© Allen & Overy LLP 2016 The Eurosystem’s Corporate Sector Purchase Programme (CSPP) – opportunities for non-financial corporates and beyond June 2016
© Allen & Overy LLP 2016
The Eurosystem’s Corporate
Sector Purchase Programme
(CSPP) – opportunities for non-financial
corporates and beyond
June 2016
2 The Eurosystem’s Corporate Sector Purchase Programme (CSPP) – opportunities for non-financial corporates and beyond | 2016
© Allen & Overy LLP 2016
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Contents
Introducing the CSPP and our offering 4
CSPP’s Market Segments and A&O’s presence 5
CSPP – Structure and the rules 6
Our key contacts 11
About Allen & Overy 15
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Introducing the CSPP and our offering The complexity of financial market rulemaking, supervision and unprecedented monetary policy activity conducted across
the Eurozone has increased dramatically since the 2008 financial crisis. This includes targeted monetary policy action by
the European Central Bank (ECB) together with the individual Eurozone National Central Banks in the Eurosystem
operating asset purchase programmes across various sectors as part of their monetary policy transmission into the
Eurozone’s ‘real economy’. On 8 June 2016, the Eurosystem’s Corporate Sector Purchase Programme (the CSPP)
commenced operation and began buying euro denominated investment grade bonds provided they meet the eligibility
criteria of the CSPP. The CSPP is a decentralised purchase programme, coordinated by the ECB, with purchases
executed by six Eurozone national central banks (CSPP NCBs) covering specific market segments in both the
primary and secondary debt capital markets, as described on the next page. The ECB has announced that
disclosure of CSPP holdings and the availability to engage in securities lending transactions in respect of those
holdings is scheduled to commence on 18 July 2016. The following provides an overview of the CSPP and the areas
where our ‘ECB CSPP Interest Group’ composed of specialist lawyers can assist.
The scope of assets that are eligible for purchase as part of the CSPP is set out in an ECB Decision, i.e. a binding legal act,
dated 1 June 2016. This is further supplemented by various non-binding but scene-setting ‘CSPP Q&A’ documents as well
as the binding rules and ‘eligibility criteria’ set out in the Eurosystem’s General Documentation which is used for ECB
and Eurosystem collateral operations. Together, these various documents form the ‘CSPP Eligibility Criteria’.
The launch of the CSPP should however, as with other purchase programmes, also be assessed within the wider context
of the new post-crisis Eurozone supervisory environment that impacts banking and capital markets more generally.
This includes various continuing integration efforts such as the Banking Union comprising the ECB-led Single
Supervisory Mechanism (SSM) and the Brussels-based Single Resolution Mechanism (SRM), the Single Rulebook
upon which Banking Union rests, as well as the EU’s ongoing work to complete the EU’s Single Market through its
Capital Markets Union project (CMU) which started in September 2015.
A&O’s ECB CSPP Interest Group is a specialised team made up of lawyers from our debt capital markets (DCM)
practice and our regulatory lawyers focusing on ECB supervisory and monetary policy matters. Our ECB CSPP
Interest Group operates on a multi-jurisdictional and cross-functional basis, bringing together local market insight from
each of our Eurozone and other key global offices. Our ECB CSPP Interest Group is further supported by our
‘Global Markets Group’ which covers and cooperates with local counsel firms in jurisdictions in which Allen & Overy
is not currently based. Specifically, the ECB CSPP Interest Group assists clients in navigating this new complex
environment and seizing opportunities for sell-side and buy-side clients in relation to transactional and regulatory
matters connected with:
New issuances: of financial instruments that
comply with the ECB’s General Documentation;
CSPP Eligibility Criteria compliance: of issuance
and transaction structures in the primary and
secondary markets with the CSPP Eligibility
Criteria including assistance in relation to any
Eurosystem disclosure, reporting or confirmation
requests as well as assistance with CSPP templates
or otherwise;
Purchases and sales: of individual and portfolios
of holdings and related legal and regulatory
due diligence;
Refinancing, restructuring and repacking
transactions: to meet eligibility criteria or Banking
Union specific rules;
Other ECB or Eurosystem monetary policy:
driven purchase programmes or collateral operations
including use of a range of Eurosystem compatible
collateral mobilisation channels;
Structuring and bringing prudential or
loss-absorbency capital instruments to markets:
as well as any entity-optimisation work driven by
legal and regulatory rules; and
Regulatory driven portfolio optimisation: helping
with impact assessments from a prudential capital
or liquidity perspective and proposing efficient
legal structures.
