Managing Global Compliance in a Changing World

Managing Global Compliance in a Changing World

The global corporate compliance landscape is constantly shifting, making global corporate governance complex for companies.

During this hour-long event, we will explore the challenges of managing a multinational portfolio, how the global corporate secretarial outlook is evolving, and discuss ways that CSC can assist, including:

  • UBOs, GLEIs, and more
  • Simplifying the challenges of global entity compliance management: jurisdictional, cultural, and logistical (language, currency, etc), among others
  • Centralizing data and documents for full portfolio transparency

Transcript:

Disclaimer: Please be advised that this recorded webinar has been edited from its original format, which may have included a product demo. To set up a live demo or to request more information, please complete the form to the right, or if you are currently not on CSC Global, there is a link to the website in the description of this video. Thank you.

Annie: Hello, everyone, and welcome to today's webinar, "Managing Global Compliance in a Changing World." My name is Annie Triboletti, and I will be your moderator. Joining us today are John LaPalomento and Andrea Jonaitis.

John is a product manager on the CSC Global Subsidiary Management Team. He has been with CSC for over nine years, previously as a sales team leader and a product engineer with CSC Matter Management Solutions. John works with GSM prospects to present an accurate and clear scope of services and remains in contact with them as the overall relationship manager for all GSM clients.

Andrea is a sales engineer in the Corporate and Legal Solutions group at CSC. Since joining CSC in 2017, Andrea has specialized in global subsidiary management and entity management, working with prospects to present an accurate and clear scope of services, including helping subsidiaries stay in compliance as well as demonstrating CSC Entity Management. And with that, let's welcome John and Andrea.

John: Annie, thanks so much, and certainly welcome to everybody here on today's call. Thank you for making time. Good morning if you're here in the United States and certainly good afternoon and good evening for those of you joining us from around the world. Again, my name is John LaPalomento. I'm a consultant for our suite of global subsidiary management services, and I'm excited to share this time with you today.

Andrea: Excellent. Good morning, everybody. My name is Andrea Jonaitis. I am also a consultant in our global subsidiary management services, and I specialize in the technology that can be paired with the service to bring a very powerful, completed service and technology for managing your global entities. We are so excited that you're here to share some time with us. I know that things are very busy. You're probably joining us from the home office. So we're so excited to be sharing this time with you to discuss a little bit about the challenges of managing the multinational portfolio. We'll be talking about some considerations for managing entities internationally. We'll talk a little bit about some services in the industry. We'll also have a little bit of a toe-dip into our technology here.

So let's kind of look at our formal agenda today. We'll begin our discussion by talking about the global corporate governance and the industry landscape. There's a lot of changes happening. There's a lot of things that you need to be aware of. CSC is at the cutting edge of being aware of those changes and communicating them to you. So we want to make sure that you're aware of them. We'll also talk about the challenges of managing a multinational entity portfolio, the way that CSC can assist you with your global corporate governance. Then we'll talk about how you can understand the status of your entities traditionally through a corporate health check project. This will help you to understand the status and achieve your international statutory compliance.

John and I are also going to share with you CSC's core service to support your global entities. We call that annual compliance support. We'll tell you a little bit about what that means for you, what that entails. We'll also talk about some international transactional work that CSC can assist with for your portfolio. We'll talk briefly about Global Legal Entity Identifier or GLEI as you may know them. We'll also have the opportunity to talk about how you can maintain trustworthy data in a centralized repository. CSC offers our repository. We call CSC's Entity Management Solution.

At the end of our discussion today, we'll have the opportunity to actually view a live demonstration of that entity management platform together. So stick around for that.

