Do we know where J Aron wants us to settle the trade done from London?  If it 
is still settled by payment to New York, this one trade probably does not 
cause too much heartburn. (See the note from Steve Douglas in Tax next 
following.)
---------------------- Forwarded by Mark Taylor/HOU/ECT on 01/28/2000 08:58 
AM ---------------------------
To: Mark Taylor/HOU/ECT@ECT
cc: Jeff Blumenthal/HOU/ECT@ECT 
Subject: Re: J Aron & Co - Master User in New York , Sub User in London  

Yes.  Our tax compliance system is premised upon the trading "pattern" (type 
of trader, location, etc.) represented to us in the materials pursuant to 
which we establish a counterparty.  In this case, J Aron is transacting via 
either a different legal entity in London or a branch of the entity that was 
initially approved that is located in London with a password acquired on the 
basis that they would be trading from New York (presumably from a U.S. 
corporation).  In either event, while there may not be an issue as to this 
particular transaction, because we do not know the type of counterparty with 
whom we are transacting, we could potentially have a U.S. tax withholding 
issue when settlement payments are made (this, of course, assuming that we 
settle with the London branch/entity trading with the U.S. approved 
password).  Consequently, we would prefer to more tightly contain the trading 
patterns of counterparties and not permit this type of trading (doesn't this 
violate reps made in the GTC?).  Alternatively, if all that is occurring is 
that a U.S. approved counterparty is using a password to transact from a 
different physical location, this presents an issue for the counterparty 
(namely, creation of a taxable presence in London or such other location) 
but, so long as we only settle with the approved counterparty under the terms 
pursuant to which their account was set up (i.e., in the U.S. in the case of 
this transaction), this should not present an issue for EOL.  Give me a call 
should you want to follow up.  Steve.


   
	
	
	From:  Mark Taylor                           01/27/2000 11:46 AM
	

To: Stephen H Douglas/HOU/ECT@ECT, Jeff Blumenthal/HOU/ECT@ECT
cc:  
Subject: J Aron & Co - Master User in New York , Sub User in London

Any concerns?
---------------------- Forwarded by Mark Taylor/HOU/ECT on 01/27/2000 11:43 
AM ---------------------------
   Enron London - EOL Product Control Group                01/27/2000 11:24 AM

Sent by: Arfan Aziz
To: Edmund Cooper/LON/ECT@ECT, Justin Boyd/LON/ECT@ECT, Mark 
Taylor/HOU/ECT@ECT
cc: Enron London - EOL Product Control Group/LON/ECT@ECT, Product Control - 
Houston 
Subject: J Aron & Co - Master User in New York , Sub User in London

The EOL help desk received a call from Isabelle Ealet at J Aron in London 
(0171 774 2103).  She was asking them why she could not trade with her id and 
password that she had been given.

I called her and explained that she could not use a Guest Id to trade and 
told her that she needed to send in a UK PA (explained to her the location of 
the form on the web site).  She said she would send one to us.

Then she told me that it was not a problem anyway because she called her New 
York office and asked them to give her and id - they set her up as a sub 
user.  She then told me that she transacted a deal in London for EN590.  I 
told her that her PA would not cover this and I am not sure she understood 
this ?

Therefore she will have transacted in London under a US PA - correct ?  
Please advise as to how we are to deal with this.

Thanks

Arfan