MiFID II Bank Seminar 1 December 2017 London

Transcription

1 MiFID II Bank Seminar 1 December 2017 London

2 Contents Introduction Investor Protection: Product Governance Corporate Finance Underwriting & Placing Market Structure Introduction Trading Obligation Transparency Post-trade transparency Best execution Reporting Governance Appendix Systematic Internaliser - calculation Liquidity & SSTI deferrals 2

3 Disclaimer The information in this document has been compiled by SEB Large Corporates & Financial Institutions, a division of Skandinaviska Enskilda Banken AB (publ) ( SEB ). Nothing in this document may be seen as legal advice. It is produced for private information of recipients and SEB is not soliciting any action based upon it. All information has been compiled in good faith from sources believed to be reliable. However, no representation or warranty, expressed or implied, is made with respect to the completeness or accuracy of its contents and the information is not to be relied upon as authoritative. Recipients are urged to base any investment decisions upon such investigations as they deem necessary. To the extent permitted by applicable law, no liability whatsoever is accepted for any direct or indirect loss arising from the use of this document or its contents.

4 Introduction Until the Directive is adopted, it does not apply. Norway delayed till MiFIR applies to all EEA members directly 3 Jan Finanstilsynet adopted most of MiFIR on Nov 9, fc dd3a8e9c9f/mifid-ii-regulations.pdf "I tried to count Q&As on MiFID and I gave up," Denmark FSA Deputy Director Birgitte Holm No intention of taking enforcement action against firms for not meeting all requirements straight away Mark Steward, UK FCA s Director or Enforcement & Oversight 4

5 More asset classes in scope Equity and equity-like instruments Non-Equity Shares ETFs Emission allowances Structured finance Depository Receipts Certificates Derivatives Bonds Equity Derivatives FX Derivatives Securitised Derivatives Credit Derivatives CFDs Interest Rate Derivatives Commodity Derivatives MiFID MiFID II 5

6 Key Themes Investor Protection Market Structure Reporting Governance Information to clients -client categorisation -client agreement -best execution policy -cost & charges Product Governance Rules on inducements & commissions, third-party research Advisory process suitability reports All asset classes are now in scope Best execution Trading obligation Pre & post trade transparency Systematic Internaliser Dark Pools Controls for algorithmic trading Regulatory reporting: - Legal Entity Identifier becomes mandatory - National Identifiers - identify decision makers - market identifier codes Transparency real time pre & post execution trade data to APA (subject to deferral rules) Publication of execution quality Remuneration rules Demonstrate more responsible trading behaviour via: - management body - remuneration rules - role of compliance - regular assessments for product governance, best execution quality and algorithmic trading Record keeping 6

7 Investor Protection Product Governance 7

8 Product governance concepts Manufacturers and Distributors Investment firms that create, develop, issue and/or design financial instruments, including when advising corporate issuers on the launch of new financial instruments are manufacturers Investment firms that offer or sell financial instrument[s] are distributors (with no connection to the manufacturer being explicitly required); 8

9 Product Governance Meaning of execution of a Target Market & Distribution Strategy For each product, product manufacturers must identify, and communicate to distributors a compatible Target Market of investors and a Distribution Strategy The Target Market must be reviewed on an annual basis. PRIIPs: Packaged Retail and Insurance-based Investment Products For packaged products, manufacturers (including issuers), must provide a 3-page Key information document (KID) before a packaged product is made available to EEA retail investors and keep it updated Distributors must provide the KID to EEA investors before contract Agreement among syndicate banks on joint responsibilities New requirement that Syndicate banks must document their mutual responsibilities in a written agreement The written agreement should also include a common definition of the chosen Target Market Provision of information about a financial instrument to distributors Investment firms to ensure that it includes about the appropriate channels for distribution of the financial instrument, the product approval process and the target market assessment and is of an adequate standard to enable distributors to understand and recommend or sell the financial instrument properly 9

10 Corporate Finance Underwriting & Placing 10

11 Underwriting and Placing Before accepting a mandate Meaning of execution of a Information requirements to issuer clients: The various financing alternatives available with the firm, and an indication of the amount of transaction fees associated with each alternative; The timing and the process with regard to the corporate finance advice on pricing of the offer; The timing and the process with regard to the corporate finance advice on placing of the offering; Communication of allocation policy and relevant information about proposed allocation methodology; Details of the target investors, to whom the firm intends to offer the financial instruments; The job titles and departments of the relevant individuals involved in the provision of corporate finance advice on the price and allotment of financial instruments; Firm's arrangements to prevent or manage conflicts of interest that may arise where the firm places the relevant financial instruments with its investment clients or with its own proprietary book. If the firm cannot mitigate conflicts of interest, they should not accept the mandate. 11

