Worldwide: Proposed Revisions To Basel Securitisation Framework

Keywords: proposed revisions, Basel securitisation framework, banking supervision.

In December 2012 the Basel Committee on Banking Supervision (BCBS) published a consultation paper (BCBS 236)1 proposing substantial changes to the methods banks use to calculate risk-based capital requirements related to securitisation exposures (Proposal). The Proposal's stated objectives are to make securitisation capital requirements more prudent and risk-sensitive, to lessen reliance on external credit ratings, and to reduce "cliff effects" (in which small differences in credit quality or other parameters produce large differences in capital requirements). Comments on the Proposal are due 15 March 2013.

The Proposal would change the securitisation framework within the Basel II bank capital requirements framework (Basel II)2 that BCBS adopted in 2004 and to which it made some amendments, collectively known as Basel II.5,3 following the financial crisis of 2008. The member states of the European Union and many other countries have already implemented Basel II and Basel II.5 and are in the process of adopting and implementing Basel III.4 The United States, however, never fully implemented Basel II, and in 2012 its bank regulators proposed rules to implement modified versions of

Basel II and II.5 as well as Basel III.5 Some elements of the Proposal resemble elements of the US proposed rules.

Highlights of the proposal are as follows:

  • BCBS is considering two alternative hierarchies of approaches for determining risk weights of securitisation exposures. The two alternative hierarchies (Alternative A and Alternative B) are significantly different from each other and from those included in the standardised approach (SA) and the internal ratings-based approach (IRB) under the Basel II securitisation framework.
  • BCBS has proposed, for both alternative hierarchies, a revised ratings-based approach (Revised RBA or RRBA) based on the ratings-based approach (RBA) used in the Basel II IRB, a modified supervisory formula approach (MSFA) based on the supervisory formula approach (SFA) used in the Basel II IRB, and a simplified supervisory formula approach (SSFA) similar to that included in the US proposals.
  • Both alternative hierarchies also make use of "concentration ratio" approaches based on risk weights of the underlying securitised exposures. Under Alternative B, a concentration ratio approach (CRKIRB) based on the weighted average risk weights of underlying exposures determined under the IRB (KIRB) would be used to determine securitisation risk weights of exposures other than senior high-quality exposures. Under both alternative hierarchies, a backstop concentration ratio approach (BCRA) based on risk weights of underlying exposures determined according to the SA (KSA) would be used to determine risk weights of exposures where other methods could not be used, as a backstop before applying a risk weight of 1250%. A similar concentration ratio approach, based on risk weights determined under the revised securitisation framework, would be used to determine risk weights of all re-securitisation exposures.
  • Securitisation exposures would have a minimum risk weight of 20%, rather than 7% as under the Basel II IRB. Re-calibration of the ratings-based and supervisory formula approaches would result in higher risk weights for high credit quality exposures and lower risk weights for some lower credit quality exposures. The concentration ratio approaches, when applied to securitisation approaches other than the most junior tranches, result in relatively high-risk weights because they do not take account of the credit protection provided by the junior tranches.
  • Under both the MSFA and the RRBA, risk weights would vary according to maturity of the securitisation exposure (and not just the underlying exposures), with a minimum of one year and a maximum of five years. For this purpose, the tranche maturity would be determined based on mandatory contractual cash flows of the securitisation tranche rather than those of the underlying assets. So, for an asset-backed security with a typical "pass-through" structure, the maturity would be the legal final maturity (which typically falls up to two years later than the latest contractual maturity of the underlying assets).
  • BCBS will conduct a quantitative impact study (QIS) on the Proposal beginning during the period for comments on the Proposal and will consider the comments and QIS results in formulating a revised securitisation framework.

Alternative hierarchies

Under Alternative A, for a bank to determine the risk weight of any securitisation exposure:

  • If the bank had supervisory permission and sufficient information to determine IRB risk weights for all underlying exposures, it would apply the MSFA.
  • If the bank could not use the MSFA, then, according to the method chosen by the relevant jurisdiction, the bank would apply either (a) the RRBA (or, if applicable, the internal assessment approach (IAA) provided in the Basel II IRB for securitisation exposures to asset-backed commercial paper (ABCP) conduits) or (b) the SSFA.
  • If the bank could not use the second approach adopted in its relevant jurisdiction, then it would apply the BCRA.
  • If the bank could not apply the BCRA, it would assign a risk weight of 1250%.

