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TABLE OF CONTENTS INTRODUCTION WHAT CONSTITUTES A CLIENT RELATIONSHIP? TYPES OF CLIENT CLASSIFICATIONS CASES OF REQUIRING CLIENT CONSENT REGARDING THEIR CLASSIFICATION WHAT IS NIPS ONLY BUSINESS?: HOW DOES THAT AFFECT CLIENT CLASSIFICATION RECATEGORISING CLIENTS CLIENT PROFILES CONSEQUENCES OF CLIENT CLASSIFICATION NOTIFICATION TO THE CLIENT WBCL CLIENT OR WEL CLIENT RECORD-KEEPING CLIENT CLASSIFICATON SPECIMEN LETTER 2 .
INTRODUCTION The Markets in Financial Instruments Directive (MiFID)) is Europe-wide legislation that came into effect in November 2007. i. any reference to “Westpac London”. This document outlines how Westpac’s policy and procedures ensure that the firm is compliant with the FSA’s rules on client classification.g.e. skill and expertise and therefore understands the need to treat clients in accord with their differing levels of knowledge.where Westpac provides a facility to the other party such as the facilitation of transactions or providing an opportunity to trade (iii) Whether the relationship involves fiduciary. agency or similar obligations Investment Service Vs Investment Activity 3 .where Westpac undertakes a transaction that it enters into / brings about with another party . Criteria indicating that Westpac has a client relationship with another party include: (i) the nature of the obligations that each party has agreed to undertake (ii) whether the relationship involves some act or work to be done for the other party e. “the firm” or “London branch” encompasses references to both Westpac Banking Corporation. skill and expertise. an ancillary service [DEFINE AND REFER TO]. . persons or entities to whom a financial promotion is or is likely to be communicated is a client of Westpac. in conjunction with an assessment of their level of skill. The firm classifies all its clients dependent on the products and activities that they undertake with or through us in relation to financial instruments. REASONS FOR CLIENT CLASSIFICATION Westpac recognises that investors have different levels of knowledge. Westpac does this in accordance with its regulatory obligations under the FSA’s rules. The definition of a client also includes a potential client in relation to financial promotion rules. WHAT IS A CLIENT The FSA defines a client as an entity to whom a firm provides. In writing this policies and procedures document the following pieces of regulation have been taken into account: • FSA Conduct of Business Sourcebook • Principles of Business • Regulated Activities Order • Markets in Financial Instruments Directive 2007 In writing this policies and procedures document the following pieces of guidance have been taken into account: • FSA Client Classification paper 2006 This Client Classification policy applies to all clients of Westpac Banking Corporation London and Westpac Europe Limited. intends to provide or has provided a financial service in the course of carrying on a “Regulated Activity” or in the case of MiFID or equivalent third country business. where Westpac communicates the financial promotion or approves the Financial Promotion. knowledge and expertise (i. unless specifically stated otherwise. In order to comply with this legislation the Financial Services Authority (FSA) amended their client classification criteria relating to business that falls into the scope of MiFID legislation. client type). For the purpose of this document. The different classifications are important as they determine our obligations to our clients.customisation of a particular product / transaction to meet the needs of that other party .e. London branch and Westpac Europe Limited unless specifically stated otherwise.
as opposed to non-clients. then Westpac London is accepting a deposit Client classification procedures are to be followed If YES. An example of the above case is when Westpac conducts the activity of dealing on own account with a counterpart where the client relationship is based on pure investment activity and the trading is occurring between dealers. where Westpac is dealing on own account with a counterparty and is also providing an advisory service to the counterpart to the transaction in relation to that transaction or other transactions. Here. as an ECP client of the firm. the nature of the relationship is deemed to be inter-counterparty rather than “firm” and “client”. Client of London branch? If YES. In the FSA’s view where the trading relationship is as such. the opposing party to the transaction need not be considered a client of the firm. on their respective accounts. then Westpac London is carrying out that business Client classification procedures are to be followed 4 . clients that are not provided the full complement of protections that MiFID requires (i.The FSA have taken a view that where a firm is only conducting an investment activity with a counterparty in the absence of an investment service. all “investment activities-only” relationships between counterparties can fall within the ECP regime). for example. a contract is signed by the Westpac London on behalf of another Westpac Group entity or the transaction is booked to an account in the ledger of the London office then this would strongly indicate that the business is being carried out by the Westpac London. the counterpart to the transaction will be considered a Client of the firm (as an investment service is being provided in relation to an investment activity). regardless of whether the contract is written or oral or made directly or indirectly with the London branch? Is the business carried out by an individual who is based in the London office? (an indication of this would be where the individual is registered with the FSA) NB if the business passes through the procedures of the London office. Regulated Activity Description Regulated activity but not DIB (Designated Investment Business): Deposit-taking See figures 1 and 2 for further details MiFID (business that is also Designated Investment Business) See figures 1 and 2 for further details Test Status as client of London Branch Will the deposit be booked to an account in the London Branch Ledger. the table below summarises the point at which a party becomes a client of the firm. In contrast to this.e.e. the counterpart to the activity does not need to be classified as a client of the firm. Westpac’s policy is to classify any client that it conducts mutual “investment activities-only” business with. In the former case. (in the non-client relationship example) the FSA have taken the view that counterparties to investment activities can either be seen as non-clients or alternatively can be classified as Eligible Counterparties (ECPs) i. Further to the above.
