On liquidity fragmentation, FESE members believe that ESMA is interpreting its mandate too widely by proposing not only a definition but also the remedies to the potential issues posed by liquidity fragmentation.

In addition, our members believe that the definition of liquidity fragmentation proposed is too narrow.

With regard to the way in which CCPs should manage their resources, we consider that ESMA should have a more realistic recognition of the fact some CCPs belong to a wider group and may share resources within the group.

Finally, FESE members believe that the technical standards should include a minimum liquidation period of 1 day for listed derivatives, rather than 2 days, as this would be well within safety margins and in line with other major jurisdictions.