Scanning No.1

CACEIS European Regulatory Watch Newsletter

LUXEMBOURG Bearer Shares - Bill 6625 Admission of the concept of floating financial year CSSF 2013 annual report – Asset management key messages SWITZERLAND Banker’s Vow: Compliance Requirements in financial sector in the Netherlands TAX IRS FAQ update IRS publishes Notice 2014-33 European FATCA - like tax regime (CRS) and Savings Directive TAX - BELGIUM TAX - ITALY 1 2014 JUNE No.1

EUROPE ELTIFs Council compromise proposal EMIR - List of central counterparties (CCPs) ESMA informs EU Commission of its intention to ease the frontloading requirement under EMIR ISDA and FIA Europe published European Cleared Derivatives Execution Agreement Additional piece in the implementation of EMIR Fund Processing Standardisation Council adopts MiFID II/MIFIR Commission request for advice to ESMA on delegated acts for MiFID II and MiFIR IOSCO issues response to consultation on shadow banking BELGIUM Changes of Belgian law relating to UCITS New fees and contribution to cover the operating costs of the FSMA

W hat’s next

B ackground

? W hat’s in there

...

?

EUROPE ELTIFs Council compromise proposal Background

« ELTIFs should be able to borrow cash amounting for up to 30% of their assets.

648/2012 (EMIR) and which expressly agreed to have their name mentioned publicly. This list is not exhaustive. What’s next? The list will be subject to further updates accord- ing to ESMA. ESMA’S LIST IS AVAILABLE HERE. ESMA informs EU Commission of its intention to ease the frontloading requirement under EMIR Background ESMA’s letter to the Commission concerns the frontloading requirement. The frontloading re- quirement is the obligation to clear OTC derivative contracts which will be subject to the clearing ob- ligation entered into after a central counterparty (CCP) which is able to clear those OTC derivative contracts has been authorized under EMIR and be- fore the date of the clearing obligation. What’s in there? On 8 May 2014, ESMA informed the Commission of its intention to ease the frontloading require- ment under EMIR. According to an analysis by ESMA the requirement may introduce significant uncertainties in the market with the consequences mainly borne by derivative end-users. The front- loading window can be divided into two periods: Period A: between the notification of the classes of OTC derivative contracts to ESMA and the entry into force of the Regulatory Technical Standards (RTS) on the clearing obligation. Period B: between the entry into force of the RTS

Portfolio composition and diversification: « As a rule, ELTIFs may not invest more than 10% of their assets in transferable securities issued by a single body; the threshold would be raised to 25% for bonds issued by a credit institution subject by law to special public supervision de- signed to protect bond-holders. « The depositaries of ELTIFs marketed to retail investors would not be able to discharge them- selves of liability in case of a loss of financial instruments held by a sub-depositary. What’s next? The regulation needs to be adopted by the Parlia- ment and the Council. The regulation would enter into force 6 months after its adoption. The Council Presidency proposal dated 8 May 2014 is AVAILABLE HERE. EMIR - List of central counterparties (CCPs) Background Article 25 of Regulation 648/2012 on European Market Infrastructure Regulation (EMIR) provides for the recognition of third country CCPs by ESMA, and the necessary requirements to allow those CCPs to provide clearing services to clearing mem- bers and trading venues established in the EU. What’s in there? On 29 April 2014, ESMA issued a list of CCPs established in non-EEA countries which have ap- plied for recognition under Article 25 of regulation Specific provisions concerning the depositary of an ELTIF marketed to retail investors:

European Long Term Investment Funds (ELTIFs) are EU-AIFs managed by EU authorised AIFMs that do not offer regular redemption before the end of the vehicle’s life and invest in long-term assets. ELTIFs benefit from an EU passport and might be marketed to retail investors across the EU. On 26 June 2013, the Commission issued a Pro- posal for a regulation of the European Parliament and of the Council on European long-term invest- ment funds ( “the Regulation” - AVAILABLE HERE ). The Regulation shall ensure that uniform require- ments apply to the investment and operating con- ditions of ELTIFs. On 17 April 2014, the European Parliament in ple- nary adopted amendments to the Commission’s proposal (available here – a note from the General Secretariat of the Council to the Permanent Repre- sentatives Committee on the outcome of the Parliament’s first reading is available here). On 24 April 2014, the Presidency of the Council is- sued a first compromise proposal ( available here ) . What’s in there? On 8 May 2014, the Presidency of the Council is- sued a second compromise proposal. The main changes to the regulation are the following: Eligible investment assets: « Units or shares of AIFs would be eligible assets to the extent that such AIFs (i) are not allowed to invest in aggregate more than 10% of their cap- ital in other UCIs, (ii) invest at least 70% of their assets in ELTIFs’ eligible investments (iii) do not undertake any short selling activities or do not take direct or indirect exposure to commodities and (iv) have a depositary;

page 2 - Scanning - June 2014

and the date of application of the clearing obliga- tion for the class of OTC derivative contracts. ESMA proposes to only apply frontloading to con- tracts entered in Period B. What’s next? ESMA will outline further solutions in a public con- sultation before the finalisation of the draft RTS. The Commission will have to provide its views on this issue. THE LETTER IS AVAILABLE HERE. ISDA and FIA Europe published European Cleared Derivatives Execution Agreement Background The International Swaps and Derivatives Associa- tion (ISDA) and the Futures Industry Association of Europe (FIA Europe) foster safe and efficient deriv- atives markets to facilitate effective risk manage- ment for all users of derivative products. What’s in there? On 15 May 2014, ISDA and FIA Europe jointly an- nounced the publication of the ISDA/FIA Europe Cleared Derivatives Execution Agreement for prin- cipal-to-principal client clearing. The ISDA/FIA Europe Cleared Derivatives Execu- tion Agreement is designed to be used as a tem-

plate for market participants when negotiating ex- ecution agreements under English law for swaps that are intended to be cleared by central counter- parties located outside of the US. The agreement was developed with the assistance of a working group of both buy and sell-side insti- tutions in the European cleared over-the-counter (OTC) derivatives markets. What’s next? This ISDA / FIA template can be used in conjunc- tion with the ISDA/FOA Client Clearing Addendum to cover the obligations from the upcoming clear- ing obligation under EMIR when negotiating with other market participants. The clearing obligation will enter into force most Additional piece in the implementation of EMIR Background On 16 August 2012, the Regulation (EU) No 648/2012 of the European Parliament and of the Council of 4 July 2012 on Over-The-Counter Derivatives, Central Counterparties (CCPs) and Trade Repositories (TRs), also known as the EMIR Regulation entered into force. What’s in there? The EU Commission has published on 12 May 2014 one additional piece in the implementation of EMIR. The Commission Implementing Regula- tion (EU) No 484/2014 lays down implementing technical standards with regard to the hypothet- ical capital of a CCP according to Regulation (EU). likely end of 2014 / beginning of 2015. THE AGREEMENT IS AVAILABLE HERE.

Fund Processing Standardisation Background

Since May 2009 EFAMA & SWIFT regularly pub- lish reports on trends in standardisation and au- tomation rates of fund orders received by transfer agents in Luxembourg and Ireland. What’s in there? On 30 April 2014, EFAMA & SWIFT issued the an- nual report on automation and standardisation of cross-border funds orders in 2013. The current report is the full-year 2013 report. It combines the data from Luxembourg and Ireland into one report. The report provides: 1) an aggregated view on both fund processing centers together; 2) a detailed overview per fund processing center; 3) a regional perspective of fund processing STP rates per fund processing center. What’s next? The next report is planned for Q4 of 2014. It will cover the first half of 2014. THE REPORT IS AVAILABLE HERE. In October 2011 the European Commission pub- lished its proposal for the Markets in Financial In- struments Directive (MiFID) II and Regulation (MI- FIR). The European Parliament adopted the MiFID II package in a final vote on 15 April 2014. What’s in there? On 13 May 2014 the Council adopted the MiFID II package. For further information on this legislative package please refer to our earlier news on the adoption of the package by the European Parliament. What’s next? In line with the traditional approach for European legislation, the key next steps for the complete adoption of MiFID II regime are the following: Q2 2014: Publication in the Official Journal of the European Union; Q2 2014: Consultation by ESMA (advice, Regula- tory Technical Standards (RTS) and Implementing Technical Standards (ITS); Council adopts MiFID II/ MIFIR Background