knowledgeable and sophisticated and able to assess their own risk and are afforded fewer regulatory protections • Eligible counterparties are entities that take on limited business with the firm and are afforded the fewest of client protections Meanings of client classification are detailed below. retail clients are clients who have limited knowledge and experience of the financial markets and therefore these types of clients will demand the highest levels of protection.knowledge of the relevant financial market and instruments and furthermore has sufficient experience of these . 5 .Unregulated Investment Business (i. business that is not regulated by the FSA) See figures 1 and 2 for further details Is the business carried out by an individual who is based in the London office? NB if the business passes through the procedures of the London office. at the time of writing this document does not deal with Retail Clients. Retail Clients and Professional Clients with a separate and distinct third category.the risk appetite and objectives that match the investment under consideration Westpac London.the financial means to sustain any losses that the individual may incur as a result of direct investment (the firm would need to do a detailed assessment of the client’s assets and liabilities) . there are two main categories of client. Retail Clients The firm does not deal with Retail Clients and as such these clients are only discussed briefly here. These clients are typically individuals profiling the average consumer or small non-investment corporate entities. for example. If YES. applicable when Westpac undertakes a limited range of business with a counterparty. termed Eligible Counterparties.e. then Westpac London is carrying out that business Client classification procedures are to be followed TYPES OF CLIENT CLASSIFICATIONS Under MiFID. a contract is signed by the Westpac London on behalf of another Westpac Group entity or the transaction is booked to an account in the ledger of the London office then this would strongly indicate that the business is being carried out by the Westpac London. Generally speaking. Firms that deal with retail clients would generally need to satisfy themselves that the client has: . Client Types: • Retail Clients (RC) • Professional Clients (PC) • Eligible Counterparties (ECP) (limited business clients) Different levels of regulatory protection are attached to each client category and hence to clients within each category Level of Protection: • Retail clients are afforded the most regulatory protection • Professional clients are considered to be more experienced.
(ii) a net turnover of EUR 25.000 (b) net turnover of EUR 40. a public body that manages public debt. (f) a local or public authority. (b) an undertaking that meets (or any of whose holding companies or subsidiaries meets) two of the following tests: (i) a balance sheet total of EUR 12. an international or supranational institution (such as the World Bank. the IMF.000000 (3) In relation to business that is not MiFID (See figure 1 for details) or equivalent third country business a large undertaking meeting two of the following conditions: (a) a body corporate (including a limited liability partnership) which has (or any of whose holding companies or subsidiaries has) (or has had at any time during the previous two years) called up share capital or net assets of at least £5 million (or its equivalent in any other currency at the relevant time).Per Se Professional Client Criteria Professional clients are considered to be clients that are more experienced. personal pension scheme or stakeholder pension scheme) which has (or has had at any time during the previous two years) assets of at least £10 million (or its equivalent in any other currency at the relevant time) calculated by aggregating the value of the cash and designated investments forming part of the trust’s assets. the ECP.000. SSAS.000. a central bank. (4) a national or regional government. The following list includes all authorised entities carrying out the characteristic activities of the entities mentioned. Each of the following is a professional client.000. (iii) an average number of employees during the year of 250. but before deducting its liabilities (e) a trustee of an occupational pension scheme or SSAS. the EIB) or another similar international organisation.000. unless and to the extent that they are eligible counterparties: (1) an entity required to be authorised or regulated to operate in the financial markets.000. and (ii) assets under management of at least £10 million (or its equivalent in any other currency at the relevant time). or a trustee or operator of a personal pension scheme or stakeholder pension scheme where the scheme has (or has had at any time during the previous two years): (i) at least 50 members. 6 .500. whether authorised by an EEA state or a third country and whether or not authorised by reference to a directive: (a) a credit institution (b) an investment firm (c) any other authorised or regulated financial institution (d) an insurance company (e) a collective investment scheme or the management company of such a scheme (f) a pension fund or the management company of a pension fund (g) a commodity or a commodity derivatives dealer (h) a local (i) any other institutional investor (2) In relation to MiFID or equivalent third country business (See figure 1 for details) a large undertaking meeting two of the following size requirements on a company basis: (a) a balance sheet total of EUR 20. knowledgeable and sophisticated and able to assess their own risk and are therefore afforded fewer regulatory protections in comparison to retail clients.000 (c) own funds of EUR 2. (c) a partnership or unincorporated association which has (or has had at any time during the previous two years) net assets of at least £5 million (or its equivalent in any currency at the relevant time) and calculated in the case of a limited partnership without deducting loans owing to any of the partners (d) a trustee of a trust (other than an occupational pension scheme.