12 Underwriting and Placing Transaction process Inform / involve the issuer client: Meaning of execution of a On how recommendation as to the pricing and timing of the offering is determined About any proposed hedging or stabilisation strategies for the issue On the development of pricing of the issue In discussions about the placing process in order to understand and take into account the issuer s interests and objectives Obtain issuer s agreement on proposed allocation per type of client in accordance with the allocation policy Recording of issuer client instructions and placement allocation decisions Investment firms shall keep records of the content and timing of instructions received from clients A record of the allocation decisions taken for each operation shall be kept to provide for a complete audit trail between the movements registered in clients' accounts and the instructions received by the investment firm. 12

13 Market Structure Introduction 13

14 Market structure what does it mean? Trading location Where / How should trading take place? Transparency What rules around communicating trade information to the market? 14

15 Market Structure Trading Obligation 15

16 Market venues where will trading take place? Equity & equity-like instruments Systematic Internalisers a counterparty, not a venue Trading on own account = internalisation Many own account trades on ISIN level = Systematic i.e. that firm is a Systematic Internaliser (SI) (in respect of that specific ISIN) Becoming a SI means getting caught up in pre-trade transparency; also responsible for transparency reporting Non-equity instruments LSE Blmbrg BGC SEB 16

17 Trading obligation Overview Trading obligation shares Organised Trading Facilities Regulated Markets Multilateral Trading Facilities Third country venues Systematic Internalisers Trading obligation derivatives (sub-set of mandatory cleared IRS) ETFs and bonds are not subject to the Trading Obligation 17

18 Trading obligation for IRS and CDS Clearing obligation IRS deemed subject to the Trading Obligation must be executed via Trading Venues 29 Sept 2017, ESMA published proposed IRS contracts subject to trading obligation Currency IRS type Libor rolls Tenors Fixed leg day count Fixed leg payment Floating leg EUR IRS Fixed to Float single currency 3 M 2,3,4,5,6,7,10,15,20,30Y 30/360 or Actual/360 Annual or semi-annually Quarterly, Actual/360 EUR IRS Fixed to Float single currency 6 M 2,3,4,5,6,7,8,9,10,12,15,20,30Y 30/360 or Actual/360 Annual or semi-annually Semi-ann or Qtrly, Actual/360 USD IRS Fixed to Float single currency 3 M 2,3,4,5,6,7,10,12,15,20,30Y 30/360 or Actual/360 Annual or semi-annually Quarterly, Actual/360 USD IRS Fixed to Float single currency 6 M 2,3,4,5,6,7,10,12,15,20,30Y 30/360 or Actual/360 Annual or semi-annually Semi-ann or Qtrly, Actual/360 GBP IRS Fixed to Float single currency 3 M 2,3,4,5,6,7,10,15,20,30Y 30/360 or Actual/360 Annual or semi-annually Quarterly, Actual/365F GBP IRS Fixed to Float single currency 36M 6 M 2,3,4,5,6,7,10,15,20,30Y 30/360 or Actual/360 Annual or semi-annually Semi-ann or Qtly, Actual/365F Index CDS Series Tenor itraxx Main and itraxx Crossover On the run series; first off the run series Common features: - Trade start type: Spot (T+2) - Tenor: -/+ 5 days - Constant notional trades only - No optionality 5y OTC derivatives classes IRD (EUR, GBP, USD) Credit derivatives DATE OF APPLICATION: Category of counterparty Category 1 Category 2 Category 3 Category 4 Date of application of RTS on the TO Date of application of RTS on the TO Date of application of RTS on the TO Date of application of RTS on the TO 21 June December June May 2019

19 Market Structure Transparency 19

20 Transparency Pre-trade transparency publishing quotes and indications of interests Post-trade transparency publishing trade details (price and volume) Key questions: - What are the rules of pre- and post-trade transparency (per asset class)? - Who is responsible for transparency reporting? - Criteria relating to waivers (pre-trade) and deferrals (post-trade)? - What are the different deferral regimes (given local NCA responsibilities)? 20

