-
Summary
of Recommendations
(with important decisions for
hedge funds) from the paper "Financial Regulatory Reform: A New
Foundation" by the US Department of the Treasury
-
The five key objectives of the US
Financial Regulatory Reform
-
The new acronyms: "Tier 1 FHC"
(Tier 1 Financial Holding Company) and
“nonbank”
banks.
Welcome to the May 2010 edition of
our newsletter.
Last month we tried to understand what is next for
hedge funds in the European Union. This month we will study an
interesting proposal, the
"Financial Regulatory Reform: A New
Foundation" by the US Department of the Treasury, where we can
understand what is next for hedge funds in the United States of
America.
SUMMARY OF RECOMMENDATIONS
From the paper "Financial Regulatory Reform: A New
Foundation" by the US Department of the Treasury, we read:
I. PROMOTE ROBUST SUPERVISION
AND REGULATION OF FINANCIAL FIRMS
A.
Create a Financial Services Oversight Council
1. We propose the creation
of a Financial Services Oversight Council
to facilitate information sharing and coordination,
identify emerging risks, advise the Federal Reserve on the
identification of firms whose failure could pose a threat to
financial stability due to their combination of size, leverage,
and interconnectedness (hereafter referred to as a Tier 1 FHC),
and provide a forum for resolving jurisdictional disputes
between regulators.
a. The membership of the
Council should include
(i) the Secretary of the
Treasury, who shall serve as the Chairman;
(ii) the Chairman of the Board
of Governors of the Federal Reserve System;
(iii) the Director of the
National Bank Supervisor;
(iv) the Director of the
Consumer Financial Protection Agency;
(v) the Chairman of the SEC;
(vi) the Chairman of the CFTC;
(vii) the Chairman of the
FDIC; and
(viii) the Director of the
Federal Housing Finance Agency (FHFA).
b. The Council should be
supported by a permanent, full-time expert staff at Treasury.
The staff should be responsible for providing the Council with
the information and resources it needs to fulfill its
responsibilities.
2. Our legislation will
propose to give the Council the authority to gather information
from any financial firm and the responsibility for referring
emerging risks to the attention of regulators with the authority
to respond.
B.
Implement Heightened Consolidated Supervision and Regulation of
All Large, Interconnected Financial Firms
1. Any financial firm
whose combination of size, leverage, and interconnectedness
could pose a threat to financial stability if it failed (Tier 1
FHC) should be subject to robust consolidated supervision and
regulation, regardless of whether the firm owns an insured
depository institution.
2. The Federal Reserve
Board should have the authority and accountability for
consolidated supervision and regulation of Tier 1 FHCs.
3. Our legislation will
propose criteria that the Federal Reserve must consider in
identifying Tier 1 FHCs.
4. The prudential
standards for Tier 1 FHCs – including capital, liquidity and
risk management standards – should be stricter and more
conservative than those applicable to other financial firms to
account for the greater risks that their potential failure would
impose on the financial system.
5. Consolidated
supervision of a Tier 1 FHC should extend to the parent company
and to all of its subsidiaries – regulated and unregulated, U.S.
and foreign.
Functionally regulated and
depository institution subsidiaries of a Tier 1 FHC should
continue to be supervised and regulated primarily by their
functional or bank regulator, as the case may be.
The constraints that the
Gramm-Leach-Bliley Act (GLB Act) introduced on the Federal
Reserve’s ability to require reports from, examine, or impose
higher prudential requirements or more stringent activity
restrictions on the functionally
regulated or depository
institution subsidiaries of FHCs should be removed.
6. Consolidated
supervision of a Tier 1 FHC should be macroprudential in focus.
That is, it should consider risk to the system as a whole.
7. The Federal Reserve, in
consultation with Treasury and external experts, should propose
recommendations by October 1, 2009 to better align its structure
and governance with its authorities and responsibilities.
