Monday, May 26, 2008

Wagner-Westerman Managing Directors - Goldman Sachs

Thomas A. Wagner
Daniel Wainstein
Timothy D. Walding
Fred Waldman
John E. Waldron
Kevin A. Walker
Paul Walker
Robert P. Wall
Hueh Ming Wang
Michael W. Warren
Haruko Watanuki
Toby C. Watson
Alan S. Waxman

Nicholas H. Weber
John S. Weinberg
Daniel S. Weiner
Gregg S. Weinstein
Scott R. Weinstein
Stefan Weiser
Richard A. Weissmann
Andrew J. Weisz
George W. Wellde, Jr.
Martin M. Werner
Owen O. West
Matthew C. Westerman*

Saturday, May 24, 2008

Yae - Zucker Managing Directors Goldman Sachs

John M. Yae

Tetsufumi Yamakawa
Goldman Sachs Group Inc. has relocated chief Japan economist Tetsufumi Yamakawa to London from Tokyo, leaving the investment bank's Japanese operations without a head analyst. 9April 28, 2008)

Takeshi Yamamoto

Yoshihiko Yano
Managing Director, Head of M&A in Japan, Investment Banking Division,
Goldman Sachs Japan Co., Ltd.

Shinichi Yokote

W. Thomas York, Jr.*

Managing director,
Head of private wealth management
Goldman, Sachs & Company
1 New York Plaza, 41st Floor
New York, New York 10004
Business Phone: 212-902-8892
Education: BSBA; MBA, Harvard

For Article having an interview with him by Senior Editor Tony Chapelle visit

Wassim G. Younan

Paul M. Young

Thomas G. Young
William J. Young
Pei Pei Yu

Peter J. Zangari

Paolo Zannoni

Yoel Zaoui*
Haitao Zhai
Xing Zhang
Yi Kevin Zhang
Han Song Zhu
Wei Zhu
Joan H. Zief
Lauren J. Zucker

Friday, May 23, 2008

Intersting Articles on Compliance in Investment Organizations

Conflicts of interest chief compliance officers face in implementing compliance programs for investment funds and investment advisers
Thomas M. Majewski. The Journal of Investment Compliance. London: 2006. Vol. 7, Iss. 4; pg. 23

Compensating mutual fund advisers: a return to the basics of properly structured performance fees
F. Scott Thomas, John C. Jaye. The Journal of Investment Compliance. London: 2006. Vol. 7, Iss. 4; pg. 28

The investment company chief compliance officer: three years later - an assessment of the evolution of the role of the CCO
Michael R. Rosella, Domenick Pugliese. The Journal of Investment Compliance. London: 2006. Vol. 7, Iss. 4; p. 16

Hedge fund side letters: guidance for UK managers
Peter D. Astleford, Richard Frase, Andrew Hougie, Stuart Martin. The Journal of Investment Compliance. London: 2007. Vol. 8, Iss. 1; p. 13

NASD expands broker-dealer's duty of best execution
Soo J. Yim, Christie Farris Öberg. The Journal of Investment Compliance. London: 2007. Vol. 8, Iss. 1; p. 25

SEC releases new interpretive guidance on soft dollar arrangements
Stuart J. Kaswell, Alan Rosenblat, Michael L. Sherman. The Journal of Investment Compliance. London: 2006. Vol. 7, Iss. 3; p. 4

Personal trading policies for hedge fund managers
Thomas S. Harman, Monica L. Parry. The Journal of Investment Compliance. London: 2006. Vol. 7, Iss. 2; p. 34

Hedge fund marketing overview
Ethan W. Johnson. The Journal of Investment Compliance. London: 2006. Vol. 7, Iss. 2; p. 48

Adviser recordkeeping requirements
W. John McGuire. The Journal of Investment Compliance. London: 2006. Vol. 7, Iss. 1; p. 43

E-thics: the new moral methodology for business
Paul Johns. The Journal of Investment Compliance. London: 2006. Vol. 7, Iss. 1; p. 83

The new supervisory rules regime: a practical look at areas of exposure for broker-dealers and senior personnel
Bruce Hiler, Thomas Kuczajda, Aseel Rabie. The Journal of Investment Compliance. London: 2006. Vol. 7, Iss. 1; p. 34

Converting hedge funds into mutual funds - a primer
F. Scott Thomas, John C. Jaye. The Journal of Investment Compliance. London: 2005. Vol. 6, Iss. 4; p. 25

The development of a compliance culture
Jeffrey C. Morton. The Journal of Investment Compliance. London: 2005. Vol. 6, Iss. 4; p. 59

The evolution of compliance
Chris Taylor. The Journal of Investment Compliance. London: 2005. Vol. 6, Iss. 4; p. 54

New supervisory control requirements for branch and remote offices
Amy N. Kroll, Anders W. Franzon. The Journal of Investment Compliance. London: 2005. Vol. 6, Iss. 3; p. 32

The role of compliance
The Journal of Investment Compliance. London: 2005. Vol. 6, Iss. 3; p. 4

Registered investment adviser compliance in a hedge fund environment
David A Scott. The Journal of Investment Compliance. London: 2005. Vol. 6, Iss. 2; p. 20

Thursday, May 22, 2008

Martin Roll - CEO of VentureRepublic

Martin Roll, CEO of VentureRepublic, a leading advisory firm on branding, brings more than 15 years of management experience from the international advertising and branding industry to the table. He is a popular speaker at global conferences and at INSEAD business school and has recently published Asian Brand Strategy.
He can be contacted at:

Marketing - Servicing Capability Balance

Servcing capability comes in security market intermediaries with investment in physical facilities, data processing and document production and reproduction capabilities and in human resources apart from buying memberships of various exchanges. As firms invest more and more in servicing capability, they need to invest more in devoping a market their services. Unless they have a big market to cater to they cannot recover their investment in servicing capability.

"The high level of investment necessary to maintain production capabilities and rising cost of R&D for product differentiation, makes strong marketing capabilities and unique brands pre-requisites for modern companies to cover these heavy investments. How can companies and management teams catch up?"

Martin Roll is CEO of Venture Republic and a strategic advisor on branding excellence to corporate boards and top-management teams, provides his view on the above question in an article.