Annie highlighted the Q&A widget that you have in the bottom corner of your application or your web page today. John and I love when this is conversational. Now understanding that it's a webinar and that we're talking and you're listening. We want to keep it as conversational as possible. Please do use that Q&A widget. We are looking at it regularly. We love your participation, your thoughts, your questions, your feedbacks. We're going to be watching that Q&A widget, not just for your questions, but your feedback, maybe the direction you'd like our conversations to go, and maybe some future things you'd like to see from us. So we'll keep an eye on the Q&A widget. But with that being said, let's get into our first topic today, which is going to be the global corporate landscape. John, I'll turn things back over to you here.

John: Very good. Well, like I had said, I'm excited to share this time with all of you today, talking about changes in landscape. I'll be very honest. When we started to plan for this presentation today, we were going to talk about all of the things that you see on the screen now, talking about changes that have become part of the global world, since leaks like the Panama Papers, the Paradise Papers. We're going to talk about ultimate beneficial owner registrations and changes around the world there. But I think the obvious change that needs to be discussed now is the way global businesses are operating very differently in the wake of the COVID-19 challenges around the world. So let's touch on that briefly because it's so important.

And please know that if you're already working with CSC, whether it's in a global capacity or domestically here in the United States, CSC like no other corporate services provider is taking the necessary steps to protect you, to protect your business, and to make sure that we are working within the confines of the law to absolutely serve service of process according to any new changes that are happening here in the United States and working globally to have your best interests at heart as well. CSC certainly is an important part of your corporate legal landscape, and we're here to back that up.

We're working coast to coast here in the United States. We're working carefully. We're observing social distance. As a matter of fact, the three of us on the call today are joining from our home offices in Delaware where our headquarters are in Pennsylvania, and I'm in my basement office in New Jersey with my three children up above me, hopefully staying quiet during this call today. The different way to work but CSC is nimble. We're flexible, and we're here to adapt to the ever-changing needs.

When it comes to global changes, of course, we are working globally in over 145 countries around the world, and very importantly, our clients are leaning on us when it comes to changes. Registry closures, delays in filings, you can lean on us and trust us. While there's over a dozen or so public registries closed around the world, including jurisdictions like Italy, Spain, and Ireland, on many different continents, there are changes. CSC is recognizing those changes. We have in-country support constantly monitoring changes and full-time researchers here out of our Wilmington, Delaware headquarters understanding the impact of these changes and making sure that our clients are kept up-to-date and properly have the proper solutions in place.

If you have any questions as to how we're handling things, even here in the United States where it's so important, please reach out to a member of our customer service team or your client solutions manager for even more detail. While we're here talking about changes in the corporate landscape, I think one of the other big pieces to talk about are changes to UBO or Ultimate Beneficial Owner registries around the world. In a post-9/11 world, in a post-Panama and Paradise Papers world where there have been disclosures of information, we're here to make sure that we're working within the confines of the law and adhering to the ultimate beneficial owner registrations and making sure that you're set up to succeed.

For those of you who aren't familiar with UBO registrations or Ultimate Beneficial Owner registrations, we're working in a world where it's imperative that countries and jurisdictions understand with whom they're working and make sure that the business that is carried out is happening in a way that is supporting good people and not bad actors. So, so many jurisdictions, even some that historically have allowed you to work anonymously like Cayman Islands, are installing these rules and legislature around disclosing ultimate beneficial ownership. And usually, there's a threshold of some sort. Anybody who owns greater than 10% of a company or owns greater than 25% of the company, in the UK, you might know this as the persons of significant control register. CSC is here to make sure that you and your organization are aware of these new policies and these changes around the world and ultimately here to satisfy even the initial filing or modifications to your UBO registration.

I think the biggest change right now is in Canada, our neighbors to the north where so many of our CSC clientele are working in Canada. It's very natural if you're an American business or a global business to be working in Canada, and CSC is here to understand the changes. Not only are there changes and new registrations that are going to be in place across Canada by the end of the year, but now there's some delays to those changes based on COVID-19. So we're here to help you as a client of ours understand those nuances and set you up ultimately to succeed.

That brings us now to the challenges of managing a multinational entity portfolio, and for that, I'm going to turn it back over to Andrea.

