EMIR 2.1 Takes Effect Imminently: Implications for EU and Non-EU Asset Managers and Funds

Morgan Lewis

Morgan Lewis

Following an assessment by the European Commission (the Commission) of how the European Market Infrastructure Regulation (EMIR) has been working since it entered into force on 16 August 2012 and the phasing in of its various requirements, an EU regulation[1] that makes targeted modifications to EMIR—known colloquially as EMIR 2.1 or EMIR Refit—enters into force on 17 June 2019. Controversially, some significant regulatory requirements emanating from modifications wrought by EMIR Refit will take effect immediately on 17 June, a mere 20 days after publication of EMIR Refit on 28 May 2019 in the Official Journal of the European Union.[2]

From the buy-side perspective, the key modifications are the expanded definition of a financial counterparty (FC), the exemption for sub-threshold or small FCs and, for EU asset managers only, the application of the trade reporting obligation to the EU manager of the fund, rather than, as now, the fund itself. In addition, in a welcome deregulatory development, EMIR Refit abolishes the contentious backloading aspect of the trade reporting obligation and the frontloading aspect of the clearing obligation.

The Commission assessed EMIR over the summer of 2015, consulting the public and taking into account reports from the European Securities and Markets Authorities (ESMA), the European Systemic Risk Board, and the European System of Central Banks. The Commission then waited on the separate Call for Evidence on the EU Regulatory Framework carried out between September 2015 and January 2016. The Commission found that while no fundamental change should be made to the core requirements of EMIR, EMIR could usefully be amended in certain areas to eliminate disproportionate costs and burdens on some counterparties and to simplify certain rules. At that stage, the EMIR assessment was fed into the wider 2016 Commission's Regulatory Fitness and Performance programme (REFIT), which led to the use of the expression "EMIR Refit" to describe the amending EU regulation that arose from the assessment. However, EMIR Refit is not the product of a comprehensive review of EMIR, as the Commission considers that it is still too early to draw a firm conclusion on EMIR's long-term impacts. This approach makes sense, given the welcome gradual phasing in over several years of its requirements.

Expanded Definition of an FC

FCs under EMIR (prior to EMIR Refit) already include any EU or non-EU alternative investment funds (AIFs) managed by EU alternative investment fund managers (AIFMs) authorised or registered under the Alternative Investment Fund Managers Directive[3] (AIFMD) (but not EU AIFs managed by non-EU AIFMs, which are typically classified as non-financial counterparties (NFC)), as well as EU banks, investment firms, undertakings for collective investments in transferable securities (UCITS), and insurers. EMIR Refit extends the definition of an FC to also include: i) any EU AIF irrespective of the location or status under AIFMD of its manager; and ii) a fund's AIFM if the AIFM is EU-established. Therefore, an EU AIF managed by a non-EU AIFM (which is currently classified as an NFC) will instead be an FC under EMIR Refit. The change to the FC definition will not impact UCITS which already constitute FCs under EMIR.

The classification of an AIF as an FC or NFC is critical since it determines the application of certain EMIR requirements, such as those relating to clearing and margin and other risk mitigation requirements. EU counterparties to AIFs, whether EU or non-EU, must therefore know what classification the AIFs fall into. An FC is under an obligation to centrally clear standardised over-the-counter (OTC) derivative contracts—subject to the new small financial counterparty (SFC) exemption described below—or perform risk mitigation procedures for uncleared OTC derivatives, such as the posting of margin and trade reporting.

EMIR Refit clarifies that AIFs that are securitisation special purpose entities (SSPEs) or established solely for employee share purchase plans (ESPPs) are excluded from the new FC definition and will therefore be classified as NFCs.

Small Financial Counterparty Exemption

In another deregulatory initiative, EMIR Refit helpfully recognises that FCs whose volume of trades falls below specified clearing thresholds qualify as SFCs and should not be subject to the clearing obligation at all. The clearing thresholds for this purpose are the same as those under EMIR that determine whether an NFC is an NFC – or NFC+[4], except that hedging transactions that an FC enters into must be included in the calculation. ESMA recently clarified that if an AIF wishes to rely on the SFC exemption, it must have calculated its aggregate month-end average position for the previous 12 months as at the date EMIR Refit comes into force, 17 June 2019. The SFC exemption reflects the disproportionate costs that smaller counterparties would otherwise bear in order to meet the clearing obligation.

The extended scope of EMIR by the wider definition of an FC is, therefore, partially countered with the introduction of the new SFC exemption, which will reduce the number of counterparties that need to comply with the EMIR clearing obligation. Accordingly, the impact upon funds and their asset managers might not prove to be as significant in practice as it first appears.