C. Strengthen Capital and
Other Prudential Standards For All Banks and BHCs
1. Treasury will lead a
working group, with participation by federal financial
regulatory agencies and outside experts that will conduct a
fundamental reassessment of existing regulatory capital
requirements for banks and BHCs, including new Tier 1 FHCs.
The working group will issue a
report with its conclusions by December 31, 2009.
2. Treasury will lead a
working group, with participation by federal financial
regulatory agencies and outside experts, that will conduct a
fundamental reassessment of the supervision of banks and BHCs.
The working group will issue a
report with its conclusions by October 1, 2009.
3. Federal regulators
should issue standards and guidelines to better align executive
compensation practices of financial firms with long-term
shareholder value and to prevent compensation practices from
providing incentives that could threaten the safety and
soundness of supervised institutions.
In addition, we will support
legislation requiring all public companies to hold non-binding
shareholder resolutions on the compensation packages of senior
executive officers, as well as new requirements to make
compensation committees more independent.
4. Capital and management
requirements for FHC status should not be limited to the
subsidiary depository institution. All FHCs should be required
to meet the capital and management requirements on a
consolidated basis as well.
5. The accounting standard
setters (the FASB, the IASB, and the SEC) should review
accounting standards to determine how financial firms should be
required to employ more forward-looking loan loss provisioning
practices that incorporate a broader range of available credit
information.
Fair value accounting rules
also should be reviewed with the goal of identifying changes
that could provide users of financial reports with both fair
value information and greater transparency regarding the cash
flows management expects to receive by holding investments.
6. Firewalls between banks and their affiliates should be
strengthened to protect the federal safety net that supports
banks and to better prevent spread of the subsidy inherent in
the federal safety net to bank affiliates.
D.
Close Loopholes in Bank Regulation
1. We propose the creation
of a new federal government agency, the National Bank Supervisor
(NBS), to conduct prudential supervision and regulation of all
federally chartered depository institutions, and all federal
branches and
agencies of foreign banks.
2. We propose to eliminate
the federal thrift charter, but to preserve its interstate
branching rules and apply them to state and national banks.
3. All companies that
control an insured depository institution, however organized,
should be subject to robust consolidated supervision and
regulation at the federal level by the Federal Reserve and
should be subject to
the nonbanking activity restrictions of
the BHC Act.
The policy of separating
banking from commerce should be re-affirmed and strengthened.
We must close loopholes in the
BHC Act for thrift holding companies, industrial loan companies,
credit card banks, trust companies, and grandfathered
“nonbank” banks.
E.
Eliminate the SEC’s Programs for Consolidated Supervision
The SEC has ended its
Consolidated Supervised Entity Program, under which it had been
the holding company supervisor for companies such as Lehman
Brothers and Bear Stearns.
We propose also eliminating
the SEC’s Supervised Investment Bank Holding Company program.
Investment banking firms that
seek consolidated supervision by a U.S. regulator should be
subject to supervision and
regulation by the Federal Reserve.
F.
Require Hedge Funds and Other Private Pools of Capital to
Register
All
advisers to hedge funds (and other private pools of capital,
including private equity funds and venture capital funds) whose
assets under management exceed some modest threshold should be
required to register with the SEC under the
Investment
Advisers Act.
The advisers should be
required to report information on the funds they manage that is
sufficient to assess whether any fund poses a threat to
financial stability.
G.
Reduce the Susceptibility of Money Market Mutual Funds (MMFs) to
Runs
The SEC should move forward
with its plans to strengthen the regulatory framework around
MMFs to reduce the credit and liquidity risk profile of
individual MMFs and to make the MMF industry as a whole less
susceptible to
runs.
The President’s Working Group
on Financial Markets should prepare a report assessing whether
more fundamental changes are necessary to further reduce the MMF
industry’s susceptibility to runs, such as eliminating the
ability
of a MMF to use a stable net asset value or requiring
MMFs to obtain access to reliable emergency liquidity facilities
from private sources.