above. a central bank 10. 2. which is that the client has to be classifiable as one of the following type of entities: 1. In order to be classified as an eligible counterparty the client will also need to meet the second requirement ((ii) above). another financial institution authorised or regulated under EU legislation or the national law or an EEA state 7. there is a lesser need for client protection. This classification recognises that clients of type as listed in (1) to (5). including a public body that deals with public debt 9. Retail clients are defined as clients that do not meet the above criteria. This is discussed in further detail below To meet the first requirement ((i) above). above. In order to be classified as an Eligible Counterparty the client has to: (i) be conducting limited business with us known as “eligible counterparty business” (defined below) and (ii) be an entity capable of being treated as an eligible counterparty. In relation to other services (falling outside (a) to (c)). If the client falls into one of the types listed above in (1) to (10) and its dealings with Westpac are limited to the activities listed in (a) to (c). a supranational organisation Financial Institutions ((6) above) includes regulated institutions in the securities. an investment firm a credit institution an insurance company a collective investment scheme authorised under the UCITS Directive or its management company 5. This includes entities dedicated to the securitisation of assets or other financing transactions. an undertaking exempted from the application of MiFID under Article 2(1)(k) (certain own account dealers in commodities or commodity derivatives) or Article 2(1) (l) (locals) of that directive 8. 3. 4. Eligible Counterparty business is defined as follows: a) dealing on own account. a national government or its corresponding office. Per Se Eligible Counterparties Criteria This client classification is only applicable for clients conducting a limited range of business with Westpac. banking and insurance sectors. a pension fund or its management company 6. or b) any ancillary service directly related to a service or activity referred to in (a). This categorisation recognises that for the type of activities listed above with the types of entities listed above. then that client can be classified as an Eligible counterparty. require a lower degree of protection in comparison to Retail clients. the same client would be treated as a professional client. and c) arranging in relation to the business which is not MiFID or equivalent third country business. the client’s activities with Westpac have to be limited to “eligible counterparty business”. execution of orders on behalf of clients or reception and transmission of orders. Scope of Application of these Classifications 7 .(5) another institutional investor whose main activity is to invest in financial instruments (in relation to the firm’s MiFID or equivalent third country business) or designated investments (in relation to the firm’s other business).
