The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement

Asset Management Approach (Cont.) (2) Rely on the exemption under Article 61 of the FIEA (Article 61 Exemption) • Foreign asset managers may provide a discretionary/nondiscretionary investment management service to Japan DIMS under the Article 61 Exemption • If a Japan DIM has a mandate from a pension fund and a foreign asset manager acquires a mandate from the Japan DIM (i.e., the foreign asset manager is sub delegated the authority to manage the assets contributed by the pension fund), a foreign asset manager may indirectly provide the investment management service to the pension funds Pension Fund Morgan Lewis Japan DIM Article 61(2) Foreign AM 16

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