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CSPP’s Market Segments and
A&O’s presence A&O’s ECB CSPP Interest Group has been active in all of the markets in which the CSPP is active. With our monetary
policy and Banking Union regulatory lawyers we have a wealth of experience in coordinating engagement with ECB as
well as the various CSPP NCBs, each of which may have additional CSPP-specific preferences.
CSPP NCBs conducting
purchases
Responsible for market segment in terms
of purchases
ECB CSPP Interest Group
capability on the ground
Belgium:
National Bank of Belgium
– Belgium
– Luxembourg
– Netherlands (with the Netherlands as a
residence country and a country of risk
other than Germany, Spain, Italy)
– Slovakia
– A&O offices in Brussels and
Antwerp
– A&O offices in Luxembourg, the
Netherlands and Slovakia
– Cyprus
– Greece
– Malta
– Portugal
– Slovenia
– Global Markets Group coverage
and transactional expertise
Germany:
Bundesbank
– Germany
– Netherlands (with the Netherlands as a
residence country and Germany as
country of risk)
– A&O offices in Frankfurt,
Düsseldorf, Munich
and Hamburg
– A&O office in the Netherlands
Spain:
Banco de España
– Spain
– Netherlands (with the Netherlands as a
residence country and Spain as a country
of risk)
– A&O offices in Madrid and
Barcelona
– A&O office in the Netherlands
Finland:
Suomen Pankki
– Austria
– Estonia
– Finland
– Ireland
– Latvia
– Lithuania
– Global Markets Group coverage
and transactional expertise
France:
Banque de France
– France – A&O office in Paris
Italy:
Banca d’Italia
– Italy
– Netherlands (with the Netherlands as a
residence country and Italy as a country
of risk)
– A&O offices in Milan and Rome
– A&O office in the Netherlands
6 The Eurosystem’s Corporate Sector Purchase Programme (CSPP) – opportunities for non-financial corporates and beyond | 2016
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CSPP – Structure and the rules The CSPP commenced operations across the Eurozone
on 8 June 2016. The CSPP is the newest addition to the
ECB-led expanded asset purchase programme (APP)1
i.e., “quantitative easing” including through
decentralised purchases conducted by Eurosystem2
national central banks. The ECB describes the APP and
the CSPP as “dynamic and subject to change depending
on the impact against its additional monetary policy
objectives to facilitate stimulus and growth transmission
into the ‘real economy’ of the euro area”
(the Eurozone). The CSPP does not require eligible
bonds to have a minimum yield or minimum issuance
volume or to be eligible for purchase. This means that
even small issuance volumes or those with a negative
yield to maturity are eligible for purchase. Purchases of
nominal marketable debt instruments at negative yield to
maturity or (yield to worst) above the deposit facility
rate are permissible.
Purchases will be conducted in the primary market
(subject to restrictions), in the secondary market and,
where desirable and relevant, following experience on
other Eurosystem APP programmes, through block
trades and other private transactions. Disclosure of CSPP
holdings that have been purchased will be made publicly
available on a weekly basis, without revealing holding
sizes, from 18 July 2016 and updated every Monday
thereafter. This periodic publication will assist in the
disclosure of which CSPP holdings are available for
securities lending activity, which also starts on 18 July
2016.