No 648/2012 of the European Parliament and the Council. In particular, it contains standards for:

« Reference dates set for CCPs,

« Transitional provision reporting dates for CCPs,

« Frequency of reporting for CCPs.

These regulatory technical standards also com- plete Regulation (EU) 575/2013 (CRD IV) regarding the calculation of own fund requirements for trade exposures with CCPs. What’s next? The Implementing regulation has entered into force on 2 June 2014. THE IMPLEMENTING REGULATION IS AVAILABLE HERE.

Scanning - June 2014 - page 3

Q1-Q2 2015: Delivery of ESMA advice, RTS and ITS to the European Commission; Q2 2015: Drafting of Delegated acts by the Euro- pean Commission; Q2 2016: Transposition in national laws; Q4 2016: Application of new rules for firms in scope. THE TEXT OF THE REGULATION IS AVAILABLE HERE. Commission request for advice to ESMA on delegated acts for MiFID II and MiFIR Background MiFID II and MiFIR have been adopted by the EU Parliament on 15 April 2014. This Regulation and this Directive are meant to improve the efficiency of financial markets, and improve investor protec- tion while keeping pace with technological devel- opments. What’s in there? On 23 April 2014, the Commission published a request to ESMA for technical advice on possible delegated acts and implementing acts concerning MiFID II and MIFIR. The EU Commission, in order to adopt delegated acts in accordance with MiFID II and MiFIR, is seeking ESMA’s advice on various technical is- sues, namely: « Clarify when an activity is exempted for persons providing an investment service in an incidental manner in the course of a regulated activity; « Specify the notion of derivatives contracts relat- ing to commodities that can be physically settled THE TEXT OF THE DIRECTIVE IS AVAILABLE HERE.

and are traded on an organised Trading Facility (OTF) as financial instruments in respect of whole- sale energy products; « Provide advice on adjustments to the definitions of investment advice, money market instru- ments, systematic internaliser, algorithmic trad- ing, direct electronic access; « Provide advice on organisational requirements, and more specifically on the compliance func- tion and on the handling of complaints; « Provide advice on the effective organisation- al requirements that firms need to establish to maintain full compliance with the telephone recordings and electronic communications re- quirements; « Provide advice on future requirements concern- ing the provision and content of information to clients, including investment advice and the suit- ability test; « Provide advice on the possibility for investment firms providing investment advice on an inde- pendent basis and portfolio management, to receive third-party payments and benefits ("in- ducements"); « Provide technical advice on requirements to be complied with by investment firms providing investment advice on an independent basis, among others. ESMA is invited to consult stakeholders on these matters. What’s next? Delegated acts to be adopted by the Commission will enter into force 30 months after the entry into force of MiFID II and MiFIR, which is expected to be in June 2014. The date of application of the Directive and of the Regulation is expected to be 30 months after their entry into force. ESMA should provide its technical advice by the end of the year 2014. YOU WILL FIND THE COMMISSION DOCUMENT HERE.

