Any capital-markets issue that is collateralized will tend to have an independent third-party trustee as holder of the security. This is a simple structure that originated in the common law (the Anglo-Saxon systems found in the UK, the former British Commonwealth and the US) and has been harnessed elsewhere, such as Scandinavia and the Middle East (see last month’s Financial Lawyer). But, hitherto, unsecured plain-vanilla issues have tended to be done without inserting a trustee structure, but with a fiscal agent instead.
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