On June 22, 2016, the Joint Associations Committee on Retail Structured Products (JAC), along with the International Capital Market Association (ICMA) and ISDA (with the support of the Associazione Italiana Intermediari Mobiliari (ASSOSIM)), wrote to the Bank of Italy with observations and questions relating to the Bank of Italy Circular entitled Information reporting as contemplated in Article 129 of the TUB relating to the issue and offer of financial instruments in Italy. The letter points to critical doubts concerning the interpretation of the Circular, and lists practical questions raised by several banks ahead of the new reporting requirements applicable as of October 1, 2016. Please also see an earlier letter dated July 14, 2014 further down this page.