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IBOR transition: Opportunities and challenges for the asset management industry

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EY Wealth & Asset Management explores the practical implications and the way forward for the transition to the new risk-free rates. This presentation aims to help asset managers and asset owners explore IBOR transition strategies that are compliant and future-focused.

Publié dans : Économie & finance
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IBOR transition: Opportunities and challenges for the asset management industry

  1. 1. IBOR transition Opportunities and challenges for the asset management industry 1 April 2020
  2. 2. Impact on asset managers and products4 Transition progress3 ECB EUR RFR working groups perspective5 How are firms migrating?6 Q&A7 Speaker introduction2 Webinar introduction1 Agenda Joint EFAMA and EY IBOR transition webcast To ask a question during the session, please use the Q&A box to the left of the slides. Q&A Page 1 April 2020
  3. 3. Speakers Joint EFAMA and EY IBOR transition webcast Agathi Pafili Head of EU Government Relations at Capital International Management Company Dr Anthony Kirby EMEIA Wealth and Asset Management Advisory Regulatory Intelligence and IBOR Lead at EY Silvia Devulder Head Geneva Legal, Regulatory and Compliance for Financial Services and IBOR Legal Solution Lead, EY Switzerland Vincent Ingham Director, Regulatory Policy at EFAMA, the European Fund and Asset Management Association Page 2 April 2020
  4. 4. Speakers April 2020 Joint EFAMA and EY IBOR transition webcastPage 3 Dr Anthony Kirby Topic: IBOR transition progress
  5. 5. IBOR: historic background to changes foreseen in the markets April 2020 Joint EFAMA and EY IBOR transition webcastPage 4 Drivers underpinning IBORs reform Systemic risk due to the uncertainty surrounding the durability of IBORs Reluctance from LIBOR and EURIBOR panel banks to submit quotes Charges of attempted manipulation and false reporting Decline in the liquidity within the interbank unsecured funding markets Key reform initiatives by regulators globally and resulting outcomes ► Wheatley review of LIBOR >2012 ► G20 asked the FSB to reform major interest rate benchmarks ► The official sector steering group (OSSG) established 2013 ► IOSCO principles published 2013 ► IBOR market participants group (MPG) established 2014 ► Recommendation to enhance existing IBORs and promote alternative nearly risk-free reference rates (RFRs). ► Working groups convened to propose alternative RFRs. ► Market participants have begun to assess the impacts Interbank Offered Rates (IBORs) impact over $370tn notional value of financial instruments across the globe. Several cases of manipulation by banks of major benchmarks and indices including IBORs have led to considerable censoring and initiation of reform by regulators globally to restore confidence in the reliability and robustness of benchmark rates.
  6. 6. IBOR transition — situation in Europe Joint EFAMA and EY IBOR transition webcast Products affected by LIBOR transition (i.e., reference to floating interest rate benchmarks) 2018 2019 2021 High level timeline Derivatives (ETD, OTC) Loans (Consumer, Bilateral, Syndicated) FRNs Securitizations Exotic derivatives, e.g., CCY swaps, floors and caps Indirectly — funds and mandates (e.g., benchmarks, etc.) Key industry milestones in the UK: Reformed SONIA as alternative RFR for GBP LIBOR IBORtransition Validation of scope High level impact assessment Deep dive gap analysis Implementation program setup and support Embedding new processes LIBOR transitioned out by end 2021 01/04/20 Example timeline for IBOR transition at an asset manager 28 April 2017: reformed SONIA selected 23 April 2018: reformed SONIA benchmark effective Dec 2017: SONIA futures published 1 January 2018: EU benchmark regulation (BMR) effective End 2021: FCA announced support to sustain LIBOR until end of 2021 01 January 2020: BMR transition period ends H2 2019: Term SONIA reference rate available based on reformed SONIA-derivatives market. 17 October 2020: LCH plans Oct 2020 SOFR discounting switch 2 March 2020: BoE/FCA call to MMs to change market convention for new swaps to SONIA 22 June 2020: eurex and LCH plans Jun 2020 €STR discounting switch 30 September 2020: earliest date for withdrawing LIBOR for loans in UK 2020 Page 5 April 2020
