USE OF CUSTOMER SECURITIES BY UK PRIME BROKERS: THE ROAD AHEAD
|
|
- Wilfrid Hubbard
- 8 years ago
- Views:
Transcription
1 USE OF CUSTOMER SECURITIES BY UK PRIME BROKERS: THE ROAD AHEAD DERIVATIVES AND TRADING A. INTRODUCTION The subject of the right of use of customer securities under English law has been greatly in focus since the collapse in 2008 of Lehman Brothers International (Europe) (LBIE), the London-based arm of the failed US investment bank. LBIE, like its UK competitors, was an habitual user of customer assets and its prime brokerage customers were therefore exposed to its balance sheet as a result of such activity. The Legal Certainty Group, mandated by the European Commission to examine the dismantling of the barriers having legal issues at their source, advised in 2008 that EU legislation is needed in this area providing for a more harmonised legal framework for intermediated securities and a better protection of investors rights enshrined in their securities. The European Council invited the Commission to present its response to the Legal Certainty Group Advice as a matter of urgency, including an outline of proposed legislative measures, accompanied by precise timelines for their effective submission to the European legislator, bearing in mind the benefits of maintaining global compatibility with other jurisdictions. 1 Since then, the European Commission issued a wide-ranging consultation paper in 2010, with the title Legislation on Legal Certainty of Securities Holding and Dispositions. 2 The European Commission Services are currently preparing a draft Directive on legal certainty of securities holding and transactions. The Directive is expected to address three issues: (i) the legal framework of holding and disposition of securities held in securities accounts, covering aspects belonging to the sphere of substantive law as well as conflict-of-laws; (ii) the legal framework governing the exercise of investor s rights flowing from securities through a chain of intermediaries, in particular in crossborder situations; and (iii) the submission of any activity of safekeeping and administration of securities under an appropriate supervisory regime. 3 At a Member States Technical Working Group in November 2012, the Commission signalled its intention to possibly change the scope of its proposals to include, inter alia, client asset regimes and rehypothecation as regards arrangements for making it easier to identify who owns what securities This is according to the Commission s website: securities-law/index_en.htm There has also been discussion amongst some participants in the financial markets as to whether any new European securities legislation should seek to provide increased protection to customers of financial services firms and more specifically whether such protections should include a limitation on the extent to which a financial services firm (such as a prime broker) is permitted to use customer securities. 4 The focus on the practice has therefore never been so sharp. It is hoped the views in this paper will contribute to the surrounding discussion. B. TERMINOLOGY SEMANTIC OR CONCEPTUAL CONFUSION? The term rehypothecation is employed widely in the global prime brokerage market. Its modern usage has its origins in the United States, within broker-dealer regulation applicable to prime brokerage business. The expression has since taken root in the City of London. Despite its wide use within the market as shorthand for the accepted practice of a financial services firm accessing and using a customer s securities, it is nevertheless a conceptually confusing label for English lawyers, as it does not necessarily describe what typically happens in practice. Hypothecation in English law, and by derivation rehypothecation, did not historically always involve a transfer of ownership. In modern practice it typically does. The International Swaps and Derivatives Association has been even more definitive: [T]he term rehypothecation is best avoided as its commercial meaning differs from its legal meaning, which can give rise to confusion Commercially, the term rehypothecation is generally used to signify any use of collateral by a collateral holder (including sale and repo) whereas its strict meaning is merely to repledge. 5 In the London prime brokerage market, the use of assets typically involves a prime broker removing securities from the customer s segregated custody account (where they had been subject to a mortgage or charge) and taking ownership or exercising a right of use as owner. 6 Arguments from some quarters that such a practice was contrary to certain equitable rules, e.g. the rule against a clog on the equity of redemption and the maxim once a mortgage always a mortgage, have been overcome as a result of the certainty afforded such arrangements under the Directive 2002/47/ 4 See, for example, the article published on the COOConnect website, a peer group network of COOs working in fund management: 5 User s Guide to the ISDA Credit Support Documents under English Law, page 53 6 Either under a title transfer financial collateral arrangement or a security financial collateral arrangement with an accompanying a right of use - see the Financial Collateral Arrangements (No 2) Regulations For discussion of such arrangements in practice, see Re Lehman Brothers International (Europe) (No 2) [2009] EWCA Civ 1161
2 EC of the European Parliament and of the Council of 6 June 2002 on financial collateral arrangements, as implemented in the UK through the Financial Collateral Arrangements (No 2) Regulations 2003 and various subsequent amending and supplementing regulations. Focus on the vocabulary is not mere semantics. In the United States, an investor knows that despite rehypothecation of his assets, he has statutory protections through the customer asset protection rules whereby the rehypothecated assets are treated as part of his net equity claim upon the failure of the prime broker. Prime brokers regulated in the United States by the Securities and Exchange Commission have a right of rehypothecation which is capped at 140 per cent of the customer s debt. In relation to rehypothecated assets, the protection comes in the distribution priority afforded to customers with net equity claims. The amount of a customer s net equity claim in liquidation is the value of its customer long positions minus the value of its obligations. Under that particular regime, customers whose securities have been rehypothecated have the same priority as customers whose securities have not been. Therefore the customer of the SEC-regulated prime broker associates the expression with a certain level of protection. 7 To the non-lawyer, it is easy to equate use of exactly the same expression in the London market as attracting a similar customer asset protection regime as is present in the United States. But that assumption would be misplaced. In Englishlaw governed arrangements, with the transfer of ownership 8 on use of customer securities by a prime broker, the customer ceases to have a proprietary interest; the securities cease to be customer securities benefiting from regulatory protections. The use converts the status of the customer s claim. From having an interest in rem, the customer has a contractual right, in personam, to equivalent securities, thereby making the customer a potential creditor of the financial institution because the property becomes an asset of the financial institution s estate. Of course the customer would typically have the benefit of insolvency or contractual set-off so as to reduce that risk to a net risk. Rightly, on several recent occasions, English judges, regulators and legislators have steered away from the temptation to adopt the expression rehypothecation when the subject-matter has involved the right of use, as understood by the commercial community. 