Among the largest EU countries, Germany has similarly indicated that it will miss the January 31, 2007, deadline for transposing the directive. The more likely date for completion of this process is March, explains Georg Baur, director for financial markets at the Association of German Banks in Berlin. This means the country’s financial firms will have only seven months to prepare for implementation – and it could be even less if the legislative process takes longer than now predicted. But “we absolutely need at least nine months; and even that is not enough to deal with some aspects of the directive,” Baur says, citing the transparency and transaction reporting rules.

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