  7. 7. Summary of transition progress Joint EFAMA and EY IBOR transition webcast Working groups in each jurisdiction have recommended robust, alternative RFRs to transition away from existing IBORs. The RFR benchmarks are overnight whereas current use of IBORs is largely in term rates. Jurisdiction IBORs GBP LIBOR USD LIBOR EURIBOR, Euro LIBOR CHF LIBOR JPY LIBOR, JPY TIBOR, EUROYENTIBOR Working Group Working group on sterling risk-free reference rates dear CEO letter Alternative reference rates committee Working group on euro risk-free rates National working group on Swiss franc reference Rate dear CEO letter Study group on risk-free reference rates Alternative RFR Reformed sterling overnight index average (SONIA) Secured overnight financing rate (SOFR) Euro short-term rate (ESTER) Swiss average rate overnight (SARON) Tokyo overnight average rate (TONAR) Description ► Unsecured ► Fully transaction-based ► Overnight, nearly risk-free reference rate ► Includes a volume-weighted trimmed mean ► Dear CEO letters issued to banks/insurers in Sep 2018 and asset managers in Feb 2020 ► Secured ► Fully transaction-based ► Overnight, nearly risk-free reference rate that correlates closely with other money market rates ► Covers multiple repo market segments, allowing for future market evolution ► Unsecured ► In Sep 2018 ECB has announced that ESTER is chosen as ARR. Launched Oct 2019 ► Reflects the wholesale borrowing costs of euro area banks ► Dear CEO letter issued by ECB to banks in Jul 2019 ► Secured ► Became the reference interbank overnight repo on 25 August 2009 ► Secured rate that reflects interest paid on interbank overnight repo ► Unsecured, transaction-based ► Uncollateralized overnight call rate market ► The Bank of Japan calculates and publishes the rate daily using information provided by money market brokers, Tanshi ► As an average, weighted by the volume of transactions corresponding to the rate Rate administrator Bank of England Fed. Res. Bank of New York ECB SIX Swiss Exchange Bank of Japan Page 6 April 2020
  8. 8. April 2020 Joint EFAMA and EY IBOR transition webcastPage 7 “Failure to transition away from reliance on the London Interbank Offered Rate (LIBOR) and other unsustainable benchmarks may cause harm to market integrity and poor outcomes for consumers. The FCA has made clear that firms should plan on the basis that LIBOR will cease from the start of 2022. Your firm should recognise its responsibilities to facilitate and contribute to an effective transition to new, more appropriate rates, such as SONIA.” – Marc Teasdale, Director of Wholesale Supervision 20 January 2020 Dear CEO letter on LIBOR from the FCA was addressed to dual-regulated firms and provided indication of the FCA’s broad expectations. “The continued reliance of global financial markets on Libor poses a risk to financial stability that can only be reduced through a transition to alternative risk-free rates (RFRs) by end-2021’ – Financial Stability Report by The Financial Policy Committee The FCA’s ‘Dear CEO’ letter issued (Feb 2020) stated: “LIBOR ending is a market event and the transition to alternatives is market-led. We expect you to take proactive steps now where appropriate and not to wait for instructions from clients…” ► The FCA expects firms to: “… take all reasonable steps to ensure the end of LIBOR does not lead to markets being disrupted or harm to consumers, and to support industry initiatives to ensure a smooth transition” – this is pretty open-ended legally! ► The FCA recognises three key recommendations made by the Bank of England and Working Group on Sterling Risk-Free Reference Rates; ► Nick Miller’s letter features five focal points = 1) Products/Services; 2) Governance/Transition Planning; 3) Alternative Rates/Modelling; 4) 3rd Party Mandate Mgmt; 5) Managing Conflicts; ► The letter draws attention to a particular Q&A focus on Conduct Risk – the hypertext link however links to a FCA page with examples drawn from the sell-side; ► Buy-side conduct risk areas, such as cited on link https://www.fca.org.uk/print/markets/libor/conduct-risk-during-libor-transition published 19th November 2019 are more relevant; ► The new ‘transition for LIBOR’ FCA website hypertext link published - https://www.fca.org.uk/markets/libor. Current Market Position — issue of ‘Dear CEO’ letters by the FCA This follows the issue of ‘Dear CEO’ letters for dual-regulated firms in Sept. 2018
  9. 9. 10 key client considerations Joint EFAMA and EY IBOR transition webcast It’s not just ‘new products’ IBOR has similar traits to previous mega programmes Front to back nature The need for transition enablers Number of external dependencies The challenge of appropriate testing Conduct risk adds complexity Resource constraints Dependency on key internal decisions Unforeseen downstream impact Page 8 April 2020
