European Union: EMIR – European Commission Responds To Draft RTS On IRS Clearing

The European Commission has publicised its decision to endorse draft regulatory technical standards ("RTS") submitted to it by the European Securities and Markets Authority ("ESMA") on the clearing of interest rate OTC derivatives ("IRS") under EMIR,1 with certain amendments.2 ESMA has until 29 January 2015 (six weeks from the date of the communication from the Commission) to re-submit the draft RTS to the Commission with amendments consistent with those proposed by the Commission or to make a different proposal.3 The European Parliament and the Council will have at least three months from the time when final RTS are adopted by the Commission to raise any objections to them.4

The draft RTS:

  • Define the classes of IRS that are going to be subject to the clearing obligation in EMIR;
  • Divide counterparties into four categories for the purposes of determining when the clearing obligation takes effect and the extent to which outstanding IRS will have to be cleared when the clearing obligation takes effect ("frontloading");
  • Set the effective dates of the clearing obligation for the different categories of counterparty; and
  • Set the minimum remaining maturities of IRS in the different classes that will need to be cleared if they were entered into or novated during the frontloading window.

In this Alert, we summarise the provisions of the draft RTS on IRS clearing, as amended by the Commission.5 Finally, we provide an update on the status of the RTS for the clearing of certain classes of credit OTC derivatives ("CDS") and OTC foreign-exchange non-deliverable forwards ("NDFs") under EMIR.

Classes of IRS Subject to the Clearing Obligation

The classes of IRS subject to the clearing obligation in EMIR are:

  • Single currency floating-to-floating or "basis" swaps settled in EUR, GBP, JPY or USD, where the floating reference rate is EURIBOR (for EUR basis swaps) or LIBOR (for GBP, JPY and USD basis swaps), with a maturity of between 28 days and 50 years (for EUR, GBP and USD basis swaps) or between 28 days and 30 years (for JPY basis swaps), with a constant or variable (but not conditional) notional amount and with no embedded optionality.
  • Single currency fixed-to-floating or "plain vanilla" interest rate swaps, settled in EUR, GBP, JPY or USD, where the floating reference rate is EURIBOR (for EUR fixed-to-floating swaps) or LIBOR (for GBP, JPY and USD fixed-to-floating swaps), with a maturity of between 28 days and 50 years (for EUR, GBP and USD fixed-to-floating swaps) or between 28 days and 30 years (for JPY fixed-to-floating swaps), with a constant or variable (but not conditional) notional amount and with no embedded optionality.
  • Single currency Forward Rate Agreements ("FRA"), settled in EUR, GBP or USD, where the floating reference rate is EURIBOR (for EUR FRA) or LIBOR (for GBP and USD FRA), with a maturity of between three days and three years, with a constant or variable (but not conditional) notional amount and with no embedded optionality.
  • Single currency Overnight Index Swaps ("OIS"), settled in EUR, USD or GBP, where the floating reference rate is EONIA (for EUR OIS), FedFunds (for USD OIS) or SONIA (for GBP OIS), with a maturity of between seven days and three years, with a constant or variable (but not conditional) notional amount and with no embedded optionality.

As long as they meet the conditions set out in the RTS, IRS entered into in connection with covered bonds are excluded from the clearing obligation. IRS entered into by securitisation or structured finance special purpose vehicles do not benefit from this exclusion.

As noted in our previous Alert, ESMA Plans Phased-in Approach to EMIR OTC Derivatives Clearing, the classes of IRS proposed to be subject to mandatory clearing under EMIR are very similar to the IRS classes that are currently required to be cleared under Title VII of the U.S. Dodd-Frank Act, although there are a few differences. Please see our previous Alert for additional detail.

