UK: The Securities Financing Transactions Regulation

Last Updated: 27 January 2016
Article by Rosali Pretorius and Luca Salerno

The SFTR will improve transparency in securities and commodities lending, repos, margin loans and some collateral arrangements.

The Regulation on Transparency of Securities Financing Transactions and of Reuse (2015/2365) (the SFTR) is a key part of the EU's initiative to reform shadow banking following the 2007-2008 financial crisis. Its aim is to improve transparency in securities and commodities lending, repurchase transactions, margin loans and certain collateral arrangements.

When was the SFTR adopted?

The SFTR was adopted in November 2015 and published in the Official Journal of the European Union on 23 December 2015. It applies from 12 January 2016. However, a combination of staggered effective dates and the need to wait for Level 2 measures means that most of its requirements will become effective after 13 July 2016.

Overview of requirements

The SFTR requires "counterparties" established in the EU and EU branches of non-EU counterparties that are parties to securities financing transactions (SFTs) or a collateral arrangement to:

  • report SFTs to recognised trade repositories (TRs), or to the European Securities and Markets Authority (ESMA) if trade repositories are not established (Reporting);
  • keep a record of SFTs for five years after their conclusion, modification or termination (Record Keeping); and
  • in order to be able to reuse financial instruments obtained as collateral under collateral arrangements, disclose the risks of such arrangements to, and obtain express consent from, the party that transferred the collateral (Reuse of Collateral).

The SFTR also requires managers of UCITS and alternative investment fund (AIFs) to disclose to investors in the fund some key information about SFTs and total return swaps (TRSs) to which the fund is a party.

The SFTR's requirements will be phased in, with some of the rules such as those on disclosures by fund managers already in force on 12 January 2016 and others, such as the ones on Reuse of Collateral, effective as early as 13 July 2016. At the end of this article we provide the complete timeline of the different obligations.

Transactions and other arrangements in scope

For the purpose of Reporting and Record Keeping, the definition of SFT covers the following types of transactions:

  • securities or commodities lending and securities or commodities borrowing (e.g. transactions under GMSLA and loans of gold or other precious metals);
  • buy/sell-back transactions or sell/buy-back transactions relating to securities or commodities (i.e. sell/buy- backs of securities that are documented as two separate transactions – in order to benefit from true sale analysis, or otherwise – certain types inventory finance/monetisation structures relating to commodities);
  • repurchase transactions relating to securities or commodities (e.g. transactions under GMRA); and
  • margin lending transactions, defined as transactions in which a counterparty extends credit in connection with the purchase, sale, carrying or trading of securities, but not including other loans that are secured by collateral in the form of securities (this would include prime brokerage agreements where a broker extends credit to the client against the client's securities portfolio with that broker).

The definition is wide enough to encompass collateral swaps, namely the lending of liquid assets (such as highly rated government bonds) in return for the receipt of less liquid collateral combined with the payment of a fee. Depending on how such transactions are structured, they could be characterised as derivatives. However, recital 7 of the SFTR is clear in excluding from its scope "derivative" transactions as these are defined in EMIR. 

That said, in relation to the disclosure obligations of fund managers, the SFTR also covers TRS transactions (which are derivatives under EMIR).

The SFTR's requirements around Reuse apply to "collateral arrangements" defined as:

  • title transfer financial collateral arrangements as defined in the Directive on Financial Collateral Arrangements (2002/47/EC) (FCD) between counterparties to secure any obligation; and
  • security financial collateral arrangements as defined in the FCD between counterparties to secure any obligation.

The definition of "collateral arrangement" overlaps with the definition of SFT where – as is the case under a repo under GMRA – the provision of securities as collateral is part of the SFT transaction.

However, "collateral arrangement" is broad enough to cover collateral in the form of securities that is not provided in connection with SFTs, such as "eligible credit support" provided under a credit support annex to an ISDA Master Agreement documenting derivatives transactions.