Download it from

Articles on Branding - Interbrand

Choosing a Powerful Brand Name

Picking a brand’s name is an important process

The Living Brand Manual

How to Become a Trailblazer Brand: Reinvigorating your brand's future

Building a Brand from the Inside Out

Ten Thoughts on Branding

Understanding the Purpose of a Corporate Branding Strategy

Brand Building for UBS 2004

Jestyn Thirk-White, Head of Brand Strategy at UBS explained the branding exercise uundertaken by UBS in an article in Admap July/August 2004

Prophet, a San Francisco based brand consultancy closely associated with branding guru David Aaker was the partner in the exercise.

The foundation of the new brand strategy was an in-depth understanding of the
needs and desires of the target market,which was developed through a market research
project. In three phases, 3,500 clients and potential clients and 300 staff in 14
countries were interviewed.

The qualitative phases used Wirthlin Worldwide’s VISTA (Values in Strategy assessment) methodology, which was used determining the relative importance of financial services characteristics,understand the connections between those characteristics and higher-order needs, and assess which characteristics were positively or negatively associated with UBS.

Quantitative research was conducted to test the appeal and potential for differentiation of specific benefit statements developed different client segments, based on input from the qualitative research and an understanding of business model and offering.

It was found that from CEOs to retail clients, what clients and potential clients wanted most from a relationship with a financial services provider was confidence in the financial decisions they were making – be it a merger or the choice of mutual funds to invest in.

Business group interests are protected through a matrix management structure,
in which the heads of marketing of each business group are also part of the brand
management team, and formally responsible,together with the head of brand
management, for the development of the brand. Agency rivalries were eliminated
with the adoption of a single advertising agency globally (Publicis), again tasked
with ensuring consistency of message around the world and across businesses
and product areas.

To start addressing these issues, we have run several training initiatives,
focused on two core constituencies: middle management – the top 600 members
of the firm – and ‘brand influencers’. Brand influencers are a diverse group
who either create communications materials for UBS, or have influence over the
behaviour of UBS employees – this includes members of the various marketing
departments within the firm, people from media relations, investor relations,
employee communications, HR training and recruitment staff, product development
staff, etc. Training for middle management took place as part of the firm’s annual Senior Leadership Conference,and was more strategic in nature,explaining the rationale for the brand, what it should mean to their businesses and how they could help make it a reality. Brand influencer training is much more hands-on, and designed to help people use the brand identity in the development of communications messages,training programmes and new products and services. Ongoing communication
and training about what the brand means for UBS and how it should be reflected in
everything we do remain a key goal.

In the last year we have centralised our brand communications management,
development and spending, retired the PaineWebber and Warburg brands,
adopted a single UBS brand, transformed its communications messaging and strategy
and launched a high-profile new brand campaign, all with the aim of starting
to match our brand strength to our undoubted business strength.

The authors concludes the article on a positive note.

So, will it work? The simple answer is: we don’t yet know.
However, early signs are encouraging. The January survey showed that, despite fairly
low advertising presence in the second half of 2003, the introduction of the single
brand had already had a positive effect in our business-to-business client segments,
where the removal of our competing brands has helped to halve the gap between familiarity with UBS and familiarity with key competitors in the US, our
highest-priority market. We are looking forward to the results of our next survey,
available late this summer, and hoping that we have made good progress towards
making the invisible giant more visible.

For some more information visit

Training Connection LLC - Chicago - Customer Service Training

Training Connection LLC is a computer and business skills training company.
230 W Monroe Street
Suite 610
Illinois 60606


Our Training Philosophy

Our main focus is to provide exceptional computer desktop and business skills training. We strive to achieve this by following a 5 cornerstone approach:

1. Our Instructors

Without a doubt our most valuable assets and the most important cornerstone to providing exceptional training. We hand pick our instructors carefully making sure that:

They are expert in their chosen field.
They have valuable Real World experience they can share with their classes.
They have a passion for teaching and sharing their knowledge.
They are great communicators and they are very approachable.
All our instructors need to maintain and overall student rating of above 90% to remain in our program.

2. Ease of Booking

Our website allows you to easily check course outlines, upcoming class dates, availability, student testimonials, instructor bios, our great package deals and of course book training online. Of course bookings can be placed over the phone by calling 312.698.4475 or email.

3. Modern spacious training facility

There is nothing worse that training in cramped training rooms with old grimy computers. Training should be a pleasant experience in pleasant environment.

Our facilities include:

Spacious training labs with ergonomically designed desks and chairs.
State of the art Intel Core Duo computers with 20" flat screen monitors.
Data projectors and white boards in every lab.
Comfortable breakout facility with plasma TV.
Fresh brewed Starbucks coffee and filtered water.
4. Great Customer Service

Each training center has customer service staff employed to ensure you have a great experience and you are well looked after. Our training center staff are friendly and polite and will see to your needs.

5. After the Course

After completing of our hands-on training courses its time to unwind. What better way to unwind than watching a movie. As a small thank you for your patronage please enjoy 2 AMC movie vouchers on us.
Also if you wish to repeat any class, you can do so free of charge for up to 6 months from your original class

Exceptional Customer Service

Course Description
It is estimated that it costs 40% more to sell to a new customer than to an existing customer. Delivering excellent customer service is paramount to any business's long-term survival.

This Customer Service course provides guidelines and best practices for providing excellent customer service that will enable front-line associates and service staff in back-up and support roles to build, maintain, and increase a loyal customer base.

Target Audience
This Customer service training is recommended for customer service professionals, service agents, front-line workers, managers, supervisors and business professionals, who wish to specialize in the customer service business segment. This course is also applicable as a refresher course.

Leaning Objectives
Upon successful completion of this Customer Service training class students will be able to:

Maintain a Positive Attitude.
Show Attentiveness to Customers.
Build Rapport with Customers.
Use Customer Friendly Language.
Deal Effectively with Customer Complaints and Problems.
Handle Angry and Difficult Customers.
Interpret Non-Verbal Communication.
Provide Quality Service over the Phone.
Communicate Effectively through E-mail.