H.
Enhance Oversight of the Insurance Sector
Our legislation will
propose the establishment of the Office of National Insurance
within Treasury to gather information, develop expertise,
negotiate international agreements, and coordinate policy in the
insurance sector.
Treasury will support
proposals to modernize and improve our system of insurance
regulation in accordance with six principles outlined in the
body of the report.
I.
Determine the Future Role of the Government Sponsored
Enterprises (GSEs)
Treasury and the
Department of Housing and Urban Development, in consultation
with other government agencies, will engage in a wide-ranging
initiative to develop recommendations on the future of Fannie
Mae and Freddie Mac, and the Federal Home Loan Bank system.
We need to maintain the
continued stability and strength of the GSEs during these
difficult financial times.
We will report to the
Congress and the American public at the time of the President’s
2011 Budget release.
II. ESTABLISH COMPREHENSIVE
REGULATION OF FINANCIAL MARKETS
A.
Strengthen Supervision and Regulation of Securitization Markets
1. Federal banking
agencies should promulgate regulations that require originators
or sponsors to retain an economic interest in a material portion
of the credit risk of securitized credit exposures.
2. Regulators should
promulgate additional regulations to align compensation of
market participants with longer term performance of the
underlying loans.
3. The SEC should continue
its efforts to increase the transparency and standardization of
securitization markets and be given clear authority to require
robust reporting by issuers of asset backed securities (ABS).
4. The SEC should continue
its efforts to strengthen the regulation of credit rating
agencies, including measures to promote robust policies and
procedures that manage and disclose conflicts of interest,
differentiate between structured and other products, and
otherwise strengthen the integrity of the ratings process.
5. Regulators should
reduce their use of credit ratings in regulations and
supervisory practices, wherever possible.
B.
Create Comprehensive Regulation of All OTC Derivatives,
Including Credit Default Swaps (CDS)
All OTC derivatives
markets, including CDS markets, should be subject to
comprehensive regulation that addresses relevant public policy
objectives:
(1) preventing activities in
those markets from posing risk to the financial system;
(2) promoting the efficiency
and transparency of those markets;
(3) preventing market
manipulation, fraud, and other market abuses; and
(4) ensuring that OTC
derivatives are not marketed inappropriately to unsophisticated
parties.
C. Harmonize Futures and
Securities Regulation
The CFTC and the SEC
should make recommendations to Congress for changes to statutes
and regulations that would harmonize regulation of futures and
securities.
D.
Strengthen Oversight of Systemically Important Payment,
Clearing, and Settlement Systems and Related Activities
We propose that the
Federal Reserve have the responsibility and authority to conduct
oversight of systemically important payment, clearing and
settlement systems, and activities of financial firms.
E.
Strengthen Settlement Capabilities and Liquidity Resources of
Systemically Important Payment, Clearing, and Settlement Systems
We propose that the
Federal Reserve have authority to provide systemically important
payment, clearing, and settlement systems access to Reserve Bank
accounts, financial services, and the discount window.
III.
PROTECT CONSUMERS AND INVESTORS FROM FINANCIAL ABUSE
A. Create a New Consumer Financial
Protection Agency
1. We propose to create a
single primary federal consumer protection supervisor to protect
consumers of credit, savings, payment, and other consumer
financial products and services, and to regulate providers of
such products and services.
2. The CFPA should have
broad jurisdiction to protect consumers in consumer financial
products and services such as credit, savings, and payment
products.
3. The CFPA should be an
independent agency with stable, robust funding.
4. The CFPA should have
sole rule-making authority for consumer financial protection
statutes, as well as the ability to fill gaps through
rule-making.
5. The CFPA should have
supervisory and enforcement authority and jurisdiction over all
persons covered by the statutes that it implements, including
both insured depositories and the range of other firms not
previously subject to comprehensive federal supervision, and it
should work with the Department of Justice to enforce the
statutes under its jurisdiction in federal court.
