The Eurosystem’s Corporate Sector Purchase Programme ... Eurosystem's... · 4 The Eurosystem’s...

© Allen & Overy LLP 2016

The Eurosystem’s Corporate

Sector Purchase Programme

(CSPP) – opportunities for non-financial

corporates and beyond

June 2016

2 The Eurosystem’s Corporate Sector Purchase Programme (CSPP) – opportunities for non-financial corporates and beyond | 2016


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Contents

Introducing the CSPP and our offering 4

CSPP’s Market Segments and A&O’s presence 5

CSPP – Structure and the rules 6

Our key contacts 11

About Allen & Overy 15



Introducing the CSPP and our offering The complexity of financial market rulemaking, supervision and unprecedented monetary policy activity conducted across

the Eurozone has increased dramatically since the 2008 financial crisis. This includes targeted monetary policy action by

the European Central Bank (ECB) together with the individual Eurozone National Central Banks in the Eurosystem

operating asset purchase programmes across various sectors as part of their monetary policy transmission into the

Eurozone’s ‘real economy’. On 8 June 2016, the Eurosystem’s Corporate Sector Purchase Programme (the CSPP)

commenced operation and began buying euro denominated investment grade bonds provided they meet the eligibility

criteria of the CSPP. The CSPP is a decentralised purchase programme, coordinated by the ECB, with purchases

executed by six Eurozone national central banks (CSPP NCBs) covering specific market segments in both the

primary and secondary debt capital markets, as described on the next page. The ECB has announced that

disclosure of CSPP holdings and the availability to engage in securities lending transactions in respect of those

holdings is scheduled to commence on 18 July 2016. The following provides an overview of the CSPP and the areas

where our ‘ECB CSPP Interest Group’ composed of specialist lawyers can assist.

The scope of assets that are eligible for purchase as part of the CSPP is set out in an ECB Decision, i.e. a binding legal act,

dated 1 June 2016. This is further supplemented by various non-binding but scene-setting ‘CSPP Q&A’ documents as well

as the binding rules and ‘eligibility criteria’ set out in the Eurosystem’s General Documentation which is used for ECB

and Eurosystem collateral operations. Together, these various documents form the ‘CSPP Eligibility Criteria’.

The launch of the CSPP should however, as with other purchase programmes, also be assessed within the wider context

of the new post-crisis Eurozone supervisory environment that impacts banking and capital markets more generally.

This includes various continuing integration efforts such as the Banking Union comprising the ECB-led Single

Supervisory Mechanism (SSM) and the Brussels-based Single Resolution Mechanism (SRM), the Single Rulebook

upon which Banking Union rests, as well as the EU’s ongoing work to complete the EU’s Single Market through its

Capital Markets Union project (CMU) which started in September 2015.

A&O’s ECB CSPP Interest Group is a specialised team made up of lawyers from our debt capital markets (DCM)

practice and our regulatory lawyers focusing on ECB supervisory and monetary policy matters. Our ECB CSPP

Interest Group operates on a multi-jurisdictional and cross-functional basis, bringing together local market insight from

each of our Eurozone and other key global offices. Our ECB CSPP Interest Group is further supported by our

‘Global Markets Group’ which covers and cooperates with local counsel firms in jurisdictions in which Allen & Overy

is not currently based. Specifically, the ECB CSPP Interest Group assists clients in navigating this new complex

environment and seizing opportunities for sell-side and buy-side clients in relation to transactional and regulatory

matters connected with:

New issuances: of financial instruments that

comply with the ECB’s General Documentation;

CSPP Eligibility Criteria compliance: of issuance

and transaction structures in the primary and

secondary markets with the CSPP Eligibility

Criteria including assistance in relation to any

Eurosystem disclosure, reporting or confirmation

requests as well as assistance with CSPP templates

or otherwise;

Purchases and sales: of individual and portfolios

of holdings and related legal and regulatory

due diligence;

Refinancing, restructuring and repacking

transactions: to meet eligibility criteria or Banking

Union specific rules;

Other ECB or Eurosystem monetary policy:

driven purchase programmes or collateral operations

including use of a range of Eurosystem compatible

collateral mobilisation channels;

Structuring and bringing prudential or

loss-absorbency capital instruments to markets:

as well as any entity-optimisation work driven by

legal and regulatory rules; and

Regulatory driven portfolio optimisation: helping

with impact assessments from a prudential capital

or liquidity perspective and proposing efficient

legal structures.