The company has trained Goldman Sachs employees

Course Outline

Customer Service Fundamentals

Rediscover Importance Of Customer Service
Who Are Your Customers?
Company Loyalty
Personal Responsibility In Customer Management
Setting Goals For Learning And Application
Simulation Activities based on participant experience
Revisit Customer Service Strategy
Review Service Attitude And Customer Expectations
How To Build Rapport With Language
Tips On Non-Verbal and Telephone Etiquette
Make Your Customer Service Strategy Competitive
Simulation Activities based on participant experience

Customer Service Process and Strategy

Positive Attitude And Motivation Techniques
Tips On Improving Quality Of Your Service
The Customer Service Process
Problem Resolution And Recovering Customer Relationship
Learning From Problem Resolution
Simulation Activities Based On Participant Experience

Customer Management
Taking Responsibility And Exercising Discretionary Skills
Preventing Dissatisfaction
Non-Verbal And Verbal Do's And Don'ts
Handling Complaints, Upset And Angry Customers
Stress Management
Simulation Activities Based On Participant Experience

Customer Communication

Identify the Importance of Effective Communication
Special Attention To Telephone Skills
Revisit Your Telephone Service Script
Email And Follow-Up Communications
Compose Effective And Professional E-Mail Messages
Review Principles, Simulation Activities, And Set Application Goals

Edward Jones - BusinessWeek customer service ranking

February 2007

The global financial-services firm Edward Jones is the highest-ranking brokerage firm
on BusinessWeek magazine's first-ever ranking of “Customer Service Champs.”

The St. Louis-based firm ranked No. 6 among 25 national and international companies that -- according to the magazine's March 5 edition -- are the "best providers of customer service."

The BusinessWeek list ranks the best providers of customer service, and digs into the techniques,strategies and tools they use to deliver great service, according to the magazine.

"Edward Jones ranked 50 points higher than average full-service brokers overall," the magazine reported. "Their financial advisors, which received high marks for knowledge levels, scored 11.9 points higher than the industry average."

Said James D. Weddle, managing partner of Edward Jones. "It's another reflection of our commitment to providing outstanding service to our clients, the true judges of service quality."

To launch the process, BusinessWeek created a list of companies based largely on brands in J.D.Power & Associates' database. In addition, the magazine polled 3,000 of its readers, generating a pool of names most associated with treating customers well. J.D. Power then surveyed customers about the brands that were nominated by readers but not already in its database.

In addition to the BusinessWeek accolades, Edward Jones ranks highest in full-service investor satisfaction for the second consecutive year, according to the J.D. Power and Associates 2006 Full Service Investor Satisfaction Study(SM). The firm ranked highest by J.D. Power and Associates in 2005, and highest in 2002, when the study began. Recently, Edward Jones in Canada announced the firm's highest ranking in J.D. Power and Associates' Canadian study.

Raymond James Financial was ranked 16th in the list.

Stock Broker Adopts Stock broker follows the Southwest Airlines People Strategy

American Portfolios Financial Services, Inc. (APFS) is a full-service broker/dealer and registered FINRA/SIPC member firm whose primary function is to support independent financial professionals in private practice. The firm currently has close to 500 highly seasoned affiliated representatives located in over 200 branch locations throughout the nation.

APFS has created a decidedly competitive presence in the industry as one of the top 50 independent broker/dealers in the country. The firm offers a full range of: 1) non-proprietary investment products, 2) personal services such as insurance planning, retirement, estate and college planning, 3) full service securities brokerage through dual clearing relationships with Bear, Stearns Securities Corp and Pershing, LLC and 4) fee based asset management services through parent company subsidiary, American Portfolios Advisors, Inc. (APA).

Lon Dolber, president of American Portfolios, loves everything about the way Southwest Airlines does business. He flies with the carrier every opportunity he gets, appreciates it safety record and even likes its customer service policy.

But what impresses Dolber most about Southwest is that employees have ownership in the airline. Ownership, Dolber said, motivates employees to make the business successful.

On Sept. 10, 2001, Dolber and another founder, Russell Clark, opened American Portfolios Financial Services. 200 brokers or "registered representatives," who were previously at Nathan & Lewis, joined them quickly. Prior to this business venture Dolber worked at Nathan and Lewis and made his business model known to his superiors as well as colleagues.

According to Dolbers, The brokers own the company and therefore they care about it.

While employees are given stock options, brokers are issued units of participation that are only of value at the time of a triggering event - such as an acquisition or an initial public offering.

He gives employees a copy of "Nuts!: Southwest Airlines' Crazy Recipe for Business and Personal Success."

Dolbers recruit only brokers with good track records, and if necessary, he helps brokers get space and equipment. He provides an attorney to negotiate a lease, pays for the license transfer and assists with obtaining errors and omissions coverage. And, like a franchisor, he provides training for being in private practice.

according to Tom Wirtshafter, an investor in American Portfolios who sits on its board Lon created a place where brokers feel wanted and respected. He adds taht Lon understands how to treat brokers because he was one himself.

Customer Service - 1

Customer service is a very important concept for security market intermediary organizations. They are in the service business. Customer interacts with them frequently. It is a highly competitive business with a large number of stock broking companies who are members of recongnized stock exchanges, a large number of mutual funds and investment banks.If some firms succeeded and garnered large market shares, customer services was responsible for it.

Customer Service - Articles

How To Keep Your Customers Coming Back - Understanding Customer Retention

Motivate Your Team For Outstanding Customer Service

25 Ways to Keep Customers for Life

Tuesday, May 20, 2008

Goldman Sachs - Current Management - 20 May 2008

Board of Directors

Lloyd C. Blankfein
Chairman and Chief Executive Officer

Jon Winkelried
President and Co-Chief Operating Officer

Gary D. Cohn
President and Co-Chief Operating Officer

John H. Bryan

Claes Dahlbäck

Stephen Friedman

William W. George

Rajat K. Gupta

James A. Johnson

Lois D. Juliber

Edward M. Liddy

Ruth J. Simmons

John F. W. Rogers
Secretary to the Board

Executive Committee

Lloyd C. Blankfein
Chairman of the Board and Chief Executive Officer
Mr. Blankfein has been the Chairman and Chief Executive Officer since June 2006 and a director since April 2003. Previously, he had been the President and Chief Operating Officer since January 2004. Prior to that, from April 2002 until January 2004, he was a Vice Chairman of Goldman Sachs, with management responsibility for Goldman Sachs’ Fixed Income, Currency and Commodities Division (FICC) and Equities Division (Equities). Prior to becoming a Vice Chairman, he had served as co-head of FICC since its formation in 1997. From 1994 to 1997, he headed or co-headed the Currency and Commodities Division. Mr. Blankfein is not on the board of any public company other than Goldman Sachs. He is affiliated with certain non-profit organizations, including as a member of the Harvard University Committee on University Resources, the Advisory Board of the Tsinghua University School of Economics and Management and the Governing Board of the Indian School of Business, an overseer of the Weill Medical College of Cornell University, and a director of the Partnership for New York City and Catalyst.

