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FESE feels that the Draft Report is giving more emphasis to the settlement of securities than to the clearing side, and therefore suggests a slightly more balanced document by inviting particular comments from practitioners and legal experts in the field of clearing.
FESE also suggests to check the wording of the sections on the individual barriers whether they really exist in the areas of clearing and of settlement. More precise definitions could increase the quality of the comments and the focus of the proposals, thereby facilitating their easier acceptance and later implementation.
Comments on the Preliminary Draft Sections