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CSPP’s Market Segments and

A&O’s presence A&O’s ECB CSPP Interest Group has been active in all of the markets in which the CSPP is active. With our monetary

policy and Banking Union regulatory lawyers we have a wealth of experience in coordinating engagement with ECB as

well as the various CSPP NCBs, each of which may have additional CSPP-specific preferences.

CSPP NCBs conducting

purchases

Responsible for market segment in terms

of purchases

ECB CSPP Interest Group

capability on the ground

Belgium:

National Bank of Belgium

– Belgium

– Luxembourg

– Netherlands (with the Netherlands as a

residence country and a country of risk

other than Germany, Spain, Italy)

– Slovakia

– A&O offices in Brussels and

Antwerp

– A&O offices in Luxembourg, the

Netherlands and Slovakia

– Cyprus

– Greece

– Malta

– Portugal

– Slovenia

– Global Markets Group coverage

and transactional expertise

Germany:

Bundesbank

– Germany


residence country and Germany as

country of risk)

– A&O offices in Frankfurt,

Düsseldorf, Munich

and Hamburg

– A&O office in the Netherlands

Spain:

Banco de España

– Spain


residence country and Spain as a country

of risk)

– A&O offices in Madrid and

Barcelona


Finland:

Suomen Pankki

– Austria

– Estonia

– Finland

– Ireland

– Latvia

– Lithuania

– Global Markets Group coverage

and transactional expertise

France:

Banque de France

– France – A&O office in Paris

Italy:

Banca d’Italia

– Italy


residence country and Italy as a country

of risk)

– A&O offices in Milan and Rome




CSPP – Structure and the rules The CSPP commenced operations across the Eurozone

on 8 June 2016. The CSPP is the newest addition to the

ECB-led expanded asset purchase programme (APP)1

i.e., “quantitative easing” including through

decentralised purchases conducted by Eurosystem2

national central banks. The ECB describes the APP and

the CSPP as “dynamic and subject to change depending

on the impact against its additional monetary policy

objectives to facilitate stimulus and growth transmission

into the ‘real economy’ of the euro area”

(the Eurozone). The CSPP does not require eligible

bonds to have a minimum yield or minimum issuance

volume or to be eligible for purchase. This means that

even small issuance volumes or those with a negative

yield to maturity are eligible for purchase. Purchases of

nominal marketable debt instruments at negative yield to

maturity or (yield to worst) above the deposit facility

rate are permissible.

Purchases will be conducted in the primary market

(subject to restrictions), in the secondary market and,

where desirable and relevant, following experience on

other Eurosystem APP programmes, through block

trades and other private transactions. Disclosure of CSPP

holdings that have been purchased will be made publicly

available on a weekly basis, without revealing holding

sizes, from 18 July 2016 and updated every Monday

thereafter. This periodic publication will assist in the

disclosure of which CSPP holdings are available for

securities lending activity, which also starts on 18 July

2016.

CSPP – OVERVIEW OF ITS STRUCTURE

AND RULES

The CSPP is built around the ECB coordinating

decentralised purchases that are conducted by six

Eurosystem constituent national central banks

(CSPP NCBs). Additional Eurosystem National

Central Banks might be added to the initial list of CSPP

NCBs as the programme evolves. The CSPP will

initially target purchases:

1 See: http://www.ecb.europa.eu/mopo/implement/omt/html/index.en.html 2 A reference to the Eurosystem refers to the ECB and the national central

banks of the Eurozone Member States.

of investment grade rated debt instruments issued in

euro (EUR) that meet Eurosystem and CSPP

specific eligibility criteria (CSPP Eligible Bonds);

issued by Eurozone domiciled issuing entities of

non-financial corporates (NFCs) or by other eligible

financial market participants that are not regulated

as a ‘credit institution’3 and which meet Eurosystem

eligibility criteria (CSPP Eligible Issuers); and

of CSPP Eligible Bonds that may be guaranteed by

guarantors based in the EEA.