Jon Winkelried
President and Co-Chief Operating Officer
Mr. Winkelried has been President and Co-Chief Operating Officer and a director since June 2006. Previously, he had been the co-head of Goldman Sachs’ Investment Banking Division since January 2005. From 2000 to 2005, he was co-head of FICC. From 1999 to 2000, he was head of FICC in Europe. From 1995 to 1999, he was responsible for Goldman Sachs’ leveraged finance business. Mr. Winkelried is not on the board of any public company other than Goldman Sachs. He is also a trustee of the University of Chicago.

Gary D. Cohn
President and Co-Chief Operating Officer
Mr. Cohn has been our President and Co-Chief Operating Officer and a director since June 2006. Previously, he had been the co-head of Goldman Sachs’ global securities businesses since January 2004. He also had been the co-head of Equities since 2003 and the co-head of FICC since September 2002. From March 2002 to September 2002, he served as co-chief operating officer of FICC. Prior to that, beginning in 1999, Mr. Cohn managed the FICC macro businesses. From 1996 to 1999, he was the global head of Goldman Sachs’ commodities business. Mr. Cohn is not on the board of any public company other than Goldman Sachs. He is affiliated with certain non-profit organizations, including as a member of the Treasury Borrowing Advisory Committee of the Securities Industry and Financial Markets Association and as a trustee of the Gilmour Academy, the NYU Child Study Center, the NYU Hospital, the NYU Medical School, the Harlem Children’s Zone and American University.

John S. Weinberg
Vice Chairman
Mr. Weinberg has been a Vice Chairman of Goldman Sachs since June 2006. He has been co-head of Goldman Sachs’ Investment Banking Division since December 2002. From January 2002 to December 2002, he was co-head of the Investment Banking Division in the Americas. Prior to that, he served as co-head of the Investment Banking Services Department since 1997. He is affiliated with certain non-profit organizations, including as a board member at NewYork-Presbyterian Hospital, The Steppingstone Foundation, the Greenwich Country Day School and Community Anti-Drug Coalitions of America. Mr. Weinberg also serves on the Visiting Committee for Harvard Business School.

J. Michael Evans
Vice Chairman
Mr. Evans has been a Vice Chairman of Goldman Sachs since February 2008 and chairman of Goldman Sachs Asia since 2004. Prior to becoming a Vice Chairman, he had served as global co-head of Goldman Sachs’ securities business since 2003. Previously, he had been co-head of the Equities Division since 2001. Mr. Evans is a board member of CASPER (Center for Advancement of Standards-based Physical Education Reform). He also serves as a trustee of the Bendheim Center for Finance at Princeton University.

Michael S. Sherwood
Vice Chairman
Mr. Sherwood has been a Vice Chairman of Goldman Sachs since February 2008 and co-chief executive officer of Goldman Sachs International since 2005. Prior to becoming a Vice Chairman, he had served as global co-head of Goldman Sachs’ securities business since 2003. Prior to that, he had been head of the Fixed Income, Currency and Commodities Division in Europe since 2001.

David A. Viniar
Executive Vice President and Chief Financial Officer
Mr. Viniar has been an Executive Vice President of Goldman Sachs and Chief Financial Officer since May 1999. He has been the head of Operations, Technology, Finance and Services Division since December 2002. He was head of the Finance Division and co-head of Credit Risk Management and Advisory and Firmwide Risk from December 2001 to December 2002. Mr. Viniar was co-head of Operations, Finance and Resources from March 1999 to December 2001. He was Chief Financial Officer of The Goldman Sachs Group, L.P. from March 1999 to May 1999. From July 1998 until March 1999, he was Deputy Chief Financial Officer and from 1994 until July 1998, he was head of Finance, with responsibility for Controllers and Treasury. From 1992 to 1994, he was head of Treasury and prior to that was in the Structured Finance Department of Investment Banking. He also serves on the Board of Trustees of Union College.

Gregory K. Palm
Executive Vice President, General Counsel and Secretary of the Corporation
Mr. Palm has been an Executive Vice President of Goldman Sachs since May 1999, and General Counsel and head or co-head of the Legal Department since May 1992.

Esta E. Stecher
Executive Vice President, General Counsel and Secretary of the Corporation
Ms. Stecher has been an Executive Vice President of Goldman Sachs and General Counsel and co-head of the Legal Department since December 2000. From 1994 to 2000, she was head of the firm's Tax Department, over which she continues to have senior oversight responsibility. She is also a trustee of Columbia University.

Alan M. Cohen
Executive Vice President and Global Head of Compliance
Mr. Cohen has been an Executive Vice President of Goldman Sachs and Global Head of Compliance since February 2004. From 1991 until January 2004, he was a partner in the law firm of O'Melveny & Myers LLP.

Management Committee
As of April 2008

Lloyd C. Blankfein
Jon Winkelried
Gary D. Cohn
John S. Weinberg
J. Michael Evans
Michael S. Sherwood
Kevin W. Kennedy
Richard A. Friedman
Gregory K. Palm
Masanori Mochida
David A. Viniar
Christopher A. Cole
Esta E. Stecher
David B. Heller
Marc A. Spilker
Edward C. Forst
Richard J. Gnodde
Richard M. Ruzika
Yoel Zaoui
Gordon E. Dyal
David M. Solomon
Edith W. Cooper
Edward K. Eisler
Gwen R. Libstag
John F.W. Rogers
Pablo J. Salame
Donald R. Mullen
Harvey M. Schwartz
Alan M. Cohen

Goldman Sachs Global Leaders 2008

Since 2001, the Goldman Sachs Global Leaders Program (GSGLP), developed by The Goldman Sachs Foundation and IIE, has been a pioneer in identifying and developing some of the world's most promising future leaders. Students are selected through a rigorous competition on the bases of academic excellence and leadership potential. This year 150 outstanding second-year students were selected this spring from over 100 of the world's top colleges and universities.

Over the past eight years, 900 students from more than 20 countries have been honored as Goldman Sachs Global Leaders. They have built an extensive network with each other and, with modest seed funding from the program's Social Entrepreneurship Fund, have joined forces to launch innovative social ventures, including a school in rural India, a technology education program in China, an art therapy program for AIDS-affected children in Namibia, and a micro-enterprise initiative for women entrepreneurs in Macedonia.

Each Global Leader receives a $3,000 grant for educational expenses, as well as continued support for their academic and professional advancement through an international alumni network. In addition, 75 of this year's 150 Global Leaders, including 15 from Indian universities, will be selected to participate in the annual Goldman Sachs Global Leadership Institute in July in New York City. At the Institute, they will engage in meaningful dialogue with experts from the private, public and nonprofit sectors about their own leadership roles and critical global issues such as environmentalism and emerging markets. Past Institute speakers have included executives from Goldman Sachs and other companies, diplomats from the United Nations, and leaders of influential non-governmental organizations.