  10. 10. Why act now? Joint EFAMA and EY IBOR transition webcast Late mobilization of execution could result in: Increased costs in 2021 as compressed timelines and scarcity of talent/SMEs driving project costs higher Increased delivery risk due to reduced ability to proactively manage dependencies and less time contingency Increased operational risk due to reduced time for testing, with potential implications for downstream consumers of data Increased conduct risk, as window to approve new products and migrate clients safely will be compressed Loss of market share and competitive advantage as peers are able to offer alternative products based on RFRs A worse client experience with greater potential for confusion, compounded by their experience at more advanced peer firms Page 9 April 2020
  11. 11. Current market position EY Risk Management for Asset Management Survey — IBOR April 2020 Joint EFAMA and EY IBOR transition webcastPage 10 Comparison of IBOR Risk Themes (NB: Early Stages only) Established governance and organized cross-functional team 73% Started firm-wide impact assessments to identify IBOR exposures 70% 54% 49% 51% 80% Designed strategy to communicate implications/transition activities Implemented 'no regret' actions to support trading of alternative RFRs Firm started reviewed existing contractual fall-back provisions Firm employing derivatives to hedge Established GRC for IBOR migration in each country of scope Managing Conflicts of Interest considered Markets & strategic direction modelled Enterprise Risk Management modelled Valuation & Risk Mgmt. considered (e.g., Value Transfers/Collateral) Capital Requirements and cross-impacts considered Repapering of forward book modelled Repapering of back book modelled (e.g., fall-backs/disclosures, etc.) Cash flow hedges/hedge accounting/IAS39 & IFRS9 modelled Transfer pricing/tax deductabilities, disclosures/returns evaluated Operating models/operational changes to business delivery examined Vendor applications examined and IT impact analysis Communications with end investors started 56% 21% 37% 39% 60% 21% 28% 15% 1% 4% 11% 13% 32%
  12. 12. Current market position WAM Client IBOR Timelines Reflect External Dependencies on Banks April 2020 Joint EFAMA and EY IBOR transition webcastPage 11 More Proactive? More Reactive? ApproachtoIBOR Starting Planning Early Analysis Gap Analysis 46% 22% 32% KEY: Insurer-captive Bank-captive Independent ► Preparations are most advanced for Derivative/Swap-based products and least for Loans. Retail firms are least prepared. The lack of historic data for new RFRs hampered the calculation of stressed Expected Shortfall, and will impact terms and contractual agreements such as fall-back provisions; ► Firms who are captives of banking or insurance-HQd parents tended to leverage their parent entities in order to drive specific ► Firms were relatively concerned at implementing consistent strengthened fall-back language ► Consequences of lagging: 1. There could be extra capital add-ons 2. Extra delivery costs in a distressed environment under tight timeframes leading to conduct/other risks 3. Risk of loss of market-share from more agile competitors
  13. 13. Sector Priorities Program Mobilization and Technology Considerations April 2020 Joint EFAMA and EY IBOR transition webcastPage 12 Federated Centralised 6% 12% 30% 12% 6% 6% 24% Program governance/design/ impact assessment Modelling markets/ Valuations/ Risk Mgt. Product governance and design Repapering fall-back & disclosure legal services Hedge accounting and IFRS modelling Tax deductabilities and tax returns Business/operating model implementation Vendor services and third party coordination 4% Expected areas of spend (Estimate at end 2019)Program Governance
  14. 14. Speakers April 2020 Joint EFAMA and EY IBOR transition webcastPage 13 Silvia Devulder Topic: Continuity of contracts
  15. 15. ► With the UK regulatory announcements on 16 January 2020 re-iterating the need to substantially address the legacy population for GBP trades by Q1 2021 firms must have detailed and robust plans in place for updating legacy documentation ► Most banks are looking to commence repapering of legacy contracts in H2 of 2020 with most firms expecting the process to last at least till the end of 2021 ► Most of the survey participants reported that their legal teams do not have sufficient BAU capacity to cater for reviewing all contracts required as part of the IBOR transition ► Over a third of survey participants stated that their outreach efforts would involve more than 20,000 clients Contract repapering Joint EFAMA and EY IBOR transition webcast Review and remediation of legacy contracts The majority of banks expect to leverage technology to streamline efforts around contracts identification and repapering 33% 33% 24% 19% 14% We are currently analysing available internal technology options and potential external vendor solutions Yes, for identification and scoping Yes, for full end-to-end contract process requirements No Other Note: Percentages do not add up to 100% as some respondents selected more than one answer option. Page 14 April 2020
