SEC Division of Trading and Markets no-action letter: London International Financial Futures and Options Exchange (LIFFE)

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March 3, 2000

Mr. David R. Merrill Deputy General Counsel Office of the General Counsel Commodity Futures Trading Commission Three Lafayette Centre 1155 21st Street, N.W. Washington, D.C. 20581

Re: Application of the London International Financial Futures and Options Exchange Regarding the Offer and Sale to U.S. Persons of Futures Contracts Based on the FTSE Eurotop 100 Index

Dear Mr. Merrill:

Pursuant to Section 2(a)(1) of the Commodity Exchange Act ("CEA"), 1 the Division of Market Regulation ("Division") of the SEC hereby responds to the request of the CFTC for the SEC's views on the application by the London International Financial Futures and Options Exchange ("LIFFE") to offer and sell to U.S. persons futures contracts on the FTSE International Eurotop 100 Index ("FTSE Eurotop 100" or "Index"). 2 Based on the information provided to the Division, and for the reasons noted below, the Division will not object if the staff of the CFTC takes a no-action position concerning the offer and sale of FTSE Eurotop 100 futures contracts to U.S. persons. 3

I. Applicable Statutory Criteria

Section 2(a)(1)(B)(v) of the CEA prohibits any person from offering or selling a futures contract based on "any group or index of such securities or any interest therein or based on the value thereof" except as permitted under Section 2(a)(1)(B)(ii). Section 2(a)(1)(B)(ii) of the CEA, in turn, permits the designation of a contract market for futures trading on an index or group of securities only if: (1) settlement of the futures contract is limited to the delivery of cash or exempted securities (other than municipal securities); (2) trading in the futures contract is not readily susceptible to manipulation, nor to causing or being used in the manipulation of the price of an underlying security, an option on such security, or an option on a group or index including such securities; and (3) the index or group of securities is a widely-published measure of, and reflects, the market for all publicly-traded equity or debt securities, or a substantial segment thereof, or is comparable to such measure. 4 A foreign board of trade may apply to the CFTC for certification that its futures contract meets the above requirements without seeking or obtaining designation by the CFTC as a contract market. 5

II. Description of LIFFE's Proposal

The Index is designed to measure the collective performance of the most actively-traded common stocks on the major European stock exchanges. Specifically, the Index is based on the prices of 100 European stocks from nine countries. 6 As of October 29, 1999, the Index includes stocks from the following countries: the United Kingdom ("U.K."), Germany, France, Switzerland, the Netherlands, Italy, Spain, Sweden, and Belgium.

As of October 29, 1999, the total market capitalization of the Index was approximately US $3.88 trillion. The company with the largest market capitalization was BP Amoco PLC, which had a market capitalization of US $175.9 billion. The company with the smallest market capitalization was Alusuisse AG, which had a market capitalization of US $3.8 billion. In addition, the highest-weighted stock accounts for only 4.54 % Index's value, while the top three are 11.71 % of the Index's value. Further, the stocks in the Index are diverse, representing 27 industry sectors. 7