Definition of "counterparty" and territorial scope

The requirements of the SFTR apply to "counterparties". "Counterparty" is defined by Article 3(2) to include both "financial counterparties" and "non-financial counterparties". The definition of "financial counterparty" in Article 3(3) of the SFTR originates from Article 2(1) of EMIR and covers: 

  • investment firms authorised in accordance with MiFID 2;
  • credit institutions authorised in accordance with CRD 4;
  • insurers and reinsurers authorised in accordance with Solvency 2;
  • central counterparties (CCPs) authorised in accordance with EMIR;
  • central securities depositories authorised in accordance with the Central Securities Depository Regulation;
  • UCITS and their management companies authorised under the UCITS Consolidation Directive;
  • AIFs managed by AIF managers authorised under the AIF Managers DIrective;
  • occupational pensions institutions (IORPs) authorised under the IORP Directive; and
  • third-country (i.e. non-EU) entities which would require authorisation or registration under any of these pieces of legislation if established in the EU.

Non-financial counterparties are undertakings "established" in the EU other than financial counterparties. An undertaking is considered to be "established" in the EU where the counterparty has its head office (if a natural person) or registered office (if a legal person) in the EU.

Unlike under EMIR, which provides an exemption from mandatory clearing (although not reporting) for non-financial counterparties below certain thresholds, the SFTR does not have a lighter regime for non-financial counterparties with smaller books of SFTs.

A counterparty will be caught by the SFTR if:

  • with respect to Reporting and Record Keeping, it is a counterparty to an SFT and is established either in:

i) the EU (including any branch, regardless of where the branch is); or

ii) a third country and the SFT is concluded in the course of operations of its EU branch; and

  • with regard to Reuse of Collateral, it is a collateral taker and is established either in:

i) the EU (again, including all branches, anywhere); or

ii) a third country if either:

  • the reuse is effected in the course of operations of its EU branch; or
  • the reuse concerns financial instruments provided under a collateral arrangement with a counterparty established in the EU or an EU branch of a counterparty established in a third country.

Reporting and Record Keeping (Article 4)

The Reporting obligation consists of reporting, not later than one working day after the SFT has been entered into, modified or terminated, the salient information about such SFT, to a TR established in the EU and registered with ESMA, a third-country TR recognised by ESMA or, where a TR is not available, directly to ESMA.

The information to be reported will be specified in regulatory technical standards (RTS) that ESMA must submit to the Commission for approval by 13 January 2017 and that are therefore likely to come into force in the second quarter of 2017.

Transaction reports will have to include the following information as a minimum:

  • the parties to the SFT;
  • the principal amount;
  • currency;
  • assets used as collateral and their type, quality and value;
  • the method used to provide collateral;
  • whether collateral is available for reuse and, if so, whether it has been reused;
  • any substitution of collateral;
  • the repurchase rate;
  • lending fee or margin lending rate;
  • any haircuts;
  • value date;
  • maturity date;
  • first callable date;
  • market segment; and
  • where applicable, details of cash collateral reinvestment and securities or commodities being lent or borrowed.

When will the Reporting obligation apply?

Under Article 33, the Reporting obligation will apply:

  • 12 months after the coming into force of the RTS for EU and non-EU investment firms and credit institutions;
  • 15 months after the coming into force of the RTS for EU and non-EU CCPs and central securities depositories;
  • 18 months after the coming into force of the RTS for EU and non-EU insurance undertakings, AIFMs, UCITS and IORPs; and
  • 21 months after the coming into force of the RTS for non-financial counterparties.

The Reporting obligation applies to SFTs that have been entered into after the relevant application date referred to above but also SFTs that are existing at that date and either: (i) have a remaining maturity of 180 days; or (ii) have an open maturity (e.g. "rolling" SFTs) and remain outstanding for 180 days after the effective date (Existing SFTs).

Existing SFTs must be reported within 190 days of the Reporting application date. This is effectively a "backloading" mechanism.

As is the case under EMIR, Reporting can be delegated but the ultimate responsibility to comply with such obligation remains solely with the counterparty.

Where an SFT has been entered into by a financial counterparty and a non-financial counterparty, the financial counterparty is responsible for reporting for both parties if the non-financial counterparty does not exceed more than one of the thresholds below:

  • balance sheet total of €20 million;
  • net turnover of €40 million; and
  • average of 250 employees during the financial year.

For investment funds, the UCITS or AIF manager is responsible for Reporting.

Article 4(4) provides that counterparties must keep a record of the SFTs they are a party to for five years from the termination of the transaction. This Record Keeping obligation applies to every counterparty irrespective of whether it carries out the Reporting or delegates it. The SFTR does not specify when the Record Keeping obligation becomes effective. Our view is that the obligation will become effective when the RTS comes into force.