9 The discussion on vocabulary does not end there. Interestingly, in the context of a contractual right of use governed by English law, several prime brokers use the terms use and appropriate interchangeably, despite the fact that the first is really a tool and the second a remedy. When customer securities are used by a prime broker the customer has a corresponding receivable a claim for equivalent securities. In contrast, appropriation is a self-help remedy 10. In both cases, the collateral-taker acquires an indefeasible interest in the collateral. However, in the case of appropriation, the customer no longer has a contractual claim for equivalent securities because his claim is effectively notionally monetised and the value applied against his debt (the customer has a right to be paid the amount by which the value of the collateral exceeds the amount of the debt). The distinction is commercially important because, in the absence of a default, in the ordinary course of business a customer might expect some of its assets to be used, but would not expect its long securities positions to be subject to appropriation if the effect is that its profit and loss in those positions is crystallised and the value applied to eliminate its portfolio leverage. 11 C. THE COMMERCIAL AND LEGAL BASIS FOR USING CUSTOMER SECURITIES There is surely a commercial and legal basis for use of customer securities in certain circumstances, such as where the customer is receiving long- or short-side financing from the prime broker. Equally, there is surely a case in the context of English law-governed rights of use for exercising such a right in a proportionate manner. However, it does not necessarily follow from this that legislation, over and above bilateral contractual agreement, is required. To suggest otherwise implies that legislation is the saving supplement of contract, which doesn t say much for the law of contract. These views are examined below. 7 The US regime has its own challenges. For example, the account is valued at the close of business on the filing date of the liquidation proceeding. Obviously the market can move against the customer before distribution 8 In English property law the expression absolute ownership has no single, precise meaning, but it is in general used to refer to the quantum of an owner s interest, rather than to its character as legal or equitable ownership, per Lord Walker in Cukarova Finance International Ltd. v. Alfa Telecom Turkey Ltd. [2012] UKPC 20, at paragraph 33. Note that the transfer of legal and beneficial ownership may be technically unworkable in situations involving an intermediated chain holding of book-entry securities because the customer may be at the bottom of the chain see Pearson v Lehman Brothers Finance [2010] EWHC In such cases it is transferring its full ownership, consisting of equitable title 2 9 In the courts, the principal judgments relating to the collapse of Lehman Brothers International (Europe) where a right of use was part of the fact-pattern before the court, the court declined to adopt the term rehypothecation : Lomas & Ors v RAB Market Cycles (Master) Fund Ltd & Ors [2009] EWHC 2545; Re Lehman Brothers International (Europe) (No 2) [2009] EWHC 2141; Re Lehman Brothers International (Europe) (No 2) [2009] EWCA Civ 1161; Lehman Brothers International (Europe) v CRC Credit Fund Limited & Ors [2009] EWHC 3228; Lehman Brothers International (Europe) v CRC Credit Fund Limited & Ors [2010] EWCA Civ 917; Lehman Brothers International (Europe) v CRC Credit Fund Limited & Ors [2012] UKSC 6. Similarly, the Financial Services Authority has also declined to adopt the term, preferring the expressions right to use or right of use (e.g. see CASS rules 7.2, 9.2 and 9.3). Legislators too: the expression right of use is used in the Financial Collateral Arrangements (No. 2) Regulations Introduced by the Financial Collateral Arrangements (No 2) Regulations 2003 (which implemented Directive 2002/47/EC) 11 For a full analysis of appropriation see Cukarova Finance International Ltd. v. Alfa Telecom Turkey Ltd. [2012] UKPC 20; and Lord Millett, The Remedy of Appropriation Under a Share Mortgage (2008) 2 Law and Financial Markets Review 333
3 To the casual observer it is incongruous that, in the absence of a customer s default, a prime broker can on the one hand maintain a safekeeping account for the customer s securities and, on the other hand, access those securities for its own purposes. Once armed with securities and free of custodial obligations, the prime broker can use those securities as a funding tool to raise cash via the overnight repo market and other funding sources. In such circumstances, he would say: What is going on here? But there are in fact various justifications for the use of customer assets. A prime broker will wish to use customer securities to collateralise funding it obtains to support the customer s borrowings. More than that, a prime broker will want to use customer securities with a value in excess of the value of the loans extended to the customer (the precise ratio may be subject to negotiation), on the basis that to raise one pound or dollar in the money markets the prime broker will inevitably be required to post more than one pound s or one dollar s worth of assets to the payer of the cash leg of the repurchase agreement. When explained in these terms to the customer enquiring as to the justification for the value of securities used exceeding the amount of the debt, such explanation is routinely accepted. A customer whose securities have been used to fund his borrowings recognises there is a direct nexus between benefit and risk and accepts credit risk of the prime broker as the quid pro quo. The second justification is that use of customer securities enables the financial institution to fund its own proprietary business (rather than just customer accounts). When it comes to the institution s own business, the ability to improve access to cash enhances the institution s liquidity. There are counter-arguments to this as a business model but that is not for this paper. The third justification is that use of customer securities may in theory enhance cash and securities liquidity in the market. The fourth justification is that use of the securities of customer A, can allow a prime broker to cover the short sale of that security by customer B which assists liquidity for customer B and reduces the risk of naked short sales (and the prime broker makes a profit in the form of a lending fee under such an arrangement). Clearly some of the reasons for exercising a right of use listed above are necessary for the customer to implement its strategy, some may not be necessary but produce a commercial benefit to the customer and some have a less direct benefit to the customer but are justifiable as producing indirect benefits or benefits to the other clients of the prime broker, to the prime broker itself and/or to the market as a whole. For example, the more assets that can be used by a prime broker, the cheaper it can make borrowing costs for customers generally. D. LIMITING THE EXTENT OF USE But, in the context of English-law arrangements, should there be some limit on a prime broker s right to use customer assets? And how should any uniform limit be established? The answer to the first question is surely yes ; the answer to the second, it is suggested, is only with very careful consideration and, in any event, with great difficulty. If justification over and above common-sense is needed to arrive at the affirmative answer for the first question, it is perhaps illustrative to test the proposition by way of examples. Take the master of a ship transporting cargo in the eighteenth century. Mid-voyage the ship requires certain necessary equipment to enable completion of the voyage. The master does not have sufficient funds available and no other source of credit to fund the necessaries. In the absence of the owner of the cargo on the voyage and faced with the extreme difficulty of communication with the owner, can the master hypothecate (or indeed sell) the cargo, in order to obtain credit to fund the replacement equipment? There is an extensive specialist body of law in this area, mainly consisting of cases from the 1700s and 1800s, well-beyond the experience of the writer. At the risk of over-simplifying works in that specialist area, it appears that the courts kept the master on a tight rein and vested him with only a limited implied authority to hypothecate part of the cargo to the extent necessary to fund the necessary equipment to enable the vessel to complete the voyage. 