In order to ensure that the Index reflects the most liquid stocks on the European stock markets, there are specific Index rules that determine: (1) the countries represented in the Index; (2) the base weightings of the countries in the Index; (3) the stocks from each country represented in the Index; and (4) the weightings of stocks in the Index. First, the FTSE Eurotop 100 Rules ("Rules") provide that only European countries that have stock exchanges with high overall market capitalizations are eligible to be represented in the Index. 8 Second, the Rules provide that country weightings within the Index are determined according to the relative stock market capitalization of countries included in the Index. 9 Third, the Rules provide that only liquid issues are eligible to be included in the Index by selecting individual stocks on the basis of cumulative effective turnover (turnover by value) over the past three calendar years. 10 Fourth, the Rules provide that the stocks selected from each country are weighted based on their market capitalization. In order to ensure that the Index will remain representative of the most actively-traded stocks on the major European stock exchanges, periodic adjustments to the selection and base weightings of countries or stocks will occur annually, immediately following the third Friday in April, provided that all the relevant stock exchanges are customarily open for normal, regulated trading. In addition, the Index will be adjusted to account for corporate actions that involve one or more component companies, such as mergers, and certain other corporate actions by component companies, such as stock dividends or rights offerings. 11 Consistent with the design and operation of the Index, the FTSE Eurotop 100 Rules will continue to provide that any necessary changes will be made in such a way as to result in minimal changes in the value of the Index. For purposes of calculating the Index, the LIFFE will use the last sale price of each component stock, reported by the principal stock exchange in its home country. Countries in the FTSE Eurotop 100 that adopted the Euro on January 1, 1999 are Germany, France, the Netherlands, Italy, Spain, and Belgium. The prices of component stocks in these countries were converted to Euros on this date. Because of this conversion, the stock prices in these countries no longer need to be crossed with another currency to determine the stock prices in Euros. The countries in the Index that have not adopted the Euro are the U.K., Sweden, and Switzerland. For these three countries, on an instantaneous and continuous basis, the value of each component stock in its respective home country currency first will be converted into U.S. dollars and then into Euros, based on the U.S. dollar/Euro exchange rate disseminated by Reuters PLC. 12 Accordingly, for both Euro and non-Euro countries, Index values will reflect the last available component stock prices in Euros. The Index value will be
calculated every 15 seconds every business day from 10:00 a.m. to 5:00 p.m. Central European Time (4:00 a.m. to 11:00 a.m. Eastern Standard Time), at which time trading has ceased on the primary markets in all the countries contained in the Index. In addition, the Index value will be disseminated every 15 seconds to data vendors, such as Dow Jones Telerate, Reuters, and other quote vendors. 13

The LIFFE's application indicates that the unit of trading for Index futures will be Euro 20 times the Index. 14 Prices for the FTSE Eurotop 100 futures will be quoted in the same form as the Index, with the minimum fluctuation of the contract being .5 Index points, equivalent to Euro 10 per contract. The contract months are March, June, September, and December. The LIFFE's Index futures contract is settled in cash, and the last trading day in expiring Index futures contracts will be on the third Friday of the contract month. The settlement value of the Index will be calculated on the last day of trading of the contract month based on the average of the prices of the Index every fifteen seconds between (and including) 12:40 and 13:00 Central European Time (6:40 to 7:00 a.m. Eastern Standard Time). 15 Delivery day is the first business day after the last trading day.

III. Discussion of Statutory Criteria

A. Futures Contract Must Settle in Cash

The settlement of the FTSE Eurotop 100 futures contract is limited to the delivery of cash. Accordingly, because there is no delivery or transfer of securities in the settlement of FTSE Eurotop 100 futures, the first Accord standard is satisfied.

B. Index Must Measure and Reflect Market or Substantial Segment of Market

The CEA requires the Index to be a widely published measure of, and reflect, the market for all publicly traded equity or debt securities or a substantial segment thereof. Among other things, this requirement reduces the likelihood that futures on a securities index could serve as a surrogate for futures on individual component securities, and also minimizes the potential for manipulation. In determining whether a particular stock index measures and reflects the overall equities market or a substantial segment of that market, the Division generally considers the design and structure of the proposed index ( e.g. , number of component securities, capitalization of the index and individual component securities, diversity and weighting of the component securities, and depth and liquidity of trading in the component securities). The SEC also considers the manner in which the proposed index tracks the performance of the overall equities market or an identified segment of the equities market that is substantial. The Division concludes that the FTSE Eurotop 100 measures and reflects the market for all publicly traded equity securities in Europe. First, the 100 stocks in the Index represent a market capitalization of approximately $3.88 trillion 16 and reflect the combined performance of 100 of the largest companies in nine European countries. Second, the stocks in the Index represent 27 industry sectors. Third, no security or group of stocks dominates the Index. For example, the most highly weighted stock in the Index represents 4.54 % of its value, while the top three stocks represent 11.71 % of the value. Finally, the component stocks of the Index are actively traded in their home markets. In this regard, as described above, the stock selection and weighting procedures for the Index should continue to ensure that component stocks are actively traded. The Division believes that the FTSE Eurotop 100 is structured sufficiently broadly to reflect the diverse performance of the major European equity markets because, inter alia , the FTSE Eurotop 100 represents a large portion of the European equity market and includes a wide range of companies from nine countries and many different industry sectors. The Division also believes that the Index is a broad and comprehensive collection of the leading exchange-listed companies from the major European countries. The inclusion of highly-capitalized, widely-held, and regularly-traded European stocks is designed to ensure that the Index accurately mirrors the combined performance of markets in nine European countries. Therefore, the Division is satisfied that the Index measures and reflects the major European equity markets. The Division further notes that the FTSE Eurotop 100 will be a widely published index. According to LIFFE, the Index value will be calculated and publicly disseminated every 15 seconds during market hours. Accordingly, for all of the above reasons, the Division concludes that the Index meets the
requirements of Section 2(a)(1)(b)(ii) of the CEA.

