Disclosure Requirements - Investment Funds - U.S.A.


Disclosure Category: 2

Clearstream Banking S.A (“CBL”) may be required to disclose the identity and holdings of customers and ultimate beneficial owners, upon request, in the case of holding of securities in U.S. investment funds.


In order to comply with the local legislation, customers with holdings in U.S. investment funds or entering into transactions in the U.S. market must consent and are hereby deemed to consent to the required legal disclosure. Such consent includes the appointment of the requestor (for example, the Fund Manager, Transfer Agent, Regulator) as their attorney-in-fact, under power of attorney, to collect from CBL the required information to be disclosed. Customers who do not grant such authority cannot hold such investment funds or financial instruments in their accounts with CBL.

Disclosure requirements

Customers are advised that the local laws and regulations oblige CBL to disclose the requested information on CBL customers, third parties and ultimate beneficial owners to the party that is entitled by law to receive such information.

Under U.S. law, registered investment funds will be required to disclose details of concerning investors to the Securities and Exchange Commission (SEC). At the same time, an Investment Fund are subject to disclosure for purposes of providing related services or for internal marketing or cross-selling.


The information contained in the Disclosure Requirements is based on the legal opinion obtained by CBL that was issued on 18 June 2019. CBL believes the information to be correct as of that date but disclaims any responsibility as to the accuracy and completeness of the information after that date. In the case of discrepancy between the information provided by CBL and the local laws and regulations, the latter shall prevail. The Disclosure Requirements do not constitute legal advice and customers should seek advice from independent professional counsel.

Customers are responsible for ensuring compliance with the disclosure requirements and agree to indemnify and hold harmless CBL, for any loss, expense, liability, damage or claims, whether direct or indirect, against or incurred by CBL arising out of or resulting from such non-compliance.