Recent Comment Letters
(January 1, 2022 - Present) 

The Association of Global Custodians has recently issued public commentary concerning regulatory and market structure issues that are of common interest to its members.
Key topics and the related comments are set forth below.

Depository Information-Gathering Project

• 2024-2025 Depository Information-Gathering Project: A Report for Clients and Participating Depositories, January 31, 2025

• 2023-2024 Depository Information-Gathering Project: A Report for Clients and Participating Depositories, January 31, 2024

• 2022-2023 Depository Information-Gathering Project: A Report for Clients and Participating Depositories, January 31, 2023

• 2021-2022 Depository Information-Gathering Project: A Report for Clients and Participating Depositories, January 31, 2022

 Middle East & Africa

Bahrain

• Letter to Bahrain Clear regarding Delivery-Versus-Payment Enhancement Initiative, January 19, 2022

• Letter to Bahrain Clear, Kuwait Clearing Company, Muscat Depository Company, Qatar Central Securities Depository and the Securities Depository Center Company regarding Simplification of Market Entry and Depository Account Opening Requirements, January 19, 2022

  Jordan

• Letter to the Securities Depository Center of Jordan regarding Simplification of Market Entry and Depository Account Opening Requirements, January 19, 2022

  Kuwait

• Letter to the Kuwait Clearing Company regarding Request for Review of Safekeeping and Transaction Fees, January 19, 2022

  Nigeria

• Letter to the Central Securities Clearing System Plc regarding Planned Implementation of T+1 Settlement Cycle for NGX Listed Equities, September 26, 2022

  Qatar

• Letter to the Qatar Central Securities Depository regarding Dual Account Structure Reform, January 19, 2022

Zimbabwe

• Letter to the Zimbabwe Stock Exchange regarding Minimum Notice Period in Event of Termination of Listing by Request of Issuer, November 28, 2022

Tax Issues

Denmark

• Letter to Danish Ministry of Taxation Requesting Guidance regarding Income Entitlement Rules, January 3, 2024

European Union Institutions

• AGC, EBF, and AFME Joint Letter to the European Commission regarding the EU’s FASTER Initiative, February 20, 2024

• Letter to the European Commission regarding European Commission proposal for a Council Directive on Faster and Safer Relief of Excess Withholding Taxes, September 18, 2023

• Letter to European Commission, regarding Follow-up to the September 28th Meeting and Survey on Withholding Tax Procedures, November 14, 2022

• Response to European Commission's Public Consultation on New EU System for the Avoidance of Double Taxation and Prevention of Tax Abuse in the Field of Withholding Taxes, June 24, 2022

Finland

• Letter to Finnish Ministry of Finance regarding Feedback on Consultation on the need to improve the TRACE model for dividend payments to nominee-registered shares, February 14, 2024

• Letter to Finnish Tax Administration regarding Feedback on Guidance for Investor Self Declarations, July 15, 2022

• Letter to Finnish Ministry of Finance and Finnish Tax Administration regarding Follow-up to February 11, 2022 Discussion of Finland's TRACE Regime, April 22, 2022

Germany

• Letter to Dr. Christian Schleithoff, Ministry of Finance, regarding Mandatory Electronic Submissions of German Tax Reclaims, December 20, 2022

IRS

• Letter to Internal Revenue Service and US Treasury Department regarding Application of Form 1099-DA to Tokenised Securities and Other Digital Initiatives, December 5, 2024

• Letter to Internal Revenue Service and US Treasury Department regarding Final Section 1446(f) Regulations, June 30, 2022