Association of Global Custodians - Comment Letters

AIFMD Press Communications

· Letter to The Financial Times from Ranjit Chatterji, Chair, Association of Global Custodians (AGC), regarding AIFMD will transfer undue risk to custodian banks, April 4, 2012

Clearing & Settlement

· Letter to Kathleen Holemans (Euroclear Bank) and Russell Callaway (Clearstream Banking), regarding ISMAG, March 21, 2012

· Letter to Pierre Francotte (Euroclear S.A.) and Jeff Tessler (Clearstream) regarding ICSD Payment Reversals, October 20, 2009

· Letter to the European Central Bank, regarding the Initial Public Consultation, 1 September 2008, on the Eurosystem Single Interface ("ESI"), November 26, 2008

· Letter to Jean-Michel Godeffroy, Director General, Payment Systems and Market Infrastructure, European Central Bank ("ECB"), regarding ECB's Public Consultation Papers on T2S User Requirements and the T2S Economic Impact, April 1, 2008

· Letter to Dr. Luis Correia da Silva, Oxera Consulting, Ltd., conveying the Association's Views regarding Oxera's Methodology and Assumptions on the Industry-Wide Public Initiative Undertaken for the European Commission, January 28, 2008

· Letter to Jean-Michel Godeffroy, Director General, Payment Systems and Market Infrastructure, European Central Bank, June 26, 2007

· Letter to Mr. Mario Nava, European Commission, regarding Comments on the Code of Conduct for Clearing and Settlement, December 14, 2006

· Letter to Mr. Mario Nava, European Commission, regarding Comments on the Draft Document on Post-Trading, September 22, 2006

· Letter to Mr. Mario Nava, European Commission, regarding Comments on the Draft Working Document on Post-Trading, June 30, 2006

· Letter to DG Competition, regarding Comments on the May 25, 2006 Consultative Paper, "Competition in EU Securities Trading and Post-Trading", June 30, 2006

· Letter to Commissioner Charles McCreevy, Member of the European Commission, regarding Association Views Regarding Cross-Border Clearing and Settlement in Europe and the Commission's Regulatory and Legislative Assessment, March 31, 2006

· Letter to Jean -Michel Godeffroy, Director General, Payment Systems, European Central Bank and Eddy Wymeersch, Chairman, Banking and Finance Commission, regarding: Public Statement -- Follow-up Work by the ESCB/CESR Joint Working Group, September 13, 2005

· Letter to DG MARKT24 G4, European Commission, regarding: Comments on Shareholder Rights Consultation Document of the Services of the Internal Market Directorate General, December 16, 2004

· Letter to DG Competition, European Commission, regarding: Comment on "Overview of EU25 securities trading, clearing, central counterparties, and securities settlement.", November 22, 2004

· Letter to DG MARKT G1, European Commission, regarding: Communication from the Commission to the Council and the European Parliament - Clearing and Settlement in the European Union - the way forward, July 29, 2004

· Letter to Jean-Michel Godeffroy, Director General, European Central Bank, regarding: Revised ESCB-CESR Standards for Securities Clearing and Settlement in the European Union, June 21, 2004

· Letter to Arthur Docters van Leeuwen, Chairman, Committee of European Securities Regulators, regarding: Additional Time Needed to Develop Commentary and Presentations Regarding the Revised Standards for Clearing and Settlement Systems in the European Union, May 17, 2004

· Letter to Jean -Michel Godeffroy, Director General, Payment Systems, European Central Bank and Eddy Wymeersch, Chairman, Banking and Finance Commission, regarding: Fair Opportunity to Prepare Commentary and Organize Presentations in Connection with the Issuance of Revised Standards or the Scheduling of Consultative Hearings, April 16, 2004

· Letter to Jean-Michel Godeffroy, Director General, Payment Systems, European Central Bank, regarding: Association Views on the ESCB-CESR Standards -- Standards for Securities Clearing and Settlement Systems in the European Union, February 23, 2004

· Letter to Frits Bolkestein, European Commissioner for Internal Market, Regarding Anticipated Commission Communication Regarding Clearing and Settlement Issues -- Standards for Securities Clearing and Settlement Systems in the European Union, February 17, 2004

· Letter to Elias Kazarian, Secretariat, European Central Bank, regarding: Executive Summary and Chart summarizing Association comments to ESCB-CESR -- Standards for Securities Clearing and Settlement Systems in the European Union, November 19, 2003

· Letter to Jean-Michel Godeffroy, European Central Bank, and Eddy Wymeersch, Banking and Finance Commission, regarding: Comment on the Standards Report and Scope Statement -- Standards for Securities Clearing and Settlement Systems in the European Union, October 31, 2003

· Letter to Jean-Michel Godeffroy, European Central Bank, and Eddy Wymeersch, Banking and Finance Commission, regarding: Request for Comment on Consultative Report -- Standards for Securities Clearing and Settlement Systems in the European Union, October 1, 2003