Andrea: Okay. Perfect. I mean, kind of continuing with our theme of this COVID-19 challenge, I think, again, before we develop these slides, being able to bring everybody together from anywhere around the world, not just across the United States, but anywhere around the world, and being able to have all of these different offices in which you're operating all around the globe to be centrally connected to understand what's happening, what's the status of the work that is being done or the requirements and their completion, and having that type of transparency is critical. That goes a bit hand in hand with some of our discussion items pertaining to data management and logistics, but certainly, we'll explore these items a little bit further.

So, throughout our various conversations with our clients and prospective clients, John and I regularly hear some recurring themes in terms of challenges that companies are facing when it comes to managing a global portfolio. One of the biggest challenges that we hear quite often is expertise or lack thereof. So clients approach CSC looking for help with managing their global portfolios because there are so many nuances that vary from country to country, and these nuances are very different from U.S. law and what we are familiar with here domestically in the United States. So I'll just talk a bit about the corporate landscape and some of the more stringent requirements.

It can be very difficult to understand the nuances and the requirements that are necessary to conduct businesses in other countries. Let's be real. We don't necessarily speak the language. We're not living there every day. It can be very easy to feel like international entities can and should be managed or handled in a very similar way to what we're used to with managing U.S. secretarial requirements for our United States entities. That's simply not the case. We don't have that luxury of treating those the same because of those different nuances from country to country.

Managing those filing requirements for your global entities isn't as straightforward as appointing a registered agent or filling your annual reports throughout the year. It is critical to have an expert or a team of experts in place that can help you with understanding those different complexities, the various jurisdictional needs in order to give you and your organization the peace of mind that everything is being handled appropriately.

Another challenge is logistics, the challenge of coordinating multiple projects with multiple vendors all around the world, especially now, again, that we're working remotely from home offices or not able to communicate face-to-face with our team. The impact that this has on your time and resources. The vendors that you're working with most typically from what we hear obviously are located in other countries. Often times they're in inconvenient time zones. There's also the struggle of the receipt of invoices in different currencies, and those currencies might fluctuate throughout the course of your business. Even more frustrating and confusing would be language barriers if vendors aren't speaking your language or speaking English with you.

All of these logistical challenges can become very confusing. They can easily overburden you or overburden the process, and it can really create a lot of confusion as to what has or hasn't been completed when you're trying to manage these different requirements. And really, John and I hear it all the time in our daily discussions with people who are considering our services. Many begin their conversations with us, "Well, I think that our vendors are handling these responsibilities," or, you know, "I really hope that they are." You know, a hope and a prayer is okay, but we need that security, that absolute knowledge and that peace of mind.

Next is understanding cost. That can be very challenging in addition to the fluctuating currencies I just mentioned. Creating a budget and understanding the current spend for your services that are associated with managing your global entities can be very difficult, especially when you're dealing with in-country law firms. You're at the mercy of hourly rates. There could be potentially unclear invoices for services rendered. It can often be tough to match up costs for each specific entity, challenges around discerning the difference between fees that are tied to the direct management of your entities versus maybe fees that are charged for some other unrelated services.

Very unfortunately, John and I also speak with companies who have received surprise invoices from their vendors for standard or routine filings and services. Maybe a filing took a little bit longer than expected. Maybe there was some type of amendment or additional components of that filing. Receiving that type of surprise invoice is just ridiculous, and nobody wants to be on the receiving end of these unexpected fees above and beyond what was originally discussed. When a vendor gives you a cost for a project, that is the cost of the project that you should be incurring with no additional fees down the line.

Lastly, data management. So it's important to have a system in place that meets all of your needs and allow you to centrally see and manage all of your data and documents for all of your entities from anywhere around the globe, whether it's your home office in that basement in New Jersey or if it is your partner office in Rome or Australia, any location around the world. You need to have that visibility, that team collaboration in that centralized repository. It's even more important that you're able to feel confident that that system that everybody's accessing is reliable, that it's up to date.