CSPP – OVERVIEW OF ITS STRUCTURE
AND RULES
The CSPP is built around the ECB coordinating
decentralised purchases that are conducted by six
Eurosystem constituent national central banks
(CSPP NCBs). Additional Eurosystem National
Central Banks might be added to the initial list of CSPP
NCBs as the programme evolves. The CSPP will
initially target purchases:
1 See: http://www.ecb.europa.eu/mopo/implement/omt/html/index.en.html 2 A reference to the Eurosystem refers to the ECB and the national central
banks of the Eurozone Member States.
of investment grade rated debt instruments issued in
euro (EUR) that meet Eurosystem and CSPP
specific eligibility criteria (CSPP Eligible Bonds);
issued by Eurozone domiciled issuing entities of
non-financial corporates (NFCs) or by other eligible
financial market participants that are not regulated
as a ‘credit institution’3 and which meet Eurosystem
eligibility criteria (CSPP Eligible Issuers); and
of CSPP Eligible Bonds that may be guaranteed by
guarantors based in the EEA.
The framework of rules determining the eligibility of
CSPP Eligible Bonds and the running of the CSPP
are composed of the Eurosystem’s eligibility criteria,
as set out in its General Documentation, as modified
by the following components of what then forms the
CSPP Eligibility Criteria:
a) An ECB Decision published on 3 June 2016 is
available at:
http://www.ecb.europa.eu/ecb/legal/pdf/celex_3201
6d0016_en_txt.pdf setting out the broad strokes of
how governance of the CSPP is run and how the
General Documentation is applied in terms of CSPP
Eligibility Criteria (the CSPP Act);
b) ECB/Eurosystem non-public rules setting out
internal procedures, processes and controls, any due
diligence, pre-trade operations and decision-making,
including obtaining quotes, pricing/risk appetites,
execution parameters and post-trade operation of the
CSPP (the CSPP Guideline); as supplemented by:
a) any ad-hoc public or non-public directions; and
b) any ECB and/or CSPP NCB specific
preferences.
Together this framework comprises what can be termed
the CSPP Eligibility Criteria that both CSPP Eligible
Bonds and CSPP Eligible Issuers will need to observe
and comply with. These CSPP Eligibility Criteria are
relevant to CSPP purchases in both the primary and
secondary markets.
3 As defined in Regulation 575/2013 also known as CRR or the Capital
Requirements Regulation.
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CSPP – MARKET SEGMENTS FOR
PURCHASES AND ELIGIBILITY CHECKS
While the CSPP NCBs are responsible for purchases in
their assigned defined market segments, it is the
respective Eurosystem National Central Banks located in
the respective places of issuance of the CSPP Eligible
Bonds that check compliance with the Eurosystem’s
eligibility criteria and the CSPP Eligibility Criteria. The
CSPP NCBs conducting purchases will each be
responsible for specific market segments. The
Netherlands will be subject to ISO’s ‘country of risk’
concept, determined by management location, country of
primary listing, country of revenue and reporting
currency. The allocation of market segments is as set out
in the table on page 5. Consequently, an Irish-listed
CSPP Eligible Bond with its CSPP Eligible Issuer
domiciled in Belgium will have:
its Eurosystem eligibility criteria and CSPP
Eligibility Criteria check conducted by the Central
Bank of Ireland (also the listing authority)
regardless of primary market or secondary market
activity; and
purchase of such an Irish-issued CSPP Eligible
Bond would be conducted by the CSPP NCB
in Belgium.
We would remind market participants that Eurosystem
National Central Banks do not provide pre-structuring
advice or forward guidance in relation to satisfaction of
their eligibility criteria relating to Eurosystem ‘Open
Market Operations’ or for purchases conducted in the
APP. We would add a caveat that even where a debt
instrument may not end up meeting the CSPP Eligibility
Criteria, then, depending on issuance, transaction and
issuer specifics, other options do exist. Consequently, a
debt instrument that is not purchased under the CSPP
might still be eligible for mobilisation using any number
of other collateral channels acceptable to the Eurosystem
or could be included in any number of structuring
options on other Eurosystem programmes and APP
activity.