The framework of rules determining the eligibility of

CSPP Eligible Bonds and the running of the CSPP

are composed of the Eurosystem’s eligibility criteria,

as set out in its General Documentation, as modified

by the following components of what then forms the

CSPP Eligibility Criteria:

a) An ECB Decision published on 3 June 2016 is

available at:

http://www.ecb.europa.eu/ecb/legal/pdf/celex_3201

6d0016_en_txt.pdf setting out the broad strokes of

how governance of the CSPP is run and how the

General Documentation is applied in terms of CSPP

Eligibility Criteria (the CSPP Act);

b) ECB/Eurosystem non-public rules setting out

internal procedures, processes and controls, any due

diligence, pre-trade operations and decision-making,

including obtaining quotes, pricing/risk appetites,

execution parameters and post-trade operation of the

CSPP (the CSPP Guideline); as supplemented by:

a) any ad-hoc public or non-public directions; and

b) any ECB and/or CSPP NCB specific

preferences.

Together this framework comprises what can be termed

the CSPP Eligibility Criteria that both CSPP Eligible

Bonds and CSPP Eligible Issuers will need to observe

and comply with. These CSPP Eligibility Criteria are

relevant to CSPP purchases in both the primary and

secondary markets.

3 As defined in Regulation 575/2013 also known as CRR or the Capital

Requirements Regulation.

http://www.ecb.europa.eu/mopo/implement/omt/html/index.en.html

http://www.ecb.europa.eu/ecb/legal/pdf/celex_32016d0016_en_txt.pdf

http://www.ecb.europa.eu/ecb/legal/pdf/celex_32016d0016_en_txt.pdf

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CSPP – MARKET SEGMENTS FOR

PURCHASES AND ELIGIBILITY CHECKS

While the CSPP NCBs are responsible for purchases in

their assigned defined market segments, it is the

respective Eurosystem National Central Banks located in

the respective places of issuance of the CSPP Eligible

Bonds that check compliance with the Eurosystem’s

eligibility criteria and the CSPP Eligibility Criteria. The

CSPP NCBs conducting purchases will each be

responsible for specific market segments. The

Netherlands will be subject to ISO’s ‘country of risk’

concept, determined by management location, country of

primary listing, country of revenue and reporting

currency. The allocation of market segments is as set out

in the table on page 5. Consequently, an Irish-listed

CSPP Eligible Bond with its CSPP Eligible Issuer

domiciled in Belgium will have:

its Eurosystem eligibility criteria and CSPP

Eligibility Criteria check conducted by the Central

Bank of Ireland (also the listing authority)

regardless of primary market or secondary market

activity; and

purchase of such an Irish-issued CSPP Eligible

Bond would be conducted by the CSPP NCB

in Belgium.

We would remind market participants that Eurosystem

National Central Banks do not provide pre-structuring

advice or forward guidance in relation to satisfaction of

their eligibility criteria relating to Eurosystem ‘Open

Market Operations’ or for purchases conducted in the

APP. We would add a caveat that even where a debt

instrument may not end up meeting the CSPP Eligibility

Criteria, then, depending on issuance, transaction and

issuer specifics, other options do exist. Consequently, a

debt instrument that is not purchased under the CSPP

might still be eligible for mobilisation using any number

of other collateral channels acceptable to the Eurosystem

or could be included in any number of structuring

options on other Eurosystem programmes and APP

activity.

DRILLING DOWN THE DETAILS FURTHER ON

CSPP ELIGIBLE BONDS AND CSPP ELIGIBLE

ISSUERS

CSPP Eligible Bonds must satisfy all of the following

criteria:

they are eligible as collateral for Eurosystem credit

operations, based on the requirements defined in the

Guideline on the implementation of the Eurosystem

monetary policy framework (ECB/2014/60) (a.k.a

the General Documentation);

they are denominated in EUR;

they have a minimum first-best credit assessment of

at least credit quality step 3 (rating of BBB- or

equivalent) i.e. have at least an ‘investment grade’

rating obtained from an external credit assessment

institution as set out in the General Documentation;

their minimum remaining maturity is at least

six months and their maximum remaining maturity

is no more than 30 years and 364 days at the time

of purchase;

they are non-subordinated issuances;

they are issued by a CSPP Eligible Issuer, i.e.:

− the issuer is incorporated in the Eurozone.