12 The concept of proportionality is apparent. This is not easily translated into the modern context, other than to observe the starting point for the courts of the time: that the master was first and foremost a carrier of cargo, rather than a hypothecator. In the old shipping cases involving hypothecation there was typically no transfer of possession or ownership. The need for proportionality, in the writer s view, applies, a fortiori, where there is a transfer of ownership. 12 See, generally, the well-regarded treatise by the American lawyer, William Story: A Treatise on the Law of Contracts (5th Ed, 1874). With contracts of bottomry, the master of the ship could borrow money on the security of the ship s keel to finance completion of the voyage. Contracts of respondentia were the cargo equivalent 3
4 So to another example. Take the prime brokerage customer with no debt to his prime broker who permits the prime broker to use all of his securities held in custody. No collateral moves from the prime broker and no fee is paid for the privilege of use. That customer will struggle to identify the risk/reward if the prime broker becomes insolvent at a time when the prime broker has used 100,000,000-worth of securities, leaving the customer as an unsecured creditor of the prime broker (unless of course he had no real choice in the circumstances other than to use that prime broker on those terms). 13 On the question of how to arrive at a limit, there are two distinct options: contractual agreement or legislative prescription. 14 In reality, the vast majority of customers (typically hedge funds) accept the prime broker s contractual right of use, not only because of the commercial justifications but also because that is the way the prime brokerage world works. The business structures and investment strategies of certain hedge funds mean that the use of a prime broker is, for those types of funds, important, and the prime brokerage market generally operates on terms that require a right of use. Lord Justice Patten recently observed: Hedge funds do not have substantial back office functions of their own. They therefore require a third party to deal with the trades themselves and thereafter to provide custodial and reporting services. As part of these transactional arrangements, prime brokers such as LBIE lent cash and securities to the hedge funds and provided foreign exchange services. Any finance was usually secured against the assets of the hedge fund held by or through the prime broker. 15 However, it does not mean to say that limits on a right of use cannot be agreed contractually. Indeed they are commonly agreed. Hedge funds are generally alive to the existence of a right of use and the risks associated with such a right. If they are not, they are made aware of the risks. A prime broker acts in several capacities. Two of these capacities are of particular note. It is a custodian of customer securities. But it is also a lender of cash and securities to the customer (the typical 13 Total transfer of title arrangements have existed see the observations of Briggs J at first instance In the Matter of Lehman Brothers International (Europe), Lomas and others v. RAB Market Cycles (Master) Fund Limited and others [2009] EWHC 2545 para 8 14 Some jurisdictions impose limits on rights of use on certain types of funds established in those jurisdictions, e.g. Ireland, which prime brokers need to adhere to as a condition of the fund doing business with the prime broker. These jurisdictions do not include the Cayman Islands, where a large proportion of hedge funds are established 15 Re Lehman Brothers International (Europe) (No 2) [2009] EWCA Civ 1161 para 2 customer is a hedge fund either wishing to lever its long investments through borrowing money and/or to borrow securities to cover its short sales). It is in its capacity as a lender that the prime broker has a second relationship to the securities: that of user. There is an inherent but recognised potential conflict of duty and interest here. On the one hand, the prime broker, as a custodian and nominee shareholder of securities beneficially owned by the customer, is obliged to act in the interests of the customer with respect to those securities, subject to its rights as a secured lender. On the other hand, the prime broker has an interest in removing the securities from custody and using them to raise finance, as a potentially deeper and cheaper alternative pool of funding to its own treasury reserves. This is not entirely self-serving as the customer receives the commercial benefit of cheaper financing. It follows that if it is to use the securities for its own account (and make profit from such use), the prime broker is obliged to obtain the informed consent of the customer. This is typically achieved by disclosure to the customer 16, who consents by signing the prime brokerage contract. With knowledge of the risks arising when a right of use is exercised, hedge funds may wish to limit, by contract, the extent of the right of use and often seek to do so. As with any commercial negotiation, any cap is entirely a matter for the two parties and many factors will come into play in arriving at an agreement. F. USE OF CUSTOMER SECURITIES: BEYOND CREDIT RISK Does the exercise of a right of use bring with it risks to the customer other than counterparty credit risk? Indeed it does. On the prime broker s insolvency, the customer may not have upto-date information as to which securities were used and which were not. This creates uncertainty when it comes to valuing the customer s portfolio (which it needs to do for investors) and managing its investments (e.g. the hedge fund may not know whether its bond, which was being held as part of an arbitrage against a short swap, still exists in its portfolio or not, and therefore whether the arbitrage exists or whether the fund is now directional). New FSA Rules impose on prime brokers an obligation to provide transparency reports, incorporating the value of collateral where the firm has exercised a right of use. 17 However, this is provided on a next-day basis and does not reveal the specific securities used (only their value). 16 Usually a term of the contract but now supplemented by a regulatory obligation to make disclosure, including detailing the key risks: see FSA CASS rule FSA CASS rule 9.2(3)(c) 4
