Ecb update tltro and qe

Milan, 16th March 2017
Cristiana Corno – Strategist
Fabrizio Ligurgo – Strategist
Capital Markets – Trading – Banca IMI
ECB update: TLTRO and QE

2
1 ECB update
2 QE monitor
Appendix: Cac and Non-Cac securities3

3
ECB: where we stand
Eonia 1y1y forward and Btp-Bund spread: repricing
more advanced in govies due to political risk
Political development probably explain ECB’s caution ahead of stronger data
and higher inflation.
House view: if data confirms acceleration of recovery and risk of Le Pen
winning reduces, June could see ECB adopting a more symmetrical
communication on rates and purchases (starting discussing modalities of
non-standard exit measures).
Market is marginally pricing the possibility of a depo rise, before APP ends.
Source: Bloomberg
-0.7
-0.6
-0.5
-0.4
-0.3
-0.2
-0.1
0
0.1
0.2
0.3
0.4
0.50
0.70
0.90
1.10
1.30
1.50
1.70
1.90
2.10
2.30
Jan-14
Mar-14
May-14
Jul-14
Sep-14
Nov-14
Jan-15
Mar-15
May-15
Jul-15
Sep-15
Nov-15
Jan-16
Mar-16
May-16
Jul-16
Sep-16
Nov-16
Jan-17
Mar-17
ITDE10 Eonia 1Y1Y Fwd
We think it is a possibility
due to:
1. turn-around in NIRP
policy in 2016;
2. huge excess reserve
amount in ECB
balancesheet

4
ECB: negative rates amendments
Acknowledging the hit on banks’ profitability, both BOJ and ECB have amended
the negative rates policy:
 2-tier system in Japan
 negative repo rate in Europe
and acted on curve shape, via:
 yield curve control in Japan
 depo rate limit removal in Europe
Correlation between curve slope and
financial stock performance
0%
5%
10%
15%
20%
25%
30%
35%
40%
0
1
2
3
4
5
6
7
8
9
10
Trillions
Outstanding Amount (value) Outstanding Amount (%)
Amount of G7 bonds trading at negative
rates: absolute and %
Source: ECB, Bloomberg; IMI calculations

5
ECB amendments: negative repo and PSPP change
ECB has amended the negative rates policy alleviating bank hit, via:
 Negative repo rate
 Steeper curve: allowing buying below the Depo rate, ECB has:
• increased the pool of eligible assets
• reduced market distortion (long end)
• steepened the curve.
0
2
4
6
8
10
12
Billions
33%
40%
50%
Source: BOJ, Bloomberg
-
1
2
3
4
5
6
7
8
Billions
Change in eligible pool with cap raised 40%-50%
for non-Cac securities (see Appendix)
Change in eligible pool with Depo limit removal.
Less distortions: simulated available buying on
the curve

6
ECB excess reserve and distribution
Considering the large amount of excess reserves created via QE (1.9tn at
current QE purchase pace in Dec17) and penalized at -0.4%, and recent
speeches (Mersch*), we give a significative probability of a depo rise to
0% in 2017, or, at least, the market’s pricing the scenario.
Germany, France and Netherlands are the most penalized by negative rate
on excess reserves.
Excess reserve amount and APP cumulated
buying: evolution based on current pace
Excess reserve distribution: German banks the
most hit
0
200,000
400,000
600,000
800,000
1,000,000
1,200,000
1,400,000
1,600,000
1,800,000
2,000,000
-
200,000
400,000
600,000
800,000
1,000,000
1,200,000
1,400,000
1,600,000
1,800,000
2,000,000
Excess reserve APP
0
100000
200000
300000
400000
500000
600000
*”ECB needs to take rate cuts off the table”

7
Best trades: short end and belly
 Therefore, we like to play a short position on Euribor strip (Mar18 best
choice) outright or via options. A long volatility position on Euribor strip
could also benefit from Euribor reform (end H1-H2)
 Short end steepeners (Eu swap 1y-2y or 2y-3y)
 Since the 5y has underperformed versus the move in rates: we like a long
in the 5y belly versus 2y and 10y with an additional short duration of
9% on 2y bucket.
Euribor strip volatility marginally lower than Eu
swaptions 1y1y
5y belly underperformance is not in line with
history: 5y cheap versus swap level
-0.3
-0.25
-0.2
-0.15
-0.1
-0.05
0
0.05
0.1
0.15
.EU5210 U Index Fit