Categories of Counterparties 

The Position under EMIR

In summary, mandatory clearing under EMIR applies to dealings in OTC derivatives where the counterparties fall into the following categories:

  • The counterparties are both "financial counterparties";6
  • The counterparties are both "non-financial counterparties" that have exceeded the "clearing threshold";7
  • One counterparty is a financial counterparty and the other counterparty is a non-financial counterparty that has exceeded the clearing threshold; or
  • One counterparty is a financial counterparty or a non-financial counterparty that has exceeded the clearing threshold and the other counterparty is an entity established outside of the European Union (the "EU") that would be subject to the clearing obligation if it were established in the EU.8

The Four New Categories of Counterparties Created under the RTS

The draft RTS divide financial counterparties and non-financial counterparties subject to the clearing obligation in EMIR into four further categories:

  • Category 1 comprises counterparties ("Category 1 Counterparties") that, on the date when the RTS come into force,9 are participants in (or "clearing members" of) a clearing house (or "CCP"), as long as they participate in the clearing of at least one of the classes of IRS subject to the clearing obligation (see Classes of IRS Subject to the Clearing Obligation earlier) and the CCP of which they are a member has been authorised or recognised under EMIR before that date to clear at least one of those classes of IRS.
  • Category 2 comprises counterparties ("Category 2 Counterparties") other than Category 1 Counterparties, who belong to a group whose aggregate month-end average of outstanding gross notional amount of non-centrally cleared derivatives for the three months after the RTS are published in the Official Journal of the EU (the "OJ"), excluding the month of publication, exceeds €8 billion (the "Category 2 Threshold"), as long as they are either:
     
    • financial counterparties; or
    • "alternative investment funds" ("AIFs") within the meaning of the Alternative Investment Fund Managers Directiv10 that are classed as non-financial counterparties under EMIR.
  • Category 3 comprises counterparties ("Category 3 Counterparties") other than Category 1 Counterparties and Category 2 Counterparties, as long as they are either:
     
    • financial counterparties; or
    • AIFs within the meaning of the Alternative Investment Fund Managers Directive that are classed as non-financial counterparties under EMIR.
  • Category 4 comprises non-financial counterparties ("Category 4 Counterparties") other than Category 1 Counterparties, Category 2 Counterparties and Category 3 Counterparties.

The Treatment of AIFs under EMIR and the Draft RTS 

AIFs are only classified as "financial counterparties" under EMIR if they have a manager who is authorised or registered under the Alternative Investment Fund Managers Directive (see The Position under EMIR  earlier). Other AIFs established in the EU (i.e., those without a manager authorised or registered under the Alternative Investment Fund Managers Directive) are classified as "non-financial counterparties" under EMIR. However, for the purposes of the draft RTS, AIFs classified as non-financial counterparties under EMIR are treated in the same way as AIFs classified as financial counterparties under EMIR.

Threshold Calculation – Assessment Period

The assessment period for the Category 2 Threshold calculation is made up of the three months following the month during which the RTS are published in the OJ. This represents a change from the draft RTS proposed by ESMA, which would have required counterparties to base the Category 2 Threshold calculation on month-end figures for the three months prior to the month in which the RTS were set to come into force. 

Threshold Calculation – Meaning of "Group" in the Case of Funds

The European Commission stated in its covering letter to ESMA that it considered it necessary to clarify the calculation of the Category 2 Threshold in the case of counterparties who are "investment funds". The Commission proposed to include a recital in the RTS to the effect that the Category 2 Threshold should be calculated for an individual fund, and not at a group level, as long as the fund is not collateralised, guaranteed or supported by other funds or by the manager of the fund. In the current draft of the RTS, there is no direct confirmation of how a fund should calculate its "group's" outstanding gross notional amount of non-centrally cleared derivatives. It is hoped that this point will be clarified in a subsequent draft of the RTS, however.

Treatment of "Third-Country Entities" under the RTS

Counterparties who are established outside of the EU (referred to as "third-country entities" in EMIR and its supporting regulations) are not given a distinct classification in the draft RTS. As a result, in line with the treatment of third-country entities for other purposes under EMIR and the views expressed by ESMA during the consultation process leading up to the draft RTS proposed by ESMA, non-EU entities, if they have dealings in OTC derivatives with a counterparty classed as a financial counterparty or a non-financial counterparty that has exceeded the clearing threshold under EMIR, should treat themselves as belonging to the category of counterparty to which they would belong if they were established in the EU. 