21 Transparency - Architecture Consolidated tape CTP CTP Consolidated Tape Provider Consolidates all trade data and disseminate a consolidated feed APA Approved Publication Arrangement Reports transactions done outside a trading venue Website APA Trading Venues RM MTF OTF SI OTC Investment Firm 21

22 Transparency waivers and deferrals (non-equity) Both pre-trade and post-trade rules depend on a) trade size and b) liquidity status TRADE SIZE - Trade size determines whether pre-trade transparency, or post-trade deferrals apply - RFQ systems = Size Specific to the Instrument (SSTI) - Trading Venues = Large in Scale (LIS) - ESMA sets relevant size per ISIN every 3 months, based on percentile calculations (see appendix) - First quarter 2018 = indicative levels set at same level for all ISINs LIQUID STATUS - Each instrument is defined as Liquid if it fulfills certain criteria set by ESMA, based on trading activity - Status re-set every quarter, based on previous 6 month s data - Bonds published on 1 December 2017 by ISIN - Only 4 IRS tenors currently deemed liquid for trade transparency, so post-trade deferrals mostly apply - All FX = illiquid

23 Pre-trade transparency publishing quotes Trading venues required to make public current bid and offer prices depth of trading interests at those prices actionable indications of interests SI equities publish 2 way quotes on continuous basis for liquid stocks SI non-equities publish quotes to clients where Liquid instrument Prompted for a quote by a client; and They agree to provide a quote 23

24 Available pre-trade transparency waivers Trading venues SI Large in Scale Waiver Order Management Waiver Reference Price Waiver Negotiated Trade Waiver EQ LIS OMW RFP NTW Non- EQ LIS LIS OMW RFQ>SSTI Illiquid instruments Orders > LIS do not have pre-trade transparency requirement Iceberg orders, Stop loss orders etc EQ: dark pool waiver EQ: trades negotiated privately off book SSTI waiver for RFQ-systems Illiquid instruments EQ: negotiated trade reports > LIS are not subject to the Double Volume CAPs Each equity = subject to volume caps: 4% of volume per trading venue 8% of volume in aggregate across the EU Non-equity SI related waivers 24

25 Systematic Internalisers and pre-trade transparency Shares 25 Publish two-way quotes on continuous basis for liquid stocks (otherwise disclose on request ) Prices reflecting prevailing market conditions (MiFIR 600/2014 Article 14(3)) Price improvement allowed in justified cases (MiFIR 600/2014 Article 15(2)) Prices should be available at all times Obligation is to quote 10 % of Standard Market Size (SMS) at marketable prices. In the systematic internaliser it is possible to have different pricing logic for the accepted client categories. Matched principal will not be allowed (see recent Commission proposal) Still no clarity whether tick-size rules should be applied (RTS ESMA 2015/1464 p 32) 25

26 Systematic Internalisers and pre-trade transparency Non-equities Requirements Make public quotes for liquid instruments (to APA or own website) Conditions When prompted by client When agree to provide a quote Access to quotes Must make available to other clients, but within commercial policy (objective and non-discriminatory) Obligation Enter transactions under published conditions if at or below size specific to the instrument Conditions: Update / withdraw Can update any time but can only withdraw in exceptional conditions Quotes requirements Must achieve best execution and reflect prevailing market conditions Acceptable limits Number of trades any quote provided non-discriminatory and transparency Price improvements Only in justified cases if it fails within public range close to market conditions 26

27 Market Structure Post-trade transparency - How to fix trade reporting 27

28 Post-trade transparency publishing trades - WHO IS RESPONSIBLE FOR REPORTING (outside Trading Venues)? - HOW WILL TRADE REPORTING BE DONE (outside Trading Venues)? ONCE REPORTED, WHICH DEFERRAL REGIME APPLIES? The rules are based on: Whether instrument is liquid The size of the quote or the trade, relative to a defined standard only trades below a certain size should be subject to pre- and post-trade transparency requirement AND the deferral rules are set by the local regulator for each EU jurisdiction 28

29 Traded on a Trading Venue (TOTV) All financial instruments within MiFID II scope must have an ISIN. ISINs for OTC derivatives are issued by ANNA-DSB, using their protocols. When a new OTC derivative (or even order) is created, IFs must check if an ISIN exists (from ESMA s Financial Instrument Reference Database (FIRDS)), or create one. If an ISIN was already available, quoted or traded on a Trading Venue, it is within scope of the MiFID II transparency regime. 29