The FSB and the IOSCO issued response to consultation on shadow banking Background

The FSB and the IOSCO published on 8 January 2014 a consultation paper on the assessment methodologies for identifying non-bank non-insur- er ("NBNI") global systemically important financial institutions ("SIFIs"). The new SIFI framework that to date only covers banks and insurers would be extended to all other financial institutions. On 7 April 2014, ALFI responded to the consultation. The consultation closed on 7 April 2014. What’s in there? IOSCO published on 25 April 2014 together with the FSB the responses to the FSB-IOSCO consul- tation from 8 January 2014, on the assessment methodologies for identifying non-bank non-insur- er ("NBNI") global systemically important financial institutions ("SIFIs"). Forty-seven comment letters were posted. What’s next? The FSB and the IOSCO will develop within the SIFI framework the incremental policy measures need- ed to address the systemic risks posed by NBNI SIFIs, once the identification methodologies have been finalised and published. You will find the responses to the consultation here. BELGIUM Changes of Belgian law relating to UCITS Background A Belgian law concerning several modifications dated April 25th, 2014, was published in the Bel- gian Official Gazette on May 7th, 2014. What’s in there? This Belgian law contains modifications of several Belgian laws, and in particular the law of 3 August

page 4 - Scanning - June 2014

LUXEMBOURG Bearer Shares/ Bill 6625 Background Bill 6625 was introduced on 4 October 2013 fol- lowing Financial Action Task Forces's (FATF) rec- ommendations; it seeks to amend the law of 10 August 1915 by setting rules applying to the im- mobilisation of bearer shares. In particular, it will put an end to the free transfer of bearer shares by delivery of certificate and will require (i) the im- mobilisation of the bearer shares by a professional depositary and (ii) the identification of the bearer shareholders. Bill 6625 covers both shares to be issued after the entry into force of the law and existing bearer shares. Only bearer shares exchanged on a regu- lated market are out of scope. Among other, bearer shares issued or to be issued by investment funds (SICAV or FCP) are in the scope of Bill 6625. Bill 6625 has been amended on 1 st April 2014. What’s in there? On 22 April 2014, the Luxembourg Chamber of Commerce issued a set of comments on Bill 6625. In general, the Chamber of Commerce welcomed the provisions of the draft law but expressed the following concerns: « The six-month deadline to appoint a depositary may not be sufficient, considering that the safe- keeping of bearer shares is a new activity that will require Luxembourg depositaries to adapt their business organisation; « The six-month deadline for bearer shares reg- istration should start as from the end of the six- month deadline granted to companies to appoint a depositary. More information should be provided on the iden- tity of the person(s) other than the shareholder himself who will be allowed to register bearer shares. What’s next? Bill 6625 is to be voted by the Chambre des Députés (vote not scheduled so far). THE CHAMBER OF COMMERCE’S OPINION IS AVAILABLE HERE.

2012 on certain forms of collective management of investment portfolio. From the date of the pub- lication in the Belgian Official Gazette, the admin- istrators and the effective managers of UCITS (of- fering shares to the Belgian public) / management company/ credit institution will be only natural persons. Legal entities will be prohibited as ad- ministrators and/ or effective managers in those institutions. What’s next? NA. New fees and contribution to cover the operating costs of the FSMA. Background A Royal Decree modifying the Royal Decree dated 17th May, 2012, concerning the cover of the oper- ating costs of the FSMA dated March 28th, 2014, was published in the Belgian Official Gazette on May 13th, 2014. What’s in there? The Royal Decree updates the fees to be paid to the FSMA following several new control/duties of the FSMA (for example on AIF and AIFM). The Royal Decree also adds a new contribution for the sector already controlled by the FSMA and finally adapts the percentage that determines the part of each kind of contributor in the funding of the FSMA. A distinction is made in the Royal Decree between the fund with an appointed management compa- ny or a self-managed fund and the control on the public shares of public funds. A fee is added for self managed funds. What’s next? NA.

