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FESE believes that it is key to draft Regulatory Technical Standards that are technology neutral – that is, which avoid having different rules according to the technology used. FESE further believes that the “same business, same risks, same rules” principle should apply, to uphold the values of transparency, fairness, stability, investor protection, and market integrity. Finally, ESMA should conduct a review of the regime in terms of content as a separate initiative, one which is not addressed to a specific type of technology that is used for trading/settlement.