FPL’s response to Giovannini Draft Protocol Recommendation - January 2006 The essence of FPL’s response to the Giovannini Protocol Recommendation in February 2006 was:

FPL believes the Giovannini recommendation represents an important initiative to guide, inform and encourage standardisation of settlement processing, and FPL believes in the same four principles identified by the Giovannini Group of leverage, inclusivity, neutrality and openness.

In response to the specific question of whether the updated recommendation is an acceptable solution, FPL answered yes provided that the scope is settlement processing and that the distinction between ISO15022 and ISO20022 and the depiction of standards within diagram 1 is clarified.

Consistent with Giovannini’s principle of leverage, FPL believes that extending the most widely adopted standard in a space to universal coverage in that space is the best first step towards achieving the industry’s goals of simplicity, automation and ROI.  Thus, for the recommendation’s primary focus on cash equities and fixed income, FPL sees the FIX Protocol being used from pre-trade up to and including post-trade/pre-settlement, and the ISO15022-based MT54x series (and relevant downstream) messages being used to service settlement.

FPL appreciates having been invited to provide feedback on this important initiative and having had the opportunity to participate in the Independent Advisory Group to further refine the recommendation in 2005.  Given that the current Giovannini recommendation states that relevant expert bodies will be consulted for exchange traded derivatives, FPL looks forward to the opportunity to participate in this next phase.

FPL’s Response Letter

Elimination of Giovannini Barrier 1: Draft Protocol Recommendation – October 2005

Elimination of Giovannini Barrier 1: Consultation Paper – January 2005

Giovannini resource page