And oftentimes, it's very challenging to really achieve that type of streamlined system or that peace of mind. When you're using systems or processes like Excel spreadsheets or network share drives, that can help to ease your burden a bit, but those processes are still very manual. They can easily become outdated. They can easily become incorrect with information that hasn't been updated. And when you have other pressing responsibilities that also need attention, you just can't get to that type of data update.

Companies also tell John and me that they're heavily dependent upon the information or the communication from their vendors. They need their vendors to provide updated information or documents as a prerequisite to actually getting their manual systems updated appropriately. So, if that communication isn't received from your partners or your vendors, despite your best efforts, the system is going to break down. So finding a different way to streamline the management of your data is really crucial.

John: Very good. So we're going to talk a little bit about the CSC solutions. Well, we've already highlighted some of the challenges working globally. CSC offers a dynamic service that we call Global Subsidiary Management or you'll commonly hear us use the phrase GSM. GSM is a lot of different things, but if I were to use two words to describe GSM, it really is about centralizing and simplifying global corporate governance.

Here's some of the partnership. There's no magic wand that CSC has to wave and to make this workload go away. In fact, I shy away from using the word outsourcing. There's no way for us to completely carry the burden of global corporate governance. What we are is a serious resource in making your challenges much, much easier, streamlining your workflows to one point of contact in a central fashion and being one conduit of information, working together with you as an extension of your legal team, essentially providing a concierge level of support.

We're also very flexible. When we talk about flexibility, please know that we have organizations come to us of all shapes and all sizes. Whether you're a smaller organization starting to work internationally or a large corporate business working with hundreds of entities around the world, CSC is situated equally to handle your needs.

We're here to do so in a flexible way in the fact that if you have capabilities in some jurisdictions and need our services in some more challenging jurisdictions, we can take those on, or if you have extended needs, such as the fulfillment of resident directors or fulfilling registered office appointments in different jurisdictions, again, we're here to be flexible and making sure that we're working within the confines of custom in a jurisdiction, but fulfilling your needs is necessary.

GSM truly is comprehensive. As mentioned, it's not a one-size-fits-all situation, and from jurisdiction to jurisdiction where you have different needs, we're comprehensively going to be able to fill those gaps.

Global Subsidiary Management truly is dynamic, and I think a testament to that are some of the challenges going on in today's world. Part of what we're doing with the COVID-19 challenges around the world are constantly managing these changes, understanding and researching what has to happen differently and dynamically fulfilling these voids. But when you have changes that have to happen quickly, we're here to dynamically work as well.

GSM truly is efficient. When I talk about efficiency, I really talk about this in multiple different ways. I think the most obvious efficiency, at least to me, are the efficiency that we're going to bring you in terms of workflow. Our services really are predicated on centralization and giving you a point of contact most commonly here in the United States, but we have hubs for the service out of our London office and our Hong Kong office. When we go back to the flexibility statement, we're going to work in the way that best fits your organization's needs. But if you're based here in the U.S. and you're looking to centralize through a U.S. partner, CSC is going to do that tremendously efficiently, giving you a regular point of contacts, giving you scheduled contact to discuss what's coming up over the next 30, 60, 90 days and so on and making that one process.

We're also efficient in terms of cost-effectivity. You're going to see, of course, natural scales of efficiency when we're talking about costs working globally as opposed to working in one jurisdiction with one provider. But you're also going to see some significant wins when it comes to cost-effectiveness due to the flat rate structure building U.S. dollar. You're going to have ultimate budget certainty, understanding what your spend looks like well in advance of challenges around the world.

Ultimately, GSM is a marriage of our time-tested service and our award-winning technology. Please know I want to highlight this here. This is not simply a corporate secretarial service, and this is not just a piece of technology to help you. We're marrying together CSC Entity Management Solution with our time-tested support and automating the capture of data and documentation within this system. When we draft documentation for you in dual language with English support, that documentation automatically flows into the system. When we make changes for you, there's changes to the database happening in real-time. This is, in my opinion, the best part of what we do.