C. Trading in Futures Contract Must not be Readily Susceptible to Manipulation

The Division typically has considered several factors in evaluating whether a futures contract on a securities index is not readily susceptible to manipulation, nor to causing or being used in the manipulation of the price of an underlying security, an option on such security, or an option on a group or index including such securities. These factors include: (1) the number of securities comprising the index or group; (2) the capitalization of those securities; (3) the depth and liquidity of the secondary markets for those securities; (4) the diversification of the group or index; (5) the manner in which the index group is weighted; and (6) the ability to conduct surveillance of the futures contract and the underlying securities. 17 These criteria, along with the requirement that the group or index of securities be broad-based, are designed to ensure that the underlying securities are sufficiently capitalized, liquid, and diverse so as to make the futures and related markets not readily susceptible to manipulation. In addition, these criteria ensure that the index calculation method accurately reflects the value of the component securities and that there is a mechanism in place to detect and deter trading abuses. Relying on the factors listed above, the Division previously has concluded that options and futures on the Eurotop 100, which is the same index as the FTSE Eurotop 100, are not readily susceptible to manipulation. 18 The Division concludes that futures contracts on the FTSE Eurotop 100 are not readily susceptible to manipulation nor to causing or being used in the manipulation of any related market, given the number of components and the diversification of the Index, the market capitalization of the Index, the weighting methodology of the Index, and the deep and liquid markets of the securities comprising the Index. The Division notes that the FTSE Eurotop 100 is comprised of 100 securities that represent a cross-section of the leading European companies. In addition, the Division observes that the Index is capitalization-weighted; the value of a capitalization-weighted index is more difficult to affect than that of a price-weighted index. The Index also has a low concentration of weighting. In this regard, the Division notes that, as of October 29, 1999, no single stock in the Index represented more than of 4.54% the Index's value and the five most heavily weighted stocks accounted for 17.44% of the Index's value. The FTSE Eurotop 100 includes stocks that trade in nine European countries. As of October 29, 1999, the stocks traded in any one country (the United Kingdom) did not represent more than 37.51% of the Index's value. Further, the Index is comprised of securities from 27 industry sectors. 19

As of October 29, 1999, the total capitalization of the FTSE Eurotop 100 was US $3.88 trillion. In addition, the component stocks of the Index are actively traded in their home markets. 20 Based on these factors, the Division believes that it is unlikely that attempted manipulations of the prices of a small number of issues would significantly affect the value of the Index. Another significant factor the Division considers in evaluating the potential for manipulation of proposed index futures contracts is the existence of information sharing agreements between the futures and the underlying securities markets and between the countries in which the component securities trade. Information sharing agreements between the futures and underlying securities markets are important to ensure the availability of information to both markets in order to detect and deter potential manipulations and other trading abuses, thereby making the stock index future less readily susceptible to manipulation. In many cases, without information sharing agreements, the Division would be unable to approve such products. The Division, however, recognizes that, in a multi-country index, the construction of an index, including the diversification and active and deep markets for component securities, can mitigate against the need to require that information sharing agreements be concluded with all of the markets whose securities underlie that index. Indeed, the SEC has commented favorably upon a prior proposal by the FTA to offer and sell to U.S. persons futures contracts on the Eurotop 100, which is the same index as the FTSE Eurotop 100. In that case, the securities from the countries in the Eurotop 100 for which the FTA had information sharing agreements equated to approximately 58% of the Index's value. 21

