Our Vision. In this issue: Sharing solutions with our clients and their shareholders through insights, technology and a solid tradition.

Transcription

1 December 2018 Global Fund Services Our Vision Sharing solutions with our clients and their shareholders through insights, technology and a solid tradition. In this issue: U.S. Bank Global Fund Services 2 Strength in leadership 3 Depositary services 4 SEC liquidity rule 5 ETF rule 6 FinCEN beneficial ownership 8 Celebrating 50 years 9 Foreign tax reclaim 10 Transfer agent excellence 11 Innovation and service excellence 12 Feature: Introducing U.S. Bank Global Fund Services As we ve grown, our product capabilities have broadened and our clients can partner with us in many more ways. To reflect this change, we re excited to share that U.S. Bancorp Fund Services and Quintillion have changed their names to U.S. Bank Global Fund Services. Page 2 usbank.com/globalfundservices

2 Introducing U.S. Bank Global Fund Services For the past two years, we ve been on a journey to more successfully align our brand for future growth and deliver a clear, compelling message to our partners. Earlier this year, our business line name changed from Securities Services to Investment Services. We made this change to create new opportunities to position us in the market in a way that clearly explains what we do and what we offer to our clients. We re excited to share the next step in our brand evolution. U.S. Bancorp Fund Services and Quintillion have changed their names to U.S. Bank Global Fund Services. As we ve grown, our product capabilities have broadened and our clients can partner with us in many more ways. Our updated brand reflects this strong alignment and will help us more effectively communicate with you our clients, prospects and partners. We look forward to continuing to serve you under our new name, providing you with the same high level of service and expertise you have come to expect from us. Our complete services provide you tailored solutions to help you succeed Grounded on the highest ethical standards, U.S. Bank partners with you to provide reliable and responsive corporate trust, custody and fund services tailored to our diverse client base. With $6.4 trillion in assets under custody and administration, our Investment Services division operates a network of nearly 4,500 employees in more than 100 offices across the U.S. and Europe to fully support your unique local, national and international needs. As your business expands and you look to offer new products, we hope you continue to consider us your partner of choice. Through our broad range of solutions, we can offer you the following: Corporate trust services: Providing a broad range of debt and collateralized obligation instrument servicing in the United States and Europe Custody services: Offering comprehensive asset servicing capabilities for domestic and global portfolios Asset management services: Supporting clients through specialized institutional short fixed income investment management services Banking and financial services: Providing customized banking services to meet investment services market needs For more information about our comprehensive investment services offering, visit us at usbank.com/investmentservices. 2 U.S. Bank Global Fund Services

3 Strength in leadership As U.S. Bank Global Fund Services celebrates its 50th anniversary next year, our vision of building on a strong foundation remains steadfast. We continue to transform our business to meet the evolving needs of the investment industry and have made changes to help support the success of you, our clients. New chief global strategy officer and interim head of transfer agent operations: This past May, Christine Waldron was named chief global strategy officer for U.S. Bank Global Fund Services. In this role, Christine works with our leadership team to drive strategy and execute key business plans. As continuous improvement requires us to evaluate the alignment of our resources, Christine also recently assumed the role as interim head of mutual fund transfer agent operations. Alternative investments management leadership: Our alternative investment solutions team, formerly led by Christine Waldron, is now under the leadership of Brian Bekiers and Linda Gorman. Brian leads our alternative investment business in the U.S., while Linda serves as head of our European alternative investment business. Mutual fund accounting and fund administration leadership: We will continue to have separate accounting and administration servicing teams, but we ve combined the leadership of both teams under Dana Armour. Effective collaboration between these two teams is critical and aligning this leadership team will bring a greater synergy to our service model. New head of business development: Dylan Curley joined our team in June as global head of sales, replacing Bob Kern, who retired in July. Dylan is responsible for leadership of all fund services business development efforts, including our mutual fund and alternative investment products. Regulatory Support Services team expands: We recently aligned Quasar Distributors, under the leadership of Teresa Cowan, with our Regulatory Support Services department led by Anita Zagrodnik. Teresa has served as Senior Vice President and Chief Compliance Officer for Quasar since This realignment will allow us to more efficiently utilize our mutual fund and broker dealer business and compliance experience across Global Fund Services. At U.S. Bank, we know that people make the difference. Through the expertise and commitment of our employees, we look forward to continuing our partnership. Thank you for your understanding as we integrate these changes. Joe Neuberger, President December