Admission of the concept of floating financial year Background Generally, a financial year lasts 12 months in Lux- embourg, which may match the calendar year. However, for operational purposes (e.g. consol- idated statements, cross-border groups), busi- nesses may have recourse to a floating financial year, which characteristic is a variable end-date. Opinions and recommendations from the GIE "Commission des Normes Comptables" the reg- ulator in charge of accounting standards ("CNC") have a general meaning and do not target any specific situation in which a natural person or le- gal entity may be. What’s in there? On 2 April 2014, the CNC issued a general opin- ion ref. CNC 01/2014 in relation to the concept of floating financial year as adopted by the Manage- ment Board of the CNC. It is of the view that Lux- embourg companies should be authorised to have floating financial years regardless of the account- ing standards under which their annual accounts are prepared (IFRS or LUX GAAP), as long as: « Opening dates and closing dates shall remain predictable and determinable; « Comparability remains guaranteed: a floating financial year shall have a duration close to a 12-month financial year (e.g. no more than 52 to 53 weeks). Luxembourg companies having floating financial years shall notify their opening and closing dates every year for every floating financial year to the Registre du Commerce et des Sociétés (the Trade and Companies Register). What’s next? N/A YOU WILL FIND THE GENERAL OPINION HERE (IN FRENCH ONLY).

Scanning - June 2014 - page 5

ALFI Guidelines on Operational Risk Management within UCITS Background The Law of December 17, 2010 and CSSF Re- gulation 10-4 have brought attention to the re- quirement for management companies managing UCITS and Self-Managed UCITS SICAV to have in place adequate risk management processes. On 17 April 2012, ALFI has issued its “Best practic- es proposals for the organisation of the risk func- tion of a UCITS” (available here). What’s in there? On 9 May 2014, ALFI published guidelines on op- erational risk management within UCITS. The doc- ument shall be seen as a set of best practices pro- posals for the management of operational risk. The ALFI guidelines consist in the following sections: « Highlight of the key sources of legal and regu- latory guidance in relation to risk management; and « A set of best practices regarding: - The identification of all relevant operational risks to which UCITS are or may be exposed; - The measurement and management of these identified operational risks; - The reporting with regard to these risks and re- lated information to senior management and the Board by the risk management function. What’s next? N/A THE GUIDELINES ARE AVAILABLE HERE.

2013 annual report Asset management key messages Background The CSSF issues on an annual basis a consolidat- ed report providing statistics on the Luxembourg financial industry and information on its supervi- sory practice. What’s in there? The CSSF 2013 annual report was published on 9 May 2014. THE CSSF ANNUAL REPORT IS AVAILABLE HERE. SWITZERLAND Revision of the FINMA Collective Schemes Ordinance (CISO-FINMA) Background The Collective Investment Schemes Act (CISA) and the Collective Investment Schemes Ordinance (CISO) were partially revised and came into force on 1st March 2013 with the effect to render the re- vision of the CISO-FINMA necessary. Indeed, they contain new requirements for the management, custody and distribution of collective schemes with the consequence to change the legal basis for the CISO-FINMA. What’s in there? The CISO-FINMA’s revision aims in particular to strengthen investor’s protection and to maintain EU market access in light of new national and in- ternational standards, and in this respect, tends to simplify and modernize the rules it prescribes. Risk calculation of derivative financial instruments will now, in line with EU regulations, exclude the calculation of risks according to three different risk categories, market, credit and currency risks. The new draft of the Ordinance also sets out new general requirements on the quality, administra- tion and custody of securities accepted by collec- tive investment schemes and the requirements for the independent risk management of the fund management companies, SICAVs and asset man-

agers. The mode of calculating the "de minimis threshold" for asset managers and the require- ments on professional liability insurance will also be set forth in the future Ordinance. Finally, due to the introduction of the provision about master feeder structures in the CISO, the new CISO-FINMA will provide regulations on this matter. What’s next? The consultation opened by the FINMA about the CISO-FINMA’s revision ended on 19th May 2014, deadline for communicating a potential position paper. A summarizing report of the taking parties’ positions will be published in a few months. Pre- liminary publication of the final version is sched- uled for October 2014 and the entry into force of the revised CISO-FINMA should take place on 1 st January 2015.