  16. 16. Specific areas of documentation impact for asset managers April 2020 Joint EFAMA and EY IBOR transition webcastPage 15 Bilateral loan documentation ISDA/CSA Local master agreements In-house derivatives agreements LMA syndicated loan documentation Non-standard syndicated loans Other IBOR impacted agreements GMRA GMSLA Other repo and stocklending agreements Bonds, Floating Rate Notes, Certificates, Commercial paper, etc. 1 Illustrative IBOR referred as Benchmark Investment guidelines IBOR Definition (calculation and purpose) Management objectives Fund prospectus Performance fees Investment strategy
  17. 17. Client transition Joint EFAMA and EY IBOR transition webcast ► Perform contract review and due diligence exercise to identify and remediate impacted contracts, enabled by technology ► Determine client cohorts and set cohort treatment strategy ► Consider conduct risk across the lifecycle of the programme and embed into all workstreams ► Complete client outreach to proactively engage with clients Client cohort-led, Technology-enabled Page 16 April 2020
  18. 18. Speakers April 2020 Joint EFAMA and EY IBOR transition webcastPage 17 Agathi Pafili Topic: ECB EUR RFR working group’s perspective
  19. 19. EUR RFR WG — Key features April 2020 Joint EFAMA and EY IBOR transition webcastPage 18 Mandate ► Strengthening existing interest rate benchmarks by underpinning them with transaction data as far as possible ► Developing alternative, nearly risk-free, reference rates (RFRs) Composition / Governance ► ECB, FSMA, ESMA and the EC initiated the launch of the EUR RFRF WG / first meeting in February 2018 ► Private-led / Industry group chaired by a representative from the private sector / members from major banks ► Secretariat provided by the ECB ► ESMA, European Commission, FSMA and ECB participating as observers ► ISDA, EMMI, EFAMA and other industry representatives participate as non-voting members Major EU interest rates ► Euribor & Euro Overnight Index Average (EONIA) are based on the unsecured interbank market and designated as critical by the EC ► EURIBOR, a quote-based interest rate benchmark, available for several tenors ► EONIA, an overnight reference rate computed on the basis of real transactions in the interbank market, but has showed declining geographic representation of the underlying market
  20. 20. Key deliverables April 2020 Joint EFAMA and EY IBOR transition webcastPage 19 Recommend RFRs consistent with the IOSCO principles & compliant with the EU Regulation on Benchmarks Recommend RFRs as best practice for certain new derivatives and other contracts, including mortgage contracts Alternative RFRs Contract Robustness Legacy contracts Best practices for contract design ensuring robustness and resilience to the possible cessation or material alteration of the underlying benchmark Target: involving a broad group of market participants via consultations and dedicated hearings and outreach ISDA’s role given the ongoing work in the derivatives community Creation of a plan and timeline for the transition from current benchmarks Sub-group for retail contracts in charge of identifying appropriate alternatives for term structured benchmarks
  21. 21. Milestones April 2020 Joint EFAMA and EY IBOR transition webcastPage 20 September 2018: Recommendation for the euro short-term rate (€STER) to become the new euro risk-free rate and replace EONIA / €STER will also provide a basis for developing fallbacks for contracts referencing the Euribor March 2019: Modification of EONIA methodology to become €STR plus a fixed spread until end-2021 to facilitate transition from EONIA to €STR & recommendation for a methodology based on OIS tradeable quotes for calculating a €STR-based forward-looking term structure as a fallback in EURIBOR-linked contracts July 2019: Call for expressions of interest — administrator for a €STR-based forward-looking term structure as a fallback in EURIBOR-linked contracts July 2019: Recommendations on the legal action plan for new and legacy contracts August to November 2019: Reports on the financial accounting and risk management implications of the transition and its impact on cash and derivatives products November 2019: Recommendations for fallback arrangements for the €STR