5 A customer of an insolvent prime broker would presumably therefore say that something more is needed. Customer accounts typically do not show a debit corresponding to use of the particular security by the prime broker. This is on the basis that in the absence of the prime broker s insolvency and even though the customer s risk changes, as a business matter the customer would regard its balance sheet as unaffected given that it has a receivable for equivalent securities. A customer needs to know, in one place, what its portfolio composition is, whether in the form of proprietary positions or contractual receivables so, commercially, consolidated reporting makes sense. Subject of course to what is operationally achievable, in the writer s view the customer accounts should continue to show the used positions, but with an annotation that they have been used. This would allow the prime broker to provide the customer with the information it needs as to its total assets and liabilities (with assets comprising proprietary positions and contractual receivables) but also enable the customer to identify what positions are at risk. G. CONCLUSIONS Some thoughts, by way of conclusion: 1. There is a sound legal and commercial basis for proportionality when it comes to the extent of the right of use of customer assets. This is often expressed by way of contractual limitation through an agreed cap. 2. When it comes to caps, one-size does not fit all. The precise ratios of customer debt to value of securities used may vary customer to customer for a variety of reasons, including the fundability of the particular customer portfolio. For example, a prime broker accessing a very liquid and easy-to-fund hedge fund portfolio, where the securities used for repurchase are not subject to significant haircuts, will not need as many assets by value to raise finance as the prime broker accessing a very illiquid portfolio. 3. Contract allows for the flexibility required to address these variables; a hard-coded regulatory cap would be inconsistent with the conclusion above. If there was such a cap, applied across the board, it would therefore need to err on the side of allowing more rather than less, and therefore away from the direction of customer protection, if the commercial justifications for use were to still be achievable. A one-cap-fits-all approach may therefore end up benefitting some sections of the hedge fund market and harming others, particularly those who may otherwise have negotiated lower caps. For that reason, any regulatory cap should be expressed as a maximum amount, so as to give the parties scope to negotiate a lower amount. 4. It would be clumsy to simply follow the 140 per cent cap in the United States because that is set against a specific framework that allows for rehypothecated securities to form part of a customer s net equity claim. A similar regime is not in existence in the UK. 5. If the market is capable of agreeing caps bilaterally, would the additional cost and time needed to implement a regulatory cap (which would include building logic into prime brokerage asset sweeping systems) achieve a great deal? 6. Operational challenges duly acknowledged, annotations on customer accounts against specific security lines, to indicate whether they have been used and, if so, in what proportion, would be a useful risk management tool for hedge funds. CONTACT DETAILS If you would like further information or specific advice please contact: DANIEL HARRIS 18 DD: +44 (0) daniel.harris@macfarlanes.com MARCH Solicitor-at-law. The views expressed are the writer s and do not necessarily represent the views of Macfarlanes LLP. Nothing in this paper shall constitute legal advice and it may not be relied upon as legal advice. The writer is grateful for the thoughts of Damian Morris, General Counsel EMEA, ICAP plc and Lord Millett, on an earlier draft. Any errors are entirely those of the writer This article was first published in the March issue of Law and Financial Markets Review. MACFARLANES LLP 20 CURSITOR STREET LONDON EC4A 1LT T: +44 (0) F: +44 (0) DX 138 Chancery Lane This note is intended to provide general information about some recent and anticipated developments which may be of interest. It is not intended to be comprehensive nor to provide any specific legal advice and should not be acted or relied upon as doing so. Professional advice appropriate to the specific situation should always be obtained. Macfarlanes LLP is a limited liability partnership registered in England with number OC Its registered office and principal place of business are at 20 Cursitor Street, London EC4A 1LT. The firm is not authorised under the Financial Services and Markets Act 2000, but is able in certain circumstances to offer a limited range of investment services to clients because it is authorised and regulated by the Solicitors Regulation Authority. It can provide these investment services if they are an incidental part of the professional services it has been engaged to provide. Macfarlanes March 2013
CORPORATE MEMBERS OF LIMITED LIABILITY PARTNERSHIPS
1. INTRODUCTION CORPORATE MEMBERS OF LIMITED LIABILITY PARTNERSHIPS 1.1 This note, prepared on behalf of the Company Law Committee of the City of London Law Society ( CLLS ), relates to BIS request for
More informationInternational Swaps and Derivatives Association, Inc. COLLATERAL LAW REFORM GROUP UNITED KINGDOM COUNTRY REPORT
International Swaps and Derivatives Association, Inc. COLLATERAL LAW REFORM GROUP UNITED KINGDOM COUNTRY REPORT Supplement to Collateral Arrangements in the European Financial Markets: The Need for National
More informationTrusts: A Realistic Alternative to Security?
Trusts: A Realistic Alternative to Security? This article, written by restructuring & insolvency senior associate Rebecca Walker, first featured in the April 2014 edition of Butterworths Journal of International
More informationSecurity over Collateral. CAYMAN ISLANDS Walkers
Security over Collateral CAYMAN ISLANDS Walkers CONTACT INFORMATION Louise Groom Walkers Walkers House 87 Mary Street Grand Cayman KY1-9001 Cayman Islands +1.34.59.265.600 louise.groom@walkersglobal.com
More informationPublic consultation on the possibility for an investment fund to originate loans
Public consultation on the possibility for an investment fund to originate loans The purpose of this consultation is to gather the opinions of all interested parties about the possibility for French investment
More informationtrends in prime brokerage
trends in prime brokerage The swift and unexpected collapse of Lehman Brothers revealed serious shortcomings in the traditional prime brokerage model. Lehman Brothers prime brokerage clients faced considerable
More informationASSIGNMENT AND CHARGES OF CONTRACTUAL RIGHTS AND RECEIVABLES
ASSIGNMENT AND CHARGES OF CONTRACTUAL RIGHTS AND RECEIVABLES A version of this article, written by Head of Banking & Finance, Jonathan Porteous, first featured in Butterworths Journal of International
More informationFinal European Standards for Derivatives Collateralisation
Client Alert 17 March 2016 Final European Standards for Derivatives Collateralisation On 8 March 2016, the three European Supervisory Authorities (ESAs) 1 published their final draft regulatory technical
More informationNEPAL ACCOUNTING STANDARDS ON INVESTMENT IN ASSOCIATES
NAS 25 NEPAL ACCOUNTING STANDARDS ON INVESTMENT IN ASSOCIATES CONTENTS Paragraphs SCOPE 1-2 DEFINITIONS 3-13 Significant influence 7-11 Equity method 12-13 APPLICATION OF THE EQUITY METHOD 14-33 Impairment
More informationThe Scottish Investment Trust PLC
The Scottish Investment Trust PLC INVESTOR DISCLOSURE DOCUMENT This document is issued by SIT Savings Limited (the Manager ) as alternative investment fund manager for The Scottish Investment Trust PLC
More informationSTANDARD LIFE INVESTMENTS PROPERTY INCOME TRUST LIMITED