6. The CFPA should pursue
measures to promote effective regulation, including conducting
periodic reviews of regulations, an outside advisory council,
and coordination with the Council.
7. The CFPA’s strong rules
would serve as a floor, not a ceiling.
The states should have the
ability to adopt and enforce stricter laws for institutions of
all types, regardless of charter, and to enforce federal law
concurrently with respect to institutions of all types, also
regardless of charter.
8. The CFPA should
coordinate enforcement efforts with the states.
9. The
CFPA should have a wide variety of tools to enable it to perform
its functions effectively.
10. The Federal Trade
Commission should also be given better tools and additional
resources to protect consumers.
B.
Reform Consumer Protection
1. Transparency. We
propose a new proactive approach to disclosure.
The CFPA will be authorized to
require that all disclosures and other communications with
consumers be reasonable: balanced in their presentation of
benefits, and clear and conspicuous in their identification of
costs, penalties, and risks.
2. Simplicity. We propose that
the regulator be authorized to define standards for “plain
vanilla” products that are simpler and have straightforward
pricing.
The CFPA should be authorized
to require all providers and intermediaries to offer these
products prominently, alongside whatever other lawful products
they choose to offer.
3. Fairness. Where efforts
to improve transparency and simplicity prove inadequate to
prevent unfair treatment and abuse, we propose that the CFPA be
authorized to place tailored restrictions on product terms and
provider
practices, if the benefits outweigh the costs.
Moreover, we propose to
authorize the Agency to impose appropriate duties of care on
financial intermediaries.
4. Access. The Agency
should enforce fair lending laws and the Community Reinvestment
Act and otherwise seek to ensure that underserved consumers and
communities have access to prudent financial services, lending,
and
investment.
C.
Strengthen Investor Protection
1. The SEC should be given
expanded authority to promote transparency in investor
disclosures.
2. The SEC should be given
new tools to increase fairness for investors by establishing a
fiduciary duty for broker-dealers offering investment advice and
harmonizing the regulation of investment advisers and
broker-dealers.
3. Financial firms and
public companies should be accountable to their clients and
investors by expanding protections for whistleblowers, expanding
sanctions available for enforcement, and requiring non-binding
shareholder votes on executive pay plans.
4. Under the leadership of
the Financial Services Oversight Council, we propose the
establishment of a Financial Consumer Coordinating Council with
a broad membership of federal and state consumer protection
agencies, and a
permanent role for the SEC’s Investor
Advisory Committee.
5. Promote retirement
security for all Americans by strengthening employment based and
private retirement plans and encouraging adequate savings.
IV.
PROVIDE THE GOVERNMENT WITH THE TOOLS IT NEEDS TO MANAGE
FINANCIAL CRISES
A.
Create a Resolution Regime for Failing BHCs, Including Tier 1
FHCs
We recommend the creation
of a resolution regime to avoid the disorderly resolution of
failing BHCs, including Tier 1 FHCs, if a disorderly resolution
would have serious adverse effects on the financial system or
the economy.
The regime would supplement
(rather than replace) and be modeled on to the existing
resolution regime for insured depository institutions under the
Federal Deposit Insurance Act.
B.
Amend the Federal Reserve’s Emergency Lending Authority
We will propose legislation to
amend Section 13(3) of the Federal Reserve Act to require the
prior written approval of the Secretary of the Treasury for any
extensions of credit by the Federal Reserve to individuals,
partnerships, or
corporations in “unusual and exigent
circumstances.”
V.
RAISE INTERNATIONAL REGULATORY STANDARDS AND IMPROVE
INTERNATIONAL COOPERATION
A. Strengthen the
International Capital Framework
We recommend that the
Basel Committee on Banking Supervision (BCBS) continue to modify
and improve Basel II by refining the risk weights applicable to
the trading book and securitized products, introducing a
supplemental leverage
ratio, and improving the definition of
capital by the end of 2009.