· Letter to DG MARKT F2, European Commission, regarding: Communication From the Commission to the Council and the European Parliament on Clearing and Settlement in the European Union, October 1, 2002

· Letter to Christoph Crüwell, Secretariat, Committee of European Securities Regulators and Elias Kazarian, European Central Bank, regarding: Joint Work of the European System of Central Banks and the Committee of European Securities Regulators in the Field of Clearing and Settlement, May 23, 2002

Commission

· Letter to Maria Teresa FABREGAS FERNANDEZ, European Commission, regarding European Commission's MiFID II/MiFIR Proposals, October 12, 2012

· Letter to Jonathan Faull, European Commission, regarding the European Commission's letter of May 30th to the Association - AIFMD Level 2 Issues, June 25, 2012. The AGC's reply letter and the underlying, referenced communication from Jonathan Faull were elements in a series of communications between the AGC and European Commission officials concerning AIFMD L2

· Letter to Martin Foelsch, Permanent Representation of Germany to the European Union, regarding Commission Proposal for a Directive amending Directive 97/9/EC of the European Parliament and of the Council on Investor Compensation Schemes, April 7, 2011

· Letter to Patrick Pearson, European Commission, regarding Public Consultation - Central Securities Depositories and the Harmonization of Certain Aspects of Securities Settlement in the European Union, March 7, 2011

· Response to Consultation Paper on the UCITS Depositary Function and on the UCITS Managers' Remuneration, January 31, 2011

· Response to the European Commission Consultation - Legislation on Legal Certainty of Securities Holding and Dispositions, January 21, 2011

· Letter to the European Commission Services - DG Market, regarding Commission Services (DG MARKT) Consultation Paper on the UCITS Depositary Function, September 2, 2009

Cross Border Voting

· Letter to Corinne van Ginkel, Ministry of Justice, The Hague, regarding: Consultative Document on Cross-Border Voting in Europe, June 12, 2002

European Insurance and Occupational Pensions Authority

· Response of the AGC to the European Insurance and Occupational Pensions Authority, January 2, 2012

European Securities and Markets Authority

· Letter to European Commission and ESMA, regarding UCITS V, AIFMD and CSD Regulation: Treatment of Central Securities Depositories, April 4, 2016

· Letter to Richard Stobo, The European Securities and Markets Authority, regarding AIFMD Implementation Issues, April 26, 2013

· Letter to The European Securities and Markets Authority, regarding Association Comments on ESMA's Consultation paper, "Draft technical advice to the European Commission on possible implementing measures of the Alternative Investment Fund Managers Directive in relation to supervision and third countries", 23 August 2011 - ESMA 2011/270, September 23, 2011

· Letter to The European Securities and Markets Authority, regarding Association Comments on ESMA's Consultation paper, "Draft technical advice to the European Commission on possible implementing measures of the Alternative Investment Fund Managers Directive", 13 July 2011 - ESMA 2011/209, September 12, 2011

· Letter to Richard Stobo, The European Securities and Markets Authority, regarding CESR Call for Evidence Concerning Implementing Measures on the Alternative Investment Fund Managers Directive ("AIFMD"), January 14, 2011

Offshore Fund Processing

· Letter to the German Federal Ministry of Finance, regarding: German Investment Statute Consultation Proceeding - Comments Directed to Matters Affecting Custodian/Depotbank Duties in Servicing Hedge Funds, Funds of Hedge Funds and Real Estate Funds, June 30, 2005

· Letter to Gary Palmer, Chief Executive, Dublin Funds Industry Association, regarding: Regulatory Issues in Connection with Custodian/Trustee Supervision of Third Parties In Hedge Funds and Funds of Hedge Funds Context, August 19, 2004

Parliament and Council

· Letter to Dr. Kay Swinburne, Member of the European Parliament, Parlement européen, regarding Proposal for a Regulation on Improving Securities Settlement in the EU and on CSDs, June 27, 2012

· Letter to Jean-Paul Gauzes, Member of the European Parliament/Rapporteur, Dolores Duran Bono, Office of the European Council President and Ugo Bassi, European Commission, regarding Custodians' Continuing Concerns about Draft AIFMD Provisions, February 19, 2010

· Letter to Frederick Reinfeldt, President of the European Council, regarding Proposed Re-draft of Article 17 - Alternative Investment Fund Managers Directive, December 2, 2009

· Letter to Frederick Reinfeldt, Prime Minister of Sweden, President of the European Council, regarding Proposal for a Directive of the European Parliament and of the Council on Alternative Investment Fund Managers [2009/0064(COD)]; Provisions on Depositaries, July 3, 2009

Transparency Directive

· Letter to Peter W. Skinner, Member of European Parliament, regarding: Draft European Union Transparency Directive, October 8, 2003

· Letter to Klaus-Heiner Lehne and Peter W. Skinner, Members of European Parliament, regarding: Draft European Union Transparency Directive, July 11, 2003

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