Ultimately, CSC provides peace of mind with our global subsidiary management offering. You know that you have partners at CSC who have your best interests at heart. We're here to make life easy and to bring confidence to your minds.

Andrea: Let's move into the next section, which is to address this concept of your comfort to shed some light into where your entities are in compliance and in status. You can achieve your compliance through this preliminary research project, what we call the corporate health check project. When clients first come on board with CSC, the first step in our relationship together is to understand the status of each of your entities to understand the requirements that are necessary to remain in good standing from jurisdiction to jurisdiction to understand where your portfolio is in the completion of those requirements. This is all achieved through the corporate health check. This is a very common term. It's a process you may have heard of before, but briefly, we'll talk about it now here.

The corporate health check is a comprehensive audit of your global entities, and it helps to do specifically three things. First function helps us to understand your current entity status. Through a review of data from the public registry in-country, CSC is able to understand what has or has not been completed for each of your entities and to identify any deficiencies within a global portfolio according to the business registry that might need to be addressed. So some common deficiencies that we uncover through our corporate health check projects. This includes things like missed annual general meeting filings or other general filings, perhaps an incorrect number of officers or directors in place, an incorrect address on file perhaps, or some other company change that wasn't updated within the registries or some kinds of missed filing or updates.

The second function of the corporate health check project is the uncovering of the current and correct data, all of that vetted data and information, things like your officer or director slate, your powers of attorney, jurisdictional IDs, address information, share capital and ownership, really a complete understanding of the filing responsibilities and deadlines by entity and by jurisdiction. After the corporate health check is complete, your dedicated project manager here will review the results with you. If deficiencies do exist in your portfolio, we're going to sit with you. We'll develop a plan for remediation. We'll help to assist with bringing those entities back into good corporate health.

The third function of the corporate health check includes the migration of all of that beautiful vetted data and information, the requirements, the deadlines all into the technology. CSC is award-winning entity management platform. Our proprietary technology solution captures all of the current entity information. It provides clients with visibility and complete transparency across their organization all in one secure and evenly accessible central repository. That data really forms the foundation of our core service of ongoing entity maintenance, which we refer to as Annual Compliance Support. And John is going to take us through what is included in that annual compliance support offering. John?

John: Thanks, Andrea. Certainly, I will. This really is the core of CSC's Global Subsidiary Management offering, and this is predicated, again, on centralization. So while we're going to talk about components of annual compliance support, the overarching theme is an understanding that CSC is going to be maintaining all of your corporate events, all of your compliance events for each of your entities around the world in a centralized fashion through your project manager most commonly here in Wilmington, Delaware or for our hubs for our service out of London and Hong Kong. The other big overarching theme is the constant and automated capture of data and documentation in our award-winning technology.

Annual compliance support though really is a bundled service highly inclusive, and what we're doing is bundling together all of the required functions for your entities in each jurisdiction that's commonly maintained by a corporate services provider like CSC. It does vary based on the jurisdiction. So please know when I'm discussing today is a broad overview, but in jurisdictions where there are nuances, in most cases, we're absorbing those nuances.

The services themselves, highly inclusive, most commonly including the maintenance of minute books and shareholder registers. Of course, we're always doing this digitally in CSC Entity Management but in jurisdictions where we're taking on a role that requires us to maintain physical documentation and minute books, we're doing so as a standard inclusion. We're also going to be handling any of the documentation required for the oversight of annual general meetings, the drafting of those documents proactively and in dual languages. Everything having an English counterpart is such a big part of what we do, making your documents universally readable around the world.

We're also going to be handling any of the subsequent filings around annual meetings, and when I say annual meetings, I mean that fairly loosely. In some jurisdictions, there truly is one annual meeting as your requirement, very different than here in the United States where lots of good companies certainly have directors meetings, but there's no requirement there other than possibly self-imposed in your bylaws.