NB:CSPP Eligible Bonds issued by

corporations incorporated in the Eurozone

whose ultimate parent is not based in the

Eurozone are also eligible for purchase under

the CSPP, provided they satisfy all the other

relevant CSPP Eligibility Criteria;

− the issuer of the CSPP Eligible Bond:

− is not a credit institution4;

− is not a ‘supervised entity’ or a member of

a ‘supervised group’, or a subsidiary of a

supervised entity or a supervised group –

each as such terms are defined in the SSM

Framework Regulation5;

− does not have a parent undertaking

(as defined in Article 4(15) of the Capital

Requirements Regulation) that is also a

credit institution (as defined in Article 2

(14) of the General Documentation);

4 As such term is defined in the General Documentation and in the CRR. 5 See: http://www.ecb.europa.eu/ecb/legal/pdf/celex_32014r0468_en_txt.pdf

http://www.ecb.europa.eu/ecb/legal/pdf/celex_32014r0468_en_txt.pdf



− does not have a parent company which is

subject to ‘banking supervision’

(undefined term) outside the Eurozone;

− is not an ‘investment firm’ as defined in

MiFID II6;

− is not a ‘bad bank’ i.e., an asset management

vehicle (as defined in the Bank Recovery and

Resolution Directive and Single Resolution

Mechanism Regulation) or a national asset

management and divestment fund established

to support financial sector restructuring

and/or resolution;

− is not an eligible issuer within the remit of the

ECB-led Public Sector Purchase Programme;

the issuer of the CSPP Eligible Bond has not issued

any of the following instruments, as defined in the

Eurosystem’s Eligibility Criteria:

− an asset-backed security;

− a multi cédula7; or

− a structured covered bond.

Reference to the term ‘corporation’ and how it is used

in the General Documentation includes a wide range

of corporate vehicle types. It should also be noted that

the limits imposed on a CSPP Eligible Issuer in respect

of issuance of other financial instruments would not

necessarily apply to affiliated entities.

CSPP – PURCHASES LIKELY TO BE DRIVEN

BY EUROSYSTEM MONETARY POLICY

OBJECTIVES TO DELIVER STIMULUS TO THE

EUROZONE’S REAL ECONOMY

Whilst the CSPP does not seem to have any hard and

fast rules as to which CSPP Eligible Bonds in the

universe of eligible assets might be viewed more

favourably in comparison to their peers this is likely to

change as deal structures change to meet the CSPP

Eligibility Criteria. Equally, the purchasing behaviour of

the CSPP NCBs in certain sectors and ratings buckets is

6 See: http://eur-lex.europa.eu/legal-

content/EN/TXT/PDF/?uri=CELEX:32014L0065&from=EN which

sets out that: “ ‘investment firm’ means any legal person whose regular

occupation or business is the provision of one or more investment

services to third parties and/or the performance of one or more investment

activities on a professional basis.” It should be noted that the term

‘investment services’ in this context means those services and activities

listed in Section A of Annex I i.e. MiFID Investment Services relating

to any of the instruments listed in Section C of Annex I i.e. MiFID

financial instruments. 7 Debt instruments issued by specific Spanish SPVs enabling a certain

number of small-sized single Spanish covered bonds to be pooled together.

likely to evolve as the CSPP develops and priorities of

how to direct monetary policy through the APP changes.

It should be noted that the CSPP has comparably lower

due diligence requirements than the ECB-led asset-

backed securities purchase programme (ABSPP)

component of the Eurosystem’s APP. That being said,

the CSPP NCBs undertaking the purchases are likely to

consider how a particular issuance fits within the

Eurosystem’s monetary policy objectives. The CSPP

will be subject to full income and loss sharing in the

Eurosystem and thus follow other APP activities and

governance arrangements which includes periodic

reviews of governance and efficacy of the programme.

Therefore, based on the purchasing activity on other

APP programmes, both in the Eurozone periphery and

core jurisdictions, there are some common features that

CSPP NCBs might look at when assessing whether to

purchase a specific CSPP Eligible Bond issuance in the

primary or secondary market. This includes whether the

proposed purchase of the CSPP Eligible Bond:

is in relation to a country and/or industry sector that

is relevant to the Eurosystem’s monetary policy

objective of driving stimulus to the ‘real economy’.

We anticipate that to a certain extent, including as

the CSPP evolves, this might involve an increased

preference for certain CSPP Eligible Issuers (even if

quoting specific issuer names, bonds or notional

amounts may be discouraged when engaging with

the CSPP NCBs) and consideration of the issuances

listed use of proceeds as set out in the offering

documentation. Given the monetary policy aims of

the CSPP it might be conceivable that consideration

is given as to whether use of proceeds are used for

any capital expenditure commitment or dedicated

growth financing;

would help tighten spreads and financing conditions

generally or for peers without distorting

competition; and

is in keeping with the risk appetites and credit risk

performance of peers and/or overall

exposure/concentration in a given sector.