We also urge the BCBS to
complete an in-depth review of the Basel II framework to
mitigate its procyclical effects.
B.
Improve the Oversight of Global Financial Markets
We urge national authorities
to promote the standardization and improved oversight of credit
derivative and other OTC derivative markets, in particular
through the use of central counterparties, along the lines of
the G-20 commitment,
and to advance these goals through
international coordination and cooperation.
C.
Enhance Supervision of Internationally Active Financial Firms
We recommend that the
Financial Stability Board (FSB) and national authorities
implement G-20 commitments to strengthen arrangements for
international cooperation on supervision of global financial
firms through establishment and
continued operational
development of supervisory colleges.
D.
Reform Crisis Prevention and Management Authorities and
Procedures
We recommend that the BCBS
expedite its work to improve cross-border resolution of global
financial firms and develop recommendations by the end of 2009.
We further urge national authorities to improve
information-sharing arrangements and implement the FSB
principles for cross-border crisis management.
E.
Strengthen the Financial Stability Board
We recommend that the FSB
complete its restructuring and institutionalize its new mandate
to promote global financial stability by September 2009.
F.
Strengthen Prudential Regulations
We recommend that the BCBS
take steps to improve liquidity risk management standards for
financial firms and that the FSB work with the Bank for
International Settlements (BIS) and standard setters to develop
macroprudential tools.
G.
Expand the Scope of Regulation
1. Determine the
appropriate Tier 1 FHC definition and application of
requirements for foreign financial firms.
2.
We urge national authorities to implement by the end of 2009 the
G-20 commitment to require hedge funds or their managers to
register and disclose appropriate information necessary to
assess the systemic risk they pose individually or collectively
H.
Introduce Better Compensation Practices
In line with G-20
commitments, we urge each national authority to put guidelines
in place to align compensation with long-term shareholder value
and to promote compensation structures do not provide incentives
for excessive risk taking.
We recommend that the BCBS
expediently integrate the FSB principles on compensation into
its risk management guidance by the end of 2009.
I. Promote Stronger
Standards in the Prudential Regulation, Money
Laundering/Terrorist Financing, and Tax Information Exchange
Areas
1. We urge the FSB to
expeditiously establish and coordinate peer reviews to assess
compliance and implementation of international regulatory
standards, with priority attention on the international
cooperation elements of prudential
regulatory standards.
2. The United States will
work to implement the updated International Cooperation Review
Group (ICRG) peer review process and work with partners in the
Financial Action Task Force (FATF) to address jurisdictions not
complying with international anti-money laundering/terrorist
financing (AML/CFT) standards.
J.
Improve Accounting Standards
1. We recommend that the
accounting standard setters clarify and make consistent the
application of fair value accounting standards, including the
impairment of financial instruments, by the end of 2009.
2. We recommend that the
accounting standard setters improve accounting standards for
loan loss provisioning by the end of 2009 that would make it
more forward looking, as long as the transparency of financial
statements is
not compromised.
3. We recommend that the
accounting standard setters make substantial progress by the end
of 2009 toward development of a single set of high quality
global accounting standards.
K.
Tighten Oversight of Credit Rating Agencies
We urge national
authorities to enhance their regulatory regimes to effectively
oversee credit rating agencies (CRAs), consistent with
international standards and the G-20 Leaders’ recommendations.
The five key objectives of the US
Financial Regulatory Reform
From the paper "Financial Regulatory Reform: A New
Foundation" by the US Department of the Treasury, we read:
(1) Promote robust supervision and
regulation of financial firms.
Financial institutions that are
critical to market functioning should be subject to strong
oversight.
No financial firm that poses a
significant risk to the financial system should be unregulated
or weakly regulated.
We need clear accountability in
financial oversight and supervision.
We propose:
• A new
Financial Services Oversight Council of financial regulators to identify emerging systemic
risks and improve interagency cooperation.
•
New authority for the Federal Reserve to supervise all
firms that could pose a threat to financial stability, even
those that do not own banks.