8
 Tight credit versus swap and sovereign risk
 Itraxx Main and Senior indexes are significantly exposed to «-exit»
Itraxx Main geographical composition Itraxx Senior geographical composition
Hedge French elections with short credit
0.00%
5.00%
10.00%
15.00%
20.00%
25.00%
30.00%
AT BE CH DE DK ES FI FR GB IT NL NO SE US
0.00%
5.00%
10.00%
15.00%
20.00%
25.00%
CH DE DK ES FR GB IT NL

9
Best trade for core and semi core: long TLTRO
Economically the TLTRO has been successful* in immunizing the applied
lending rates from the drift in sovereign risk (charts below), leading to a
more uniform transmission of monetary policy. Going forward the
completion of the banking union will be crucial in resolving the remaining
weaknesses and reduce the sovereign-banking nexus (importance of
European deposit insurance scheme and European safe asset**).
Notwithstanding sovereign cds’ widening …. …. lending rates (spread over Eur swap) have
remained stable or compressed
0
50
100
150
200
250
300
350
400
CDS Austria
CDS Belgium
CDS Germany
CDS Spain
CDS France
CDS Ireland
CDS Italy
CDS Netherlands
0
0.5
1
1.5
2
2.5
3
3.5
4
4.5
Austria
Belgium
Germany
Spain
France
Ireland
Italy
Netherlands
Portugal
*«MFI lending rates: pass-throguh in the time of non-standard monetary policy», ECB Economic Bulletin Jan17
** Market focus - «The shape of yield curve to come...risk free»

10
Growth in loan demand has differed through countries, but due to TLTRO’s
construction most countries have already achieved the benchmark enabling
them to pay the Depo rate prevalent at the time of allotment for 4 years.
Loan demand still diverging between
core and…
…peripherals (plus Netherlands)
100000
120000
140000
160000
180000
200000
220000
240000
800000
900000
1000000
1100000
1200000
1300000
1400000
1500000
Germany France Austria Belgium
0
50000
100000
150000
200000
250000
300000
350000
400000
450000
500000
950000
970000
990000
1010000
1030000
1050000
1070000
1090000
Spain Italy Ireland
Netherlands Portugal
Best trade for core and semi core: long TLTRO

11
TLTRO rate: benchmark stock
At Jan18, the target
benchmark is the
benchmark stock
increased by 2.5%.

12
Cheap financing with Depo achieved
Most of the countries have already achieved their target benchmark, therefore,
given ECB’s more neutral stance, we would expect a significative uptake on
the last TLTRO (21st announcement, 29th settlement).
In table, we show the 2016
stock benchmark, the
2018 target and the last
value of the stock of
eligible loans (loans to non
financial corporations and
households,net of lending
for house purchase).
Austria Belgium Germany Spain France
2015-Jan 215,744 131,788 1,335,226 715,502 1,121,165
2016-Jan 214,222 137,673 1,355,782 690,467 1,165,709
net lending benchmark -1,522 5,885 20,556 -25,035 44,544
% growth -0.71% 4.47% 1.54% -3.50% 3.97%
benchmark 2016 212,700 137,673 1,355,782 665,432 1,165,709
target 2018 218,018 141,115 1,389,677 682,068 1,194,852
last value 217,468 146,269 1,392,495 672,617 1,199,786
%growth rate extrapol 2.24% 6.24% 2.71% 1.08% 2.92%
applied rate -0.359% -0.400% -0.400% -0.173% -0.400%
max uptake 64,267 41,302 406,735 207,140 349,713
Greece Ireland Italy Netherland Portugal
2015-Jan 139,196 89,238 1,057,021 459,359 109,081
2016-Jan 130,667 71,030 1,055,816 435,616 104,333
net lending benchmark -8,529 -18,208 -1,205 -23,743 -4,748
% growth -6.13% -20.40% -0.11% -5.17% -4.35%
benchmark 2016 122,138 52,822 1,054,611 411,873 99,585
target 2018 125,191 54,143 1,080,976 422,170 102,075
last value 127,013 63,207 1,041,721 419,930 99,809
%growth rate extrapol 3.99% 19.66% -1.22% 1.96% 0.22%
applied rate -0.400% -0.400% 0.000% -0.313% -0.036%
max uptake 39,200 21,309 316,745 130,685 31,300