4 Announcing new depositary services in Ireland After more than a year in development, we re excited to announce the launch of our enhanced depositary services offering in Ireland. Now, we re able to provide cash monitoring, safe-keeping and oversight to Irish collective investment schemes in combination with our affiliate U.S. Bank Depositary Services. Through this offering, clients who have or wish to launch Irish funds can rely on us to support equities, fixed income, mutual funds, money markets, hedge funds, private equity funds, funds of funds, structured securities, cash, infrastructure and real estate/property. A customized solution We re committed to supporting all your depositary needs with our customizable service offerings, innovative technology and global resources. We ll work closely with you to determine your product s specific requirements so we can provide just the right selection of services. Our capabilities include trade and cash settlement, asset servicing, information and reporting tools, straight-through processing, board level reporting, and processing securities movements. Additionally, we can provide depositary lite services applicable to non-eea domiciled funds managed by EEA managers who are marketing the fund in the EU under the National Private Placement regimes. All regulated investment funds domiciled in the EU are required to appoint a depositary to comply with the Alternative Investment Fund Managers Directive (AIFMD) and the Undertakings for Collective Investments in Transferable Securities (UCITS) Directive. The important roles of monitoring cash flows overseeing compliance with applicable regulations and investment restrictions and safekeeping /recordkeeping of assets means you need a depositary you can rely upon to fulfill numerous regulatory requirements. Our dedicated experts will partner with you to identify all your custodial, reporting and operational needs. We ll provide a flexible, cost-effective solution that not only meets all necessary AIFMD and UCITS Directive obligations, but instills absolute confidence as well. Benefits of an experienced partner Maintaining compliance with the AIFMD and UCITS Directive presents many challenges for fund managers. In addition to securing a depositary solution for the fund s assets, managers are also responsible for meeting the reporting obligations and investment restriction compliance as laid out by the applicable regulations. Navigating these regulations can seem overwhelming, particularly if it s your first time launching an Irish product, but it s significantly easier when you work with a full-service depositary partner who can guide you through your options and monitor the complexities for you. About our Investment Services team Currently, our custody team services more than $2 trillion in assets across 10 locations worldwide, employing more than 750 individuals. Our fund services, custody and corporate trust teams compose our Investment Services division, which in total, holds more than $6.3 trillion in assets under custody and administration. We operate a network of nearly 4,500 employees in more than 100 offices across the U.S. and Europe to fully support your unique local, national and international needs. To learn more about our depositary services offering, please contact: Breda Sullivan, Head of Depositary Services Europe at breda.sullivan@usbank.com Barry O Brien, Head of Fund Client Relations Europe at barry.obrien@elavon.com Elavon Financial Services DAC, trading as U.S. Bank Depositary Services, is regulated by the Central Bank of Ireland and is registered in Ireland with the Companies Registration Office Reg. No U.S. Bank Global Fund Services

5 SEC liquidity rule developments In an ever-changing regulatory landscape, it s important for us to keep our clients up to date on new rules and regulations that affect their funds. Since our last update regarding the SEC s liquidity rule, there have been a number of developments. These developments fall within two primary matters: progress on a contractual third-party vendor solution for bucketing and liquidity monitoring, and amendments by the SEC to public disclosure requirements. Vendor solution for bucketing and liquidity monitoring We are finalizing a solution with ICE to provide daily liquidity bucketing to clients, which include discussions around cost and logistics. Clients using our partnership with ICE will need to provide us with their reasonable trade size and significant value impact how much value the fund is willing to give up when liquidating a position, at the fund, security or security-type level. We will send these settings along with all of the positions to ICE, and we will deliver a report from ICE the next day showing the positions and the buckets. For clients that would like to see an output sample from ICE based on a portfolio, we can help facilitate that. Additionally, if a client is looking for more than just the bucketing values (e.g., a desire for all of the underlying data behind the calculations or for the ability to change the settings frequently), they will be able to contract directly with ICE to obtain direct access to ICE s Vantage product at a higher cost. Amendments to public disclosure requirements Near the end of June 2018, the SEC amended the requirements for public liquidityrelated disclosures. Per the SEC, under the amendments, funds would discuss in their annual or semi-annual shareholder report the operation and effectiveness of their liquidity risk management programs. This requirement replaces a pending requirement that funds publicly provide a quantitative end-of-period snapshot of historic aggregate liquidity classification data for their portfolios on Form N-PORT. As your service partner, we are committed to frequent communication regarding updates and guidance to help you comply with the new rules. Between now and the end of the year, we will provide communication to update you on current developments. If you have any questions about our solutions, please contact your relationship manager or Erika Panyard at erika.panyard@usbank.com. December

