Sabine Kotz

Disclosure in Financial Markets: United States of America and Europe Sabine Kotz

Financial markets have been shaken to the core during the past few years and worldwide scandals beginning with Enron in 2001 have shown significant deficiencies of modern capital markets. Investors were left with enormous financial loss on either side of the Atlantic. How did the US being the world's leading financial market and its counterpart, the EU, respond to that? Did policy-makers have any other choice than transparency and disclosure as the cure? This book analyses the US and the EU approach to securities regulation and examines their fundamental differences and similarities. The author provides the necessary historical background to understand the rationale of the US disclosure philosophy in contrast to the EU's rather late development in this matter. The respective mandatory disclosure requirements are discussed including sections on IPOs, Admission and Trading, Prospectus, Ongoing Information and Accounting/Auditing. The author also deals with the Sarbanes-Oxley Act and its impact on EU legislation. The book is intended for lawyers interested in US and EU securities regulation, two regulatory systems on the road towards convergence in an interdependent global market.