"Our world today requires leadership that is culturally fluent and well-prepared to address complex issues that have global impact," said Stephanie Bell-Rose, President of The Goldman Sachs Foundation. "This program invests in the talented young people who make up the next generation of global leaders to ensure that they possess the skills and the networks they need to lead us to a better future."

According to IIE President and CEO Allan Goodman, the Goldman Sachs Global Leaders Program addresses the critical need to develop leaders for an interdependent globe. "These students have an extraordinary understanding of the world around them, and an unwavering desire to continue to learn how to work across cultural and national borders to solve global problems. Through the Global Leaders Program, they are learning to think and work in ways that will prepare them for a world in which international cooperation will offer the best solutions to our most pressing political, social, and humanitarian concerns," he said.

The Goldman Sachs Foundation was funded in 1999 with a $200 million donation from The Goldman Sachs Group, Inc. The Foundation's mission is to promote excellence and innovation in education worldwide. The Foundation is an important extension of the tradition of philanthropy and public leadership at Goldman Sachs. Grants have been awarded in excess of $114 million since its inception, providing opportunities for young people in more than 20 countries.

The Institute of International Education (IIE) is a leading nonprofit organization specializing in the international exchange of people and ideas. Its expertise enables institutions and individuals to build capacity in their home countries and regions. IIE designs and implements over 200 programs of study and training for students, educators, young professionals, and trainees from all sectors with funding from government and private sources. These programs include the Fulbright Student and Scholar programs as well as corporate training and scholarship programs. IIE also conducts policy research and provides advice and counseling on international educational opportunities. The Institute of International Education has a network of 19 offices worldwide, over 900 college and university members, and more than 5,000 volunteers.

An independent nonprofit organization founded in 1919, the Institute of International Education (IIE) is among the world's largest and most experienced international education and training organizations. The Goldman Sachs Foundation awarded a grant to IIE to create the Global Leaders Program, and IIE administers the Goldman Sachs Global Leaders Program in partnership with The Goldman Sachs Foundation. With a mission of Opening Minds to the World®, IIE assists donor agencies to build the international competence necessary to address global problems and forge creative solutions. Last year, more than 20,000 men and women from 175 countries received scholarships and professional training through IIE programs.

Fifty-eight Institute grantees, Trustees, and Fulbright alumni have been awarded Nobel Prizes. One of IIE's key goals is to build leadership skills and enhance the capacity of individuals and organizations to address local and global challenges. In addition to administering the Fulbright Student Program on behalf of the U.S. Department of State since that program's inception, the Institute also designs and implements international exchange and scholarship programs on behalf of many far-sighted donors and sponsors, including governments, foundations, and corporations around the world.

Brand Building Efforts - Buildings with Names

2007 news

London-based Barclays PLC, one of the world’s largest banks, sought to pump up its anemic U.S. brand by agreeing to pay nearly $400 million over 20 years for the right to have its name on an arena in Brooklyn that hasn’t even been built. The bank proudly took out full-page color ads in The New York Times and Wall Street Journal trumpeting the Frank Gehry-designed Barclays Center, which developer Bruce Ratner hopes will be built by 2009 as the new home of the New Jersey Nets basketball team.

Newark, N.J.-based Prudential Financial Inc. agreed to pay $105 million over 20 years for the name PrudentialCenter on an arena being built in the company’s hometown.

Last fall, New York-based Citigroup Inc. agreed to pay the New York Mets $400 million over 20 years to call the team’s new baseball stadium in Queens, N.Y., Citi Field.

Building a Brand on the Touchpoints That Count

Building a Brand on the Touchpoints That Count

Brand investments that customers customers truly value

By Suzanne Hogan, Eric Almquist, and Simon E. Glynn

an article Mercer Management JoOurnal 2004

You can download it from

Sunday, May 18, 2008

International Financial Law Review

International Financial Law Review

Events - Managing Director - Goldman Sachs

Inside The Goldman Sachs' Private Equity Machine: An Interview With Managing Director Henry Cornell

The mega buyouts that have taken place over the past year have largely been the domain of the independent private equity firms -- the KKRs, the Texas Pacific Groups, the Blackstones. But in many of those deals, such as the $22 billion acquisition of Kinder Morgan Inc. or the $32 billion deal for HCA, investment banks also have been in the middle of the action, playing major financing roles. In an interview with the Wall Street Journal's Henny Sender, Goldman Sachs managing director Henry Cornell will discuss how the I-bank is approaching the private equity industry, how it is attempting to steer clear of conflicts with private equity clients and how it intends to deploy one of the largest private equity funds ever raised.

Henry Cornell, Managing Director, Goldman Sachs

A highlight of the event was when David Kostin, Managing Director U.S. Portfolio Strategy for Goldman Sachs, shared his perspectives on the growth potential and investment opportunities presented by the US Hispanic market. During his compelling session titled, U.S. Hispanization: The Quest for Growth, Mr. Kostin identified growth trends for geo-demographics and consumer expenditures that underlie his investment thesis. His report details investment opportunities in the housing, retail, health care and financial services industries that are well positioned to take advantage of the growing Hispanic market. His findings can be found in the report, “US Hispanization: Long/short Strategies” at Summit2007.pdf. (Due to its length, this URL may need to be copied/pasted into your Internet browser’s address field. Remove the extra space if one exists.)

Friday, May 16, 2008

Finspreads - Business Model

Finspreads was launched 19th April 1999. In Feb 2001 launched the FIRST fully interactive online spread betting platform. In may 2002 IFX group PLC purchased Finspreads, IFX is fully listed on the LSE and is authorized and regulated by the FSA. In November 2003 launched new look online platform. In November 2004 an advanced order system was launched.

Finspreads philosophy is to become a client driven retail spread betting platform, with a fully interactive website and an emphasis on client training and support to "bring out the professional trader in you".

Finspreads has recently added binary bets to its online spread betting platform. These are win-lose propositions that allow traders to take a view as to whether a market will finish a session up or down. Clients can bet whether the FTSE or the Dow will end a given day or even a specific hour higher or lower.

