Since we're clear on regulation, the choice of entities becomes a tax issue.  
We need to identify:

which company (new or existing) will be the principal booking entity 
which company (new or existing) will be the agent (but we shouldn't use EEFT, 
our SFA entity)
whether the same principal entity can be used for both the equity and bond 
businesses, and 
as you say, whether the same agent can be used for both businesses

Could Janine/Mahesh please opine on these questions (we can meet if necessary 
to discuss) then we can set up the entity or entities as required.  Thanks

Paul





John Greene
14/09/2000 10:03
To: Paul Simons/LON/ECT@ECT, Janine Juggins/LON/ECT@ECT, Mahesh 
Lakhani/LON/ECT@ECT, Erica Gut/LON/ECT@ECT
cc: Gary Hickerson/HOU/ECT@ECT, Jeff Kinneman/HOU/ECT@ECT, Sheila 
Glover/HOU/ECT@ECT, Mark Evans/Legal/LON/ECT@ECT, Sara 
Shackleton/HOU/ECT@ECT, Laurel Adams/HOU/ECT@ECT 

Subject: Re: Bond & Equity Trading  

Now that we have the "green light", can we please start the process of 
setting up the UK entity that will act as agent for this activity.  According 
to Jeff, the bond trading activity will not start right away and, in any 
case, the volume for this activity will be fairly light.  Therefore, I think 
it would be best if we just set up one agent now and decide on the need for 
another separate entity at a later date.  

Thanks and regards,
John 



Paul Simons
13/09/2000 15:16
To: Gary Hickerson/HOU/ECT@ECT, Jeff Kinneman/HOU/ECT@ECT, John 
Greene/LON/ECT@ECT, Sheila Glover/HOU/ECT@ECT, Janine Juggins/LON/ECT@ECT, 
Mahesh Lakhani/LON/ECT@ECT, Mark Evans/Legal/LON/ECT@ECT, Andrew 
Cornfield/LON/ECT@ECT
cc: John Sherriff/LON/ECT@ECT, Michael R Brown/LON/ECT@ECT 

Subject: Bond & Equity Trading

I have just received the letter SFA promised us.  SFA have accepted our 
argument that our proprietary bond and equity trading can be carried on in 
London through an unregulated UK entity.  The letter also states that SFA 
will not be applying their consolidated capital supervision rules to the 
unregulated entity, which they have the discretion to do.

From a regulatory perspective this means we can move ahead at full speed to 
set up an appropriate Chinese Wall and then begin trading.

Best regards

Paul