This document is issued by Standard Life Investments Property Income Trust Limited (the "Company") and is made available by Standard Life Investments (Corporate Funds) Limited (the AIFM ) solely in order
More informationRules Notice Request for Comment. Summary of nature and purpose of proposed Rule
Rules Notice Request for Comment Dealer Member Rules Contact: Answerd Ramcharan Specialist, Member Regulation Policy 416 943-5850 aramcharan@iiroc.ca Please distribute internally to: Credit Institutional
More informationRISK DISCLOSURE STATEMENT
RISK DISCLOSURE STATEMENT You should note that there are significant risks inherent in investing in certain financial instruments and in certain markets. Investment in derivatives, futures, options and
More informationFinancial Services Alert
April 2008 Authors: Robert T. Honeywell 212.536.4863 robert.honeywell@klgates.com Anthony R. G. Nolan 212.536.4843 anthony.nolan@klgates.com Donald W. Smith 202.778.9079 donald.smith@klgates.com Robert
More informationCollateral Management Best Practices for Broker-Dealers
Banking & Securities Collateral Management Best Practices for Broker-Dealers Jeff Penney Collateral Management Best Practices for Broker-Dealers 1 col lat er al (noun) something pledged as security for
More informationInternational Accounting Standard 28 Investments in Associates
International Accounting Standard 28 Investments in Associates Scope 1 This Standard shall be applied in accounting for investments in associates. However, it does not apply to investments in associates
More informationInvestments in Associates
Indian Accounting Standard (Ind AS) 28 Investments in Associates Investments in Associates Contents Paragraphs SCOPE 1 DEFINITIONS 2-12 Significant Influence 6-10 Equity Method 11-12 APPLICATION OF THE
More informationSri Lanka Accounting Standard LKAS 28. Investments in Associates
Sri Lanka Accounting Standard LKAS 28 Investments in Associates CONTENTS SRI LANKA ACCOUNTING STANDARD LKAS 28 INVESTMENTS IN ASSOCIATES paragraphs SCOPE 1 DEFINITIONS 2 12 Significant influence 6 10 Equity
More informationSSAP 24 STATEMENT OF STANDARD ACCOUNTING PRACTICE 24 ACCOUNTING FOR INVESTMENTS IN SECURITIES
SSAP 24 STATEMENT OF STANDARD ACCOUNTING PRACTICE 24 ACCOUNTING FOR INVESTMENTS IN SECURITIES (Issued April 1999) The standards, which have been set in bold italic type, should be read in the context of
More informationBrown Advisory Strategic Bond Fund Class/Ticker: Institutional Shares / (Not Available for Sale)
Summary Prospectus October 30, 2015 Brown Advisory Strategic Bond Fund Class/Ticker: Institutional Shares / (Not Available for Sale) Before you invest, you may want to review the Fund s Prospectus, which
More informationLAZARD GLOBAL INVESTMENT FUNDS PUBLIC LIMITED COMPANY LAZARD EMERGING MARKETS BOND FUND SIMPLIFIED PROSPECTUS. DATE 7 December 2010
LAZARD GLOBAL INVESTMENT FUNDS PUBLIC LIMITED COMPANY LAZARD EMERGING MARKETS BOND FUND SIMPLIFIED PROSPECTUS DATE 7 December 2010 This Simplified Prospectus contains key information in relation to Lazard
More informationA Proposal to Resolve the Distress of Large and Complex Financial Institutions
A Proposal to Resolve the Distress of Large and Complex Financial Institutions Viral V Acharya, Barry Adler and Matthew Richardson 1 Due to the difficulty in resolving bankruptcies of large multinational
More informationClient Asset Requirements. Under S.I No.60 of 2007 European Communities (Markets in Financial Instruments) Regulations 2007
Client Asset Requirements Under S.I No.60 of 2007 European Communities (Markets in Financial Instruments) Regulations 2007 Instructions Paper November 2007 1 Contents 1 Contents 2 Introduction 1 2.1 Scope
More informationADVISORSHARES YIELDPRO ETF (NASDAQ Ticker: YPRO) SUMMARY PROSPECTUS November 1, 2015
ADVISORSHARES YIELDPRO ETF (NASDAQ Ticker: YPRO) SUMMARY PROSPECTUS November 1, 2015 Before you invest in the AdvisorShares Fund, you may want to review the Fund s prospectus and statement of additional
More informationAmendments recommended by the City of London Law Society to clause 48(1) of the Banking Bill 2008
The City of London Law Society 4 College Hill London EC4R 2RB Tel: 020 7329 2173 Fax: 020 7329 2190 www.citysolicitors.org.uk Amendments recommended by the City of London Law Society to clause 48(1) of
More informationFinancial collateral arrangements and the financial markets
European Bank for Reconstruction and Development SECURED LENDING IN COMMERCIAL TRANSACTIONS TRENDS AND PERSPECTIVES 4-5 November 2013, EBRD Headquarters, London Financial collateral arrangements and the
More informationInvestments in Associates and Joint Ventures
STATUTORY BOARD FINANCIAL REPORTING STANDARD SB-FRS 28 Investments in Associates and Joint Ventures This standard applies for annual periods beginning on or after 1 January 2013. Earlier application is
More informationNATIONAL FINANCIAL SERVICES LLC STATEMENT OF FINANCIAL CONDITION AS OF DECEMBER 31, 2015 AND REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM
STATEMENT OF FINANCIAL CONDITION AS OF DECEMBER 31, 2015 AND REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM Report of Independent Registered Public Accounting Firm To the Board of Directors of
More informationEUROPEAN CENTRAL BANK
19.2.2013 Official Journal of the European Union C 47/1 III (Preparatory acts) EUROPEAN CENTRAL BANK OPINION OF THE EUROPEAN CENTRAL BANK of 24 May 2012 on a draft Commission delegated regulation supplementing
More informationThe ABI s response to the European Commission s Consultation Document on Foreign Exchange Financial Instruments
The ABI s response to the European Commission s Consultation Document on Foreign Exchange Financial Instruments The ABI The UK Insurance Industry The UK insurance industry is the third largest in the world
More information2012 ANNUAL MEETING AND EDUCATION CONFERENCE American College of Investment Counsel New York, NY
2012 ANNUAL MEETING AND EDUCATION CONFERENCE American College of Investment Counsel New York, NY SESSION 4: SHORT-TERM INVESTMENTS AND SHORT-TERM FINANCING FOR INSURANCE COMPANIES: ALTERNATIVES TO THE
More information(1 April 2015 to date) COLLECTIVE INVESTMENT SCHEMES CONTROL ACT 45 OF 2002
(1 April 2015 to date) COLLECTIVE INVESTMENT SCHEMES CONTROL ACT 45 OF 2002 Government Notice 1583 in Government Gazette 24182, dated 13 December 2002. Commencement date: 3 March 2003 [Proc. No.R.18, Gazette
More informationSTRUCTURING A BUSINESS AS A LIMITED LIABILITY PARTNERSHIP (LLP)
STRUCTURING A BUSINESS AS A LIMITED LIABILITY PARTNERSHIP (LLP) CORPORATE LAW INTRODUCTION Partnerships have been used for many years as flexible business vehicles for enterprises, especially where they
More informationMARKET NOTICE - EXPANDING ELIGIBLE COLLATERAL IN THE DISCOUNT WINDOW FACILITY
MARKET NOTICE - EXPANDING ELIGIBLE COLLATERAL IN THE DISCOUNT WINDOW FACILITY 1. This Market Notice provides details on the Bank s requirements for accepting portfolios of loans as collateral in the Discount
More informationRBC Money Market Funds Prospectus
RBC Money Market Funds Prospectus November 25, 2015 Prime Money Market Fund RBC Institutional Class 1: RBC Institutional Class 2: RBC Select Class: RBC Reserve Class: RBC Investor Class: TPNXX TKIXX TKSXX
More informationINFORMATION FOR OBSERVERS
30 Cannon Street, London EC4M 6XH, United Kingdom Tel: +44 (0)20 7246 6410 Fax: +44 (0)20 7246 6411 E-mail: iasb@iasb.org Website: www.iasb.org International Accounting Standards Board This document is
More informationIndependent Commission on Banking Final Report on UK Banking Reform
Independent Commission on Banking Final Report on UK Banking Reform 13 September 2011 1. Introduction The UK Independent Commission on Banking (the ICB ) published its final report on 12 September 2011.