A breach of Article 4 will not affect the validity of the terms of an SFT.

Reuse of Collateral (Article 15)

"Reuse" is defined under Article 3(12) of the SFTR as "the use by a receiving counterparty, in its own name and on its own account or on the account of another counterparty, including any natural person, of financial instruments received under a collateral arrangement, such use comprising transfer of title or exercise of a right of use in accordance with the FCD but not including the liquidation of a financial instrument in the event of the default of the providing party".

This is the broadest possible definition of reuse, encompassing both "rehypothecation" of collateral that is subject to a security interest in favour of the collateral taker (as in the case of many terms of business for trading futures, but not the ISDA Credit Support Deed, which prohibits this) but also the use of collateral received under a title transfer arrangement (as is the case under the English law Credit Support Annex or the margin provisions of the GMRA). Reference to collateral is intended as a reference to collateral that is a "financial instrument" as defined in MiFID (bonds, shares etc. – not cash and letters of credit).

Article 15 of the SFTR provides that the right of the taker of collateral to reuse it is conditional on:

  • the collateral provider being notified in writing by the collateral taker of the risks and consequences involved in: (i) granting consent to a right to rehypothecate the collateral transferred under a security agreement and/or (ii) concluding a title transfer agreement. The notification will have to include at least the risks and consequences that may arise in the event of the default of the collateral taker, namely that such assets will not be protected in the case of the collateral taker's insolvency and that the collateral provider will rank as an unsecured creditor for an amount equal to the value of such assets. There is no requirement for this warning to be acknowledged by the collateral provider. So this requirement can be achieved via a unilateral disclosure, for example in the general terms of business, and does not need to be referred to in the master agreement in question; and
  • the collateral provider having prior written (or equivalent) consent to use collateral under a security collateral arrangement or prior written (or equivalent) consent to a title transfer collateral arrangement. This requirement should be met by the execution of market standard securities financing or credit support documentation.

In addition to such ex-ante requirements, the exercise of the right of reuse is also subject to:

  • the reuse being undertaken in accordance with the terms specified in the collateral arrangement; and
  • the financial instruments received under the collateral arrangement having been transferred directly from the account of the providing counterparty, provided that such counterparty is established within the EU and its security account is maintained in the EU.

Article 15(4) provides that the Reuse provisions of the SFTR shall not affect national law concerning the validity or effect of the collateral arrangement. This is an important safeguard which should avoid the Reuse provisions of the SFTR interfering with the enforceability of close out netting, which is fundamental for the orderly functioning of financial markets.  By providing that no transfer is tainted by a breach of its provisions, Article 15 affords certainty in connection with the transfer of collateral to third parties.

Article 15 will apply from 13 July 2016 to all collateral arrangements, both existing and future. Where the collateral arrangement provides for two- way collateral, the requirements apply to each of the two parties to the collateral arrangement.

Disclosure to investors in UCITS and AIFs (Articles 13 and 14)

From 12 January 2016, or from 13 July 2017 in respect of an AIF or UCITS constituted before 12 January 2016, the prospectus or other disclosure document for a UCITS or AIF must specify the SFTs and TRSs the manager is authorised to use, and include a clear statement that those transactions are used by the fund. It must also include the following (which ESMA may embellish upon in RTS):

  • a general description of the SFTs and TRSs used by the collective investment undertaking and the rationale for their use;
  • criteria for use of SFTs and TRSs, types of assets and maximum and expected proportion of assets under management to be subject to them;
  • criteria for selection of counterparties;
  • acceptable collateral;
  • methodology and frequency of valuation for collateral;
  • risk disclosure (e.g. operational, custodian, liquidity, counterparty);
  • restrictions on reuse (regulatory or self-imposed); and
  • policy on sharing of return on collateral, costs and fees.

From 13 January 2017 UCITS management companies, UCITS investment companies and AIFMs must disclose in their annual (or half-yearly in the case of UCITS) reports the following information on the SFTs and TRSs included in their portfolio:

  • the total amount of securities and commodities on loan as a proportion of total lendable assets (i.e. excluding cash or equivalent);
  • the amount of assets engaged in each type of SFT and TRS expressed as an absolute amount (in the collective investment undertaking's currency) and as a proportion of the collective investment undertaking's assets under management;
  • concentration data such as the 10 largest issuers of securities across all SFTs and TRSs, and the top 10 counterparties to the SFTs and TRSs;
  • aggregate transaction data such as the type of collateral currency, maturity, jurisdiction, and settlement method;
  • data on reuse of collateral such as the proportion of collateral received that is reused, and returns on cash collateral reinvestment;
  • safekeeping/custodian data, including segregation/pooling such as  assets in custody broken down by individual custodians; and
  • cost and return data.

