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Financial Markets Conduct Bill - Exposure Draft

6 September 2011

Click here to download this submission as a PDF

Click here to download additional submission as a PDF

Submission Excerpt

TCA’s General Comments

TCA is fully supportive of the intent of the review although there are a number of important areas of uncertainty highlighted below. We are concerned at the short time frame available for submissions and as a result TCA members haven’t been able to fully consider all aspects of the Bill and given the fundamental change in the securities legislation proposed. There are concerns that matters will be overlooked.  Accordingly, we reserve our position so we can submit further at a later date on important matters if necessary.

Our comments in respect of the Exposure Draft focus on areas of particular interest and concern to TCA members as a whole. Individual members will be making their own submissions on matters specific to them where appropriate. 

Our submission does not respond to the format suggested, (although most of the issues we have identified occur in Part 4). We have preferred to discuss the key topics of interest to Trustee Corporations by reference to the section numbers in the draft bill.


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