The Division notes that the LIFFE has exchange to exchange surveillance sharing agreements with the stock exchanges in two countries. In the U.K., the London Stock Exchange ("LSE") and LIFFE have signed a Regulatory Agreement that provides for the exchange of regulatory information regarding FTSE Eurotop 100 futures contracts and component stocks of the Index that are traded on the LSE. 22 In addition, the LIFFE and the Amsterdam Exchanges ("AEX") have signed an agreement which provides for the sharing of regulatory information. 23 The component stocks on the exchanges covered by these exchange to exchange surveillance sharing agreements represent approximately 43% of the value of the Index. In addition to LIFFE's information sharing agreements, the U.K. has entered into the Investment Services Directive ("ISD") with Germany, France, the Netherlands, Italy, Spain, Sweden, and Belgium. 24 Stocks traded on exchanges in these countries account for approximately 90% of the value of the Index. According to LIFFE, the ISD provides a statutory framework for a comprehensive system of cooperation and information sharing among authorities that are responsible for regulating financial services within the European Union. 25 Among other things, the ISD permits the exchange of information concerning the conduct of futures and options trading. LIFFE represents that through the ISD, it can receive information about market trading, clearing activity and customer identity necessary to conduct an investigation. 26

In considering the Index's susceptibility to manipulation, the Division also recognizes, as it has concluded previously with the Eurotop 100, 27 that in a multi-country index the construction of an index, including the diversification, capitalization, and active and deep markets for the component securities, can mitigate against the need to require that comprehensive surveillance sharing agreements be concluded with all of the markets whose securities underlie that index. Specifically, the Index contains several features that make it difficult to engage in intermarket abuses (such as manipulation or frontrunning) using futures on the Index and trading in the underlying cash markets. As noted above, the Index is comprised of the most highly-capitalized, actively-traded securities from the primary markets of nine different countries. Accordingly, because the Index's component securities are spread over nine countries, are diversified by industry sector, and are adjusted in accordance with specific rules designed to maintain specific weightings and relationships, the Division believes it would be difficult to affect the value of the Indexes. In sum, the Division believes that the Index is not readily susceptible to manipulation, and that if a manipulation were nonetheless to occur, it could be detected. While the LIFFE does not have information sharing agreements with all of the countries comprising the Index, no single uncovered country's securities account for more than 14% of the Index weight and no two uncovered countries' securities account for more than 27% of the Index weight. Accordingly, the SEC believes that the proposed Index futures contract is neither readily susceptible to manipulation nor to causing or being used in the manipulation of any related market. In reaching this conclusion and recognizing that the ISD provides an additional mechanism to share information, the SEC nevertheless continues to believe that exchange to exchange surveillance sharing agreements between the LIFFE and other exchanges trading FTSE Eurotop 100 futures, as well as all the exchanges trading component securities of the Index, would be useful in deterring potential manipulations or other improper or illegal trading involving FTSE Eurotop 100 futures. Accordingly, the SEC strongly encourages the LIFFE, as well as other exchanges trading FTSE Eurotop 100 futures and exchanges trading component securities, to continue to work together to finalize formal exchange to exchange surveillance sharing agreements.

IV. Conclusion

For the reasons above and based on the information and representations presented, the Division does not object to LIFFE's proposal concerning the offer and sale of FTSE Eurotop 100 futures contracts to U.S. persons. This conclusion is based solely on the facts and representations contained in this letter. If any of these representations were untrue or if any fact or any term of the contracts were to change in any material respect, or if our understanding proves incorrect, then the Division would have to reevaluate the conclusions reached herein in light of those changes. The Division expresses no view with respect to any other question that the proposed contracts may raise, including, but not limited to, the applicability of other federal or state laws.

Sincerely, Belinda Blaine Associate Director

Section 2(a)(1) of the CEA implements the terms of the 1982 jurisdictional accord ("Accord") between the Securities and Exchange Commission ("SEC" or "Commission") and the Commodity Futures Trading Commission ("CFTC"). Futures Trading Act of 1982, § 101, Pub. Law No. 97-444, 96 Stat 2294 [codified at 7 U.S.C. § 2(a)].

See Letter, with attachments, from David Wenman, Managing Director, LIFFE, to Harold Hardman, Assistant General Counsel, Office of General Counsel, CFTC, dated September 29, 1998 ("LIFFE Letter 1"); Letter from David Wenman, Managing Director, LIFFE, to David R. Merrill, Deputy General Counsel, OGC, CFTC, dated January 4, 1999 ("LIFFE Letter 2"); Letter from Mark Ibbotson, Director, Market Services, LIFFE, to Sharon Lawson, Senior Special Counsel, SEC, dated August 31, 1999 ("LIFFE Letter 3"); Letter from Laurence Walton, Senior Associate, Market Secretariat, LIFFE, to Sharon Lawson, Senior Special Counsel, SEC, dated October 1, 1999 ("LIFFE Letter 4"). Letter from Laurence Walton, Senior Associate, Market Secretariat, LIFFE, to Joseph Corcoran, Attorney, SEC, dated November 9, 1999 ("LIFFE Letter 5").