ESMA may embellish on these requirements in the RTS. Note they apply only to EU-authorised UCITS, UCITS managers and AIFMs – so their third-country equivalents may be caught by the extraterritorial nature of the Reporting requirement, but will not be subject to these disclosure requirements.

Consequences of breaches

The SFTR is an EU Regulation. As such its provisions have the force of law in EU Member States. However, the SFTR has also granted the competent authorities of Member States (the FCA in the UK) the power to establish reporting procedures for actual and potential infringements of Article 4 and Article 15.

Such procedures will mandate that counterparties to an SFT put in place appropriate internal procedures for their employees to report such actual and potential infringements.

For breaches of Article 4 or 15, the competent authorities will have the power to apply administrative sanctions as included in Article 22(4)(a) to (h) of the SFTR. These include a cease and desist order, a public warning and a temporary or permanent ban against anyone who is deemed responsible. In the UK, responsibility for regulatory reporting is one of the responsibilities PRA prescribes for senior management of all firms in the scope of the new individual accountability regime coming into force in March 2016, other than for small firms, credit unions and third-country branches. SFTR reporting will come within that senior manager's bailiwick.

Member States must notify the Commission and ESMA of the rules they put in place for criminal and administrative sanctions.

Conclusion

Many market participants may have paid little attention to the SFTR as it made its way through the EU legislative process. In many ways, keeping tabs on EMIR and assessing the potential impact of MiFID 2 and MiFIR will have been the focus of many.

But the SFTR is now effective, and those affected by it, and in particular senior managers and material risk takers, need to pay attention to the application dates of key provisions and ensure they are ready to comply.

Timeline for implementation

Requirement

Date by which in force

SFT reporting requirements

Investment firms and credit institutions to report SFTs to a trade depository or ESMA

Second or third quarter of 2018, namely 12 months after the entry into force of the SFT reporting RTS

Central securities depositories and central counterparties to report SFTs to a trade depository or ESMA

Third of fourth quarter of 2018, namely 15 months after the entry into force of the SFT reporting RTS

Insurance/reinsurance undertakings, UCITS/UCITS managers, AIFs/AIFMs and institutions for occupational retirement provision to report SFTs to a trade depository or ESMA

Fourth quarter of 2018 or first quarter of 2019, namely 18 months after the entry into force of the SFT reporting RTS

Non-financial counterparties to report SFTs to a trade depository or ESMA

First or second quarter of 2019, namely 21 months after the entry into force of the SFT reporting RTS

Reuse requirements

Counterparties to comply with requirements on reuse of collateral (e.g. to obtain express written consent and to disclose the risks and consequences)

13 July 2016

UCITS/AIF disclosure requirements

Prospectus or other disclosure document for an AIF or UCITS must specify SFTs and TRSs the manager is authorised to use, as well as indicate if such transactions are used and the details therof

12 January 2016

UCITS and AIFMs to disclose their use of SFTs and total return swaps in their half-yearly and annual reports (as applicable)

13 January 2017 for AIFs and UCITS that are constituted on or after 12 January 2016

UCITS and AIFMs to disclose their use of SFTs and total return swaps in their prospectus and pre-investment disclosure (as applicable)

13 July 2017 for AIFs and UCITS that are constituted before 12 January 2016

Dentons is the world's first polycentric global law firm. A top 20 firm on the Acritas 2015 Global Elite Brand Index, the Firm is committed to challenging the status quo in delivering consistent and uncompromising quality and value in new and inventive ways. Driven to provide clients a competitive edge, and connected to the communities where its clients want to do business, Dentons knows that understanding local cultures is crucial to successfully completing a deal, resolving a dispute or solving a business challenge. Now the world's largest law firm, Dentons' global team builds agile, tailored solutions to meet the local, national and global needs of private and public clients of any size in more than 125 locations serving 50-plus countries. www.dentons.com.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

To print this article, all you need is to be registered on Mondaq.com.

Click to Login as an existing user or Register so you can print this article.

