It started as a low murmur of vague unease and confusion, and soon erupted into a 36 month panic. In 2003, the Securities and Exchange Commission (SEC) served notice to the US securities lending industry that they had been doing it all wrong for the last twenty or thirty years – and they had a very short time to fix it. European regulators followed suit in 2008 with a mandate for action by 2010. Agent Lender Disclosure (ALD) had hit the market with lessons for managing today’s regulatory change.
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