More informationCode of Practice - Risk Management Including With Regard To Debtors
Code of Practice - Risk Management Including With Regard To Debtors The Code of Practice was first approved by the Minister of Finance on the 5 th July 2010, with this updated version approved by the Minister
More informationSHUAA Capital PSC INTERIM CONDENSED CONSOLIDATED FINANCIAL STATEMENTS
INTERIM CONDENSED CONSOLIDATED FINANCIAL STATEMENTS 30 SEPTEMBER INTERIM CONSOLIDATED STATEMENT OF INCOME Notes 1 July to (3 Months) 1 January to 1 July to (3 Months) 1 January to Interest income 31,906
More informationArticle 23/FUND 3.2.2R Disclosures
Article 23/ Disclosures Phoenix Asset Management Partners Ltd. is authorised and regulated by the Financial Conduct Authority (FCA) 64 66 Glentham Road London SW13 9JJ +44 (0) 208 600 0100 phoenix@pamp.co.uk
More informationCayman Islands Unit Trusts
Cayman Islands Unit Trusts Foreword This memorandum has been prepared for the assistance of those who are considering the formation of unit trusts in the Cayman Islands ( Cayman ). It is not intended to
More informationAMERICAN BAR ASSOCIATION. ADOPTED BY THE HOUSE OF DELEGATES February 4-5, 2002
AMERICAN BAR ASSOCIATION ADOPTED BY THE HOUSE OF DELEGATES February 4-5, 2002 RESOLVED, that the American Bar Association recommends that the United States sign and ratify the United Nations Convention
More informationIs your prime broker or administrator the biggest threat to the success of your business?
Is your prime broker or administrator the biggest threat to the success of your business? Managers have become so wearily familiar with completing and issuing due diligence questionnaires that there is
More informationConsolidated Financial Statements
STATUTORY BOARD FINANCIAL REPORTING STANDARD SB-FRS 110 Consolidated Financial Statements This standard applies for annual periods beginning on or after 1 January 2013. Earlier application is permitted
More informationChief Executive Officers of All National Banks, Deputy Comptrollers (District) and All Examining Personnel
O BC - 196 BANKING ISSUANCE Comptroller of the Currency Administrator of National Banks Type: Banking Circular Subject: Securities Lending To: Chief Executive Officers of All National Banks, Deputy Comptrollers
More informationAMERICAN COLLEGE OF BANKRUPTCY INTERNATIONAL INSOLVENCY INSTITUTE JOINT DISCUSSION PANEL MARCH 18, 2005
AMERICAN COLLEGE OF BANKRUPTCY INTERNATIONAL INSOLVENCY INSTITUTE JOINT DISCUSSION PANEL MARCH 18, 2005 UNCITRAL LEGISLATIVE GUIDE TREATMENT OF FINANCING INSOLVENCY PROCEEDINGS DANIEL M. GLOSBAND GOODWIN
More informationInternational Financial Reporting Standard 7 Financial Instruments: Disclosures
EC staff consolidated version as of 21 June 2012, EN EU IFRS 7 FOR INFORMATION PURPOSES ONLY International Financial Reporting Standard 7 Financial Instruments: Disclosures Objective 1 The objective of
More informationCLIENT UPDATE SEC AMENDS FINANCIAL RESPONSIBILITY RULES AND ADOPTS CUSTODY RULES
CLIENT UPDATE SEC AMENDS FINANCIAL RESPONSIBILITY RULES AND ADOPTS CUSTODY RULES NEW YORK Gregory J. Lyons gjlyons@debevoise.com Lee A. Schneider lschneider@debevoise.com Samuel E. Proctor seproctor@debevoise.com
More informationIRISH TAKEOVER PANEL CONSULTATION PAPER DISCLOSURE OF DEALINGS AND INTERESTS IN DERIVATIVES AND OPTIONS PROPOSALS TO AMEND THE TAKEOVER RULES
IRISH TAKEOVER PANEL CONSULTATION PAPER DISCLOSURE OF DEALINGS AND INTERESTS IN DERIVATIVES AND OPTIONS PROPOSALS TO AMEND THE TAKEOVER RULES 30 July 2008 Contents Page A. Introduction 4 B. Amendments
More informationGOLDMAN SACHS BANK USA AND SUBSDIARIES
GOLDMAN SACHS BANK USA AND SUBSDIARIES Consolidated Financial Statements As of and for the years ended December 31, 2014 and December 31, 2013 Financial Statements INDEX Page No. Consolidated Financial
More informationGood Practice Checklist
Investment Governance Good Practice Checklist Governance Structure 1. Existence of critical decision-making bodies e.g. Board of Directors, Investment Committee, In-House Investment Team, External Investment
More informationFREQUENTLY ASKED QUESTIONS
FREQUENTLY ASKED QUESTIONS 1) What is a TTCA? TTCA is short for Title Transfer Collateral Arrangement. This term is used to describe an agreement under which collateral is provided by one party (the Collateral
More informationBasel Committee on Banking Supervision
Basel Committee on Banking Supervision Frequently asked questions on the Basel III leverage ratio framework April 2016 (update of FAQs published in July 2015) This publication is available on the BIS website
More informationInvestments in Associates and Joint Ventures
International Accounting Standard 28 Investments in Associates and Joint Ventures In April 2001 the International Accounting Standards Board (IASB) adopted IAS 28 Accounting for Investments in Associates,
More informationLiquidity Coverage Ratio: A Quick Reference. February 2015
Liquidity Coverage Ratio: A Quick Reference February 2015 2015 Morrison & Foerster LLP All Rights Reserved mofo.com The Liquidity Coverage Ratio (the LCR or the rule ) adopted by the Office of the Comptroller
More informationMargin requirements for certain cash and security borrowing and lending arrangements - Amendments to Schedules 1, 7 and 7A of Dealer Member Form 1
Rules Notice Notice of Approval/Implementation Dealer Member Rules Contact: Answerd Ramcharan Manager, Financial Information, Member Regulation Policy 416 943-5850 aramcharan@iiroc.ca Please distribute
More informationExchange Traded Funds. An Introductory Guide. For professional clients only
Exchange Traded Funds An Introductory Guide For professional clients only Exchange-Traded Funds (ETFs) started to be used in Europe in the early 2000s but over the past few years they have grown their
More information(each a Provision and together the Provisions ).