6 SEC proposes long-awaited ETF rule On June 28, 2018, the U.S. Securities and Exchange Commission (the Commission) unanimously voted to propose new Rule 6c-11 (the Proposed Rule) under the Investment Company Act of 1940 (the 1940 Act), along with changes to certain disclosure forms (e.g., Form N-1A, Form N-CEN) used by exchange-traded funds (ETFs). 1 The Proposed Rule would eliminate the need for investment advisers to most ETFs registered under the 1940 Act to individually obtain exemptive orders from the Commission to manage index-based or actively-managed ETFs. 2 Additionally, the Proposed Rule would permit greater flexibility in the management of ETF portfolios through the use of custom baskets in a manner not available under index-based ETF exemptive orders issued since approximately 2006 and not currently available under any actively managed ETF exemptive orders. The Proposed Rule would also eliminate certain distinctions between actively managed and index-based ETFs in place of a requirement that all ETFs relying on the Proposed Rule fully disclose their holdings on a daily basis and include certain disclosures in their prospectus and on their website regarding trading costs (e.g., data on bid-ask spreads). What s in? The primary feature of the Proposed Rule is the elimination of the need for advisers to obtain exemptive relief to manage an ETF. The ETF-related portion of the more than 300 individual exemptive orders issued by the Commission would either be rescinded or automatically expire one year after the effective date of the final rule. 3 The Proposed Rule generally codifies the conditions of existing exemptive orders, including requiring that an ETF s shares are listed on an exchange, the ETF s holdings are transparent 4, and certain data points about the ETF are disclosed daily on the fund s website (e.g., NAV, market closing price). This elimination could slightly reduce the time- and cost-to-launch for new ETF issuers, although such changes are not likely to be significant. Given that ETF exemptive orders are typically issued with three to six months of submitting an application and the cost of such exemptive relief is frequently less than $25,000, this change is not generally expected to affect the ability of new issuers to enter the ETF industry. If you have questions about the ETF rule, please contact your relationship manager or Mike Castino at michael.castino@usbank.com. A second feature of the Proposed Rule is the permitted use of custom baskets 5 to manage an ETF s portfolio. This component would permit an ETF s manager to choose which securities to receive in connection with an order to create new shares and which securities to deliver out in connection with an order to redeem shares. 6 Because ETFs depend on in-kind deliveries of securities to maximize their tax efficiency, this flexibility could improve the tax efficiency of many ETFs, particularly actively managed ETFs, none of which are currently permitted to use custom baskets. In permitting the use of custom baskets by most ETF issuers and for both 6 U.S. Bank Global Fund Services

