We do not agree with the set of criteria proposed. There is no index methodology that may cover all the criteria cumulatively in general. We think that the existing ESMA / UCITS criteria should be considered.
We do not think that the levels and numbers of the proposed criteria are appropriate. Instead we suggest adopting the existing UCITS levels of 35% and 20%.
We attach a list of other indices not mentioned in Annex I of which we think that they meet the proposed criteria, or where applicable, in disagreement of the criteria requirements would still be considered as appropriately diversified or where there are already stock index futures outstanding.