30 Trade Reporting responsibility hierarchy EU investment firm + Non-investment firm, or non- EU firm = EU investment firm reports (according to their local rule) EU investment firm + EU investment firm = Seller reports (according to their local rule) EU investment firm + Systematic Internaliser = SI reports (according to their local rule) Systematic Internaliser + = Seller reports Systematic Internaliser (according to their local rule) EU investment firm without own trade reporting capacity Assisted trade reporting How will each counterparty know WHO is Systematic Internaliser for each ISIN in any case? 30

31 Assisted reporting how to make it happen in practice? Undertaking to send all trades to APA No liability for SEB Settling up Client Client trades with SEB SEB 1. Agreement set up between each party 2. Client sends list to SEB of LEIs for relevant counterparties / funds Fee agreement Trade recon reports 3. SEB registers with APA all LEIs connected to assisted trade reporting Post-trade 1. SEB sends all trades to APA APA 2. APA distinguishes which party is the relevant reporting entity, and registers the trade as reported 3. APA applies deferral rules applying to the relevant LEI Agreement arrangement Process flow 31

32 Assisted reporting how to make it happen in practice (cont d)? The complexity of multi-party arrangements - EITHER All Clients must accept the collective APAs of their trading counterparties All trading counterparties must accept the collective APAs of their clients i.e. cost impact for trading counterparties, versus reconciliation complexity for clients Client accepts all APAs used by sell-side counterparties All sell-side firms accepts the APA used by the client (in which case, they will end up joining most APAs) SEB Bloomberg SEB Bloomberg Nordea Nasdaq Nordea Nasdaq Danske Bank TRAX Client Danske Bank TRAX Client Barclays Bank Tradeweb Barclays Bank Tradeweb Deutsche Bank EUREX Deutsche Bank EUREX 32

33 Market Structure Trade transparency - Waivers and deferrals 33

34 Basic rules of post-trade transparency Real-time/near to real time disclosure: Equities 1 minute (by Trading Venue, or by SI to APA) Non-equities: within 15 minutes (5 minutes from 2020), published by APA BUT.subject to the deferral rules, based on Whether instrument is liquid The size of the quote or the trade, relative to a defined standard only trades below a certain size should be subject to post-trade transparency requirement AND the deferral rules are set by the local regulator for each EU jurisdiction 34

35 Market Structure Trade transparency - Which deferrals apply? 35

36 Post-trade transparency deferrals Application in practice Local jurisdiction applies, based on which counterparty is responsible for trade reporting Trades with subsidiaries would be under local regulator jurisdiction (separate LEI) NOTE - Not clear which jurisdiction branches fall under, but ESMA view that deferral regime relates to branches Trades executed outside, but reported to, Trading Venues, are considered on venue and follow TV jurisdiction rules Jurisdiction Proposed application UK Maximum deferral regime Germany, France Rumoured to follow UK Sweden (initial proposal) T+2 default model too opaque (less than today) Trade-by-trade price data, without volume, disseminated directly All information disseminated T+2 (19:00) 4weeks-alternative MAY be used Denmark No deferral for illiquid instruments Current Danish model to continue 36

37 Post-trade transparency deferrals AFME s interpretation of the UK FCA regime s open position (and for Germany?) Post-Trade Transparency Disclosure Proposed framework Price Volume (Non-Sov) Volume (Sov) LIQUID SSTI Real-time Real-time Real-time ILLIQUID SSTI At 7pm T+2 T+4 weeks T+4 weeks (Aggregated) LIQUID & ILLIQUID SSTI At 7pm T+2 T+4weeks T+4 weeks (Aggregated) 37

38 Post-trade transparency deferrals Application in practice Local jurisdiction applies, based on which counterparty is responsible for trade reporting Trades with subsidiaries would be under local regulator jurisdiction (separate LEI) NOTE - Not clear which jurisdiction branches fall under, but ESMA view that deferral regime relates to branches Trades executed outside, but reported to, Trading Venues, are considered on venue and follow TV jurisdiction rules Jurisdiction Proposed application UK Maximum deferral regime Germany, France Rumoured to follow UK Sweden All information disseminated T+2 (19:00) 4weeks-alternative MAY be used, but unclear when Denmark Same as Sweden, but no deferral for illiquid bonds Current Danish mortgage bond reporting model to continue 38

