Recent Comment Letters
(January 1, 2023 - Present) 

The Association of Global Custodians has recently issued public commentary concerning regulatory and market structure issues that are of common interest to its members.
Key topics and the related comments are set forth below.

Depository Information-Gathering Project

• 2024-2025 Depository Information-Gathering Project: A Report for Clients and Participating Depositories, January 31, 2025

• 2023-2024 Depository Information-Gathering Project: A Report for Clients and Participating Depositories, January 31, 2024

• 2022-2023 Depository Information-Gathering Project: A Report for Clients and Participating Depositories, January 31, 2023

Tax Issues

Denmark

• Letter to Danish Ministry of Taxation Requesting Guidance regarding Income Entitlement Rules, January 3, 2024

European Union Institutions

• AGC, EBF, and AFME Joint Letter to the European Commission regarding the EU’s FASTER Initiative, February 20, 2024

• Letter to the European Commission regarding European Commission proposal for a Council Directive on Faster and Safer Relief of Excess Withholding Taxes, September 18, 2023

Finland

• Letter to Finnish Ministry of Finance regarding Feedback on Consultation on the need to improve the TRACE model for dividend payments to nominee-registered shares, February 14, 2025

IRS

• Letter to Internal Revenue Service and US Treasury Department regarding Application of Form 1099-DA to Tokenised Securities and Other Digital Initiatives, December 5, 2024