Professional and Eligible Counterparty arise as a result of the MiFID directive and so principally apply to clients undertaking MiFID business. The consequence of this is that where non-MiFID business is being undertaken.5.g. For further information. However. namely the MiFID client classification system and it will extend this system to clients that are conducting non-MiFID business (e. if this has been the case. This means that. 8 . ECP) clients may need to meet different criteria in order to be classified as such and will have different obligations owed to them depending on whether the type of business undertaken with us is MiFID or non-MiFID. Treatment of clients within the same Classification will be non-uniform The FSA’s client classification categories. less-protective classification.6. and stated its understanding of the protections lost. However. namely. Elective Professional Clients A client who would normally be classified as a retail client can be opted-up to Professional client status under these opt-up tests. whilst under the same classification (e. ECP). under these MiFID client categories (RC. once this has been confirmed. deposittaking business). regardless of the business undertaken with them. the client additionally has had to have requested and expressly agreed to treatment under the new less-protective classification. the firm has taken the view that it will classify all clients.These client categorisations are MiFID client categorisations and so technically speaking only apply to business that falls within the scope of MiFID regulation.4 and COBS 3. PC.g. MOVING BETWEEN CLIENT CLASSIFICATIONS The MiFID provisions allow clients to move between the prescribed classifications provided that they meet additional tests. it also conducts FSA regulated business other than MiFID business such as deposit-taking and non-FSA regulated business such as Spot FX and FX and Commodity forwards for delivery of within seven days. it will only maintain one client classification system.3. Westpac does not deal with elective Professional Clients or elective Eligible Counterparties and as such the tests are not discussed in detail here. other forms of client classification criteria would apply in these cases. However. the eligible counterparty is termed an “Elective Eligible Counterparty” as opposed to per se Eligible Counterparty which is an ECP that automatically qualifies as an ECP. [SEE DIAGRAM] The result of this is that FSA’s MiFID client classifications do not technically apply in situations where we are dealing in non-MiFID business. CONSEQUENCES OF CLIENT CLASSIFICATION In this section we will briefly touch on the consequences of client classification for each client category. e. the client can be opted-up into a higher classification. the firm’s activities are not limited to MiFID business. please see COBS 3.g. Elective Eligible Counterparties A client who would normally be classified as a Professional Client can be opted-up to Eligible Counterparty status under these opt-up tests. if this has been the case then the professional client is termed an “Elective Professional Client” as opposed to per se Professional client which is a PC that automatically qualifies as a PC. the firm has taken the view that rather than run more than one client classification system. Meeting these tests allow clients who would normally be classified in a lower category to opt-up into a higher.: Retail Clients Professional Clients (Opt-up to) (Opt-up to) Professional Clients Eligible Counterparties Where a client meets a specific criteria test. Retail.
although. open an account with us with a view to conduct nonMiFID business (e. Client Classifications are important as they reflect the level of protection that is to be afforded to the underlying client and therefore the treatment of that client. the firm will categorise the client under a single MiFID categorisation. based on the business undertaken this section will highlight these differences in treatment. It is however. the firm’s responsibility to ascertain that 3) any investment recommendations made are in line with the professional client’s investment objectives. Eligible Counterparties There are no suitability protections afforded to Eligible Counterparties (ECPs) Best Execution 9 . the classification name for the client will be the same. the firm will classify the client under a MiFID client categorisation (i. A recommendation is not a personal recommendation if it is issued exclusively through distribution channels or to the public.e. the classification criteria to be net will be slightly different in relation to its non-MiFID business. we will discuss the protections in a little more detail: Suitability Suitability applies where the firm makes a personal recommendation to a client in relation to a designated investment. deposit-taking). A personal recommendation is defined as advice on investments that is presented as being suitable for the entity to whom it is made or a recommendation that is based on a consideration of the circumstances of that entity.g. In relation to a Professional client. Examples of the MiFID Client Classification System being Extended to Non-MiFID Business In cases where the firm deals with clients that conduct a mixture of non-MiFID business and MiFID business. This section discusses how client classifications affect the treatment of clients and where there are asymmetries in the treatment of clients. Professional Clients When making a personal recommendation to a professional client the firm must ensure that the recommendation is suitable for the client. PC or ECP) given that there is a good chance that the client may go on to deal in MiFID products and services with us. it can be assumed that: 1) the professional client has the necessary knowledge and experience of the investment services 2) the professional client’s financial situation is such that it can bear the financial risk of loss of any capital as a result of investments. In cases where the firm deals with a clients who. Professional Clients Under the MiFID Professional client classification regime the client is afforded the following protections: • Suitability • Best Execution • Disclosure • Conflicts of Interest • Classification acceptance requirement Eligible Counterparties Under the MiFID Eligible Counterparty regime the client is afforded the following protections: • Conflicts of Interest In the rest of this section.