  22. 22. Latest developments April 2020 Joint EFAMA and EY IBOR transition webcastPage 21 WG’s actions Market & Regulatory developments Euribor fallback provisions ► High level recommendations (November 2019) ► Fallback provisions in all new contracts referencing EURIBOR ► Legacy contracts referencing EURIBOR should be covered by robust written plans ► In legacy contracts without appropriate fallback provisions, EURIBOR fallback provisions should be introduced Seamless transition from EONIA to €STR ► Recommendations to support smooth transfer of EONIA's liquidity to the €STR (February 2020) ► All stakeholders should be made aware that EONIA-linked contracts with maturities beyond 3 January 2022 entail significant risks Feedback on Swaptions ► Public consultation (deadline 30 April) on Swaptions impacted by the CCP discount change from EONIA to the €STR ► Feedback requested as to whether the WG should issue recommendations regarding the voluntary exchange (or lack thereof) of cash compensation between bilateral counterparties to swaption contracts impacted by the CCP discounting switch from EONIA to the €STR. EUR discounting ► Eurex and LCH have announced that EUR discounting will switch from EONIA to €STR on 22 June 2020 ISDA statement ► Consultation on Spread and Term adjustments for fallbacks in derivatives referencing EUR LIBOR and EURIBOR ► Majority of responses ask for ‘compounded setting in arrears rate approach with a backward-shift adjustment’ and a spread adjustment based on a ‘historical median over a five- year lookback period’ EC endorsement of IASB phase 1 on IBOR ► Commission’s endorsement of the IASB phase 1 IBOR amendments in the Official Journal. ► They provide temporary and narrow exemptions to the hedge accounting requirements of IAS 39, IFRS 9 and IFRS 7
  23. 23. Focus on investment funds April 2020 Joint EFAMA and EY IBOR transition webcastPage 22 No official quantitative data on EONIA/Euribor usage as an investment objective for funds across the asset management sector. Nonetheless, the big majority of AMs are in the process of conducting inventories of benchmark usage in anticipation of implementing the transition and assessing compliance with the BMR. EFAMA surveyed its members on the EONIA usage in November 2018 (see WG report as revised in March 2019) with the following results ► Money market and fixed income funds are the main users of EONIA for benchmarking purposes ► No strategy change is expected as EONIA does not have investible constituents, but this would need to be assessed on a case-by-case basis ► The most commonly used instruments referencing EONIA are floating rate notes, repurchase agreements, interest rate derivatives and loan agreements Respondents to EFAMA survey expected more than 12 months being necessary for the transition starting from €STER’s publication The transition includes among others modifications to fund prospectuses, communication with clients and adaptation of systems to cope with EONIA publication on a T+1 basis EFAMA also surveyed its members on the transition impact for cash products and derivatives (see WG report, August 2019). In addition to the previous findings, some funds, e.g., those pursuing liquid strategies and total return/absolute strategies, may use EONIA as a hurdle rate for performance fee calculations. The transition from EONIA to the €STR will therefore also require amendments to the calculation formulas and adjustments to the systems used by fund administrators/ updates to prospectuses The appropriate timing for a move to the €STR will depend on the observed increase in liquidity Risk management implications (see WG report, October 2019) For NAV and risk calculations the new interest rates need to be mapped to the respective instruments and a suitable way needs to be found to move from the old regime to the new (e.g., IT applications) without creating any disruptions or inconsistencies during the transfer, for example regarding the effectiveness of hedges Publication at T+1 could have a substantial impact on internal and external reporting — especially where reports are produced over night The transition could affect existing investment guidelines referring to current IBORs (approval from both fund boards and clients) Communication to clients: fair treatment and adequate disclosures — where relevant renegotiate
  24. 24. BUT … April 2020 Joint EFAMA and EY IBOR transition webcastPage 23 ► There are important steps to take on an individual and bilateral basis — INERTIA NOT AN OPTION ► Following the WG’s recommendations doesn’t constitute a compliance safeguard ► Further engagement with national supervisors and market associations (such as ISDA) working on fallbacks and contract continuity issues is highly recommended and in some cases necessary ► The working group’s recommendations are NOT legally binding on market participants. ► They provide orientation and represent the prevailing market consensus as regards the preferred euro risk-free rate and the transition plan that market participants can put in place. ► Market participants still need to assess internally, negotiate and evaluate options with counterparties/ clients and decide on the right transition plan on a bilateral basis.
