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