13
Cheap financing with Depo achieved
Countries’ starting benchmark and target (2.5%) Achieved rate on actual loans’ growth
-25.0%
-20.0%
-15.0%
-10.0%
-5.0%
0.0%
5.0%
10.0%
15.0%
20.0%
25.0% benchmark growth realized growth target
-0.40%
-0.35%
-0.30%
-0.25%
-0.20%
-0.15%
-0.10%
-0.05%
0.00%

14
TLTRO II last chance
 According to the lending survey, profitability is the main driver of TLTRO
demand.
 In the first TLTRO (2014), the amount allotted was 50% of the allowance
(7% of eligible loans, 400bn ca); divided in 44% for core countries and 70%
for peripherals (Italy and Spain)
 Currently, the allowance is 30% of eligible loans, 1.6tn ca. Assuming 35%
and 60% of the allowance, respectively for core and peripherals, we could
see 700bn demand or 200bn more than current level. Assuming the
percentage seen in the first TLTRO (44%-70%), we get more than 300b.
 The demand should come more from Core countries, which are the
most penalized by the excess reserve balances and have already achieved
the target benchmark.

15
TLTRO trades
This argument reinforces our call for a long belly trade in both in Eur
swap and in France government market, with a small short in duration to
hedge market directionality.
Besides, a significant uptake could be a bullish signal for the economy,
bearish for rates.
TLTRO carry trade in EU swap and
French govies
5y belly in France out of line: long 5y versus 2y and
10y with 5% short on 5y
-0.6
-0.4
-0.2
0
0.2
0.4
0.6
0.8
1
EURR002W Index - EUSA4 Curncy
EURR002W Index - GFRN4 Curncy

16
TLTRO trades
Another possible trade would be a flattener in Italy and a steepener in France
(higher risk due to elections)

17
1 ECB update
2 QE monitor
Appendix. Cac and Non-Cac securities3

18
Where we stand in QE
Source: Bloomberg; IMI calculations; ECB
 At current pace different major countries will move close to the 33% issuer
limit at the end of 2017.
 Most CBs will reduce portfolio duration as buying proceeds.
Duration of the CBs portfolio and eligible pool % purchase on issuer on main Euro
countries and proximity with 33% cap
0
2
4
6
8
10
12
Duration
Purchased Outstanding

19
Where we stand in QE: April reduction
 Considering reinvestments, the actual reduction in buying is from 80bn to
67bn ca.
 We expect the programme to be reduced proportionally, with an increase of
the supra component from 10% to 12% to cover substitutes buying.
Simulated reinvestments on PSPP portfolio Possible PSPP montlhy amounts
2017 2018 2019 2020 2021
Germany 11,638 23,455 21,801 24,285 33,975
France 7,297 13,010 25,005 24,170 22,542
Italy 12,322 15,261 14,119 12,939 11,833
Spain 9,655 11,431 12,618 10,773 4,784
Nederlands 2,784 5,958 4,518 4,340 7,091
Belgium 2,589 2,242 1,723 3,198 1,109
Portugal 788 829 795 816 1,011
Ireland 942 1,580 1,561 1,890 9
Austria 654 1,506 2,580 1,155 3,094
Total 48,669 75,272 84,720 83,567 85,449
Outstanding to be reimbursed (mln of Euros)
abspp cbpp cspp pspp total
0.39 3.40 6.36 56.85 67.00
0.47 4.06 7.59 67.88 80.00
50b, 7b supra with reinvestment 60b, 6b supra
Germany 26% 13.16 15.00 16.07
France 21% 10.36 11.81 12.65
Italy 18% 9.01 10.27 11.00
Spain 13% 6.45 7.36 7.88
Nederlands 6% 2.95 3.36 3.60
Belgium 4% 1.80 2.05 2.20
Portugal 3% 1.30 1.48 1.59
Ireland 2% 0.85 0.97 1.04
Austria 3% 1.45 1.65 1.77
Rest 5% 2.70 3.08 3.30
Supra 7.00 6.00
Purchases per programme (amounts in billion euros)
- Post reduction
- As of today