7 index-based and actively managed ETFs, the Proposed Rule would level the playing field between older ETF issuers and newer entrants, and it would eliminate advantages in tax efficiency that index-based ETFs have historically had over actively managed ETFs. It would also require new and expanded disclosures by ETFs regarding trading costs and certain other fund attributes. The new disclosures include a table and line graph showing the ETF s historical premiums or discounts to NAV. If the ETF s market price has closed at a premium or discount to NAV of more than 2 percent for more than seven consecutive trading days, the website must also include (and keep for one year) a narrative disclosure regarding the cause(s) of such variances. The Proposed Rule would also require each ETF to calculate and disclose its median bid-ask spread over the most recently completed fiscal year. A new disclosure requirement introduced with the Proposed Rule would be a required set of six questions and answers (Q&As) in the summary section of the fund s prospectus. The Q&As pertain to trading costs for the ETF, including an interactive calculator to help investors understand their total trading costs based on how many purchase and sale transactions they expect and historical bid-ask spread figures for the ETF. 7 What s out? The Proposed Rule attempts to balance some of the new disclosure requirements with the elimination of certain operational and disclosure items for ETFs that the Commission has determined are no longer necessary or relevant to ETF investors. For example, the Proposed Rule would eliminate the requirement in exemptive order applications for a fund to disseminate an intraday indicative value (IIV), an estimate of the fund s intraday value based on the fund s last disclosed holdings and calculated at least every 15 seconds during the trading day. Additionally, ETFs with foreign holdings would no longer have to disclose in their statement of additional information the holidays in foreign countries that are expected to delay delivering redemption proceeds for more than seven days, and ETFs would not be subject to any particular minimum amount for the number of shares in a creation unit. The Proposed Rule also deems ETF shares relying on the Proposed Rule to be redeemable securities, which eliminates the need for some, but not all, exemptions currently obtained by most ETFs with respect to rules adopted under the Securities Exchange Act of Overall, this is a positive development in the modernization of the Commission s regulatory system for ETFs. It addresses a frequent complaint by ETF issuers that the regulatory playing field has been tilted toward older issuers, eliminates the arbitrary and disparate treatment of index-based and actively managed ETFs, and provides many issuers with new tools to improve portfolio management. 1. Exchange-Traded Funds, Securities and Exchange Commission, 83 Fed. Reg (proposed July 31, 2018). 2. The Proposed Rule would generally affect only ETFs structured as open-end funds and would not affect ETFs structured as unit investment trusts (UITs), a share class of a multi-class fund, or a leveraged or inverse ETF, although such funds may still be subject to certain new disclosure requirements regarding trading costs. The Proposed Rule also does not address the various exemptive order applications pending with the Commission for ETF-like structures that are less transparent and do not disclose their full holdings on a daily basis, nor does it address exchange-listed products that are not registered under the 1940 Act, such as exchange-listed commodity pools, grantor trusts, or exchange-listed notes (ETNs). 3. The fund-of-funds relief included in most ETF exemptive orders would not be rescinded or expire, although the Commission has placed fund-of-funds rulemaking on its regulatory agenda, which could separately affect the rescission of, or need for, such relief. 4. Currently, index-based ETFs utilizing a third-party index provider are not required to post their holdings on their website, but issuers of other ETFs, including index-based ETFs with an affiliated index provider (self-indexing), long/short ETFs, and actively-managed ETFs are required to disclose their holdings on their website on a daily basis. 5. A basket is the set of securities to be delivered to an ETF to create shares or to be received from the ETF upon redeeming shares. ETF shares may only be purchased or redeemed in large blocks of shares (e.g., 50,000 shares) by authorized participants that have an agreement with the fund or its distributor. 6. Index-based ETFs relying on certain exemptive orders received generally before 2006 are already permitted flexibility in basket construction, whereas newer orders generally require baskets to be a pro-rata representation of the fund s holdings. 7. Index-based ETFs, including those with exemptive orders issued after 2006, have generally been permitted discretion in basket composition at any time their underlying index is rebalanced or reconstituted, but actively-managed ETFs have not had such flexibility. As a result, an index-based ETF today could be more tax-efficient than an actively-managed ETF, even if both followed an identical set of investment rules. December

8 Regulatory update: The FinCEN beneficial ownership rule Earlier this year, U.S. Bank Global Fund Services successfully adopted procedures to comply with the Financial Crimes Enforcement Network (FinCEN) beneficial ownership rule, which became effective May 11, Preparation for this rule was a collaborative effort involving several departments within our organization. The beneficial ownership rule primarily requires that financial institutions collect and verify information regarding the beneficial owners of certain types of entity-owned accounts. The types of accounts impacted include those held by corporations, limited liability companies, general and limited partnerships, and business and statutory trusts. Accounts held by natural persons, sole proprietorships and most trusts are exempt. Special, limited requirements apply to nonprofit organizations and government entities. The rule defines beneficial owners as individuals who own 25 percent or more of the entity in question and individuals who manage or control the entity (the control person ). Financial institutions are required to collect and verify identifying information for these beneficial owners. This information includes name, date of birth, physical address, and Social Security number or other government-issued identification number for non-u.s. persons. Preparation for this rule entailed considerable effort involving numerous groups within our transfer agent, including: Document distribution: Verifies that all required beneficial owner information is received Retail processing: Adds beneficial owner information to the appropriate account records Contact center and retail processing resolution: Assists in providing shareholders with information regarding requirements AML/fraud prevention: Verifies the provided beneficial owner information For more information on our solutions addressing the beneficial ownership rule, please contact your relationship manager. During the preparation, two working groups were formed: an operational group that coordinated the development of necessary procedures within the impacted departments and a steering group that ensured all key requirements of the rule were being addressed. Our regulatory support services group played a critical role in this effort by clarifying the rule s requirements and helping develop the implemented procedures. Once requirements were verified, we developed internal procedures and notified clients regarding changes that were needed to account-related forms. To verify the necessary beneficial owner information, we developed a daily report that lists all new entity-owned accounts containing beneficial owner information. This report also lists accounts for which beneficial owner information has been changed or updated. 8 U.S. Bank Global Fund Services