A binary market is made between 0 (the event not happening) and 100 (the event happening). For example, we have a binary bet on whether ABC plc share price (400p) will close up or down on the day. If it closes up the Binary mkt will close at 100 and down at 0. The market is titled "ABC PLC up on the day" At the opening of the day the market will trade at 48 - 52 (which means it's 50/50 as to the outcome) you'd buy @ 52 if you agree that it will end up on the day or sell at 48 you disagree. The day progresses and ABC announce some good news which rallies the share price upwards and therefore the market settles at 100. If you bought at 52 your bet will close out at 100 which will give you a return of (100-52) = 48 x your stake. If you had sold at 48, disagreeing with the market then you'd have lost (100-48) = 52 x your stake.

Currently only 4 binary markets are offered: FTSE and Wall Street up and down on the day and hourly markets.

The fundamental principal of pricing model used is Black and Scholes, but there are many more parameters used.

Proprietory trading platform is used. But the firm affirms, we guarantee our dealing prices, so do not knock people back once they've clicked on buy or sell. You can also add place limit orders as well.

Tuesday, May 13, 2008

Dealing with Difficult People - Books

Dealing with Difficult People : 24 lessons for Bringing Out the Best in Everyone by Dr. Rick Brinkman, Dr. Rick Kirschner, Rick Brinkman, and Rick Kirschner
(Paperback - Feb 20, 2003)

New: $7.95

Coping with Difficult People: The Proven-Effective Battle Plan That Has Helped Millions Deal with the Troublemakers in Their Lives at Home and at Work by Robert M. Bramson
(Mass Market Paperback - Sep 1, 1988)
New: $7.99

Perfect Phrases for Dealing with Difficult People: Hundreds of Ready-to-Use Phrases for Handling Conflict, Confrontations and Challenging Personalities (Perfect Phrases) by Susan Benjamin
(Paperback - Aug 16, 2007)
New: $9.95

Dealing With Difficult People (The Results Driven Manager Series) by Harvard Business School Press
(Paperback - Dec 2004)
New: $14.95

Help for Dealing with Difficult People (Elf Self Help) by Lisa O. Engelhardt and R. W. Alley
(Paperback - Aug 2002)
New: $4.95

201 Ways to Deal With Difficult People (Quick-Tip Survival Guides) by Alan Axelrod and James Holtje
(Paperback - May 1, 1997)
New: $10.95

A Survival Guide for Working with Humans: Dealing with Whiners, Back-Stabbers, Know-It-Alls, and Other Difficult People by Gini Graham Scott
(Paperback - Jan 23, 2004)
New: $15.00

Dealing With Difficult People (Mighty Manager) by Dr. Rick Brinkman and Richard Kirschner
(Hardcover - Mar 23, 2006)

Winning with Difficult People (Barron's Business Success Guides) by Arthur H. Bell and Dayle M. Smith
(Paperback - Dec 4, 2003)

Dealing with Difficult People (Max on Life) by Max Lucado (Hardcover - Sep 4, 2007)

Handling Difficult People and Difficult Situations - Book

Greg Whitear, Geoff Ribbens

Pages: 300

Published: November 2007

ISBN: 1843981750
ISBN13: 9781843981756

Price: £370.00


Individual and organisational performance depends on smooth relationships with internal and external customers, and the ability of individuals and teams to cope with the difficult and stressful situations that inevitably arise. At the same time, the drive for efficiency and profit makes this more difficult; workers are asked to do more with fewer resources, and to satisfy the ever-increasing expectations of bosses, customers, colleagues and suppliers.

To meet this challenge, this toolkit contains everything you need to train people to cope with difficult people and difficult situations at work.

It contains the most useful training tools and proven techniques that can be tailored to a wide range of training needs such as customer service, combating stress in the workplace, communication skills, influencing skills, assertiveness, and interpersonal skills.

The toolkit includes mini psychometric tests, questionnaires, tools, examples, templates and tips for every aspect of handling difficult people and difficult situations, including coping strategies for dealing with difficulties arising from situations such as appraisal, discipline and grievance procedures, change, staff cuts, and poor performance.

The content is structured in a way that makes it easy to dip in and out which, along with the customisable tools, enables you to tailor to an organisation¿s specific training needs.

This toolkit is ideal for trainers and learning professionals, as well as HR professionals and coaches. Individuals can also work through it themselves.


Assessing personal style
Understanding needs at work
Ascertaining personal values
Identifying difficult people and difficult situations
Evaluating approaches to work
Working with conflict
Succeeding with orientation and attitudes
Assessing levels of pressure and stress
Recognising the effects of pressure and stress
How personality influences pressure and stress
Approaches for dealing with pressure and stress
Barriers to communication 1
Barriers to communication 2
Body language
Giving feedback
Assertiveness and assertive rights
Three essential skills of being assertive
Assertive techniques
Approaches for working with difficult people
Difficult situations: case studies and applications
Perceptual Positions
Mental presuppositions
Programming assertiveness

About the author(s)

Greg Whitear
Greg is a business and management development consultant with special skills in organisational learning, psychometric assessment, coaching, counselling, and the design and delivery of learning programmes that promote change, leadership, teamwork and employee effectiveness. Following a career in the Royal Air Force, Greg has gained considerable management and consulting experience in UK and international organisations providing business, education and learning services to a wide range of enterprises in the public and private sectors.

Geoff Ribbens
Geoff is a management consultant and trainer with special skills in Mentoring senior managers and directors. Geoff designs and delivers a variety of programmes the predominant ones tend to be Team Building, Leadership, Change and Employee Performance. After twenty-one years in the University sector Geoff set up his own consultancy in 1991 and has worked in the Public Sector, Charities, Defence Industry, Finance Sector and the Pharmaceutical industry.

Monday, May 12, 2008

Reward Management - CIPD 2007 Survey Report

Download the report from

Variable Payment Systems - Retention Issues

Based on an article in Employee Benefits on 2006-02-01

The size and prevalence of bonus payments are on the up, so the impact on staff retention is worth considering. According to Towers Perrin's Worldwide total remuneration study 2005-2006, the use of variable pay internationally is increasing with Latin America and Asian nations also implementing the systems.

Back in the UK, the results of the Chartered Institute of Personnel and Development's (CIPD) survey Reward management 2006, due to be published this month, reveal that 85% of private sector organisations and 32% of public sector organisations pay bonuses - up from 69% and 22% respectively last year.

According to the CIPD, bonuses are an attractive compensation strategy because they are self-financing and do not inflate the pay bill. Put simply, they only pay out if the money comes in.

Philip Hutchinson, director of HR and reward consulting at AWD Consulting, explains: "Employers want to reduce the risk of employing people. Bonuses reduce that risk because if you don't perform you don't get paid."