20
Deviations from capital keys
The deviations we are seeing are a result of the QE structure, in fact «if the
substitute purchases comprise marketable debt instruments issued by
international or supranational institutions located in the euro area, such
purchases will be subsumed under the 10% allocation for these securities in
the PSPP»
-1.6%
-1.1%
-0.6%
-0.1%
0.4%
0.9%
1.4%
1.9%
Deviation from capital key
Germany France Italy Spain Nederlands Belgium Portugal Ireland Austria

PORTUGAL
21
Purchase Outstanding
Cac 50.1% 42.6%
Non Cac 49.9% 57.4%
0%
3%
6%
9%
12%
15%
18%
21%
24%
27%
30%
33%
Pool Govies Agencies Regional
7.33 7.34 4.20 -
Duration
Govies 99.8% 99.5%
Agencies 0.2% 0.5%
Regional 0.0% 0.0%
PURCHASE
Portugal CB has already started to buy supranationals
bonds as substitutes for govies (30% and 70%
respectively under our simulation)
Simulated amount bought on each security

GERMANY
22
0%
3%
6%
9%
12%
15%
18%
21%
24%
27%
30%
33%
Cac 52.8% 49.4%
Non Cac 47.2% 50.6%
Govies 67.7% 76.5%
Agencies 22.2% 15.3%
Regional 10.1% 8.2%
Linkers 4.6% 6.8%
Non Linkers 95.4% 93.2%
7.71 8.97 4.13 7.16
Duration
PURCHASE
We calculated there are 225bn left to buy (144bn
govies, 31bn agencies, 52bn regional in amount) ca 17
months, which could be extended with supranational
buying

GERMANY
23
The CB can now buy govies only in the short and long end (Netherland is in a
similar position). We think the CB could start buying supranationals,
inducing further deviation from capital keys.
0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8.00
OBL01/202/23/18
OBL01/404/13/18
BKO006/15/18
BKO009/14/18
BKO012/14/18
OBL102/22/19
DBR31/207/04/19
DBR31/401/04/20
OBL004/17/20
BULABO11/207/15/20
OBL01/410/16/20
OBL004/09/21
DBR21/409/04/21
DBR201/04/22
DBR13/407/04/22
DBR11/202/15/23
DBR11/205/15/23
DBR61/401/04/24
DBR11/205/15/24
DBR01/202/15/25
DBR01/202/15/26
DBR008/15/26
DBR61/207/04/27
DBR43/407/04/28
DBRI01/204/15/30
DBR43/407/04/34
DBR41/407/04/39
DBR31/407/04/42
DBRI0.104/15/46
Billions
-
10
20
30
40
50
60
70
2 2-3.5 3-5 5-7.5 7.5-10.5 10.5-15 15-20 20-30
Billions
Possible amount to buy on each security… …and per maturity bucket.

GERMANY
24
The recent richening of German bunds (and Netherlands govies) does not
seem to be related to safe-heaven flow, rather to expectations of ECB’s
buying. We think we will see a cheapening of the German market versus
swap, absent any turmoil, as QE proceeds (5y preferred short versus long
credit protection).
5y German ASW versus other risk indicators German curve RV (z-score) and avaiable bonds
-2.00
-1.00
0.00
1.00
2.00
OBL01/2…
BKO0…
DBR4…
OBL01/4…
BKO0…
DBR33/4…
DBR31/2…
OBL0…
DBR21/2…
DBR21/4…
DBR13/4…
DBR11/2…
DBR13/4…
DBR01/2…
DBR0…
DBR55/8…
DBR51/2…
DBR41/4…
DBR21/2…
0
20
40
60
80
100
120
0
50
100
150
200
250
300
350
400
ITRXESE ITRXEBE V2X ASWABOBL
0.00
1.00
2.00
3.00
4.00
5.00
6.00
7.00
8.00
OBL01/2…
OBL01/4…
BKO0…
BKO0…
BKO0…
OBL1…
DBR31/2…
DBR31/4…
OBL0…
BULABO1…
OBL01/4…
OBL0…
DBR21/4…
DBR2…
DBR13/4…
DBR11/2…
DBR11/2…
DBR61/4…
DBR11/2…
DBR01/2…
DBR01/2…
DBR0…
DBR61/2…
DBR43/4…
DBRI01/2…
DBR43/4…
DBR41/4…
DBR31/4…
DBRI0.1…
Billions

NETHERLAND
25
Cac 44.6% 46.5%
Non Cac 55.4% 53.5%
0%
3%
6%
9%
12%
15%
18%
21%
24%
27%
30%
33%
7.73 8.59 5.20 -
Duration
Govies 74.7% 85.7%
Regional 0.0% 0.0%
PURCHASE
Similar situation to Germany.