Under Alternative B, for a bank to determine the risk weight of any securitisation exposure:

  • The bank would first determine whether the exposure was a senior high-quality exposure, that is, an exposure that was senior to or pari passu with all other exposures in the securitisation and had a very high credit quality (corresponding to a credit rating agency (CRA) rating of AAA to AA- or A1/P-1/F-1). If the bank could not determine that the exposure was senior high-quality, the bank would treat it as other than senior high-quality.
  • For senior high-quality exposures, the bank could choose to apply either the RRBA (or, in an appropriate case, the IAA) or the MSFA (or, if it could not use the MSFA and if bank supervisors in the relevant jurisdiction permitted, the SSFA). The bank's decision as to which approach to use would be based on an internal policy not primarily intended to minimise capital requirements, and should not be changed over time without adequate justification.
  • For securitisation exposures other than senior high-quality exposures, if the bank had supervisory permission and sufficient information to calculate KIRB for each underlying exposure, the bank would use CRKIRB.
  • For a senior high-quality exposure, if the bank could not apply the MSFA (or IAA) or SSFA, as applicable, and for any other securitisation exposure, if the bank could not use CRKIRB, then it would use BCRA.
  • If it could not use any other method, the bank would apply a risk weight of 1250%.

The new and modified risk weight methods are as follows:

Modified Supervisory Formula Approach (MSFA)

The MSFA is based on the SFA in the Basel II IRB, but is modified to take into account maturity of the securitisation exposure (as well as maturity of the underlying exposures), and further recalibrated to make it more conservative.

Like the current SFA, the MSFA could be used only by banks having an IRB risk weight model approved by their banking supervisors, as well as information sufficient to estimate relevant parameters, including probability of default (PB), exposure at default (EAB) and loss given default (LGD), used to determine KIRB with respect to the underlying exposures. BCBS proposes that a bank can use the MSFA for a securitisation exposure only if the bank can estimate those parameters for every underlying exposure. It is also considering whether the approach should be available to "foundation" IRB banks that do not estimate underlying loans' LGD.

BCBS expects and intends capital requirements under the MSFA generally will be somewhat higher than under the SFA, because the MSFA would take account of tranche maturity based on contractual cash flows and because BCBS would recalibrate two "supervisory add-ons", tau (reduced from 1000 to 100) and omega (reduced from 20 to 10) in order to add prudence and reduce cliff effects.

Revised Ratings Based Approach (Revised RBA or RRBA)

The RRBA, like the ratings matrix under the Basel II IRB, assigns risk weights to rated securitisation exposures based in part on qualifying CRA ratings, assigning values to each rating level from AAA to CCC- and below. However, the RRBA takes into account not only the exposure's credit rating and whether the exposure is the most senior tranche, but also the exposure's thickness (the ratio of the tranche amount to the sum of all tranches in the securitisation) and its maturity (between one and five years as described above). (On the other hand, the RRBA drops the RBA distinction between granular and non-granular exposures, which BCBS said was not clearly correlated with default risk of securitisation exposures.) To handle the extra variables, the RRBA uses formulas rather than a single ratings table. Banks would use the same RRBA whether they used the SA or the IRB to determine risk weights for the underlying exposures. In Alternative B, however, banks could apply the RRBA only to senior high-quality exposures (which would be thick senior exposures rated AAA to AA- (or A-1/P-1/F-1)), so a simplified version of the RRBA would cover the limited range of variables and outcomes.

To apply the RRBA to a securitisation exposure, the exposure would need to have at least two qualifying CRA ratings, and the bank would apply the second-best rating. In the case of an unrated exposure that was senior to a rated exposure, a bank (whether it used the SA or the IRB for the underlying exposures) could use an inferred rating under the same conditions as in the Basel II IRB.

The lowest risk weight under the RRBA, as under the revised framework generally, would be 20%, rather than 7% as under the Basel II RBA. Risk weights would be higher for tranches with longer tenors (for example, 58% rather than 7% or 20% for a senior AAA tranche with maturity of five years or more). On the other hand, 1250% risk weights would apply only to tranches rated below CCC- or unrated and thinner tranches rated BB or lower, rather than to all tranches rated B+ or lower as under the existing RBA.

Simplified Supervisory Formula Approach (SSFA)

The SSFA is similar to the SSFA included in the US proposals. It would determine the risk weight of a securitisation exposure using a formula based on the weighted average capital charge determined under the SA for the underlying exposures (KSA), the ratio of delinquent underlying exposures to their ending balance, the attachment point of the securitisation exposure (at which losses would first be allocated to the exposure), its detachment point (at which the exposure would be a total loss), and a supervisory calibration parameter (p). Subject to the QIS results, BCBS proposes to set the parameter p at 1.5, which would result in higher capital requirements than in the US proposal (in which p was set at 0.5 for ordinary securitisation exposures and 1.5 for re-securitisation). While the US proposal specified that data used in the calculation must be the most currently available and not more than 91 days old, the BCBS Proposal does not address this point. BCBS says the SSFA is designed and calibrated to produce capital requirements broadly in line with, but slightly higher than, the MSFA.