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014L0065&from=EN

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014L0065&from=EN

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It should also be noted that even where a CSPP Eligible

Bond might not be purchased by a CSPP NCB in a given

primary market issuance, this does not preclude any

number of purchases of such CSPP Eligible Bond in the

secondary market. Equally, even where a purchase is not

conducted in respect of one issuance of a CSPP Eligible

Issuer in a given period of time, this does not preclude

purchases of other CSPP Eligible Bonds from the same

or an affiliated issuer at a later date.

CSPP – PURCHASE LIMITS AND

CONCENTRATION EXPOSURE

The CSPP, in keeping with other Eurosystem APP

activity, is intended to be dynamic and not designed to

send signals of forward guidance. However, in

connection the start of the CSPP the following

indications on purchase and concentration limits have

been communicated as follows:

purchases are expected to be limited per ISIN to

70% of outstanding amounts subject to an issuer-

group-level benchmark and lower limits for

essentially government-backed entities variously

referred to as ‘public undertakings’, ‘public sector’

or ’public sector corporate bonds’, which are

generally any entity over which a state or other

regional or local authority directly or indirectly

exercises a dominant influence; and

− public undertakings will also be excluded from

primary market purchases due to the Eurosystem’s

general prohibition on monetary financing.

CSPP’S EFFECT ON THE EUROZONE CREDIT

MARKET TO DATE

At launch, it was reported that CSPP NCBs were

particularly interested in CSPP Eligible Bonds from the

utilities, auto, telecommunications, industrials and

consumer goods sectors. Prior to launch of the CSPP,

market and issuance activity between March and

June 2016 was quite buoyant, in particular since the

April 2016 announcements confirmed that CSPP

Eligible Bonds could be issued by CSPP Eligible Issuers

that are “financial corporations other than credit

institutions”. This provision opens up the universe of

CSPP Eligible Issuers and the scope of CSPP Eligible

Bonds considerably to a wider range of market

participants and not just non-financial corporates.

Furthermore, the clarifications from the ECB that CSPP

Eligible Issuers may have non-Eurozone parent entities,

provided the other CSPP Eligibility Criteria are met, has

increased the attraction and potential impact of the CSPP

further.

The clarifications from the ECB prior to the CSPP

launch and publication of the CSPP Act may also over

the longer-term encourage and assist a range of

regulatory driven portfolio reallocation opportunities.

This might also include greater opportunities for

those market participants caught by Solvency II

prudential capital requirements. More generally, these

clarifications in the lead up to launch and the final rules

in the form of the CSPP Eligibility Criteria might assist

certain investors looking to reposition their investment

capital allocation away from debt instruments into

equity holdings.

We would also draw attention to the fact that the criteria

on CSPP Eligible Issuers excludes credit institutions,

third-country banks and investment firms, each as

defined in MiFID II (legislation that is only to come into

full force in 2018) and thus the scope of CSPP Eligible

Issuers could still include a range of regulated and

unregulated fund entities and the bulk of the insurance

community. It remains to be seen whether any CSPP

Eligible Bonds would be purchased by the CSPP NCBs

from these types of issuers. The same is true in relation

to CSPP Eligible Issuers with non-EEA parent

companies. Much will likely depend on the substance

of the business and consideration of whether the use of

proceeds of any CSPP Eligible Bond with an ultimate

non-EEA parent would stimulate growth in the

Eurozone or achieve any of the other monetary

policy aims of the ECB.

As the CSPP evolves, further changes are likely to be

made, possibly after the first six to nine months of

operation when one might expect minor amendments to

fine-tune the CSPP Act. Any further operational

modalities in relation to how transactions are executed,

including block trades, pricing preferences and any

preferences on ‘standardised features’ of the CSPP

NCBs or the ECB expectations in relation to CSPP

Eligible Bonds or any assessment of the impact of the

CSPP on the ‘real economy’ are likely to be included in

the CSPP Guideline. CSPP, however, also, as in other



APP operations, fits in with the wider regulatory reform

and market integration efforts of the EU.