FRANCE
26
Cac 48.6% 39.9%
Non Cac 51.4% 60.1%
0%
3%
6%
9%
12%
15%
18%
21%
24%
27%
30%
33%
7.54 8.03 5.95 8.35
Duration
Govies 76.0% 89.3%
Regional 0.2% 0.1%
Linkers 6.5% 12.6%
PURCHASE

27
ITALY
Cac 45.7% 50.3%
Non Cac 54.3% 49.7%
0%
3%
6%
9%
12%
15%
18%
21%
24%
27%
30%
33%
8.60 8.70 4.61 -
Duration
Govies 97.7% 99.1%
Agencies 2.3% 0.9%
Regional 0.0% 0.0%
Linkers 10.4% 10.9%
PURCHASE
Both Italy’s and Spain’s CBs have bought in the
long end.

SPAIN
28
Cac 52.9% 57.3%
Non Cac 47.1% 42.7%
0
0.03
0.06
0.09
0.12
0.15
0.18
0.21
0.24
0.27
0.3
0.33
8.70 9.11 2.69 6.96
Duration
Govies 91.9% 95.2%
Agencies 5.7% 3.5%
Regional 2.5% 1.3%
Linkers 5.5% 3.9%
PURCHASE

IRELAND
29
Cac 56.6% 44.4%
Non Cac 43.4% 55.6%
0%
3%
6%
9%
12%
15%
18%
21%
24%
27%
30%
33%
8.89 8.71 - -
Duration
PURCHASE
Ireland has started to buy supranational substitutes

BELGIUM
30
Cac 44.8% 38.0%
Non Cac 55.2% 62.0%
0%
3%
6%
9%
12%
15%
18%
21%
24%
27%
30%
33%
9.85 9.81 - 12.94
Duration
Govies 98.9% 99.4%
Agencies 0.0% 0.0%
Regional 1.1% 0.6%
PURCHASE

AUSTRIA
31
Cac 37.3% 37.0%
Non Cac 62.7% 63.0%
0%
3%
6%
9%
12%
15%
18%
21%
24%
27%
30%
33%
9.17 9.33 8.55 -
Duration
Govies 79.3% 91.1%
Agencies 20.7% 8.9%
Regional 0.0% 0.0%
PURCHASE

SUPRANATIONALS
32
PURCHASE
Pool EFSF EIB EU ESM COE
7.22 5.91 7.43 9.50 7.68 5.35
Duration
0%
5%
10%
15%
20%
25%
30%
35%
40%
45%
50%
Purchase
EFSF 31.2%
EIB 40.5%
EU 13.8%
ESM 11.9%
COE 2.6%
Around 140bn left to buy, mainly in EFSF and EIB.

33
1 ECB update
2 QE monitor
Appendix: Cac and Non-Cac securities3

34
Collective action clauses in Euro Cac Model
Available bonds to buy (IMI calculations)
Summary of quorum and approval threshold
requirements in Euro Cac Model (Linklaters)
Contractual provision which enables a qualified majority to modify the
relevant term of bond prospectus and make it binding for all bondholders
ECB position
Recent IMF proposal is to have a single limb voting procedure across
bond series at aggregate level, subject to a single supermajority
requirements (to avoid blocking investors)
ECB cannot restructure
voluntarily as it would constitute
monetary financing. With 33% of
cap, the Cac procedure is already
impaired

35
Collective action clauses in Euro Cac Model
Written consent 66.6% majority
With 33% of cap, the Cac procedure is already impaired
Meeting: 2 steps quorum 66.6% and 75%
majority
ecb percentage %
holdout % 0 10 25 33 40
0 100 90 75 67 60
10 90 80 65 57 50
20 80 70 55 47 40
30 70 60 45 37 30
40 60 50 35 27 20
ecb percentage %
holdout % 0 10 25 33 40
0 100 90 75 67 60
10 90 80 65 57 50
20 80 70 55 47 40
30 70 60 45 37 30
40 60 50 35 27 20
quorum 0 10 25 33 40 50
66 100 85 62 50 39 24
75 100 87 67 56 47 33
85 100 88 71 61 53 41
95 100 89 74 65 58 47
100 100 90 75 67 60 50