Notification and justification for the UK Financial Conduct Authority s ( FCA s ) requirements relating to safe custody assets and client money, under Article 4 of Directive 2006/73/EC ( Level 2 Directive
More informationHow to start a Hedge Fund
How to start a Hedge Fund How to start a Hedge Fund Introduction When setting up a hedge fund, you will need to consider the following matters: Jurisdiction Fund structure Eligible investors Authorisation
More information(Legislative acts) REGULATIONS
24.3.2012 Official Journal of the European Union L 86/1 I (Legislative acts) REGULATIONS REGULATION (EU) No 236/2012 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 14 March 2012 on short selling and
More informationRegulatory Practice Letter September 2013 RPL 13-18
Regulatory Practice Letter September 2013 RPL 13-18 Financial Responsibility Rules for Broker-Dealers Final Revisions Executive Summary The Securities and Exchange Commission (SEC) has issued its long
More informationThe Commercial Agents Regulations.DOC. The Commercial Agents Regulations
The Commercial Agents Regulations.DOC The Commercial Agents Regulations Contents 1. Introduction... 1 2. The Previous Position... 1 3. Commercial Agent... 2 4. Rights and Duties... 3 5. Remuneration...
More informationIPSAS 7 INVESTMENTS IN ASSOCIATES
IPSAS 7 INVESTMENTS IN ASSOCIATES Acknowledgment This International Public Sector Accounting Standard (IPSAS) is drawn primarily from International Accounting Standard (IAS) 28 (Revised 2003), Investments
More informationNavigating Through the New Broker-Dealer Reporting & Financial Responsibility Rules
EisnerAmper LLP Accountants and Advisors www.eisneramper.com Navigating Through the New Broker-Dealer Reporting & Financial Responsibility Rules eisneramper llp TABLE OF CONTENTS 04 New Rules Affecting
More informationMargin requirements for certain cash and security borrowing and lending arrangements - Amendments to Schedules 1, 7 and 7A of Dealer Member Form 1
Rules Notice Request for Comments Dealer Member Rules Please distribute internally to: Credit Institutional Internal Audit Legal and Compliance Operations Regulatory Accounting Senior Management Trading
More informationEngland and Wales Treasury Shares Guide IBA Corporate and M&A Law Committee [2014]
England and Wales Treasury Shares Guide IBA Corporate and M&A Law Committee [2014] Contact Greg Scott, Partner Memery Crystal LLP gscott@memercrystal.com 1 Contents Page SCOPE OF THIS REPORT... 3 GENERAL
More informationBasel Committee on Banking Supervision. Frequently Asked Questions on Basel III s January 2013 Liquidity Coverage Ratio framework
Basel Committee on Banking Supervision Frequently Asked Questions on Basel III s January 2013 Liquidity Coverage Ratio framework April 2014 This publication is available on the BIS website (www.bis.org).
More informationSTANDARD LIFE EUROPEAN PRIVATE EQUITY TRUST PLC
This document is issued by Standard Life European Private Equity Trust PLC (the "Company") and is made available by SL Capital Partners LLP (the AIFM ) solely in order to make certain particular information
More informationEuropean Bank for Reconstruction and Development. The EBRD Green Energy Special Fund
European Bank for Reconstruction and Development The EBRD Green Energy Special Fund Annual Financial Report 31 December 2012 Contents Statement of comprehensive income... 1 Balance sheet... 1 Statement
More informationIn depth A look at current financial reporting issues
inform.pwc.com In depth A look at current financial reporting issues December 2014 No. INT2014-11 What s inside: Background: Illustrative tabular disclosures: Frequently asked questions: Contacts: Frequently
More informationDaily Income Fund Retail Class Shares ( Retail Shares )
Daily Income Fund Retail Class Shares ( Retail Shares ) Money Market Portfolio Ticker Symbol: DRTXX U.S. Treasury Portfolio No Ticker Symbol U.S. Government Portfolio Ticker Symbol: DREXX Municipal Portfolio
More informationINVESTMENT POLICY April 2013
Policy approved at 22 April 2013 meeting of the Board of Governors (Minute 133:4:13) INVESTMENT POLICY April 2013 Contents SECTION 1. OVERVIEW SECTION 2. INVESTMENT PHILOSOPHY- MAXIMISING RETURN SECTION
More informationSECURITIES AND FUTURES ACT (CAP. 289)
Monetary Authority of Singapore SECURITIES AND FUTURES ACT (CAP. 289) NOTICE ON RISK BASED CAPITAL ADEQUACY REQUIREMENTS FOR HOLDERS OF CAPITAL MARKETS SERVICES LICENCES Monetary Authority of Singapore
More informationCP 107 Securities lending and substantial shareholding disclosure
19 August 2009 Ms Roslyn Nippita Lawyer Investment Banks Australian Securities and Investments Commission GPO Box 9827 Sydney NSW 2001 Dear Ms Nippita CP 107 Securities lending and substantial shareholding
More informationEquity Finance Explained
Department name Equity Finance Equity Finance Explained Version details Contents SECURITIES LENDING EXPLAINED 3 Development of Securities lending 3 What is Securities lending? A definition 3 Increase in
More informationInvestments in Associates and Joint Ventures
IFAC Board Exposure Draft 50 October 2013 Comments due: February 28, 2014 Proposed International Public Sector Accounting Standard Investments in Associates and Joint Ventures This Exposure Draft 50, Investments
More informationFunds in the Cayman Islands Investment Fund Regulation
Funds in the Cayman Islands Investment Fund Regulation The law is simple and straightforward. Not all investment funds are regulated under the law. Not required to be registered are close ended funds (i.e.
More informationDuring the Fall of 2008, the financial industry as a whole experienced a challenging environment for funding and liquidity as a result of the global economic crisis. Goldman Sachs has, for many years,
More informationCOMMISSION DELEGATED REGULATION (EU) /... of 10.6.2016
EUROPEAN COMMISSION Brussels, 10.6.2016 C(2016) 3446 final COMMISSION DELEGATED REGULATION (EU) /... of 10.6.2016 supplementing Regulation (EU) No 648/2012 of the European Parliament and of the Council
More informationCapital Adequacy: Asset Risk Charge
Prudential Standard LPS 114 Capital Adequacy: Asset Risk Charge Objective and key requirements of this Prudential Standard This Prudential Standard requires a life company to maintain adequate capital
More informationM&G HIGH INCOME INVESTMENT TRUST P.L.C
This document is issued by M&G Securities Limited as the alternative investment fund manager (AIFM) of M&G High Income Investment Trust PLC (the "Company") solely in order to make certain information available
More informationDECEMBER 8, 2010 FINANCIAL MARKETS UPDATE. SEC Proposes Rules Exempting Certain Private Fund Advisers from Investment Adviser Registration.