Dates from which the Clearing Obligation takes effect

The clearing obligation for the classes of IRS described in Classes of IRS Subject to the Clearing Obligation  earlier will take effect:

  • Six months after the date the RTS come into force for Category 1 Counterparties;
  • 12 months after the date the RTS come into force for Category 2 Counterparties;
  • 18 months after the date the RTS come into force for Category 3 Counterparties; and
  • Three years after the date the RTS come into force for Category 4 Counterparties.

Where the counterparties to the IRS belong to different categories, the later of the two effective dates will apply. 

Time-Limited Relief for Certain Intra-Group Transactions

Subject to certain conditions, an exemption from the clearing obligation is available under EMIR for intra-group OTC derivatives. If one of the counterparties to the OTC derivative is a third-country entity, the exemption can only be relied on if the European Commission has declared the regulatory regime of the relevant non-EU country to be "equivalent" to EMIR. As yet, no equivalence decisions have been announced by the Commission. In a change to the original RTS proposed by ESMA, the draft RTS include a provision that deems an equivalence decision to have been made in relation to third countries for the purposes of the exemption for intra-group OTC derivatives between certain EU and non-EU financial entities. The deeming provision applies for three years after the date when the RTS come into force or until an equivalence decision is actually made by the Commission in relation to the relevant non-EU country (whichever date is earlier). 

Minimum Remaining Maturities

The Frontloading Obligation in EMIR

In accordance with EMIR,11 OTC derivatives with a remaining maturity at the date when the clearing obligation takes effect higher than the "minimum remaining maturity" set in the RTS are subject to the clearing obligation if they were entered into or novated during the period (or "window") between the notification to ESMA that follows the authorisation of a CCP to clear a class of OTC derivatives and the date when the clearing obligation takes effect. This obligation to clear outstanding OTC derivatives when the clearing obligation takes effect is known as "frontloading".

The Application of the Frontloading Obligation under the RTS

The minimum remaining maturities set in the original RTS proposed by ESMA would have resulted in the frontloading obligation applying only to financial counterparties that are Category 1 Counterparties or Category 2 Counterparties and only to IRS entered into after the publication of the RTS in the OJ. 

The minimum remaining maturities set in the new draft of the RTS have the effect of limiting the frontloading obligation to financial counterparties that are Category 1 Counterparties or Category 2 Counterparties (as before) and postponing further the start date of the frontloading window until two months after the date when the RTS come into force (for financial counterparties that are Category 1 Counterparties) and five months after the date when the RTS come into force (for financial counterparties that are Category 2 Counterparties). The new draft of the RTS also clarifies that, where the counterparties to the IRS belong to different categories, the longer of the two minimum remaining maturities will apply.

In accordance with the draft RTS:

  • For financial counterparties that are Category 1 Counterparties and OTC derivatives entered into or novated before two months have elapsed since the date when the RTS come into force, the minimum remaining maturities for the different classes of IRS subject to the clearing obligation are set at such a level that the frontloading obligation does not apply. For financial counterparties that are Category 1 Counterparties and OTC derivatives entered into or novated on or after the date falling two months after the date when the RTS come into force, the minimum remaining maturity for the different classes of IRS subject to the clearing obligation is set at six months (see the summary table that follows).
  • For financial counterparties that are Category 2 Counterparties and OTC derivatives entered into or novated before five months have elapsed since the date when the RTS come into force, the minimum remaining maturities for the different classes of IRS subject to the clearing obligation are set at such a level that the frontloading obligation does not apply. For financial counterparties that are Category 2 Counterparties and OTC derivatives entered into or novated on or after the date falling five months after the date when the RTS come into force, the minimum remaining maturity for the different classes of IRS subject to the clearing obligation is set at six months (see the summary table that follows).
  • For financial counterparties that are Category 3 Counterparties, the minimum remaining maturities for the different classes of IRS subject to the clearing obligation are set at such a level that the frontloading obligation does not apply (whenever the OTC derivatives were entered into or novated).
  • Where the counterparties to the IRS belong to different categories, the longer of the two minimum remaining maturities applies.

