The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement

Asset Management Approach (1) Establish its own asset manager Regulations are heavy (similar to Type 1) ■ Must be a KK or a foreign equivalent ■ Must have a board of directors and a statutory auditor Capital requirement of JPY 50M ■ NAV requirement of JPY 50M ■ Must notify major shareholders (Note) No capital adequacy ratio requirement Cannot sell funds Required to be a de facto member of the Japan Investment Advisers Association Morgan Lewis 15

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