Concentration ratio approaches

The concentration ratio method based on KIRB (CRKIRB) is based on an approach used in the Basel II.5 revisions to the market risk framework.6 It is also similar to the "look through" method provided in the Basel II SA, as modified in the European Union Capital Markets Directive (CRD) to apply to both senior and non-senior exposures,7 but it could be used only by banks that had supervisory permission and information sufficient to calculate KIRB with respect to the underlying exposures. Under this method, the risk weight of a securitisation exposure would equal the lesser of (a) 1250% and (b) 12.5 times (i) the weighted average capital requirement of the underlying exposures determined according to the IRB (KIRB) divided by (ii) the detachment point (D). This formula, like the other "concentration ratio" approaches, "grosses up" risk weights of non-senior tranches to reflect the allocation of losses to all non-senior tranches, but does not give credit to the credit protection provided by tranches subordinated to the tranche being measured.

In both alternative hierarchies, if no other method applied, a bank would determine the risk weight of a securitisation exposure by applying the BCRA. The BCRA is similar to CRKIRB except that (a) it would be based on the weighted average capital charge determined according to the SA (KSA) rather than according to the IRB, and (b) the product 12.5 times KSA/D would be further multiplied by a factor F, which would equal 1 for a senior exposure and 2 for any non-senior exposure. That is, for any non-senior exposure, the BCRA would double the grossed-up risk weight that would otherwise apply.

For re-securitisation exposures, none of the other methods would apply, and risk weights would have to be determined according to a concentration ratio approach, similar to BCRA except that (a) it would be based on risk weights determined under the revised securitisation framework (which would not have separate SA and IRB rules for securitisation risk weights), and (b) the factor F would equal 1 (because in BCBS's view the risk weights of securitisation exposures under the revised framework would be conservative enough).

Other changes and clarifications

The Proposal also sets out further changes and clarifications:

  • The MSFA and RRBA would take into account maturity (M) of a securitisation exposure based on contractual cash flows of that exposure and not according to performance of (or contractual cash flows of) the underlying assets. For a pass-through tranche, M would equal the legal final maturity (but not less than one year nor more than five years). For committed facilities related to a securitisation exposure, M would equal the term of the commitment plus the maturity of the exposure. For certain types of credit enhancement facilities that are exposed to losses only during the stated commitment period, M would be the commitment period.
  • The minimum risk weight for any securitisation exposure would be 20% (except in an unusual case where the risk weight of the underlying assets, if held by the bank directly, would be less than 20%).
  • The revised framework would eliminate certain special provisions of the Basel II securitisation framework, namely the SA look-through approach for second loss positions in ABCP programmes,8 the IRB limited look-through for ABCP liquidity facilities,9 the SA 50% conversion factor for "eligible" liquidity facilities,10 and the early amortisation provisions for revolving credit pools11 (which the Proposal would treat as non-securitised).
  • Write-downs and purchase discounts would be used to reduce the notional amount of an exposure to which a risk weight applied, but would not be deducted directly from a bank's capital requirement.

The Proposal includes some other changes and clarifications that banks may view as relatively favourable:

  • A bank's capital requirement for a retained securitisation exposure will not be higher than the amount of capital it would be required to maintain if it held all the underlying exposures directly. This is consistent with the existing Basel II rule under the IRB,12 but the Proposal says it will apply also under the SA to banks acting as originators and sponsors.
  • For a senior securitisation exposure, a bank could apply a look-through approach to determine the maximum risk weight based on the weighted average risk weight of the underlying exposures. While this look-through exists in the Basel II SA,13 under the Proposal it would apply to rated as well as unrated securitisation exposures, and whether the risk weights of the underlying exposures were calculated under the IRB or the SA.
  • A bank that used the SA, and not only one using the IRB, to determine risk weights of underlying exposures could use inferred ratings (credit ratings of a junior rated tranche)14 to determine the risk weight of a more senior unrated securitisation exposure.
  • An originator would no longer be required (as under the Basel II SA)15 in all cases to deduct below-investment-grade retained exposures.