TAX IRS FAQ update Background

The purpose of the “IRS FATCA - FAQ General” is to provide answers to a set of questions occurring concerning the implementation of FATCA. Other FATCA FAQs are available for the FATCA Reg- istration System and the FATCA FFI List. What’s in there? On the 1 st May 2014, the IRS updated its FATCA FAQs. Questions have been added to the sections for responsible officers and registration, and a new section has been added addressing questions relat- ed to branches and disregarded entities. In particu- lar, the IRS provides answers and explanations to: « The scope and qualification required for a Re- sponsible Officer according to the specific status of the Foreign Financial Institution (FFI). « How certifications in Part IV of the FATCA Regis- tration apply to Financial Institutions treated as reporting Model 1 FFIs. « The impact of completing Part IV of the FATCA Registration on the different FATCA classifica- tions. « Registration requirements of Disregarded Enti- ties (DEs) and branches located in Model 1 IGA countries, non-IGA countries and Model 2 coun- tries. « The change in registration requirements of a DE in a Model 1 IGA jurisdiction whose laws disre- gard US tax classification elections.

page 6 - Scanning - June 2014

European FATCA-like tax regime (CRS) and Savings Directive Background With respect to the OECD Common Reporting Standard (CRS), which is relatively similar to FATCA, it seems as if the EU Commission fully sup- ports the CRS. It is expected that the CRS will be implemented into the EU Directive on Administra- tive Collaboration before the end of 2014. As a re- sult, the scope of the existing EU Savings Directive should not be extended as initially planned. The revised EU Savings Tax Directive 2014/48/EU ('the Savings Directive') which was published on 15 April 2014 aims to reduce tax fraud and eva- sion by expanding the existing rules on exchange of information on savings income. The Savings Directive was adopted by the Council of the EU on 24 March and widens the scope of Directive 2003/48/EC. What’s in there? The European Commission’s Expert Group on Tax- ation of Savings met on 28 April 2014 to review the Amended Directive 2014/48/EU and to discuss the Organisation for Economic Co-operation and De- velopment’s (OECD) work on automatic exchange of information. The end of the implementation pe- riod of the directive on 1 January 2016 could be affected by an earlier implementation of CRS. The group’s mandate was extended to include data protection as well as legal issues. What’s next? The Commission is currently seeking data to sup- port the review. The Commission requested participation in an Ex- pert Group on removing tax problems for individ- uals who are active across borders within the EU. The Commission launched two public consulta- tions on cross border taxation of citizens in EU Member States and on cross-border inheritance taxation problems, both with a response date on 3 July 2014. FIND MORE INFORMATION HERE

What’s next? The IRS will continually update its FATCA - FAQs General section according to public interest. THE FAQ IS AVAILABLE HERE.

IRS publishes Notice 2014-33 Background Under FATCA, foreign financial institution (FFIs) which do not enter into an agreement with the IRS and do not carry on the relevant process’s adap- tation on time or which refuse to comply with the regulation will face a 30% withholding tax on US sourced income for payments made. What’s in there? On 2 May 2014, the US Department of Treasury and the IRS published Notice 2014-33. The following points are the most important parts of the Notice: « Calendar years 2014 and 2015 will be regard- ed as a transition period for purposes of IRS enforcement and administration with respect to the implementation of FATCA. This means that the IRS will take into account the extent to which FFIs are making a good faith effort to comply with FATCA and related mod- ifications to existing information reporting and withholding obligations until calendar year 2016. « FFIs may treat an obligation (including an ac- count) held by an entity that is opened, executed or issued on or after 1 July 2014 and before 1 January 2015, as a preexisting obligation. How- ever, the cut-off date for accounts held by indi- viduals remains 30 June 2014. This additional delay is granted due to the fact that the IRS has not yet published instructions regarding form W-8BEN-E, which is supposed to be used by lots of FFIs to document the entity account holders. What’s next? Mechanisms such as the transition period should help to smoothen the transition process for FFIs and withholding agents and their compliance with FATCA requirements. NOTICE 2014-33 IS AVAILABLE HERE.