Around the world, though, there are not only those requirements for annual meetings but in some cases, additional meetings required. If you look at a jurisdiction like India since their newest Companies Act, there's requirements for quarterly Board of Directors' meetings and one annual shareholders' meeting. So our service is going to morph to take on that requirement.

In a jurisdiction like Spain where if you have a board of directors of more than two people, we're going to adhere to the rule of quarterly meetings. But if you're looking at a jurisdiction like the United Kingdom or Cayman Islands or so many other jurisdictions where there's no requirement, we're going to morph in that direction.

In many jurisdictions, we're going to include the concept of registered office. Now let's chat about that as a quick aside. Most countries around the world, the standard operating procedure is that your registered office address, not to be confused with the American registered agent services. The registered office address most commonly is your principal place of business, and it's most commonly facilitated through your physical brick-and-mortar location within the jurisdiction. And, of course, where that's the case, we're going to advise accordingly. But there's also a number of jurisdictions largely those that are governed by English common law where it's much more common that your corporate secretarial provider will act as your registered office and will provide that address.

In those jurisdictions, rather than nickel-and-diming our clients for a service that really is understood to be a service that we would provide, we simply include it. So that would be true in jurisdictions like Canada, United Kingdom, Ireland, Hong Kong, Singapore, Australia, Malaysia, a number of Island jurisdictions, and we make it very clear where the registered office provision is provided as a basic inclusion. That's not to say that we can't provide registered office services in other jurisdictions where you have a need. It's certainly the testament to our flexibility, where you maybe don't have a dedicated team in place or maybe it's just a sales and marketing office, and it doesn't make sense to use it as your registered address, CSC can facilitate. Similarly with resident director services that I had mentioned previously, where you have requirements for residency, most commonly makes sense to utilize your own director level people to fill those roles, but where you can't, CSC is here to assist.

As we've already mentioned, you have the benefit of automating the organization of data and documentation in CSC Entity Management, which is valuable beyond belief. What you're going to have is an ever-changing database that is always up-to-date. So when you record against your data, you can confidently record against your data and know that is current and true.

As mentioned here U.S.-based support team. Now, of course, for those of you who are based here in North America, U.S.-based support team is incredibly valuable. You're not working with outsourced teams. You're not working with a team in the Philippines or anything like that. You're working with U.S.-based CSC support with in-country experts, fulfillment specialists here out of our Wilmington office who specialize in different regions of the world, but we do have boots on the ground in over 145 countries around the world.

And, of course, one of the big highlights here, a flat-rate pricing model. Rather than relying on law firms and fielding invoices throughout the year with hourly rates for different services, we're here to bring budget certainty. Everything highlighted as part of annual compliance support will be available to you for a flat rate U.S. dollar cost. We do some flexibility with billing currency. So if you have different desires there, we can support that, but the flat-rate model will bring that budget certainty and make it completely clear what's included in that flat rate.

Andrea: Now, we've talked about what is kind of most common in-country, but we haven't talked about all of the other things that you're also going to need. We call those additional transactions. So what John just described is the core service of the items that companies need most commonly in each of the jurisdictions, but there's also going to be additional items that are outside of this scope of common offerings.

But we can assist in those regards as well. These are going to be separate needs that arise from your general day-to-day needs. These include things like your officer director changes, your ad-hoc resolution drafts, the transfer of share capital, document retrieval, research projects, formations, liquidations, so many more things that you're going to need. And CSC is positioned to assist with those items as well. When those changes occur within your global portfolios, we can simplify those projects using the same streamlined and centralized approach that really sets us apart from the competition in this space.

One of our favorite examples to illustrate this point is a very common director change project that really resonates with many of our prospective clients and I think will resonate with many of you on the webinar today. Let's say, for example, that one of your directors is retiring, and this person happens to be a director for many different entities around the world in your company.