Minimum Remaining Maturities – Summary Table

Category of Counterparties Frontloading Window Minimum Remaining Maturity
Financial counterparties that are Category 1 Counterparties Two months after the RTS come into force until the clearing obligation takes effect Six months (for all classes of IRS subject to the clearing obligation)
Financial counterparties that are Category 2 Counterparties Five months after the RTS come into force until the clearing obligation takes effect Six months (for all classes of IRS subject to the clearing obligation)

 
Does the Frontloading Obligation Apply to Non-Financial Counterparties?

As explained by ESMA during the consultation process leading up to the draft RTS proposed by ESMA, the frontloading obligation in EMIR cannot apply to non-financial counterparties who become subject to the clearing obligation because they pass the clearing threshold (see Categories of Counterparties - The Position under EMIR earlier). This position is endorsed by the European Commission in the amended draft RTS, with the result that the frontloading obligation does not apply where at least one of the counterparties to the IRS is classed as a non-financial counterparty under EMIR (including an AIF that is a non-financial counterparty classed as a Category 2 Counterparty – see Categories of Counterparties - The Four New Categories of Counterparties Created under the RTS and The Treatment of AIFs under EMIR and the Draft RTS earlier).

Update on Status of RTS for Clearing of CDS and NDFs

Consultation papers were published by ESMA proposing first drafts of RTS on the clearing of CDS and NDFs under EMIR.12 However, ESMA announced that it would delay the submission by it to the European Commission of final draft RTS for the clearing of CDS until the RTS for the clearing of IRS have been settled.13 Final draft RTS for the clearing of NDFs are also due to be submitted by ESMA to the Commission, but their submission can be expected to be subject to a similar delay.

Footnotes

1.Regulation (EU) No 648/2012 of the European Parliament and of the Council of 4 July 2012 on OTC derivatives, central counterparties and trade repositories.

2. See letter from the Commission to ESMA dated 18 December 2014 and attached amended draft RTS.

3. Regulation (EU) No 1095/2010 of the European Parliament and of the Council of 24 November 2010 establishing a European Supervisory Authority (European Securities and Markets Authority), amending Decision No 716/2009/EC and repealing Commission Decision 2009/77/EC ("Regulation 1095/2010"), Article 10(1), sixth and seventh subparagraphs.

4. Regulation 1095/2010, Article 13(1).

5. previous Alert, ESMA Plans Phased-in Approach to EMIR OTC Derivatives Clearing, discussed the position under ESMA's consultation paper on the clearing of IRS under EMIR, which contained a first draft of the RTS on IRS clearing. That draft was subsequently updated in a final report published by ESMA, containing the draft RTS that were submitted to the European Commission for endorsement.

6. In accordance with Article 2(8) of EMIR, "financial counterparties" include authorised EU investment firms, banks, insurers and undertakings for collective investment in transferable securities (UCITS), EU occupational pension funds regulated by the Institutions for Occupational Retirement Provision Directive and alternative investment funds (whether established in the EU or outside the EU) managed by alternative investment fund managers authorised or registered under the Alternative Investment Fund Managers Directive.

7. In accordance with Article 2(9) of EMIR, "non-financial counterparties" include undertakings established in the EU other than financial counterparties. A non-financial counterparty will exceed the "clearing threshold" if it and the other non-financial entities in its group execute OTC derivatives above any of the thresholds set for the different classes of OTC derivatives in the regulations supplementing EMIR. Only OTC derivatives that are not entered into for defined hedging purposes should be counted towards the threshold (see EMIR, Article 10(3)).

8. EMIR, Article 4(1)(a).

9. The RTS are set to come into force on the twentieth day after they are published in the Official Journal of the EU.

10. Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers and amending Directives 2003/41/EC and 2009/65/EC and Regulations (EC) No 1060/2009 and (EU) No 1095/2010.

11. Article 4(1)(b)(ii).

12. ESMA's Consultation Papers – Clearing Obligation under EMIR (no. 2) (published on 11 July 2014) and Clearing Obligation under EMIR (no. 3) (published on 1 October 2014 and amended on 10 October 2014).

13. See ESMA's letter to the European Commission regarding EMIR clearing obligation dated 20 November 2014.

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
 
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
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 you may opt out by clicking here

    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.

    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.

    By clicking Register you state you have read and agree to our Terms and Conditions