TAX - BELGIUM FATCA Belgium signed an IGA with the US Background On April 23th, 2014, the Belgian Minister of Fi- nance and the US Treasury signed a IGA t o im- prove International Tax Compliance and to imple- ment FATCA. What’s in there? The IGA will help to improve international tax com- pliance by introducing a reciprocal automatic ex- change of information by the way of a reporting regime for financial institutions (Model 1 IGA). What’s next? Incorporation into Belgian law.

Scanning - June 2014 - page 7

TAX - ITALY Fiscal monitoring Background

Italian Financial intermediaries report on annual basis to the Agenzia dell’ Entrate (Italian Tax Au- thority) transactions to and from foreign countries. These communications are limited to transactions performed by individuals, non-profit organizations, partnerships and associations as reported in Arti- cle 5 of the consolidated tax law and in the Decree on December 22 th 1986, no. 917. What’s in there? Threshold for financial intermediaries to send information to the Italian Tax Authority for these transactions rises from 10 to 15 thousand euros (in a single transaction or in more split transac- tions).The new provision is in line with the Italian anti-money laundering legislation (Legislative De- cree 231/2007). FATCA - Italy signed the IGA with the US Background On January 10th 2014, Italy signed an IGA with the US in Rome. What’s in there? Ministry of Economy and Finance launched the public consultation on the draft decree to ratify the IGA. The draft decree provides a reference to other regulations to be issued before 1st July 2014, to establish collection and transmission procedures as well as the content and the timing of the com- munication to Italian tax authority. What’s next? Before the deadline of 1st of July, it is expected the finalized version of the Decree will be issued to- gether with all the other regulations to implement the reporting line to Italian tax authority.

Scanning This publication is produced by Legal and Compliance teams of CACEIS with the kind support of Communication teams and Group Business Development Support teams.

Editors Gaëlle Kerboeuf, Group General Counsel @ Marie-Andrée Bonnet, Compliance and Regulatory Watch Manager (France) @ Permanent Editorial Committee Gaëlle Kerboeuf, Group General Counsel Marie-Andrée Bonnet, Compliance and Regulatory Watch Manager (France) Chantal Slim, Head of Legal (CACEIS Bank France) Eliane Meziani-Landez (Head of Fund Structuring France) Emilie Zaracki (Legal Officer) Ana Vazquez, Head of Fund Structuring and Domicile (Luxembourg) Véronique Bastin, Head of Compliance (Luxembourg) Stefan Ullrich, Head of Legal (Germany) Costanza Bucci, Legal and Compliance Manager (Italy) Mireille Mol, Legal and Compliance Manager (Netherlands) Laura Guzzi, Legal Manager (Belgium) Helen Martin, Head of Legal (Ireland) Sarah Perrier, Head of Legal and Compliance (Switzerland) Philippe Naudé, Marketing and Communication Specialist (France) Arianna Arzeni, Head of Group Business Development Support

Design Sylvie Revest, CACEIS, Communications

Photos credit Yves Maisonneuve, Yves Colllinet, CACEIS, Fotolia

CACEIS 1-3, place Valhubert 75 206 Paris CEDEX 13 www.caceis.com

This publication is provided by CACEIS from sources believed to be reliable. The present publication is not intended as an offer to sell or a commercial solicitation and may be amended at any time by CACEIS. Information contained in the present newsletter are not a substitute to legal, taxation or investment consultation or advice from an appropriately qualified profes- sional. CACEIS does not warrant the accuracy and completeness of this newsletter, nor endorse or make any interpretation about its content. In no event will CACEIS be liable for any damages whatsoever arising out of the use of, or reliance on the content of this newsletter. Unauthorized used or distribution without the prior written permission of CACEIS is prohibited.

page 8 - Scanning - June 2014