DRILLING DOWN THE DETAILS FURTHER ON
CSPP ELIGIBLE BONDS AND CSPP ELIGIBLE
ISSUERS
CSPP Eligible Bonds must satisfy all of the following
criteria:
they are eligible as collateral for Eurosystem credit
operations, based on the requirements defined in the
Guideline on the implementation of the Eurosystem
monetary policy framework (ECB/2014/60) (a.k.a
the General Documentation);
they are denominated in EUR;
they have a minimum first-best credit assessment of
at least credit quality step 3 (rating of BBB- or
equivalent) i.e. have at least an ‘investment grade’
rating obtained from an external credit assessment
institution as set out in the General Documentation;
their minimum remaining maturity is at least
six months and their maximum remaining maturity
is no more than 30 years and 364 days at the time
of purchase;
they are non-subordinated issuances;
they are issued by a CSPP Eligible Issuer, i.e.:
− the issuer is incorporated in the Eurozone.
NB:CSPP Eligible Bonds issued by
corporations incorporated in the Eurozone
whose ultimate parent is not based in the
Eurozone are also eligible for purchase under
the CSPP, provided they satisfy all the other
relevant CSPP Eligibility Criteria;
− the issuer of the CSPP Eligible Bond:
− is not a credit institution4;
− is not a ‘supervised entity’ or a member of
a ‘supervised group’, or a subsidiary of a
supervised entity or a supervised group –
each as such terms are defined in the SSM
Framework Regulation5;
− does not have a parent undertaking
(as defined in Article 4(15) of the Capital
Requirements Regulation) that is also a
credit institution (as defined in Article 2
(14) of the General Documentation);
4 As such term is defined in the General Documentation and in the CRR. 5 See: http://www.ecb.europa.eu/ecb/legal/pdf/celex_32014r0468_en_txt.pdf
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− does not have a parent company which is
subject to ‘banking supervision’
(undefined term) outside the Eurozone;
− is not an ‘investment firm’ as defined in
MiFID II6;
− is not a ‘bad bank’ i.e., an asset management
vehicle (as defined in the Bank Recovery and
Resolution Directive and Single Resolution
Mechanism Regulation) or a national asset
management and divestment fund established
to support financial sector restructuring
and/or resolution;
− is not an eligible issuer within the remit of the
ECB-led Public Sector Purchase Programme;
the issuer of the CSPP Eligible Bond has not issued
any of the following instruments, as defined in the
Eurosystem’s Eligibility Criteria:
− an asset-backed security;
− a multi cédula7; or
− a structured covered bond.
Reference to the term ‘corporation’ and how it is used
in the General Documentation includes a wide range
of corporate vehicle types. It should also be noted that
the limits imposed on a CSPP Eligible Issuer in respect
of issuance of other financial instruments would not
necessarily apply to affiliated entities.
CSPP – PURCHASES LIKELY TO BE DRIVEN
BY EUROSYSTEM MONETARY POLICY
OBJECTIVES TO DELIVER STIMULUS TO THE
EUROZONE’S REAL ECONOMY
Whilst the CSPP does not seem to have any hard and
fast rules as to which CSPP Eligible Bonds in the
universe of eligible assets might be viewed more
favourably in comparison to their peers this is likely to
change as deal structures change to meet the CSPP
Eligibility Criteria. Equally, the purchasing behaviour of
the CSPP NCBs in certain sectors and ratings buckets is
6 See: http://eur-lex.europa.eu/legal-
content/EN/TXT/PDF/?uri=CELEX:32014L0065&from=EN which
sets out that: “ ‘investment firm’ means any legal person whose regular
occupation or business is the provision of one or more investment
services to third parties and/or the performance of one or more investment
activities on a professional basis.” It should be noted that the term
‘investment services’ in this context means those services and activities
listed in Section A of Annex I i.e. MiFID Investment Services relating
to any of the instruments listed in Section C of Annex I i.e. MiFID
financial instruments. 7 Debt instruments issued by specific Spanish SPVs enabling a certain
number of small-sized single Spanish covered bonds to be pooled together.
likely to evolve as the CSPP develops and priorities of
how to direct monetary policy through the APP changes.