CSPP AS PART OF THE WIDER EU

REGULATORY REFORM PICTURE

Coinciding with the ECB’s announcement on the CSPP

in April 2016, Lord Hill, who at the time was the EU

Commissioner responsible for the European

Commission’s Directorate General on Financial

Stability, Financial Services and Capital Markets Union

(DG-FISMA), announced a ‘comprehensive review’8 of

liquidity in corporate bond markets. Ensuring that bond

markets are resilient, functioning and more integrated is

a priority of the EU’s delivery of its Capital Markets

Union (CMU) project. The announced comprehensive

review, which follows on from previous CMU-related

industry consultation, will involve input from market

participants as well as from the European Banking

Authority (EBA) and European Securities and Markets

Authority (ESMA). Each of those institutions are

responsible for rulemaking on liquidity calibrations and

implementation of capital requirements measures.

It remains to be seen to what extent liability-driven

investors, non-financial corporates and any associations

of corporate treasurers will be able to direct debate in

this area and more generally whether this

‘comprehensive review’ could be a first step to setting

parameters for an EU-wide legislative regime focusing

specifically on debt capital markets. In any event, the

CMU project and its workstreams are scheduled to be

assessed in a wider-reaching ‘comprehensive stocktake’

on progress and priorities during the course of 2017.

8 See: http://europa.eu/rapid/press-release_SPEECH-16-1527_en.htm

In any event, as with other ECB programmes, monetary

policy action delivered through the Eurosystem’s APP

activity assists the European Commission in advancing

CMU relevant legislative proposals to integrate markets.

In terms of the European debt capital markets, the CSPP,

the outcomes of the comprehensive review of liquidity in

corporate bond markets, might mark a first step to future

EU-led legislative action. An overriding priority in

CMU plans to date is to ensure European capital markets

become increasingly more integrated as part of

completing the EU’s Single Market and driving

Eurozone integration further, so that they over the

medium to longer-term have comparable levels of depth

and liquidity as their North American counterparts.

Whilst on the one hand, this assists in creating a ‘level

playing field’, further changes in the shape and

supervision of business in capital markets also carries

with it horizon risks.

http://europa.eu/rapid/press-release_SPEECH-16-1527_en.htm

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Our key contacts Allen & Overy’s ECB CSPP Interest Group, composed of DCM and the ECB and Banking Union regulatory specialists

located across the Eurozone and other EU member states, supports internal legal counsel and their internal clients and

stakeholders by bringing together local-market insight from each its Eurozone offices and other key global offices with

specialist advice in relation to ECB and Eurosystem regulatory and monetary policy action. Please do get in contact with

any of the ECB CSPP Interest Group members below or any of the wider network with any queries you may have.

For general enquiries please email: [email protected]

Germany

Christoph Enderstein Partner Germany – Frankfurt Tel +49 69 2648 5890 Mob +49 172 6998092 [email protected]

Marc Plepelits Partner Germany – Frankfurt Tel +49 69 2648 5405 Mob +49 160 7810350 [email protected]

Kai Andreas Schaffelhuber Partner Germany – Frankfurt Tel +49 69 2648 5324 Mob +49 172 6226228 [email protected]

Matthew Howard Partner Germany – Frankfurt Tel +49 69 2648 5750 Mob +49 175 9329586 [email protected]

Dennis Kunschke Senior Associate Germany – Frankfurt Tel +49 69 2648 5895 Mob +49 1725733284 [email protected]

Michael Huertas Associate Germany – Frankfurt Tel +49 69 2648 5463 Mob +49 172 4794963 [email protected]

mailto:[email protected]



United Kingdom

Theo Trayhurn Partner

UK – London

Tel +44 20 3088 2913

Mob +44 7776 240 775 [email protected]

Jamie Durham Partner

UK – London

Tel +44 20 3088 3842


Tom Grant Partner

UK – London

Tel +44 20 3088 3604

Mob +44 7824 436495 [email protected]

Matthew Hartley Partner

UK – London

Tel +44 20 3088 2824


Jonathan Mellor Partner

UK – London

Tel +44 20 3088 2813 Mob +44 7767 674403

[email protected]

Jonathan Melton Partner

UK – London

Tel +44 20 3088 2463 Mob +44 7785 500833

[email protected]

Geoff Fuller Partner

UK – London

Tel +44 20 3088 2806 Mob +44 7785 500806

[email protected]

Philip Smith Partner

UK – London

Tel +44 20 3088 2765 Mob +44 7909 926297

[email protected]