The Division has previously examined futures contracts based on the Eurotop 100, which is the same index as here. See Letter from William H. Heyman, Director, Division, SEC, to Brian Folkerts, Director, OCG, CFTC, dated May 27, 1992 (raising no objection to the designation of the Commodity Exchange, Inc. as a contract market to trade Eurotop 100 futures and futures options) ("Comex Letter"); Letter from Robert L.D. Colby, Deputy Director, SEC to Blake Imel, Deputy Director, Division of Economic Analysis, CFTC, dated April 15, 1996 (raising no objection to the offer and sale to U.S. persons by the Financiele Termijnmarkt Amsterdam N.V. ("FTA") of futures on the Eurotop 100) ("FTA Non-Objection Letter").

As the SEC has noted in the past, this third criterion is intended, in part, to ensure that a securities index futures contract, or an options contract overlying a securities index futures contract, is not readily susceptible to manipulation and will not function as a surrogate for trading in individual securities or options on those securities. By ensuring that index futures, or options thereon, will not be used as a substitute for related options or stock trading, this requirement also mitigates competitive concerns raised by the regulatory differences between the futures and securities markets or possible insider trading concerns regarding a security underlying an index through transactions in the futures market, or the related options market. See , e.g. , letter from William H. Heyman, Director, Division, SEC, to Joanne T. Medero, General Counsel, OGC, CFTC, dated August 23, 1991 (regarding the application of the Sydney Futures Exchange to permit the offer and sale to U.S. persons of futures contracts overlying the All Ordinaries Share Price Index) ("All Ordinaries No-Objection Letter"); and letter from Richard G. Ketchum, Director, Division, SEC, to Dr. Paula Tosini, Director, DEA, CFTC, dated July 5, 1985 (regarding the application of the Chicago Board of Trade ("CBT") for designation as a contract market to trade futures contracts based on the NASDAQ-100 Index).

The legislative history of the CEA provides: [N]othing in the provisions [of the CEA] prevents a foreign board of trade from applying to the [CFTC] for certification that its futures contracts conform with requirements of the [CEA] where, by its terms, the [CEA] establishes minimum requirements for a specifically identified contract. For example, a foreign board of trade may seek certification from the [CFTC] that a futures contract offered by it that is based upon a group or index of American securities meets the minimum requirements specified in subparagraphs (a) through (c) of Section 2(a)(1)(B)(ii) of the [CEA], without seeking or obtaining designation of the [CFTC] as a contract market. Any such certification is to be conducted under the procedures, and subject to the rights of other persons, set forth in the provision of the [CEA] establishing such minimum requirements.

When the application was originally filed, component stock prices were converted into European Currency Units ("ECUs") to calculate the value of the Index. However, on January 1, 1999, the ECU was replaced by the Euro on a one to one basis. See LIFFE Letter 2, supra note 2.

The Index includes the Automobile, Alcoholic Beverage, Food Product, Household Goods & Textile, Pharmaceutical, Tobacco, Retail Bank, Insurance, Life Assurance, Building Materials & Merchant, Chemical, Diversified Industrial, Electronic & Electrical Equipment, Engineering, Paper Packaging & Printing, Extractive Industry, Oil Integrated, Leisure & Hotel, Media, Food Retailer, General Retailer, Telecommunication, Brewery Pub & Restaurant, Transport, Information Technology, Electricity, and Gas Distribution sectors of the markets. See LIFFE Letter 1, supra note 2.

Specifically, a country must be a European member of the Organization of Economic Cooperation and Development. The country with the primary exchange that has the highest market capitalization at the end of the previous calendar year is chosen first. Additional countries are included in descending order of market capitalization, provided the capitalization of a country's primary stock exchange is at least 2.5% of the aggregate market capitalization of the primary stock exchanges of all the countries that are included in the Index. See LIFFE Letter 1, supra note 2.