It should be noted that the CSPP has comparably lower
due diligence requirements than the ECB-led asset-
backed securities purchase programme (ABSPP)
component of the Eurosystem’s APP. That being said,
the CSPP NCBs undertaking the purchases are likely to
consider how a particular issuance fits within the
Eurosystem’s monetary policy objectives. The CSPP
will be subject to full income and loss sharing in the
Eurosystem and thus follow other APP activities and
governance arrangements which includes periodic
reviews of governance and efficacy of the programme.
Therefore, based on the purchasing activity on other
APP programmes, both in the Eurozone periphery and
core jurisdictions, there are some common features that
CSPP NCBs might look at when assessing whether to
purchase a specific CSPP Eligible Bond issuance in the
primary or secondary market. This includes whether the
proposed purchase of the CSPP Eligible Bond:
is in relation to a country and/or industry sector that
is relevant to the Eurosystem’s monetary policy
objective of driving stimulus to the ‘real economy’.
We anticipate that to a certain extent, including as
the CSPP evolves, this might involve an increased
preference for certain CSPP Eligible Issuers (even if
quoting specific issuer names, bonds or notional
amounts may be discouraged when engaging with
the CSPP NCBs) and consideration of the issuances
listed use of proceeds as set out in the offering
documentation. Given the monetary policy aims of
the CSPP it might be conceivable that consideration
is given as to whether use of proceeds are used for
any capital expenditure commitment or dedicated
growth financing;
would help tighten spreads and financing conditions
generally or for peers without distorting
competition; and
is in keeping with the risk appetites and credit risk
performance of peers and/or overall
exposure/concentration in a given sector.
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It should also be noted that even where a CSPP Eligible
Bond might not be purchased by a CSPP NCB in a given
primary market issuance, this does not preclude any
number of purchases of such CSPP Eligible Bond in the
secondary market. Equally, even where a purchase is not
conducted in respect of one issuance of a CSPP Eligible
Issuer in a given period of time, this does not preclude
purchases of other CSPP Eligible Bonds from the same
or an affiliated issuer at a later date.
CSPP – PURCHASE LIMITS AND
CONCENTRATION EXPOSURE
The CSPP, in keeping with other Eurosystem APP
activity, is intended to be dynamic and not designed to
send signals of forward guidance. However, in
connection the start of the CSPP the following
indications on purchase and concentration limits have
been communicated as follows:
purchases are expected to be limited per ISIN to
70% of outstanding amounts subject to an issuer-
group-level benchmark and lower limits for
essentially government-backed entities variously
referred to as ‘public undertakings’, ‘public sector’
or ’public sector corporate bonds’, which are
generally any entity over which a state or other
regional or local authority directly or indirectly
exercises a dominant influence; and
− public undertakings will also be excluded from
primary market purchases due to the Eurosystem’s
general prohibition on monetary financing.
CSPP’S EFFECT ON THE EUROZONE CREDIT
MARKET TO DATE
At launch, it was reported that CSPP NCBs were
particularly interested in CSPP Eligible Bonds from the
utilities, auto, telecommunications, industrials and
consumer goods sectors. Prior to launch of the CSPP,
market and issuance activity between March and
June 2016 was quite buoyant, in particular since the
April 2016 announcements confirmed that CSPP
Eligible Bonds could be issued by CSPP Eligible Issuers
that are “financial corporations other than credit
institutions”. This provision opens up the universe of
CSPP Eligible Issuers and the scope of CSPP Eligible
Bonds considerably to a wider range of market
participants and not just non-financial corporates.