Amanda Thomas Partner UK – London

Tel +44 20 3088 2821


Nicole Rhodes PSL Counsel UK – London

Tel +44 20 3088 4408


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Belgium Luxembourg

Sylvia Kierszenbaum Partner Belgium – Brussels and Antwerp

Tel +32 3 287 74 10

Mob +32 495 59 14 66 [email protected]

Frank Mausen Partner Luxembourg

Tel +352 44 445 5329


Henri Wagner Partner Luxembourg

Tel +352 44 44 5 5409


Netherlands

Gerard Kastelein Partner

Netherlands - Amsterdam

Tel +31 20 674 1371 Mob +31 620 138 547

[email protected]

Niels van de Vijver Partner

Netherlands - Amsterdam

Tel +31 20 674 1291 Mob +31 651 289 419

[email protected]

France

Diana Billik Partner France - Paris

Tel +33140065365

Mob +33620428027 [email protected]

Herve Ekue Partner France - Paris

Tel +33140065359


Dan Lauder Partner France - Paris

Tel +33140065339


Julien Sebastien Partner France - Paris

Tel +33140065351




Spain

Salvador Ruiz Bachs Partner

Spain - Madrid

Tel +34 91 782 99 23 Mob +34 616 620 831

[email protected]

Charles Poole-Warren Partner

Spain - Madrid

Tel +34 91 782 98 53 Mob +34 696 729 497

charles.poole-

[email protected]

Juan Hormaechea Partner

Spain - Madrid

Tel +34 91 782 9845 Mob +34 649 429 364

[email protected]

Italy

Craig Byrne Partner

Italy - Milan

Tel +39 02 2904 9671 Mob +39 335 593 0540

[email protected]

Lisa Curran Senior Counsel

Italy - Rome

Tel +39 06 6842 7537 Mob +39 335 7116210

[email protected]

Cristiano Tommasi Partner

Italy - Rome

Tel +39 06 6842 7583 Mob +39 335 7115503

[email protected]

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About Allen & Overy As a firm, we have been instrumental in nearly all the major developments in the modern financial markets, starting with

the first-ever eurobond issue in the 1960s. Of the most recent developments, we have a particular track record in liability

management, regulatory capital and capital raisings for financial institutions, debt issues by emerging markets issuers,

sovereign debt offerings and have been involved in numerous landmark transactions since the development of the offshore

RMB market. Our excellence is reflected through our top-tier position in all major legal directories, Thomson Reuters and

Bloomberg debt legal adviser league tables and numerous independent market surveys and awards.

We represent the breadth of market participants on all elements of the transaction lifecycle of debt securities, structured

finance and other financial instruments, including the range of securities financing transactions (repo, securities lending or

margin loan transactions), portfolio sales, block trades, derivatives work and regulatory reporting requirements that are

connected to such instruments. We are retained for both transactional and advisory matters and assist a range of clients,

from non-financial corporate issuers to financial institutions, including underwriters and investors, as well as market

infrastructure providers, in providing proactive and flexible solutions. In addition, we work extensively with national and

EU regulatory and supervisory authorities and are active in many industry associations.

“Allen & Overy is the only firm, of the 50 that appear in the

FT rankings, to have topped the list four times and to feature

in the top three every year since it began 10 years ago. A&O

came first in the rankings in 2014, 2012, 2011 and 2007.” FT INNOVATIVE LAWYERS


GLOBAL PRESENCE

Allen & Overy is an international legal practice with approximately 5,200 people, including some 530 partners, working in 44 offices

worldwide. Allen & Overy LLP or an affiliated undertaking has an office in each of:

Abu Dhabi Amsterdam

Antwerp

Bangkok Barcelona

Beijing

Belfast Bratislava

Brussels

Bucharest (associated office) Budapest

Casablanca

Doha Dubai

Düsseldorf

Frankfurt Hamburg

Hanoi

Ho Chi Minh City Hong Kong

Istanbul

Jakarta (associated office) Johannesburg

London

Luxembourg Madrid

Milan

Moscow Munich

New York

Paris Perth

Prague

Riyadh (cooperation office) Rome

São Paulo

Seoul Shanghai

Singapore

Sydney Tokyo

Warsaw

Washington, D.C. Yangon

Allen & Overy means Allen & Overy LLP and/or its affiliated undertakings. The term partner is used to refer to a member of Allen & Overy or an

employee or consultant with equivalent standing and qualifications or an individual with equivalent status in one of Allen & Overy LLP’s affiliated

undertakings. | FR:21698566.6

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