The Unibanco Letters - Dual-Hatting Regulations and Global Enforcement

Securities Distribution Approach (Cont.) (1) Establish its own distributor (Continued) Market LP funds => Register as Type 2 FIBO ◉ Regulations are less heavy ✰ Capital requirement of JPY 10M If 500 or more investors are acquired, a securities registration statement must be filed (15 day window) No filing under the Investment Trusts and Investment Corporations Act Required to be a member of the Type II Financial Instruments Firms Association (2) Hire a local distributor Need to pay distribution fees As with handling other funds, not necessarily focused only on the group's funds Morgan Lewis 12

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