9 Personnel on our AML/fraud prevention team review this report daily and verify the beneficial owner information that is provided using the same tools used to verify customer information. Results are captured and linked to the permanent account record. Implementing procedures related to the beneficial ownership rule is an example of our collaborative approach at U.S. Bank Global Fund Services. Dedicated to maintaining a culture of ethics, transparency and compliance, we deliver seamless and effective solutions to guide our clients through times of regulatory change. Building on our strong foundation In 2019, we are excited to share that U.S. Bank Global Fund Services will be celebrating our 50th anniversary. Building on our solid foundation of service excellence, we are incredibly grateful to our clients and business partners for the relationships we have developed over the years. You have inspired us to achieve exceptional growth and innovation in the products and services we offer. As part of this historic milestone, we will be hosting our 2019 annual client conference at The American Club in Kohler, Wisconsin. Nestled just an hour north of Milwaukee, The American Club emerged in 1918 from one man s tireless determination and innovative vision. Today, it has grown to be Wisconsin s only five-star resort the perfect place for us to join together for a unique and memorable experience to commemorate the 50th anniversary of U.S. Bank Global Fund Services. Check your calendars and please save the date for our 32nd Client Conference as we are moving the conference dates this coming year to Monday, June 3 through Wednesday, June 5. We will continue to offer a range of topics covering the mutual fund, exchange traded-fund and alternative fund industries to speak to the interests of our growing client base. It s an honor to celebrate this milestone with you throughout We are thankful for your continued business and look forward to many more years of collaboration and success. Save the date June 3-5 The American Club in Kohler, Wisconsin To learn more please inquire with your relationship manager or primary administrator. Otherwise, contact Cheryl Zielinski at cheryl.zielinski@usbank.com. Photo courtesy of Kohler Co. December

10 Foreign dividend tax reclaim services The foreign tax reclaim process continues to evolve as more jurisdictions move to relief at source (RAS) treatment of withholding taxes levied on foreign investors receiving dividends. Under the RAS method, U.S. investors receiving dividends from certain foreign entities would be initially taxed upon receipt of the dividend at the lower treaty rate of the applicable foreign jurisdiction rather than the higher statutory rate. This eliminates the need to go through the normal tax reclaim filing channels and, in turn, significantly expedites the reclaim process. As shown in the examples below, complexity in tax reclaim filings continues to increase: Canada has transitioned to an RAS filing process requiring additional documentation with the introduction of the nonresident form. Norway is expected to increase their RAS documentation filing requirements sometime later this year. Denmark has recently proposed moving to an RAS market, but this has yet to be finalized. Germany is now offering RAS treatment upon the filing of status certificates for certain investors. At U.S. Bank, we have professionals who specialize in tax regulation as well as custody tax reclaim. We created a solution that assists our clients in verifying the status of outstanding tax reclaims and completing complex reclaim forms required in certain foreign jurisdictions. Our custody tax reclaim processes now includes automated third-party software from an international tax reclaim consulting firm. This ensures real-time updates on changes to withholding tax rates and tax reclaim filing requirements, including RAS filings in most foreign jurisdictions. As the foreign tax reclaim process continually changes, our team is dedicated to providing the solutions our clients need. If you have questions about tax reclaims for your funds, please contact your relationship manager or Michael McMaster at michael. mcmaster@usbank.com. 10 U.S. Bank Global Fund Services