Furthermore, the clarifications from the ECB that CSPP
Eligible Issuers may have non-Eurozone parent entities,
provided the other CSPP Eligibility Criteria are met, has
increased the attraction and potential impact of the CSPP
further.
The clarifications from the ECB prior to the CSPP
launch and publication of the CSPP Act may also over
the longer-term encourage and assist a range of
regulatory driven portfolio reallocation opportunities.
This might also include greater opportunities for
those market participants caught by Solvency II
prudential capital requirements. More generally, these
clarifications in the lead up to launch and the final rules
in the form of the CSPP Eligibility Criteria might assist
certain investors looking to reposition their investment
capital allocation away from debt instruments into
equity holdings.
We would also draw attention to the fact that the criteria
on CSPP Eligible Issuers excludes credit institutions,
third-country banks and investment firms, each as
defined in MiFID II (legislation that is only to come into
full force in 2018) and thus the scope of CSPP Eligible
Issuers could still include a range of regulated and
unregulated fund entities and the bulk of the insurance
community. It remains to be seen whether any CSPP
Eligible Bonds would be purchased by the CSPP NCBs
from these types of issuers. The same is true in relation
to CSPP Eligible Issuers with non-EEA parent
companies. Much will likely depend on the substance
of the business and consideration of whether the use of
proceeds of any CSPP Eligible Bond with an ultimate
non-EEA parent would stimulate growth in the
Eurozone or achieve any of the other monetary
policy aims of the ECB.
As the CSPP evolves, further changes are likely to be
made, possibly after the first six to nine months of
operation when one might expect minor amendments to
fine-tune the CSPP Act. Any further operational
modalities in relation to how transactions are executed,
including block trades, pricing preferences and any
preferences on ‘standardised features’ of the CSPP
NCBs or the ECB expectations in relation to CSPP
Eligible Bonds or any assessment of the impact of the
CSPP on the ‘real economy’ are likely to be included in
the CSPP Guideline. CSPP, however, also, as in other
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APP operations, fits in with the wider regulatory reform
and market integration efforts of the EU.
CSPP AS PART OF THE WIDER EU
REGULATORY REFORM PICTURE
Coinciding with the ECB’s announcement on the CSPP
in April 2016, Lord Hill, who at the time was the EU
Commissioner responsible for the European
Commission’s Directorate General on Financial
Stability, Financial Services and Capital Markets Union
(DG-FISMA), announced a ‘comprehensive review’8 of
liquidity in corporate bond markets. Ensuring that bond
markets are resilient, functioning and more integrated is
a priority of the EU’s delivery of its Capital Markets
Union (CMU) project. The announced comprehensive
review, which follows on from previous CMU-related
industry consultation, will involve input from market
participants as well as from the European Banking
Authority (EBA) and European Securities and Markets
Authority (ESMA). Each of those institutions are
responsible for rulemaking on liquidity calibrations and
implementation of capital requirements measures.
It remains to be seen to what extent liability-driven
investors, non-financial corporates and any associations
of corporate treasurers will be able to direct debate in
this area and more generally whether this
‘comprehensive review’ could be a first step to setting
parameters for an EU-wide legislative regime focusing
specifically on debt capital markets. In any event, the
CMU project and its workstreams are scheduled to be
assessed in a wider-reaching ‘comprehensive stocktake’
on progress and priorities during the course of 2017.
8 See: http://europa.eu/rapid/press-release_SPEECH-16-1527_en.htm
In any event, as with other ECB programmes, monetary
policy action delivered through the Eurosystem’s APP
activity assists the European Commission in advancing
CMU relevant legislative proposals to integrate markets.