Each country is allocated a weighting that is equal to the market capitalization of the stocks on its primary exchange, expressed as a percentage of the total capitalization of all the selected stock exchanges, and rounded to the nearest whole number. Out of the 100 stocks in the Index, each country is assigned the number of stocks equal to the country's weighting in the Index. As of October, 1999, the weighting by country is as follows: U.K. - 34%, Germany - 14%, France - 13%, Switzerland - 11%, Netherlands - 9%, Italy - 8%, Sweden - 4%, Spain - 4%, and Belgium - 3%. See LIFFE Letter 1, supra note 2; LIFFE Letter 5, supra note 2.

Specifically, the FTSE Eurotop 100 rules will continue to require that only stocks that have the highest monetary trading volume over the past three calendar years on the primary exchange of their home country be included in the Index. In addition, the FTSE Eurotop 100 rules provide that certain stocks are excluded from consideration for inclusion in the Index. Specifically, investment company stocks and securities that are not available for investment by foreigners are ineligible to be included in the Index. In addition, if more than one class of stock of the same company meets the selection criteria, only the class with the largest effective share volume will be included. See LIFFE Letter 1, supra note 2.

Operational adjustments to the weightings of stocks to maintain the Index value will be made only when the action by a company would otherwise change the value of the underlying portfolio by more than .01 Index points (1 Euro). See LIFFE Letter 2, supra note 2.

Nonetheless, in the event that there is no price change in a component stock from a non-Euro country, the stock's value will be continuously updated to reflect any changes in the home currency/U.S. dollar exchange rates. See LIFFE Letter 1, supra note 2.

See LIFFE Letter 1, supra note 2.

See supra note 6.

Of the 81 measured values, the highest 12 and the lowest 12 are discarded and the remaining 57 are averaged to calculate the Exchange Delivery Settlement Price. See LIFFE Letter 1, supra note 2.

By way of comparison, when the SEC commented favorably on the CBOT's application to offer and sell futures contracts on the Dow Jones Industrial Average ("DJIA"), the market capitalization of the DJIA was approximately $1.76 trillion. See Letter from Richard R. Lindsey, Director, Division, SEC, to Richard A. Shilts, Acting Director, Market Analysis Section, CFTC, dated August 28, 1997.

See, e.g. , letter from William H. Heyman, Director, Division, SEC, to Joanne T. Medero, General Counsel, CFTC, dated September 24, 1991 (regarding the application of the CBT for designation as contract market to trade options on the CBT's Major Market Index futures contract); and All Ordinaries Non-Objection Letter, supra note 4.

See Comex Letter and FTA Non-Objection Letter, supra note 3.

See supra note 7.

For example, the average daily trading volume in October 1999 for the five most heavily weighted stocks in the Index was: BP Amoco PLC, 5,280,918 shares; Vodafone AirTouch PLC, 70,428,025 shares; Royal Dutch Petroleum, 3,220,107 shares; British Telecommunications PLC, 11,525,075 shares; and Glaxo Wellcome PLC, 5,280,289 shares. See LIFFE Letter 5, supra note 2.

See FTA Non-Objection Letter, supra note 3.

See Regulatory Agreement between the LSE and the LIFFE, dated December 12, 1997.

See Memorandum of Understanding ("MOU") concerning the exchange of information between the AEX and the LIFFE, dated September 17, 1998. In addition to the MOU between the LIFFE and AEX, the governments of the U.K. and the Netherlands have entered into a MOU regarding the exchange of information on securities, futures, and options matters. LIFFE Letter 1, supra note 2.

In addition, the Division notes that the Financial Services Authority is a member of the Forum of European Securities Commissions ("FESCO"). The regulatory authorities comprising FESCO have entered into a Multilateral Memorandum of Understanding on the Exchange of Information and Surveillance of Securities Activities (the "Multilateral MOU") which, among other things, provides for mutual assistance among the parties to the agreement with regard to the investigation and enforcement of laws and regulations relating to insider dealing, market manipulation, and other fraudulent and manipulative practices in securities. Parties to the Multilateral MOU may use information obtained under the Multilateral MOU to initiate, conduct or assist in criminal, administrative, civil or disciplinary proceedings. The Division notes that the regulatory authorities in eight of the nine countries represented in the FTSE Eurotop 100 are parties to the Multilateral MOU.

See LIFFE Letter 1, supra note 2.

See LIFFE Letters 3 and 4, supra note 2.

See Comex Letter and FTA Non-Objection Letter, supra note 3.

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Modified:12/29/2000