to the regulator. It also thinks 0.5% is a suitable trigger threshold and a 0.1% incremental disclosure band is suitable regardless of circumstance. It agrees that market makers and underwriters should be exempt.