December 8, 2010 FINANCIAL MARKETS UPDATE SEC Proposes Rules Exempting Certain Private Fund Advisers from Investment Adviser Registration The Securities and Exchange Commission (the SEC ) has published
More informationAIFMD investor information document Temple Bar Investment Trust PLC
AIFMD investor information document Temple Bar Investment Trust PLC Temple Bar Investment Trust PLC (the Company ) was incorporated in 1926 with the registered number 214601. The Company carries on business
More informationCOMMISSION DELEGATED REGULATION (EU) /... of 18.3.2016
EUROPEAN COMMISSION Brussels, 18.3.2016 C(2016) 1372 final COMMISSION DELEGATED REGULATION (EU) /... of 18.3.2016 on classes of arrangements to be protected in a partial property transfer under Article
More informationINTERACTIVE BROKERS LLC (SEC I.D. No. 8-47257)
INTERACTIVE BROKERS LLC (SEC I.D. No. 8-47257) STATEMENT OF FINANCIAL CONDITION AS OF DECEMBER 31, 2003 AND INDEPENDENT AUDITORS REPORT AND SUPPLEMENTAL REPORT ON INTERNAL CONTROL ******* Filed pursuant
More informationThe Auditor s Consideration of an Entity s Ability to Continue as a Going Concern *
An Entity s Ability to Continue as a Going Concern 2047 AU Section 341 The Auditor s Consideration of an Entity s Ability to Continue as a Going Concern * Source: SAS No. 59. See section 9341 for interpretations
More information2 This Standard shall be applied by all entities that are investors with joint control of, or significant influence over, an investee.
International Accounting Standard 28 Investments in Associates and Joint Ventures Objective 1 The objective of this Standard is to prescribe the accounting for investments in associates and to set out
More informationHKAS 27 Consolidated and Separate Financial Statements 1
HKAS 27 Consolidated and Separate Financial Statements 1 Nelson Lam 1. Scope of HKAS 27 Hong Kong Accounting Standard (HKAS) 27 Consolidated and Separate Financial Statements shall be applied in the preparation
More informationHow To Understand The Tax Laws In Ireland
Ireland Ireland as a Location for US Life Settlement Transactions 3870785.7 Page 1 Introduction Life settlements have become increasingly popular as an alternative asset class. Ireland is an internationally
More informationConceptual Framework for Financial Reporting
Conceptual Framework for Financial Reporting Chapter 1: The Objective of Financial Reporting INTRODUCTION OB1. The first chapter of the conceptual framework establishes the objective of general purpose
More informationBy email to: ISAPeertoPeerConsultation@hmtreasury.gsi.gov.uk. ISA qualifying investments: Consultation on including peer-to-peer loans
ISA Peer to Peer Consultation Pensions and Savings Team HM Treasury 1 Horse Guards Road London SW1A 2HQ By email to: ISAPeertoPeerConsultation@hmtreasury.gsi.gov.uk 12 December 2014 Dear Sirs, ISA qualifying
More informationPOLICY STATEMENT TO REGULATION 55-103 RESPECTING INSIDER REPORTING FOR CERTAIN DERIVATIVE TRANSACTIONS (EQUITY MONETIZATION)
POLICY STATEMENT TO REGULATION 55-103 RESPECTING INSIDER REPORTING FOR CERTAIN DERIVATIVE TRANSACTIONS (EQUITY MONETIZATION) The members of the Canadian Securities Administrators (the CSA) that have adopted
More informationLAZARD GLOBAL ACTIVE FUNDS PUBLIC LIMITED COMPANY LAZARD PAN EUROPEAN EQUITY FUND. SIMPLIFIED PROSPECTUS DATE 27 August 2009
LAZARD GLOBAL ACTIVE FUNDS PUBLIC LIMITED COMPANY LAZARD PAN EUROPEAN EQUITY FUND SIMPLIFIED PROSPECTUS DATE 27 August 2009 This Simplified Prospectus contains key information in relation to the Lazard
More informationCUSTOMER FUNDS PROTECTION AT SOCIETE GENERALE NEWEDGE UK LIMITED
NEWEDGE CUSTOMER FUNDS PROTECTION AT SOCIETE GENERALE NEWEDGE UK LIMITED November 2015 OVERVIEW The foundation for protecting customer property when customer s trade is threefold: Segregation Capital Requirements
More informationFinancial Services (Collective Investment Schemes) FINANCIAL SERVICES (EXPERIENCED INVESTOR FUNDS) REGULATIONS 2012
Financial Services (Collective Investment Schemes) 2005-48 Legislation made under s. 52. FINANCIAL SERVICES (EXPERIENCED INVESTOR FUNDS) (LN. ) Commencement 12.4.2012 Amending enactments Relevant current
More informationTHE JESUIT UNIVERSITY OF NEW YORK GRADUATE SCHOOL OF BUSINESS ADMINISTRATION
FORDHAM UNIVERSITY THE JESUIT UNIVERSITY OF NEW YORK GRADUATE SCHOOL OF BUSINESS ADMINISTRATION 7 April 2014 Via e-mail to fsb@bis.org Secretariat of the Financial Stability Board c/o Bank for International
More informationNew FSA rules on disclosure of interests in UK companies
New FSA rules on disclosure of interests in UK companies The FSA s new rules on Disclosure of Contracts for Difference, which come into force on 1 June 2009, will considerably extend the scope of the disclosure
More informationIPSAS 7 INVESTMENTS IN ASSOCIATES
IPSAS 7 INVESTMENTS IN ASSOCIATES Acknowledgment This International Public Sector Accounting Standard (IPSAS) is drawn primarily from International Accounting Standard (IAS) 28 (Revised 2003), Investments
More informationBriefing. A Guide to Investment Funds in the British Virgin Islands. Client briefing. February 2007. Anti-Money Laundering. Choice of Jurisdiction
February 2007 Briefing A Guide to Investment Funds in the British Virgin Islands BVI/IF/13776284 The success of the final product is dependant on making many decisions. Whether they are; determining the
More informationCLIENT RELATIONSHIP DISCLOSURE STATEMENT
A. INTRODUCTION CLIENT RELATIONSHIP DISCLOSURE STATEMENT Securities legislation in Canada requires Deans Knight Capital Management Ltd. ( Deans Knight or the firm ) to provide you with certain information
More information