In terms of the European debt capital markets, the CSPP,
the outcomes of the comprehensive review of liquidity in
corporate bond markets, might mark a first step to future
EU-led legislative action. An overriding priority in
CMU plans to date is to ensure European capital markets
become increasingly more integrated as part of
completing the EU’s Single Market and driving
Eurozone integration further, so that they over the
medium to longer-term have comparable levels of depth
and liquidity as their North American counterparts.
Whilst on the one hand, this assists in creating a ‘level
playing field’, further changes in the shape and
supervision of business in capital markets also carries
with it horizon risks.
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Our key contacts Allen & Overy’s ECB CSPP Interest Group, composed of DCM and the ECB and Banking Union regulatory specialists
located across the Eurozone and other EU member states, supports internal legal counsel and their internal clients and
stakeholders by bringing together local-market insight from each its Eurozone offices and other key global offices with
specialist advice in relation to ECB and Eurosystem regulatory and monetary policy action. Please do get in contact with
any of the ECB CSPP Interest Group members below or any of the wider network with any queries you may have.
For general enquiries please email: [email protected]
Germany
Christoph Enderstein Partner Germany – Frankfurt Tel +49 69 2648 5890 Mob +49 172 6998092 [email protected]
Marc Plepelits Partner Germany – Frankfurt Tel +49 69 2648 5405 Mob +49 160 7810350 [email protected]
Kai Andreas Schaffelhuber Partner Germany – Frankfurt Tel +49 69 2648 5324 Mob +49 172 6226228 [email protected]
Matthew Howard Partner Germany – Frankfurt Tel +49 69 2648 5750 Mob +49 175 9329586 [email protected]
Dennis Kunschke Senior Associate Germany – Frankfurt Tel +49 69 2648 5895 Mob +49 1725733284 [email protected]
Michael Huertas Associate Germany – Frankfurt Tel +49 69 2648 5463 Mob +49 172 4794963 [email protected]
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United Kingdom
Theo Trayhurn Partner
UK – London
Tel +44 20 3088 2913
Mob +44 7776 240 775 [email protected]
Jamie Durham Partner
UK – London
Tel +44 20 3088 3842
Mob +44 7825 312 213 [email protected]
Tom Grant Partner
UK – London
Tel +44 20 3088 3604
Mob +44 7824 436495 [email protected]
Matthew Hartley Partner
UK – London
Tel +44 20 3088 2824
Mob +44 7733 124 084 [email protected]
Jonathan Mellor Partner
UK – London
Tel +44 20 3088 2813 Mob +44 7767 674403
Jonathan Melton Partner
UK – London
Tel +44 20 3088 2463 Mob +44 7785 500833
Geoff Fuller Partner
UK – London
Tel +44 20 3088 2806 Mob +44 7785 500806
Philip Smith Partner
UK – London
Tel +44 20 3088 2765 Mob +44 7909 926297
Amanda Thomas Partner UK – London
Tel +44 20 3088 2821
Mob +44 7795 396233 [email protected]
Nicole Rhodes PSL Counsel UK – London
Tel +44 20 3088 4408
Mob +44 7584 888703 [email protected]
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Belgium Luxembourg
Sylvia Kierszenbaum Partner Belgium – Brussels and Antwerp
Tel +32 3 287 74 10
Mob +32 495 59 14 66 [email protected]
Frank Mausen Partner Luxembourg
Tel +352 44 445 5329
Mob +352 621 263 528 [email protected]
Henri Wagner Partner Luxembourg
Tel +352 44 44 5 5409
Mob +352 621 267 493 [email protected]
Netherlands
Gerard Kastelein Partner
Netherlands - Amsterdam
Tel +31 20 674 1371 Mob +31 620 138 547
Niels van de Vijver Partner
Netherlands - Amsterdam
Tel +31 20 674 1291 Mob +31 651 289 419
France
Diana Billik Partner France - Paris
Tel +33140065365
Mob +33620428027 [email protected]
Herve Ekue Partner France - Paris
Tel +33140065359
Mob +33620428022 [email protected]