its employees. that arise in the course of providing any investment and / or ancillary services. its employees. Client Order handling rules Professional Clients The firm is required to execute orders on behalf of clients in a manner which is prompt. or between one client and another. Owners of the client within CIB should periodically assess the client’s information in order to ascertain that the client classification is still relevant to its nature and activities. CLIENT PROFILES Asset Managers 10 . Eligible Counterparties The firm is required to execute orders on behalf of clients in a manner which is prompt. It is important that when client accounts are passed around to different business units within the firm. Eligible Counterparties There are no Best Execution obligations for Eligible Counterparties. fair and ensures expeditious execution of client orders relative to other client order or the trading interests of the firm. that the relevant individuals within that business unit make itself aware of the client’s objectives and ensure that it tailors any personal recommendations to those objectives. the member of CIB should alert a member of compliance who will organise for the necessary changes to be made to systems and organise the issue of a new set of Terms of business. the firm ensures that it collects sufficient information in relation to the client’s investment objectives and goals and how it wants its goals to be met. Where Conflicts of interest cannot be sufficiently managed with reasonable confidence the firm should disclose the nature and the source of the conflict. or between one client and another. size. Where Conflicts of interest cannot be sufficiently managed with reasonable confidence the firm should disclose the nature and the source of the conflict. speed. tied agents or any other person linked to it by control and its clients and. that arise in the course of providing any investment and / or ancillary services. If CIB come across information which highlight a need for change in the client’s classification. fair and ensures expeditious execution of client orders relative to other client order or the trading interests of the firm.Professional Clients When executing orders. tied agents or any other person linked to it by control and its clients and. likelihood of execution and settlement. This enables Westpac to able cater its advice / personal recommendations to the client’s objectives. the firm must take all reasonable steps to obtain the best possible result for its professional clients taking into account: price. Conflicts of Interest Professional Clients The firm is required to take all reasonable steps to identify conflicts of interest between itself. Classification acceptance requirement Disclosure ASSESSING SUITABILITY In cases where the firm provides investment advice to Professional Clients. Eligible Counterparties The firm is required to take all reasonable steps to identify conflicts of interest between itself. costs. nature or any other consideration relevant to the execution of that order.
Insurance Companies Broking Firms Clients that fall under this category will in the majority of cases fall into the category of being an Eligible Counterparty. and (ii) when Westpac are providing them with services / activities that fall out of the scope of being ECP business e. non-investment companies. they have a right to request treatment as a Professional Client: (i) in order to receive protections such as best execution and suitability which they may owe to their underlying clients who may be professional clients or retail clients. (For further details see…) WBC CLIENT OR WEL CLIENT Westpac Europe Limited (WEL) is a wholly owned subsidiary of Westpac Banking Corporation (WBC). These types of client will always fall into the category of being Professional Clients provided they meet the professional client threshold conditions in terms of size and wealth i. i.e. non-regulated. when they are dealing on behalf of underlying clients requiring the protections that are provided by the Professional client classification. WEL has been created because WBC London branch has minimum passporting rights under the MiFID Directive (as it is not an EEA) and as such it is limited in the business it can conduct with 11 . whenever the firm knows that an asset management client is acting as agent or on behalf underlying funds and clients. and whenever a firm is carrying on Eligible Counterparty business it can only be classified as an eligible counterparty.. Each of the activities fall into the category of being Eligible Counterparty Business. Corporate Clients By corporate clients we mean large undertakings which are not investment firms. they need to be big enough to fall into the realms of being a PC (if they are too small they would be classified as retail clients and we do not deal with retail client). they have a right to request to be classified as a professional client and we are obliged to provide them with professional client status. Whenever the firm is aware of a pension fund client who is dealing on behalf of underlying clients who require protections bestowed by the PC classification. The reasons being that they will either be “dealing on own account” or they will be acting as broker whereby they will be carrying on the activity of “reception and Transmission of orders”. Banks Banks will nearly always be classified as Eligible Counterparties as they will nearly always be acting on own account.e. Private banking Private banking institutions will in the majority of cases request classification as a Professional Client as in most cases they will be arranging business with funds of their underlying clients who may fall into the category of requiring higher levels of protections afforded by classification as a Professional client.g. provision of advice Further to this. Westpac will automatically grant them with Professional Client status Pension Funds Although clients that are pension funds will fall under the category of eligible counterparty whenever they deal for their own account. the firm will automatically classify these clients as PC. dealing on their own account.Although asset management firms would generally be classified as eligible counterparties where they are conducting eligible counterparty business e.g.