Authors
Events from this Firm
28 Sep 2017, Seminar, London, UK

On 26 July the FCA published its long-expected consultation paper on the extension of the SMCR to all FCA-authorised firms. The so-called "core regime" introduces the key concepts of regulator-approved senior managers, firm-approved certification staff and conduct rules applicable to virtually all staff.

3 Oct 2017, Conference, Zurich, Switzerland

As the founding Partner of the Europe-Iran Forum, Dentons Europe will once again support this year’s event. This compelling event which explores all Iran-related topics will take place in Zürich on 3rd and 4th October.

4 Oct 2017, Workshop, London, UK

We are hosting an interactive workshop where we will run a mock High Court trial of an employee competition case – where the members of the audience are the judges. The session, aimed at in-house counsel and HR professionals, will offer an insight as to how disputes involving employees moving to a competitor play out in practice.

 
In association with
Related Video
Up-coming Events Search
Tools
Print
Font Size:
Translation
Channels
Mondaq on Twitter
 
Register for Access and our Free Biweekly Alert for
This service is completely free. Access 250,000 archived articles from 100+ countries and get a personalised email twice a week covering developments (and yes, our lawyers like to think you’ve read our Disclaimer).
 
Email Address
Company Name
Password
Confirm Password
Position
Mondaq Topics -- Select your Interests
 Accounting
 Anti-trust
 Commercial
 Compliance
 Consumer
 Criminal
 Employment
 Energy
 Environment
 Family
 Finance
 Government
 Healthcare
 Immigration
 Insolvency
 Insurance
 International
 IP
 Law Performance
 Law Practice
 Litigation
 Media & IT
 Privacy
 Real Estate
 Strategy
 Tax
 Technology
 Transport
 Wealth Mgt
Regions
Africa
Asia
Asia Pacific
Australasia
Canada
Caribbean
Europe
European Union
Latin America
Middle East
U.K.
United States
Worldwide Updates
Check to state you have read and
agree to our Terms and Conditions

Terms & Conditions and Privacy Statement

Mondaq.com (the Website) is owned and managed by Mondaq Ltd and as a user you are granted a non-exclusive, revocable license to access the Website under its terms and conditions of use. Your use of the Website constitutes your agreement to the following terms and conditions of use. Mondaq Ltd may terminate your use of the Website if you are in breach of these terms and conditions or if Mondaq Ltd decides to terminate your license of use for whatever reason.

Use of www.mondaq.com

You may use the Website but are required to register as a user if you wish to read the full text of the content and articles available (the Content). You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, link, display, or in any way exploit any of the Content, in whole or in part, except as expressly permitted in these terms & conditions or with the prior written consent of Mondaq Ltd. You may not use electronic or other means to extract details or information about Mondaq.com’s content, users or contributors in order to offer them any services or products which compete directly or indirectly with Mondaq Ltd’s services and products.

Disclaimer

Mondaq Ltd and/or its respective suppliers make no representations about the suitability of the information contained in the documents and related graphics published on this server for any purpose. All such documents and related graphics are provided "as is" without warranty of any kind. Mondaq Ltd and/or its respective suppliers hereby disclaim all warranties and conditions with regard to this information, including all implied warranties and conditions of merchantability, fitness for a particular purpose, title and non-infringement. In no event shall Mondaq Ltd and/or its respective suppliers be liable for any special, indirect or consequential damages or any damages whatsoever resulting from loss of use, data or profits, whether in an action of contract, negligence or other tortious action, arising out of or in connection with the use or performance of information available from this server.

The documents and related graphics published on this server could include technical inaccuracies or typographical errors. Changes are periodically added to the information herein. Mondaq Ltd and/or its respective suppliers may make improvements and/or changes in the product(s) and/or the program(s) described herein at any time.

Registration

Mondaq Ltd requires you to register and provide information that personally identifies you, including what sort of information you are interested in, for three primary purposes:

  • To allow you to personalize the Mondaq websites you are visiting.
  • To enable features such as password reminder, newsletter alerts, email a colleague, and linking from Mondaq (and its affiliate sites) to your website.
  • To produce demographic feedback for our information providers who provide information free for your use.

Mondaq (and its affiliate sites) do not sell or provide your details to third parties other than information providers. The reason we provide our information providers with this information is so that they can measure the response their articles are receiving and provide you with information about their products and services.

