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FESE welcomes the ESME recommendation that there should be at least three days in which to notify the issuer to enable data to be gathered and verified. FESE recommends an even tighter timeframe and suggests that it is set at 2 business days for investors to notify and 2 days for the Issuer or the Competent Authority to report this information to the public.
FESE also supports changes to harmonise the threshold for notification of major shareholding at the EU level at 3% but warns against new European regulation. Also, FESE would not support changes to the current mechanics of disclosure foreseen by the TD.
Finally, with regard to stock lending, FESE would not support the introduction of regulatory measures, but would support further analyses of mechanisms allowing distinguishing between actual and potential holdings.