• Stronger capital and other
prudential standards for all financial firms, and even higher
standards for large, interconnected firms.
• A new
National Bank Supervisor
to supervise all federally chartered banks.
• Elimination of the federal
thrift charter and other loopholes that allowed some depository
institutions to avoid bank holding company regulation by the
Federal Reserve.
• The registration of advisers of hedge funds and other
private pools of capital with the SEC.
(2) Establish comprehensive supervision of
financial markets.
Our major financial markets must
be strong enough to withstand both system-wide stress and the
failure of
one or more large institutions.
We propose:
•
Enhanced regulation of securitization markets, including new requirements for market transparency,
stronger regulation of credit rating agencies, and a requirement
that issuers and originators retain a financial interest in
securitized loans.
• Comprehensive regulation of all
over-the-counter derivatives.
• New authority for the Federal Reserve
to oversee payment, clearing, and settlement systems.
(3) Protect consumers and investors from
financial abuse.
To rebuild trust in our markets,
we need strong and consistent regulation and supervision of
consumer financial
services and investment markets.
We should base this oversight not
on speculation or abstract models, but on actual data about how
people make financial decisions.
We must promote transparency,
simplicity, fairness, accountability, and access.
We propose:
• A new Consumer Financial Protection Agency to protect consumers across the financial sector from
unfair, deceptive, and abusive practices.
• Stronger regulations to improve the
transparency, fairness, and appropriateness of consumer and
investor products and services.
• A level playing field and higher standards for
providers of consumer financial products and services, whether
or not they are part of a bank.
(4)
Provide the government with the tools it needs to manage
financial crises.
We need to be sure that the
government has the tools it needs to manage crises, if and when
they arise, so that we are not left with untenable choices
between bailouts and financial collapse.
We propose:
• A new regime to resolve
nonbank financial institutions whose failure could have serious systemic effects.
• Revisions to the
Federal Reserve’s emergency lending authority to improve accountability.
(5) Raise international regulatory standards
and improve international cooperation.
The challenges we face are
not just American challenges, they are global
challenges.
So, as we work to set high
regulatory standards here in the United States, we must ask the
world to do the same.
We propose:
• International reforms to support our efforts at home, including
strengthening the capital framework; improving oversight of
global financial markets; coordinating supervision of
internationally active firms; and enhancing crisis management
tools.
In addition to substantive reforms of the
authorities and practices of regulation and supervision, the
proposals contained in this report entail a significant
restructuring of our regulatory system.
We propose the creation of a
Financial Services Oversight Council,
chaired by Treasury and including the heads of the
principal federal financial regulators as members.
We also propose the creation of
two new agencies.
We propose the creation of the
Consumer Financial Protection Agency, which will be an independent entity dedicated to
consumer protection in credit, savings, and payments markets.
We also propose the creation of the
National Bank Supervisor,
which will be a single agency with separate status in
Treasury with responsibility for federally chartered depository
institutions.
To promote national coordination in the insurance
sector, we propose the creation of an
Office of National Insurance within Treasury.
Under our proposal,
the Federal Reserve and the Federal Deposit Insurance
Corporation (FDIC) would maintain their respective roles
in the supervision and regulation of statechartered
banks, and the National Credit Union Administration (NCUA) would
maintain its authorities with regard to credit unions.
The Securities and Exchange Commission (SEC) and Commodity
Futures Trading Commission (CFTC) would maintain their current
responsibilities and authorities as market regulators, though we propose to harmonize the statutory and
regulatory frameworks for futures and securities
The new acronyms: "Tier 1 FHC" (Tier
1 Financial Holding Company) and "nonbank" banks
From the paper "Financial Regulatory Reform: A New
Foundation" by the US Department of the Treasury, we read:
Tier 1 FHCs =
firms whose failure could pose a threat to financial
stability due to their combination of size, leverage, and
interconnectedness.