39 Negotiated ( Process ) Trades Process trades are negotiated off-venue (ie. bilateral) trades, concluded on venue Most MTFs/OTFs developing a non-equity negotiated trade trade workflow Benefits: - TV responsible for trade reporting trades outside SI regime - TV s jurisdictional deferral rules apply - Satisfies Trading Obligation for IRS (bilateral trade concluded on TV) - Trades only done when booked in the Trading Venue (time stamps etc) Off venue discussion RFQ 1 (on venue) MTF/OTF Process Trade flag SEB (1) Negotiation CLIENT SEB CLIENT Member A Member B Member A Member B (2) Trade Booked

40 In practice: Market Structure MTF / OTF onboarding need to sign Rule book, submit national identifiers of traders Legal Entity Identifier (LEI) ensure you have a valid one Discretionary mandate LEI or National Persons ID (NPID) Review whether you will be caught by the Systematic Internaliser regime If relying on assisted reporting (rather than TV/SI), decide on which Approved Reporting Arrangement (APA) to use, and complete documentation 40

41 Reporting 41

42 Reporting Architecture Consolidated tape CTP Consolidated Tape Provider Consolidates all trade data and disseminate a consolidated feed CTP APA Approved Publication Arrangement Reports transactions done outside a trading venue ARM Approved Reporting Mechanisms MTF Multilateral Trading Facility Website APA OTF Organised Trading Facility (non-equity only) More flexible in members/rules setting than in an MTF Trading Venues RM MTF OTF SI OTC TR (EMIR) Trade repository Report all derivatives transactions in instruments admitted to trading on a Regulated Market (T+1) Investment Firm NCA National Competent Authority TR Transaction Reporting T+1 ARM NCA 42

43 Reporting Transaction Quotes Best Execution Commodities Post-trade transaction reporting obligations requires investment firms to send more information to regulators. Legal Entity Identifiers (LEI) and National Identifiers of natural persons become mandatory when reporting trade information. Systematic Internalisers (SIs), market-makers and liquidity providers are expected to publish the results of their quoting obligations on a quarterly basis. MiFID II requires investment firms to publish their top five execution venues on a quarterly basis. Information to be based on previous year trading volumes and should also cover quality of execution at each venue. To prevent market abuse in the commodities market, MiFID II investment firms will be required to report details of their commodity positions on a daily basis in order to ensure position limits for a given month are not exceeded. Information around transaction decision makers is also required. 43

44 Appendix Supplementary information 44

45 Systematic Internaliser - non-equity calculation (mandatory basis) Liquid bond Non-Liquid bond Frequent and systematic and Substantial Frequent and systematic and Substantial # of OTC (P) transactions > 2.5% in the Union and OTC (P) transactions once a week 25% of total amount traded (within IF) or 1% of the total amount traded in that bond OTC (P) transactions in a bond once a week 25% of total amount traded in that bond (within IF) or 1% of the total amount traded in that bond That bond executed in the Union P : own account executing client orders period = past 6 months total = venues + OTC Source : Delegated Acts 25 April 2016 NO MANDATORY SYSTEMATIC INTERNALISER UNTIL SEPTEMBER 2018 TRADE REPORTING MUST RELY ON VOLUNTEERS If an investment firm ( IF ) trades a bond on average once a week AND have a market share > 1% past 6 months => The IF will be deemed to be SI in all bonds in the same class of that issuer 45

46 Non-equity transparency: liquidity and size waivers/deferrals Transparency driven by definition of a) liquidity, and b) the applicable rule as below (i.e. full transparency applies only to liquid instruments, of trade size below the deferral regime) Liquidity definitions + Pre-trade obligation & deferral rules (assuming OTC trades) Bonds: ISIN level Per ISIN, 3 tests Ave daily amount >EUR 100,000 % days traded >80% Ave daily trade no:: 15 (S1 to July 2019) 10 (S2 to July 2020) 7 (S3 Jul 20-Jul 21) 2 (S4 after Jul 21) IRS: Trade type and maturity buckets (eg. fix/float 2 yr) Per Class Ave daily notional amount >EUR 50m Ave daily number of trades: >10 Pre-trade No disclosure for trades above SSTI SSTI percentiles, per asset class Pre-trade SSTI levels S1-30 th percentile S2-40 th percentile S3 50 th percentile S4 60 th percentile Post-trade deferral Above SSTI Fixed percentile Post-trade deferral Bonds: greater of 80 th trade percentile or EUR300k/200k IRS: greater of 80 th trade percentile,60 th volume percentile, or EUR 9m New issues: Corp/covered bonds: EUR 1 bn+ (S1-2), then EUR 500m+ 46