This is a very frequent occurrence. Commonly, people will tell John and me, "Well, what we do is we reach out to our law firm in Brazil, and we reach out to the firm in Singapore and Australia and so on and so forth. And we start to handle this change piecemeal across all of our vendors and our contacts." And then they quickly find themselves juggling these 20 different projects in these 20 different jurisdictions.

Wouldn't it be so much easier for you to simply call or email your project manager here in Wilmington, Delaware and say, "Hey, Susan retired. What do we have to do?" From there, we're going to recess the scope of the project with you. We'll evaluate the best course of action. We're really going to customize a perfect and tailored solution for you so that rather than managing these 20 different projects in 20 different countries, you're managing one project with CSC spearheading the efforts to manage and execute the change on your behalf.

We have the knowledge. We have the expertise. We understand where we can mitigate your costs versus where we need to be more expeditious to avoid additional fees or penalties. So we would know, for example, that we needed to execute a director change in Australia. We'd be able to kind of have that folded in to be the upcoming general meeting within the next 30 days so that we could avoid those extraordinary measures and the additional cost that would come with that type of a change.

Very conversely, we would understand if we were handling that type of change in Hong Kong or Singapore, for example, we would need to be more expeditious. We would need to handle that change immediately within the requisite 15 days or 30 days respectively in those jurisdictions.

Very similarly to our annual compliance support services, when we complete these projects, we provide flat-rate fees and flat-rate pricing for those ad hoc services so that we can always provide budget certainty. And the work that is completed by CSC on your behalf will automatically flow into the technology, CSC's Entity Management Solution so that all of the data and the documents become available to clients in real-time as those changes occur. I see a question has come in from Erica. Do you provide local residents director in any foreign countries? John, would you like to take that answer?

John: I'm absolutely happy to, yes. So, again, speaking to the flexibility that CSC offers, where you have requirements to fulfill a resident director in a jurisdiction, CSC absolutely does provide resident director services. Now, again, I'm restating myself. In most jurisdictions, it is most customary to utilize your own people to fulfill these roles. We're always going to suggest that. We're not here to try to sell you every service that we can possibly fulfill, and we're always going to make that suggestion that you use your own people. But where you can't, CSC has the capabilities to fulfill these voids in most jurisdictions where it's a requirement. Most commonly we're fulfilling residency requirements in Canada, in Australia, in India, in Singapore, in Malaysia. We work in many different capabilities in Brazil and Ireland. We could talk more about this, but pretty universally globally, we can fulfill those needs if you have them.

Andrea: Let's go into our last topic, which is the Global Legal Entity Identifiers. Before we get into our product demonstration of our technology, John's going to discuss this concept of the GLEI.

John: I will, and I'll be brief because this might not apply to everybody. But the concept of a Global Legal Entity Identifier or commonly known as a GLEI or LEI is essentially a fingerprint that can be issued or like a Social Security number that can be issued, universally understood and managed by a clearinghouse called the Global Legal Entity Identifier Foundation or GLEIF. And certainly, I would point you in their direction if you're looking for more information. CSC does offer the services to both file for new GLEI registrations as well as handle the renewals. They renew on a biannual basis, and this very much fits CSC's model for filings and renewals that can be managed within our technology, CSC Entity Management, and then automatically file for renewals.

For those of you who aren't familiar with the concept of GLEIs, if you're banking internationally, you certainly would need one and probably have one or two on file right now. In a world after the last global market collapse, it was identified that banks were lending money fast and furious and a bit haphazardly without understanding completely who these companies were, and it was also understood that there was a need to identify these businesses around the world in one global clearinghouse. So duplicative loans weren't being assessed and so on. So the concept of the Clearinghouse was generated and these 20 character reference codes uniquely identified business. So, again, if you have any needs for filing of new or renewal Global Legal Entity Identifiers, you can reach out to any member of our customer service team, and we'll be happy to support you.