With annual bonuses in particular making up a significant proportion of salary, rational behaviour dictates that employees will delay leaving an organisation until after the bonus is paid. Because a lot of organisations pay out around February, organisations may be left short of talent in the spring, after employees have bailed out.

One can expect if bonus is paid in April fewer resignations will be in February and March than you will get in May,

Of course, employees will develop expectations about the bonus. While a high payout might prompt some to take the money and run, a disappointing bonus could also lead some others to jump ship.

Annette Cox, lecturer in human resource management at Manchester Business School, says to avoid this employers must design bonus schemes carefully, ensuring that they are robust and clearly defined to set the goalposts.

Alan Judes, a senior consultant at Hewitt Associates, says: "The old cycle of everyone moving just when the bonus is paid has been enough of a problem for organisations to take action."

But some observers believe the effect is minimal.

Brooks points out that when employees enter the employment market after taking a high bonus payment, they make an expensive proposition for other employers, so a good bonus might actually compel people to stay, not least for the promise of the same again next year.

The growth of long-term incentives, which cynics dub as golden handcuffs, has no-doubt risen partly in response to the high staff turnover that comes with a no-strings-attached gift of a cash payment. According to the CIPD's survey Reward management 2005, 40% of private sector employers now offer long-term incentives, with sharesave schemes leading the way.

"Employers are seeing the retention factor in long-term incentive plans and the wealth creation that brings. Sharesave schemes, share options, and matching shares are all things you can do so you don't get the annual exodus of talent when the annual bonus is paid," says Judes.

Brooks adds that the use of long-term incentives can fulfil those aims. "Deferred stock is used extensively by investment banks. If a proportion of the bonus comes from a deferred stock, it grows in value over time in the way any other stock does, you just don't own it for an initial period. If you are a bad leaver and go to a competitor you are likely to lose all of it, or at least most of it. If you are a good leaver, perhaps for ill health or you go to a company that isn't a competitor, then you are allowed to take most of it."

And he believes that nothing says 'I like you' than the opportunity for employees to build ownership in the company.

"If you can let people accumulate capital and ownership of the companies in which they operate, retention should follow.

Even when employers are not in the position to offer long-term incentive options, simple adjustments to the existing bonus structure may encourage retention rates. Paying a bonus for a calendar year in April, for example, ensures employees are well into next year's earnings before they receive last year's dues.

Recognition has a role apart from bonus

Manchester Business School's Cox says employers should attempt to foster a culture of recognition to improve retention.

"If your boss comes to your office and says 'Thanks for your hard work. I'll tell you now, we're going to give you a bonus to reward you', that's probably going to feel better than having a note in your payslip saying 'Here's some extra cash."

We have to remember that people go to work for more than just a pay cheque, regardless of how it is formulated.

"People aren't mercenaries. They do consider the employment opportunities, the training and development, and the colleagues they work with," says Judes.

For the full article

Bonus-payment system of Investment Banks - Result

Razak, 37, CEO of CIMB Malaysia, says he tries to emulate U.S. investment-bank management styles.

He was one of the first managers in Malaysia to reward successful staffers with fat yearend bonuses.
(His own reward: 38 million CIMB shares, or 4.4%, worth $55 million.)

That means working New York-style hours, too. "CIMB has a reputation for being a very hard place to work," he concedes. But those long days are paying off.

Issues in bonus payment systems.

I came across this issue in Mint of 12 May 2008 (page 20). The item is a reprint from Wall Street Journal.

Jeffrey Liddle, an attorney in New York, says he filed an arbitration claim this week on behalf of a former mortgage-backed securites saleman at Merrill Lynch & Co. Despite having his best year ever, the saleaman's pay plummeted to about $190,000 from $1.2 million.

"He couldn't make enouhg money to feed his family," Mr Liddle says. The employee asked to be laid off, so he could receive a severance package. Merrill Lynch declined, so the salesman quite and took a job as a stockbroker at another firm.

How could it happen?

Friday, May 9, 2008

Goldman Sachs University

At Goldman Sachs, there are no less than 2,000 training programmes available delivering training that encompasses everything from products and market knowledge, leadership and management, professional skills, to diversity and inclusion awareness. It becomes apparent that the term 'university' is rather apt – for what is on offer is a universal education designed to ensure that Goldman staff are best of breed.

At Goldman, senior business leaders are the teachers and professors. Osmond tells me that the chiefs and head honchos regularly take time out of their schedule to run a training event or teach a methodology – whether it relates to leadership or equity valuation. This does result, admits Osmond, in a leaning towards in-house training as the favoured method but it's something they are proud of and Osmond believes it is important: "The Goldman focus is very contextual."

Client training has grown nearly 10-fold in five years as word has spread within Goldman and to its clients.

Last year (2007) the bank won the Best for Training & Development Award in The Sunday Times' annual Best Companies Awards for a large company.

Can a Universal Bank be a Trusted Advisor?

Ben Stein vs. Goldman Sachs: Market-Makers, Brokers, and Trusted Advisors
by Charles H. Green posted on Tuesday, December 4, 2007

Sunday, May 4, 2008

Compliance courses - UK

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Anti-Money Laundering for Asset Managers
Anti-Money Laundering for Building Societies
Anti-Money Laundering for Financial Advisors
Anti-Money Laundering for Investment Banks
Anti-Money Laundering for Private Banks
Anti-Money Laundering for Stockbrokers
Anti-Money Laundering for The US
Anti-Money Laundering Global Edition
Approved Persons
Client Assets
COB: Accepting Customers
COB: Advising and Selling
COB: Dealing and Managing
COB: Financial Promotions
COB: Trustee and Depositary Activities
Code of Inter-Professional Conduct
Code of Market Conduct
Complaints Handling
Conduct of Business Standards
Data Protection
Ethics: Fundamental Responsibilities
Ethics: Responsibilities to Clients
Ethics: Responsibilities to Employer
Fraud Prevention
How the FSA Works
Introduction to UK Regulation
Market Abuse Regime
Personal Account Dealing
Price Stabilising Rules
Racial Discrimination
Senior Management Arrangements,
Systems and Controls
Sexual Discrimination
Training and Competence

Phone: to order over the phone call Compliance Online Sales on 020 7083 7200 and discuss your requirements. We will send you an invoice by email, fax or post.