47 Liquidity determination for primary bonds (post-trade) For primary market bonds, Level 2 proposes an initial static determination based on a class of financial instrument approach (COFIA), defined purely by issuance size relative to a variety of sub classes of bonds. Govt bonds: Liquid = EUR 1 billion and larger Other public bonds: Covered bonds: stages S1/S2: Liquid = EUR 1 billion or larger Corporate bonds: stages S3/S4: Liquid = EUR 500 million or larger Once trading data is available, the liquidity determination will be based on a dynamic instrument IBIA methodology, applying a quarterly assessment of quantitative liquidity criteria. The time before this happens depends when issue occurs: Primary issue Primary issue Reset (IBIA) here Reset (IBIA) here Primary issue January February March April May June Schuldscheine with maturity over 1 year not financial instruments, so outside of scope of MiFID (as long as not auction/bidding) 47

48 Non-equity liquidity and SSTI in practice 3 July 2017 Interim Transparency Calculations published by ESMA, for all non-equity instruments 11 Sept 2017 Interim Transparency Calculations for bonds Liquidity assessment of individual bonds published 1 Dec 2017 Corporate Eurobonds very few in corporate issues (15?) in 2017 Liquid German bond issues: Less than 1% ( 3 out of 418) of corps would be deemed to be liquid Roughly 20% of sovereign ( 43 out of 210) Source: TRAX Markets 48

49 Non-equity size-based waivers/deferrals FX Derivatives considered not having a liquid market Interest Rate Swaps only 3 EUR IRS, and 1 USD IRS Asset class Sub-asset class Currency Time to maturity bucket SSTI pretrade (EUR) LIS pre-trade (EUR) SSTI posttrade (EUR) LIS post-trade (EUR) Interest rate derivatives Fixed-to-Float single currency swap EUR TTM_4Y_5Y Interest rate derivatives Fixed-to-Float single currency swap EUR TTM_5Y_6Y Interest rate derivatives Fixed-to-Float single currency swap USD TTM_5Y_6Y Interest rate derivatives Fixed-to-Float single currency swap EUR TTM_9Y_10Y No pre-trade transparency for EUR IRS trades above 20m in size (estimated only 20% of trades done) But, post-trade transparency within 15 minutes for many EUR IRS trades (published by APAs) Credit Derivatives 2 indices Sub-asset class Underlying index Currency Time to maturity bucket SSTI pre-trade LIS pre-trade SSTI post-trade LIS post-trade Index credit default swap (CDS) ITRAXX EUROPE 5Y EUR TTM_4Y_5Y Index credit default swap (CDS) ITRAXX EUROPE CROSSOVER 5Y EUR TTM_4Y_5Y

50 FX post-trade reporting deferrals 50

51 Non-equity size-based waivers/deferrals - bonds Asset class Bond Type SSTI pre-trade LIS pre-trade SSTI post-trade LIS post-trade Bonds (all bond types except ETCs and ETNs) Corporate Bond Bonds (all bond types except ETCs and ETNs) Convertible Bond Bonds (all bond types except ETCs and ETNs) Public Bond Bonds (all bond types except ETCs and ETNs) Covered Bond Bonds (all bond types except ETCs and ETNs) Sovereign Bond Bonds (all bond types except ETCs and ETNs) Other SSTI applies to RFQ systems, LIS applies to MTFs/OTFs Pre-trade: SSTI: 30 th percentile; LIS : 70 th percentile Post-trade: SSTI: 80 th percentile; LIS: 90 th percentile The process trade (whereby a trade is executed bilaterally ie off-venue, but concluded in an MTF i.e. on-venue, thus getting the MTF s deferral regime) will be more difficult, given the relatively larger LIS 51

52 Please contact us at: Linda Jansson Risk & Regulatory SEB Large Corporates & Financial Institutions SE Stockholm Office Address: Kungsträdgårdsgatan 8 Phone: Switchboard: Phone: linda.jansson@seb.se David Eley Head of Markets Regulatory Strategy SEB Large Corporates & Financial Institutions SE Stockholm Office Address: Kungsträdgårdsgatan 8 Phone: Switchboard: Phone: david.eley@seb.co.uk Christer Wennberg Markets Regulatory Strategy - Equities SEB Large Corporates & Financial Institutions SE Stockholm Office Address: Kungsträdgårdsgatan 8 Phone: Switchboard: Phone: christer.wennerberg@seb.se 52