11 Achieving service excellence in our transfer agent At U.S. Bank, we are committed to maintaining the highest level of service for our clients and their shareholders. We focus on continuous improvement to ensure our teams have the expertise and resources needed to exceed expectations. Our efforts have not gone unnoticed. In May 2018, we were honored to be recognized by organizations that specialize in the service-related industry. Our transfer agent s contact center was named Best Small Contact Center by International Customer Management Institute (ICMI). For more than 30 years, ICMI has worked to help improve customer experiences and increase efficiencies within contact centers through training, events, consulting and informational resources. Our contact center was also recognized with the Best Employee Engagement award by NICE. NICE helps companies improve business performance, increase operational efficiency, prevent financial crime, ensure compliance, and enhance safety and security. Increased employee engagement reflects positively on the level of service we provide our customers, said Joe Neuberger, president of U.S. Bank Global Fund Services. From recognition programs and employee committees to flexible scheduling options, our contact center is committed to implementing various initiatives that keep our employees engaged and, in turn, delivering superior service to our client base. The Association for Talent Development (ATD) honored our transfer agent team with an Excellence in Practice Award for its accomplishments in the Knowledge Management category. ATD is a professional membership organization supporting those who develop the knowledge and skills of employees around the world. Winners were chosen based on their ability to demonstrate clear and measureable results of achieving organizational goals, meeting an established need, upholding appropriate design values and maintaining clear alignment with other performance improvement initiatives. Our team was selected for its exceptional application of ISO 9001 and its associated talent development results. Our employees and operations have realized unparalleled benefits, specifically from integrating accurate and accessible documentation, clear process metrics, and a knowledge management discipline, Joe said. We are honored to be recognized among other award recipients, including Fidelity Investments, EY and IBM. For more information about our transfer agent services, please visit usbank.com/globalfundservices. December

12 Leading the industry through innovation and service excellence At U.S. Bank, we re committed to innovation and exceptional customer service, and we appreciate when those efforts are recognized. We were honored to be named Best administrator for middle-office services at the HFM US Hedge Fund Services Awards in September 2018 as well as Best fund administrator for technology and reporting and Best fund distributor at the Mutual Fund Services and Technology Awards in October These awards distinguish hedge fund administrators, mutual fund administrators and distributors who have showcased service excellence and product innovation over the past 12 months. We have some of the most dedicated, engaged employees in the business, and it s an honor to see all the hard work we do to put clients first rewarded in this way. We strive to distinguish ourselves in the marketplace by listening to our clients concerns and tailoring solutions to meet their specific needs. Joe Neuberger, President U.S. Bank Global Fund Services Building on decades of investment experience Our global fund services team combines industry-leading technology with high-quality customer service to offer customized product solutions for alternative investments, mutual funds and exchange-traded products. This team and our corporate trust and custody teams compose our Investment Services division, which in total, holds more than $6 trillion assets under custody and administration. We operate a network of 7,700 employees in 76 offices across the U.S. and Europe to fully support your unique local, national and international needs. Grounded on the highest ethical standards, we partner with you to provide reliable and responsive corporate trust, custody and fund services tailored to our diverse client base. U.S. Bank Global Fund Services 777 East Wisconsin Avenue Milwaukee, WI Please send your comments and suggestions to usbfsinfo@usbank.com. usbank.com/globalfundservices U.S. Bank Global Fund Services is a wholly owned subsidiary of U.S. Bank, N. A. Custody and lending services are offered by U.S. Bank, N.A. U.S. Bank Global Fund Services (Ireland) Limited is registered in Ireland with the Companies Registration Office Reg. No and Registered Office: City Quay, Dublin 2, Ireland. U.S. Bank Global Fund Services (Ireland) Limited is authorised and regulated by the Central Bank of Ireland under the Investment Intermediaries Act, U.S. Bank Global Fund Services (Guernsey) Limited is licensed under the Protection of Investors Law (Bailiwick of Guernsey), 1987, as amended by the Guernsey Financial Services Commission to conduct controlled investment business in the Bailiwick of Guernsey. Investment products and services are: NOT A DEPOSIT NOT FDIC INSURED MAY LOSE VALUE NOT BANK GUARANTEED NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY U.S. Bank does not guarantee products, services or performance of its affiliates and third-party providers. Elavon Financial Services DAC, trading as U.S. Bank Global Corporate Trust, is registered in Ireland with the Companies Registration Office, Reg. No The liability of the member is limited. Registered Office: 2nd Floor, Block E, Cherrywood Science & Technology Park, Loughlinstown, Co. Dublin, Ireland. Regulated by the Central Bank of Ireland. United Kingdom branch registered in England and Wales under the number BR In the U.K., Elavon Financial Services DAC, trading as U.S. Bank Global Corporate Trust Services, operates from offices at 125 Old Broad Street, Fifth Floor, London, EC2N 1AR and is authorised by the Central Bank of Ireland and the Prudential Regulation Authority and subject to limited regulation by the Financial Conduct Authority and Prudential Regulation Authority. Details about the extent of our authorisation and regulation by the Prudential Regulation Authority, and regulation by the Financial Conduct Authority, are available from us on request U.S. Bank