  25. 25. Speakers April 2020 Joint EFAMA and EY IBOR transition webcastPage 24 Dr Anthony Kirby Topic: How are firms migrating?
  26. 26. Checklist of 10 things that asset managers are doing to prepare for transition? Joint EFAMA and EY IBOR transition webcast Program mobilization Processes and systems Accounting and Tax Valuation and models Agreements Communication Instruments and portfolios Governance and controls Impact assessment Delegated funds Project governance and PMO with clear roles and responsibilities to drive IBOR transition including high level solution design and communication plan. System capabilities with respect to backward fixing rates and products investigation; high level solution design; contract vendors for system and valuation models to address external dependencies. Inventory the impacted processes, policies and procedures, and update frameworks for fair value measurement and hedge accounting. Continuously analyze and quantify the financial impact of the valuation risk under different scenarios; strategic decisions regarding model redevelopment and impact on the whole value chain of models for second order effects. Inventory impacted customer contracts, and assess whether re-papering (and any updates to risk warnings and disclaimers) is required. Impact assess client agreements, documentation and related processes, such as client consents. Communication plan: clients, vendors, professional counterparties, externally managed funds and external funds, regulators and internal employees. Develop reinvestment strategy for IBOR related instruments; determine the indirect IBOR impact on funds and portfolios, including on value, return or fees of a fund. Review current governance models and existing controls, define a cross-functional governance model, and document and implement changes to control frameworks. Assess impacted products and functions, conduct gap assessment to identify Impacts to business and operating models, particularly concerning data handling; develop a transition roadmap, and implement activities. Start discussions re delegated funds to ensure alignment in transition approach and possible impact. Page 25 April 2020
  27. 27. Why EY for IBOR? Joint EFAMA and EY IBOR transition webcast Strong connections with global regulators, working groups and trade bodies Deep understanding of our clients’ businesses, products and infrastructure Leading market position for IBOR, underpinned by numerous client engagements, accelerators, methodologies and strategic third party partnerships Global integrated team with flexible delivery models and skilled resources across full E2E proposition WHY EY? Page 26 April 2020
  28. 28. Key takeaways Joint EFAMA and EY IBOR transition webcast IBOR transition will require substantial change for asset managers’ business critical functions and systems. Country EY Contact Email Address France Hermin Hologan hermin.hologan@fr.ey.com Germany Patrick Stoess patrick.stoess@de.ey.com Ireland Paul Traynor paul.traynor@ie.ey.com Italy Giovanni Incarnato giovanni-andrea.incarnato@it.ey.com Luxembourg Rafael Aguilera rafael.aguilera@lu.ey.com Netherlands Wim Weijgertze wim.weijgertze@nl.ey.com Nordics Fredrik Stigerud fredrik.stigerud@se.ey.com Switzerland Christian Rothlin christian.roethlin@ch.ey.com United Kingdom Simon Turner sturner@uk.ey.com Page 27 April 2020 For more information, please contact your local EY member office:
  29. 29. EY | Assurance | Tax | Transactions | Advisory About EY EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working world for our people, for our clients and for our communities. EY refers to the global organization, and may refer to one or more, of the member firms of Ernst & Young Global Limited, each of which is a separate legal entity. Ernst & Young Global Limited, a UK company limited by guarantee, does not provide services to clients. Information about how EY collects and uses personal data and a description of the rights individuals have under data protection legislation are available via ey.com/privacy. For more information about our organization, please visit ey.com. Ernst & Young LLP The UK firm Ernst & Young LLP is a limited liability partnership registered in England and Wales with registered number OC300001 and is a member firm of Ernst & Young Global Limited. Ernst & Young LLP, 1 More London Place, London, SE1 2AF. © 2020 Ernst & Young LLP. Published in the UK. All Rights Reserved. EY-000118395-01 (UK) 03/20. CSG London. EYG no. 001647-20Gbl ED None Information in this publication is intended to provide only a general outline of the subjects covered. It should neither be regarded as comprehensive nor sufficient for making decisions, nor should it be used in place of professional advice. Ernst & Young LLP accepts no responsibility for any loss arising from any action taken or not taken by anyone using this material. ey.com/uk