000. All other EEA jurisdictions have varying restrictions on activities that can be undertaken with domestic clients / potential clients and as such you are advised to refer to the document issued to you by the Legal Department which goes into further detail for these jurisdictions.000 together with the voidability of contracts. THE PROCEDURE 1. we do not require a passport to solicit business and as such when dealing with clients of these jurisdiction they can be classified as clients of WBC. the firm has to ensure that its client is conducting business with WEL and not WBC. As part of the KYC process CIB will collect information that will enable them to classify the potential client in accordance with the classification criteria set out in section [XXXXX] 4. Activities include soliciting EEA clients to engage in business with Westpac. A sales desk identifies a potential client that it would like to conduct business with 2. A passport enables the firm to conduct MiFID services and activities with potential clients in the EEA. If you are still in doubt please seek advice from a member of the legal team or from a member of compliance. In order to overcome these limitations and increase the scope of business conducted within the EEA we have incorporated a UK entity with passporting rights. CIB will conduct KYC on the client. EEA jurisdictions that have varying restrictions on the activities that can be undertaken are: Greece Norway Sweden The Netherlands It is important to ensure that the client is classified as the client of the correct Westpac entity given that getting it wrong can result in fines of up to EUR4. The client details are passed onto the relevant team within CIB 3. The following regions. however: Austria Finland France Italy Portugal Spain require the firm to have a passport in order to solicit conduct of business with them. Some EEA countries do not have restrictions on soliciting domestic investors to conduct business with us. Where the firm is dealing with clients of these jurisdictions. these are: Liechtenstein Luxembourg Switzerland UK Poland Ireland (except deposit-taking) Belgium Germany Denmark (except deposit-taking) In the above regions.potential clients based in the EEA. This classification is recorded within DCPK (which is the client database for Westpac London) 12 .
Before the client can go live. as part of its review of the client’s DCPK form. especially so. the compliance department will. 6. double-check the client classification assigned to the client by CIB as part of its checks compliance will double check the WBC / WEL status of the client with reference to its domicile. 13 .5. Compliance sign-off on the client will instigate the client being issued with a client classification letter with the associated Terms of Business RECORD KEEPING The firm must make a record of the following in relation to each of its clients: • The categorisation established for each client under this policy • Sufficient information to support the establishment of the client classification • Evidence of despatch and notification of client classification and associated terms of business to the client. when the classification and / or the terms of business differ from the standard form The firm will retain records in relation to the above for a period of FIVE years after the firm ceases to carry on business with or for that client.
Can local authorities / municipalities be treated as public debt bodies for the purpose of COBS 3.2 R (4) 3. Whether tests of knowledge and experience can be used more widely for very complex products e.g. Provision of more detail on the broader client categories such as COBS 3. ABS.2 R (c) and (i) Leading to further distinction as to which entities can be treated as a per se professional clients and which entities can be dropped down to elective professional clients and / or Retail clients 2.5. Training for all relevant staff will also be arranged January 2011 14 . Narrowing of the Eligible Counterparty classification The above points are currently under consultation and as and when developments come into fruition this policies and procedures document will be updated.PIPELINE POINTS TO BE NOTED CESR are looking make some amendments to the client classification criteria to the following affect: 1.5. non-standard OTC derivatives 4.
service or obligation where these are connected to the provision of the provision of investment services or ancillary services Arranging Arranging (bringing about) deals in investments. other than a right to receive a service. above. 6. making arrangements with a view to transactions in investments or agreeing to carry on either of those regulated activities Personal Recommendation MiFID or equivalent third country business. environmental or other physical variable (xi) any other asset or right of a fungible nature.Annex 1 – Definitions Definitions in relation to Eligible Counterparty Business Dealing on own account Trading against propriety capital resulting in the conclusion of transactions in one or more financial instruments Execution of orders on behalf of clients Acting to conclude to buy or sell one or more financial instruments on behalf of clients Reception and Transmission of Orders Ancillary Service Any of the services listed here: (a) Safekeeping and administration of financial instruments for the account of clients. industrial strategy and related matters and advice and services relating to mergers and the purchase of undertakings (d) Foreign exchange services where these are connected to the provision of investment services (e) investment research and financial analysis within (a) to (f). including custodianship and related services such as cash/collateral management (b) Granting credits or loans to an investor to allow him to carry out a transaction in one or more financial instruments. credit. distribution or consumption of energy derived from renewable resources (x) a geological. that is capable of being transferred (xii) an index or measure related to the price or value of. where the firm granting the credit or the loan is involved in the transaction (c) Advice to undertakings on capital structure. right. pipeline or other means (ix) an allowance. where cable. or volume of transactions in any assets. an ancillary service financial promotion 15 . that is: (i) commodities (ii) climatic variables (iii) freight rates (iv) emission allowances (v) inflation rates or other official economic statistics (vi) telecommunications bandwidth (vii) commodity storage capacity (viii) transmission or transportation capacity relating to commodities. related to the underlying of the derivatives included under section C – 5. 7 and 10. right or similar asset which is directly linked to the supply. permit.
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