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Regulator - November 2011

Welcome to our November edition of Regulator.

It's been a significant month for the banking sector with the final passage of legislation to allow the introduction of covered bonds into the Australian market. The market is keenly awaiting a rush of issues, with banks looking to take advantage of issuing covered bonds to foreign investors as an alternative to expensive wholesale funding markets. Rowan Russell and Greg Hammond have been closely following the launch of covered bonds in Australia since an initial draft Bill to amend the Banking Act to allow for covered bonds was published in March this year. In this edition of Regulator they provide an overview of the key features of the framework for covered bonds issuance by Australian ADIs.

Another issue with international attention is the push to increase obligations on product issuers and distributors for the suitability of the products they offer to clients. In their article, Jim Boynton and Minny Siu consider the implementation of suitability tests for product issuers and distributors  in relation to complex investment products in Hong Kong, Australia and Europe.

The price signalling laws have continued to engender debate and as the legislation creeps closer to being passed we thought it was timely to examine the relationship between price signalling laws and continuous disclosure. Caroline Coops considers the potential price signalling implications of a listed entity complying with its continuous disclosure obligations in her article.

As an adjunct to unfair contract terms, a recent decision in the NSW Court of Appeal has again highlighted the issues around enforcing guarantees when loans are provided solely based on security given by the guarantor without assessing the borrower's ability to repay the money borrowed. In her article, Kate Jackson-Maynes provides an overview of the case.

Also in this edition, John Edstein looks at recent high profile court decisions which have served as reminders that many tax consequences for trusts and their beneficiaries hinge on not just regulatory frameworks but the application of basic trust law principles.

Finally, across the globe, changes are afoot to the European Prospectus requirements as the European Commission responds to concerns that issuers are using final terms to disclose information to investors which should be included in underlying or associated supplementary prospectus. The European Securities and Markets Authority is assisting the Commission and has provided technical advice in the form of several proposals. Joe Newitt from our London office details the proposals and the potential consequences for issuers.

I hope you find the commentary and analysis in this edition useful. As always we welcome any feedback or suggestions you may have for future editions.

Best wishes,

Diana Nicholson

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Mallesons hosts lunch for the Hon. Penny Wong 

As part of our Market Regulation Forum series, we hosted a roundtable lunch in Sydney with guest speaker the Hon. Penny Wong, Minister for Finance and Deregulation. This was well attended by over 50 players in the Financial Services sector. Minister Wong shared her views on recent developments in the global financial markets and the Government's plans to ensure the competitiveness of Australia's markets.

10 years of making a difference

This month we are celebrating 10 years of our Mallesons in the Community program.  For more information please see our special 10 Year Anniversary edition of the annual Mallesons in the Community Report

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Key developments in financial sector regulation

IN THIS ISSUE:

The Banking Amendment (Covered Bonds) Act 2011 has amended the Banking Act 1959 to allow Australian banks and other authorised deposit-taking institutions (ADIs) to issue covered bonds.  The amendments became effective on 17 October 2011. Read more

There is a growing trend in a number of countries to impose obligations on issuers and distributors of structured and other complex products to ensure that the investor is experienced enough or qualified to invest. These obligations are in additional to any obligation on financial advisers to ensure that their advice is appropriate. This article compares the tests in Europe, Hong Kong and Australia. Read more

Trust distributions: a time to reflect and to be prepared 

Recent court decisions, legislative changes (both passed and proposed) together with a potentially reinvigorated will on the part of the ATO to test and apply black letter legal concepts, serve as a reminder for trustees and responsible entities that their trusts/schemes are governed not only by regulatory laws but also by general trust law. Read more

As the price signalling laws move closer to being enacted (at the time of writing the laws had passed the House of Representatives, and were awaiting a third reading in the Senate), it is timely to examine the interaction of the price signalling laws with a fundamental obligation imposed upon listed entities: continuous disclosure. Read more

Back to school for final terms

The European authorities are concerned that issuers are using final terms to disclose information to investors which instead should have been included in the underlying prospectus or an associated supplementary prospectus. Read more

Fast Fix loans Pty Ltd v Samardic: Does failure to assess a borrower's capacity to repay make a guarantee taken in connection with that loan unenforceable?

This recent New South Wales Court of Appeal decision suggests that if a lender relies solely on the security provided by a guarantor and does not assess the borrower’s capacity to repay then the guarantee may be unenforceable. Read more