If you do not want us to provide your name and email address you may opt out by clicking here .

If you do not wish to receive any future announcements of products and services offered by Mondaq by clicking here .

Information Collection and Use

We require site users to register with Mondaq (and its affiliate sites) to view the free information on the site. We also collect information from our users at several different points on the websites: this is so that we can customise the sites according to individual usage, provide 'session-aware' functionality, and ensure that content is acquired and developed appropriately. This gives us an overall picture of our user profiles, which in turn shows to our Editorial Contributors the type of person they are reaching by posting articles on Mondaq (and its affiliate sites) – meaning more free content for registered users.

We are only able to provide the material on the Mondaq (and its affiliate sites) site free to site visitors because we can pass on information about the pages that users are viewing and the personal information users provide to us (e.g. email addresses) to reputable contributing firms such as law firms who author those pages. We do not sell or rent information to anyone else other than the authors of those pages, who may change from time to time. Should you wish us not to disclose your details to any of these parties, please tick the box above or tick the box marked "Opt out of Registration Information Disclosure" on the Your Profile page. We and our author organisations may only contact you via email or other means if you allow us to do so. Users can opt out of contact when they register on the site, or send an email to unsubscribe@mondaq.com with “no disclosure” in the subject heading

Mondaq News Alerts

In order to receive Mondaq News Alerts, users have to complete a separate registration form. This is a personalised service where users choose regions and topics of interest and we send it only to those users who have requested it. Users can stop receiving these Alerts by going to the Mondaq News Alerts page and deselecting all interest areas. In the same way users can amend their personal preferences to add or remove subject areas.

Cookies

A cookie is a small text file written to a user’s hard drive that contains an identifying user number. The cookies do not contain any personal information about users. We use the cookie so users do not have to log in every time they use the service and the cookie will automatically expire if you do not visit the Mondaq website (or its affiliate sites) for 12 months. We also use the cookie to personalise a user's experience of the site (for example to show information specific to a user's region). As the Mondaq sites are fully personalised and cookies are essential to its core technology the site will function unpredictably with browsers that do not support cookies - or where cookies are disabled (in these circumstances we advise you to attempt to locate the information you require elsewhere on the web). However if you are concerned about the presence of a Mondaq cookie on your machine you can also choose to expire the cookie immediately (remove it) by selecting the 'Log Off' menu option as the last thing you do when you use the site.

Some of our business partners may use cookies on our site (for example, advertisers). However, we have no access to or control over these cookies and we are not aware of any at present that do so.

Log Files

We use IP addresses to analyse trends, administer the site, track movement, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Links

This web site contains links to other sites. Please be aware that Mondaq (or its affiliate sites) are not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of these third party sites. This privacy statement applies solely to information collected by this Web site.

Surveys & Contests

From time-to-time our site requests information from users via surveys or contests. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information requested. Information requested may include contact information (such as name and delivery address), and demographic information (such as postcode, age level). Contact information will be used to notify the winners and award prizes. Survey information will be used for purposes of monitoring or improving the functionality of the site.

Mail-A-Friend

If a user elects to use our referral service for informing a friend about our site, we ask them for the friend’s name and email address. Mondaq stores this information and may contact the friend to invite them to register with Mondaq, but they will not be contacted more than once. The friend may contact Mondaq to request the removal of this information from our database.

Security

This website takes every reasonable precaution to protect our users’ information. When users submit sensitive information via the website, your information is protected using firewalls and other security technology. If you have any questions about the security at our website, you can send an email to webmaster@mondaq.com.

Correcting/Updating Personal Information

If a user’s personally identifiable information changes (such as postcode), or if a user no longer desires our service, we will endeavour to provide a way to correct, update or remove that user’s personal data provided to us. This can usually be done at the “Your Profile” page or by sending an email to EditorialAdvisor@mondaq.com.

Notification of Changes

If we decide to change our Terms & Conditions or Privacy Policy, we will post those changes on our site so our users are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify users by way of an email. Users will have a choice as to whether or not we use their information in this different manner. We will use information in accordance with the privacy policy under which the information was collected.

How to contact Mondaq

You can contact us with comments or queries at enquiries@mondaq.com.

If for some reason you believe Mondaq Ltd. has not adhered to these principles, please notify us by e-mail at problems@mondaq.com and we will use commercially reasonable efforts to determine and correct the problem promptly.