Dan Lauder Partner France - Paris
Tel +33140065339
Mob +33622747561 [email protected]
Julien Sebastien Partner France - Paris
Tel +33140065351
Mob +33622747579 [email protected]
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Spain
Salvador Ruiz Bachs Partner
Spain - Madrid
Tel +34 91 782 99 23 Mob +34 616 620 831
Charles Poole-Warren Partner
Spain - Madrid
Tel +34 91 782 98 53 Mob +34 696 729 497
charles.poole-
Juan Hormaechea Partner
Spain - Madrid
Tel +34 91 782 9845 Mob +34 649 429 364
Italy
Craig Byrne Partner
Italy - Milan
Tel +39 02 2904 9671 Mob +39 335 593 0540
Lisa Curran Senior Counsel
Italy - Rome
Tel +39 06 6842 7537 Mob +39 335 7116210
Cristiano Tommasi Partner
Italy - Rome
Tel +39 06 6842 7583 Mob +39 335 7115503
15
www.allenovery.com
About Allen & Overy As a firm, we have been instrumental in nearly all the major developments in the modern financial markets, starting with
the first-ever eurobond issue in the 1960s. Of the most recent developments, we have a particular track record in liability
management, regulatory capital and capital raisings for financial institutions, debt issues by emerging markets issuers,
sovereign debt offerings and have been involved in numerous landmark transactions since the development of the offshore
RMB market. Our excellence is reflected through our top-tier position in all major legal directories, Thomson Reuters and
Bloomberg debt legal adviser league tables and numerous independent market surveys and awards.
We represent the breadth of market participants on all elements of the transaction lifecycle of debt securities, structured
finance and other financial instruments, including the range of securities financing transactions (repo, securities lending or
margin loan transactions), portfolio sales, block trades, derivatives work and regulatory reporting requirements that are
connected to such instruments. We are retained for both transactional and advisory matters and assist a range of clients,
from non-financial corporate issuers to financial institutions, including underwriters and investors, as well as market
infrastructure providers, in providing proactive and flexible solutions. In addition, we work extensively with national and
EU regulatory and supervisory authorities and are active in many industry associations.
“Allen & Overy is the only firm, of the 50 that appear in the
FT rankings, to have topped the list four times and to feature
in the top three every year since it began 10 years ago. A&O
came first in the rankings in 2014, 2012, 2011 and 2007.” FT INNOVATIVE LAWYERS
16 The Eurosystem’s Corporate Sector Purchase Programme (CSPP) – opportunities for non-financial corporates and beyond | 2016
© Allen & Overy LLP 2016
© Allen & Overy LLP 2016
GLOBAL PRESENCE
Allen & Overy is an international legal practice with approximately 5,200 people, including some 530 partners, working in 44 offices
worldwide. Allen & Overy LLP or an affiliated undertaking has an office in each of:
Abu Dhabi Amsterdam
Antwerp
Bangkok Barcelona
Beijing
Belfast Bratislava
Brussels
Bucharest (associated office) Budapest
Casablanca
Doha Dubai
Düsseldorf
Frankfurt Hamburg
Hanoi
Ho Chi Minh City Hong Kong
Istanbul
Jakarta (associated office) Johannesburg
London
Luxembourg Madrid
Milan
Moscow Munich
New York
Paris Perth
Prague
Riyadh (cooperation office) Rome
São Paulo
Seoul Shanghai
Singapore
Sydney Tokyo
Warsaw
Washington, D.C. Yangon
Allen & Overy means Allen & Overy LLP and/or its affiliated undertakings. The term partner is used to refer to a member of Allen & Overy or an
employee or consultant with equivalent standing and qualifications or an individual with equivalent status in one of Allen & Overy LLP’s affiliated
undertakings. | FR:21698566.6