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Goldman Sachs Management Policies


Goldman Sachs Environmental Policy Framework

Goldman Sachs JBwere asset management details of trade management policies

Goldman Sachs JBWere Group Privacy Statement

Compliance Problems
September 4 2003, Transaction in 30 year US govt bonds

Access to US Market for Foreign Investment Advisors

U.S. Open Market for Foreign Advisers

It is relatively easy for a foreign adviser to register as an investment adviser in the United States and to set up its own U.S. mutual funds. An adviser, including any foreign adviser that wants to manage a registered mutual fund in the United States, may register as an investment adviser under the Investment Advisers Act of 1940. It is no more difficult for a foreign adviser to register than for a domestic adviser to register under the Advisers Act. There are very few barriers to entry for investment advisers wishing to register in the United States. There are no residency requirements. Thus, an adviser can be located outside the United States and is not required to establish a U.S. subsidiary in order to register as an investment adviser in the United States. There are no minimum educational requirements, and there are no capital requirements for investment advisers, although advisers that sponsor a registered mutual fund must make sure that fund has the requisite seed money of $100,000.

The main barrier to registration as an investment adviser in the United States would be if the adviser had been the subject of certain disciplinary actions. I understand that some other regulatory jurisdictions follow a different approach for investment advisers, conducting a pre-approval merit review of those that want to sponsor a fund or manage money in a jurisdiction to ensure that they are "fit and proper" or meet similar regulatory standards.
Many foreign advisers are exempt from registration as advisers in the United States if they have 14 or fewer U.S. clients, do not hold themselves out to the U.S. public as an investment adviser and do not serve as an adviser to an investment company registered under the Investment Company Act.

The Advisers Act and its rules make certain accommodations for foreign advisers. In determining whether an adviser qualifies for the 14 or fewer clients exception from the definition of investment adviser, foreign advisers are permitted to count only U.S. clients, while U.S. advisers must count all clients. However, if a foreign adviser chooses, or is required, to register in the United States, it may do so with the Commission, regardless of the amount of assets it has under management. NSMIA amended the Investment Advisers Act so that advisers with $25 million or more in assets under management generally register with Commission, and advisers with less than $25 million generally register with the states. However, all advisers with principal offices outside the United States register with the Commission rather than the states, and this single regulator approach eases some administrative difficulties for foreign advisers. Additionally, although the Advisers Act places certain restrictions on advisory contracts, including limitations on performance fees, the Advisers Act excepts contracts with persons who are not U.S. residents. Congress added this exception in NSMIA, recognizing that the common use of performance fee arrangements in other countries placed U.S.-registered advisers operating in foreign countries at a competitive disadvantage.

Access to US Market for Foreign Mutual Funds

In 1998, it was estimated that over 14% (or $980 billion) of U.S. mutual fund assets are managed by foreign advisers or their U.S. affiliates. Certainly, foreign advisers have been able to make significant inroads in the U.S. market, but there are certain barriers.

Section 7(d) of the Investment Company Act
Section 7(d) has prevented foreign advisers from directly offering their foreign funds to a large number of U.S. investors. Under Section 7(d), only funds organized under the laws of the United States, or any state, are permitted to offer shares in the United States. However, Section 7(d) authorizes the Commission to issue orders permitting foreign-organized funds to offer shares in the United States if the Commission finds that, by reason of special circumstances or arrangements, it is both legally and practically feasible effectively to enforce the provisions of the Investment Company Act against the foreign fund and that permitting the foreign fund to offer shares in the United States is consistent with the public interest and the protection of investors. Thus, Section 7(d) ensures that U.S. investors receive the same essential investor protection whether they acquire shares in a foreign fund or U.S.-organized fund. Many foreign funds are unwilling to submit to having all provisions of the Investment Company Act imposed on them. In fact, only 19 foreign funds, most of them from Canada, have ever received orders under Section 7(d). The SEC issued the last such order in 1973.
Section 7(d) is statutory rule. Therefore, an amendment to Section 7(d) requires an act of the U.S. Congress.

In practice, however, the requirements of Section 7(d) have not posed a problem for foreign fund managers in penetrating the U.S. market. Many foreign fund managers have responded by acquiring U.S. investment management organizations or by setting up their own U.S. affiliates. A foreign investment manager may organize and register a U.S. mutual fund to be sold in the United States on the same basis as a U.S. investment manager. Moreover, it is relatively easy for a foreign firm to establish funds in the United States to replicate an existing foreign fund, which can be managed and administered outside the United States.
The SEC has shown flexibility in permitting performance information, such as that of a comparable foreign fund, to be included in prospectuses of the U.S. funds, greatly aiding foreign managers in marketing their U.S. funds. Also, the National Securities Markets Improvement Act of 1996 ("NSMIA") facilitated a true national market in the United States, eliminating substantive regulation of mutual funds by states, making it considerably easier for foreign firms to access the U.S. markets.
It should also be noted that Section 7(d), as interpreted by the Division of Investment Management, does not prohibit private offerings of foreign funds to U.S. residents, as long as those offerings comply with the private offering requirements of the U.S. securities laws. Section 3(c)(1) of the Investment Company Act provides an exemption for privately placed funds with fewer than 100 beneficial owners and Section 3(c)(7) provides an exemption for privately placed funds sold exclusively to "qualified purchasers." The SEC staff has been flexible in interpreting these provisions, taking the position that a foreign fund may make a private U.S. offering under these exemptions concurrently with an offshore public offering. (See Goodwin, Procter & Hoar, (pub. avail. Feb. 28 1997); Touche Remnant & Co. (pub. avail. August 27, 1984)). Moreover, we have confirmed that a foreign fund remains eligible for these exclusions so long as it has 100 or fewer U.S. persons as beneficial owners or has U.S. investors who are qualified purchasers, regardless of the number or sophistication of its non-U.S. investors. (Goodwin, Procter & Hoar (pub.avail. Feb. 28, 1997)). I should also note that the SEC staff has permitted foreign funds to exceed the 100 U.S. beneficial owner limit or to have U.S. investors who are not qualified purchasers if this is as a result of independent actions of the fund's security holders. (Investment Funds Institute of Canada (pub. avail. March 4, 1996)).

US law insists on independent director in the mutual fund. But,With respect to independent directors of U.S. mutual funds, that there is no residency requirement for directors. Thus, a foreign fund manager could establish a U.S. fund that has a board of all non-U.S. directors. In addition, there are several other areas where the Investment Company Act does not impose requirements in contrast to other countries. For example, the Investment Company Act does not impose high capital, staffing, residency or U.S. place of business requirements so that a U.S. registered fund can be administered outside of the United States.