Enron Mail

From:janine.juggins@enron.com
To:sara.shackleton@enron.com
Subject:Re: Bond & Equity Trading
Cc:
Bcc:
Date:Fri, 22 Sep 2000 07:20:00 -0700 (PDT)

Latest and greatest as just discussed !
Regards
Janine
---------------------- Forwarded by Janine Juggins/LON/ECT on 22/09/2000
14:23 ---------------------------

Mahesh Lakhani
22/09/2000 11:22

To: Paul Simons/LON/ECT@ECT
cc: Sheila Glover/HOU/ECT@ECT, John Greene/LON/ECT@ECT, Janine
Juggins/LON/ECT@ECT, Gary Hickerson/HOU/ECT@ECT, Jeff Kinneman/HOU/ECT@ECT,
Erica Gut/LON/ECT

Subject: Re: Bond & Equity Trading

Paul

I am in the process of drafting the agency agreement between the US principal
and the UK agent. As soon as I have completed this I will circulate it for
review.

With regard to your points on the choice of entities, I have the following
comments:

the principal booking entity - For equities : ECT Investments Inc and for
Bonds it will be ENA (Based on Sheila's note below)
the UK agent - as this should not be EEFT, we should set up a new entity for
this as I think we should have a clean company. I have started the new
company workflow process for the set up of this company. I have recommended
that the entity is a sub of EnronCredit.com and be called Enron Investment
Services Limited (unless if anyone has any other suggestions)
I confirm that the same UK agent can be used for both businesses

Regards
Mahesh



From: Sheila Glover 19/09/2000 18:43


To: Mahesh Lakhani/LON/ECT@ECT, Janine Juggins/LON/ECT@ECT, John
Greene/LON/ECT@ECT
cc: Gary Hickerson/HOU/ECT@ECT, Jeff Kinneman/HOU/ECT@ECT
Subject: Equities

Mahesh,
This confirms our discussion that the the UK entity will have two separate
service agreements. One with ENA for Prop Debt Trading and one with ECT
Investments Inc for Equities Trading.
In London, we can book directly into the underlying entity, e.g.
Energy-London Book, At the end of the month, we will record income based
upon activity to the Arranger, New UK entity, and record the offsetting
expense to the Serviced book (Energy London).
Many thanks.
Sheila

From: Mahesh Lakhani on 09/19/2000
To: John Greene/LON/ECT@ECT, Sheila Glover/HOU/ECT@ECT
Subject: Equities

I have a quick question - Would the principal for the bonds/Equities business
done from London be ENA or ECT Investments Inc. I recall from our meeting
that it was ECT due to the regulatory environment - can you please confirm

Thanks
Mahesh



Paul Simons
14/09/2000 19:27
To: Sheila Glover/HOU/ECT@ECT
cc: John Greene/LON/ECT@ECT, Janine Juggins/LON/ECT@ECT, Mahesh
Lakhani/LON/ECT@ECT
Subject: Re: Bond & Equity Trading

The agent is needed for tax reasons. I think it means that the income is
earned by a "dealer" (ie the agent) which means it is not sub-part F income
for US tax purposes and hence not double taxable.

The tax guys can correct me if I'm wrong!

Paul





From: Sheila Glover 14/09/2000 19:08


To: Paul Simons/LON/ECT@ECT, John Greene/LON/ECT@ECT, Janine
Juggins/LON/ECT@ECT
Subject: Re: Bond & Equity Trading

Paul, John and Janine,
If it is unregulated, do we still need to use an agent? If the answer is yes,
I would like to understand why and what the operational requirements will be
for the transactional flow.
Thanks. Sheila


Paul Simons
09/14/2000 04:36 AM
To: John Greene/LON/ECT@ECT, Janine Juggins/LON/ECT@ECT, Mahesh
Lakhani/LON/ECT@ECT
cc: Erica Gut/LON/ECT@ECT, Gary Hickerson/HOU/ECT@ECT, Jeff
Kinneman/HOU/ECT@ECT, Sheila Glover/HOU/ECT@ECT, Mark
Evans/Legal/LON/ECT@ECT, Sara Shackleton/HOU/ECT@ECT, Laurel
Adams/HOU/ECT@ECT, Alan Aronowitz/HOU/ECT@ECT, Lin Richardson/LON/ECT@ECT
Subject: Re: Bond & Equity Trading

Since we're clear on regulation, the choice of entities becomes a tax issue.
We need to identify:

which company (new or existing) will be the principal booking entity
which company (new or existing) will be the agent (but we shouldn't use EEFT,
our SFA entity)
whether the same principal entity can be used for both the equity and bond
businesses, and
as you say, whether the same agent can be used for both businesses

Could Janine/Mahesh please opine on these questions (we can meet if necessary
to discuss) then we can set up the entity or entities as required. Thanks

Paul




John Greene
14/09/2000 10:03
To: Paul Simons/LON/ECT@ECT, Janine Juggins/LON/ECT@ECT, Mahesh
Lakhani/LON/ECT@ECT, Erica Gut/LON/ECT@ECT
cc: Gary Hickerson/HOU/ECT@ECT, Jeff Kinneman/HOU/ECT@ECT, Sheila
Glover/HOU/ECT@ECT, Mark Evans/Legal/LON/ECT@ECT, Sara
Shackleton/HOU/ECT@ECT, Laurel Adams/HOU/ECT@ECT
Subject: Re: Bond & Equity Trading
Now that we have the "green light", can we please start the process of
setting up the UK entity that will act as agent for this activity. According
to Jeff, the bond trading activity will not start right away and, in any
case, the volume for this activity will be fairly light. Therefore, I think
it would be best if we just set up one agent now and decide on the need for
another separate entity at a later date.

Thanks and regards,
John



Paul Simons
13/09/2000 15:16
To: Gary Hickerson/HOU/ECT@ECT, Jeff Kinneman/HOU/ECT@ECT, John
Greene/LON/ECT@ECT, Sheila Glover/HOU/ECT@ECT, Janine Juggins/LON/ECT@ECT,
Mahesh Lakhani/LON/ECT@ECT, Mark Evans/Legal/LON/ECT@ECT, Andrew
Cornfield/LON/ECT@ECT
cc: John Sherriff/LON/ECT@ECT, Michael R Brown/LON/ECT@ECT
Subject: Bond & Equity Trading

I have just received the letter SFA promised us. SFA have accepted our
argument that our proprietary bond and equity trading can be carried on in
London through an unregulated UK entity. The letter also states that SFA
will not be applying their consolidated capital supervision rules to the
unregulated entity, which they have the discretion to do.

From a regulatory perspective this means we can move ahead at full speed to
set up an appropriate Chinese Wall and then begin trading.

Best regards

Pau