"We propose the creation of a Financial
Services Oversight Council to facilitate information sharing and
coordination, identify emerging risks, advise the Federal
Reserve on the identification of firms whose failure could pose a
threat to financial stability
due to their combination of size, leverage, and
interconnectedness (hereafter referred to as a
Tier 1 FHC), and provide a forum for resolving jurisdictional
disputes between regulators."
Nonbank
Banks = When Congress amended the definition of “bank” in the
BHC Act in 1987, it grandfathered a number of companies that
controlled depository institutions that became a “bank” solely
as a result of the 1987 amendments.
As a
result, the holding companies of
these so-called “nonbank banks” are not treated as BHCs for
purposes of the BHC Act.
Although few of these companies remain today, there is no
economic justification for allowing these companies to continue
to escape the activity restrictions and consolidated supervision
and regulation requirements of the BHC Act.
Under
our plan, holding companies of “nonbank banks” would become
BHCs.
Over the
past two years, the financial
system has been threatened by the failure or near failure of
some of the largest and most interconnected financial firms.
Our
current system already has strong procedures and expertise for
handling the failure of banks, but
when a bank holding
company or other nonbank financial firm is in severe distress,
there are currently only two options: obtain outside capital or
file for bankruptcy.
During most economic climates,
these are suitable options that will not impact greater
financial stability.
However, in stressed conditions it may prove difficult for
distressed institutions to raise sufficient private capital.
Thus, if
a large, interconnected bank holding company or other nonbank
financial firm nears failure during a financial crisis, there
are only two untenable options: obtain emergency funding from
the US government as in the case of AIG, or file for bankruptcy
as in the case of Lehman Brothers.
Neither
of these options is acceptable for managing the resolution of
the firm efficiently and effectively in a manner that limits the
systemic risk with the least cost to the taxpayer.
We
propose a new authority, modeled on
the existing authority of the FDIC, that should allow the
government to address the potential failure of a bank holding
company or other nonbank financial firm when the stability of
the financial system is at risk.
In
order to improve accountability in the use of other crisis
tools, we also propose that the Federal Reserve Board receive
prior written approval from the Secretary of the Treasury for
emergency lending under its “unusual and exigent circumstances”
authority.
A new regime to resolve nonbank financial
institutions whose failure could have serious systemic effects.
Dear members,
Thank you for reading our
newsletter.
Take advantage
of the distance learning and online certification program of our
Association - at a cost that is unheard of.
www.hedge-funds-association.com/Distance_Learning_and_Certification.htm
Best
Regards,
George Lekatis
President of the International
Association of Hedge Funds Professionals (IAHFP)
General
Manager, Compliance LLC
1200 G Street NW Suite 800, Washington
DC 20005, USA
Tel: (202) 449-9750
Email: lekatis@hedge-funds-association.com
Web:
www.hedge-funds-association.com
HQ:
1220 N. Market Street Suite 804, Wilmington DE 19801, USA
Tel:
(302) 342-8828
Free E-book for all
Members: 100 Job Descriptions in Risk and Compliance Management
www.hedge-funds-association.com/100_Job_Descriptions_in_Risk_and_Compliance_Management.htm
Join the
International Association of Hedge Funds Professionals. Membership
is Free
www.hedge-funds-association.com/HowToBecomeMember.html
Member Benefits
www.hedge-funds-association.com/MemberBenefits.html
Download Our Training
Catalog
www.compliance-llc.com/1_Compliance_Training_Catalog.pdf
Reading Room
www.hedge-funds-association.com/Reading_Room.htm
Privacy and
Compliance with the Federal Trade Commission Fair, the California
Online Privacy Protection Act, the Children Online Privacy
Protection Act, the Privacy Alliance, the Controlling the Assault of
Non-Solicited Pornography and Marketing Act
www.hedge-funds-association.com/Privacy.htm
|
.gif){kind=small}
.gif){kind=small}
.gif){kind=small}