36
Collective action clauses in restructuring: no trade
Evolution of % Italian bonds containing CacsPattern on Cac-securities issuance
In a previous work, we calculated that we would need to wait until 2025 to have
a 85% debt with contractual Cac. In an debt swap implemented in the near
future, the probable mechanism* would be to use:
1. statutory clauses for non-Cac-ed securities (Greece) and
2. contractual clauses for Cac securities
Therefore, Cac and non-Cac securities are probably to be considered equal in
term of blocking percentage therefore it is impossible to raise cap.
*«Euro cac and the existing rules on sovereing debt restructuring….», Martinelli, May16
Source: Bloomberg; IMI calculations

37
Collective action clauses pricing
To price the premium /discount of Cac-ed securities, we derive the Cac-ed
securities default probability curve and price the non-Cac-ed securities. This
approach does not distinguish investors’ preference for low coupon, high
convexity, liquidity.
-10.00
-5.00
0.00
5.00
10.00
1.00
8.00
15.00
22.00
29.00
36.00
43.00
Germany
-15.00
-10.00
-5.00
0.00
5.00
1.00
8.00
15.00
22.00
29.00
36.00
43.00
France
-20.00
-10.00
0.00
10.00
20.00
1.00
8.00
15.00
22.00
29.00
36.00
43.00
50.00
Italy
-25.00
-15.00
-5.00
5.00
15.00
25.00
1.00
8.00
15.00
22.00
29.00
36.00
43.00
50.00
Spain
Premium (-) or discount (+) on non Cac securities in main European markets

38
To evaluate the move of the non Cac-ed securities premium, we built an
historical, average index for France, Italy and Germany, finding that:
1. The non Cac premium/discount seems to move together across
markets, with Italy more volatile
-7
-6
-5
-4
-3
-2
-1
0
1
2
3
4
france Germany Italy
Average non Cac-ed premium: similar behaviour across markets

39
2. The value of the convexity in the market explains a significant part of
the move of the non-Cac securities spread.
Average non Cac premium and convexity value in the market (Italy and Germany)
-4
-3
-2
-1
0
1
2
3
4
Oct-14
Dec-14
Feb-15
Apr-15
Jun-15
Aug-15
Oct-15
Dec-15
Feb-16
Apr-16
Jun-16
Aug-16
Oct-16
Dec-16
actual fit
-3
-2
-1
0
1
2
3
actual fit

40
Disclaimer
This marketing communication has been prepared by the Trading Strategist department and is distributed by Banca IMI, a bank belonging to the
Intesa Sanpaolo Banking Group which is authorized to carry out investment services in Italy and is regulated by the Bank of Italy and Consob.
The information contained in this document:
constitutes a marketing communication and, as such, it has not been prepared in accordance with the legal requirements designed to promote the
independence of investment research and is not subject to any prohibition on dealing ahead of the dissemination of investment research;
may differ from the recommendations prepared by financial analysts of the Direzione Studi e Ricerche of Intesa Sanpaolo and distributed by Banca
IMI. The information contained herein does not constitute investment research within in the meaning of applicable regulatory rules in EU, or a
solicitation or invitation, or investment advice, and does not purport to offer legal, tax or any other advice. Neither the Intesa Sanpaolo Banking
Group, nor any officer, representative or employee thereof accepts any liability (for negligence or otherwise) for any direct or consequential losses
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The information and views contained in this communication are based on sources believed to be reliable and in good faith. No representation or
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of the author as of the date of its publication. The views may differ from those of others within the Intesa Sanpaolo Banking Group.
All prices and rates included herein are shown for indication only and should not be relied upon to re-evaluate any positions held by any recipient of
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The views expressed on companies mentioned herein accurately reflect independent, fair and balanced personal views;
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Other information
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Conflicts of interest
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the lending and securities industry, carrying out in particular – through its companies in possession of the necessary authorizations, where required –
investment banking, corporate finance and finance and investment activities – through merchant banking activities and proprietary trading - financial
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financial instruments, portfolio management, including the management of collective investment schemes and the management of multilateral
trading facilities.

41
Disclaimer
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