Consultation and QIS to follow

BCBS will conduct a QIS beginning during the comment period to inform its decisions and calibration of the revised securitisation framework based on the Proposal. It seeks feedback on, among other things, the different effects of the two alternative hierarchies, conditions to application of the different approaches and the formulation and calibration of the new and revised

Assumptions and calibration

BCBS stated that its assumptions and techniques for developing and calibrating the MSFA and the RRBA will be addressed further in a technical note. Its guiding principles include enhancing consistency between the securitisation framework and the general IRB framework in order to reduce arbitrage (and in particular, to rectify certain assumptions about diversification benefits of securitisation). It also assumed that CRA ratings for securitisation and corporate exposures imply similar loss rates. In focussing on the credit quality of underlying exposures, BCBS assumed that, for securitisation exposures having a given CRA rating level, the underlying exposures have a substantially lower credit quality.16 The MSFA and RRBA use similar assumptions as to credit quality, with certain adjustments to account for differences between the formulas used in the two approaches. The methods and calibrations based on these assumptions result in a significant increase in risk weights for senior tranches, and a reduction in risk weights and reduction of "cliff effects" for some junior tranches.

Footnotes

1 BCBS, Revisions to the Basel Securitisation Framework – Consultative Document (Dec. 2012), available at http://www.bis.org/publ/bcbs236.htm .

2 BCBS, Basel II: International Convergence of Capital Measurement and Capital Standards: A Revised Framework – Comprehensive Version (Jun. 2006), available at http://www.bis.org/publ/bcbs128.htm (Basel II).

3 BCBS, Enhancements to the Basel II framework (Jul. 2009), available at http://www.bis.org/publ/bcbs157.htm ; BCBS, Revisions to the Basel II market risk framework – final version (Jul. 2009), available at http://www.bis.org/publ/bcbs158.htm (BCBS 158); Mayer Brown, Basel II Modified in Response to Market Crisis (Jul. 2009), available at http://www.mayerbrown.com/publications/Basel-II-Modified-in-Response-to-Market-Crisis-07-23-2009/ .

4 BCBS, Progress report on Basel III implementation (update published in Oct. 2012), available at http://www.bis.org/publ/bcbs232.htm .

5 Board of Governors of the Federal Reserve System (FRB) and others, Notice of Proposed Rulemaking (NPR): Regulatory Capital Rules: Regulatory Capital, Implementation of Basel III, Minimum Regulatory Capital Ratios, Capital Adequacy, Transition Provisions, and Prompt Corrective Action (Jun. 2012), NPR: Regulatory Capital Rules: Standardized Approach for Risk-weighted Assets; Market Discipline and Disclosure Requirements (Jun. 2012), and NPR: Advanced Approaches Risk-based Capital Rule; Market Risk Capital Rule (Jun. 2012), all available at http://www.federalreserve.gov/aboutthefed/boardmeetings/20120607openmaterials.htm ; Mayer Brown, Federal Reserve Board Approves Basel III Proposals and Market Risk Capital Rule (Jun. 2012), available at http://www.mayerbrown.com/Federal-Reserve-Board-Approves-Basel-III-Proposals-and-Market-Risk-Capital-Rule-06-08-2012/ .

6 BCBS 158, para. 712(vi)(c).

7 Directive 2006/48/EC of the European Parliament and of the Council of 14 Jun. 2006 relating to the taking up and pursuit of the business of credit institutions (recast, as amended), Annex VII Part 4 points 9-10, available at http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CONSLEG:2006L0048:20100330:EN:PDF

8 Basel II paras. 574-75.

9 Basel II para. 63 9.

10 Basel II paras. 576, 579.

11 Basel II paras. 590-605.

12 Basel II para. 610.13 Basel II paras. 572-73.

14 Basel II paras. 617-18.

15 Basel II paras. 569-70.

16 For tranches rated BB or better, BCBS set the assumed weighted average PD and LGD of underlying exposures at 4.73% and 60% (corresponding to historical corporate bonds rated B, with appropriate stress loss severity); BCBS 236 part V text accompanying note 38.

Originally published 18 January, 2013.

Visit us at mayerbrown.com

Mayer Brown is a global legal services provider comprising legal practices that are separate entities (the "Mayer Brown Practices"). The Mayer Brown Practices are: Mayer Brown LLP and Mayer Brown Europe – Brussels LLP, both limited liability partnerships established in Illinois USA; Mayer Brown International LLP, a limited liability partnership incorporated in England and Wales (authorized and regulated by the Solicitors Regulation Authority and registered in England and Wales number OC 303359); Mayer Brown, a SELAS established in France; Mayer Brown JSM, a Hong Kong partnership and its associated entities in Asia; and Tauil & Chequer Advogados, a Brazilian law partnership with which Mayer Brown is associated. "Mayer Brown" and the Mayer Brown logo are the trademarks of the Mayer Brown Practices in their respective jurisdictions.

© Copyright 2013. The Mayer Brown Practices. All rights reserved.

This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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
 
In association with
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.

Emails

From time to time Mondaq may send you emails promoting Mondaq services including new services. You may opt out of receiving such emails by clicking below.

*** If you do not wish to receive any future announcements of services offered by Mondaq you may opt out by clicking here .

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.