While SFCs are exempt from the clearing obligation, they remain subject to risk mitigation requirements such as those relating to margin, confirmation timings, and portfolio reconciliation and compression. FCs who could qualify as SFCs will have the ability to notify ESMA if they have chosen not to run the calculation, so that they remain classified as FCs. As an SFC is still required to comply with margin requirements, asset managers may choose to clear the OTC derivative transactions rather than exchange margin.

The 30-day rolling average determination, currently used to calculate the clearing thresholds for NFCs, has been replaced by an annual determination calculated at the level of the AIF.

Under EMIR Refit, NFCs will only be subject to the clearing obligation for the specific asset classes that exceed the threshold (as NFCs pose less of a systemic risk to the financial system); FCs that exceed the threshold for any asset class will continue to be required to clear all OTC derivatives for all asset classes. However, asset managers that currently fall within the scope of EMIR may find that they no longer need to comply with the clearing obligation due to the introduction of the SFC exemption.

Changes to Reporting Obligations

Under EMIR, the trade reporting obligation is one-sided in that it applies only to EU counterparties. While EMIR currently imposes the EMIR reporting obligation on the EU AIF counterparty (whether FC or NFC + or ‑), EMIR Refit instead places responsibility and legal liability for the reporting obligation on the AIFM of the EU AIF counterparty. As of18 June 2020, the AIFM will become responsible for reporting and ensuring the accuracy of the details reported on behalf of the EU AIF. Asset managers will need to ensure that the change of reporting obligation is reflected in the management agreement and any relevant fund documents. However, this is unlikely to have a significant impact where the asset manager is already providing trade reporting services to the AIF.

FCs will become solely responsible and legally liable for reporting trades with NFCs+ on behalf of both counterparties and for ensuring the details reported are accurate. That change is mitigated by the imposition of a new obligation on NFCs to provide their counterparty FC with details of OTC derivatives that the FC cannot reasonably be expected to possess and to take responsibility for its accuracy. Where an FC deals with a non-EU counterparty, the FC will be required to report the value of any collateral posted and the mark-to-market value of each OTC derivative that it has entered into with the non-EU AIF.

EMIR Refit also removes reporting obligations for intra-group trades where at least one counterparty is an NFC because intra-group derivative transactions are primarily used for internal hedging and, therefore, do not contribute significantly to systemic risk. Additionally, the backloading requirement is abolished so that parties will no longer be required to report derivative transactions that were not outstanding on 12 February 2014, the date that the trade reporting obligation under EMIR commenced.

Impact on US and Other Non-EU AIFs

Irrespective of EMIR Refit, EMIR has an indirect impact on non-EU counterparties such as AIFs. Where an EU counterparty trades with a non-EU AIF, the clearing obligation and risk mitigation requirements for uncleared OTC derivatives already provide that the obligations of the EU counterparty are determined by reference to the equivalent categorisation of that non-EU AIF as if it were an EU AIF. Accordingly, following EMIR Refit, non-EU AIFs managed by non-EU AIFMs (who will not be directly covered by the expanded definition of an FC) will prima facie be categorised as equivalent to an FC, a third country FC. Non-EU AIFs may rely on the SFC exemption on the same deemed basis in order to be classified as equivalent to an SFC, a third country SFC, provided that the non-EU AIFs have collected the necessary data for the first clearing calculation, prior to 17 June 2019. This will allow the first calculation to be made on 17 June.

Non-EU AIFs that exceed any one of the clearing thresholds will be required to clear, but not otherwise. The changes under EMIR Refit should not of themselves cause a third-country NFC– to qualify as an FC (as opposed to an SFC) and thereby become subject to the clearing obligation. However, EMIR Refit does provide for delayed implementation for a non-EU AIF that has been re-classified as a third-country entity FC and will have four months to make clearing arrangements after 17 June 2019.

Non-EU AIFs that deal with an EU FC/NFC+ will be required to put margin agreements in place by the time EMIR Refit comes into force. In practice, that process will need to be driven by the EU dealer. Non-EU AIFs must also ensure that they notify their EU counterparties of their new status as either a third-country SFC or FC on the day on which EMIR Refit comes into force to avoid breaching any representation of their former status in current documentation.

Non-EU AIFs that are managed by an AIFM authorised or registered under AIFMD (currently, only EU AIFMs can acquire such status) are already FCs under EMIR and will remain so under EMIR Refit, subject to the SFC exemption and the exclusion for SSPEs and ESPPs.

Next Steps

EU asset managers should reassess any AIFs that they manage in order to establish whether their categorisation changes under EMIR Refit following the expanded definition of FC and, if so, prepare to notify ESMA of their FC or SFC classification on 17 June 2019. EU counterparties to AIFs will want to review any existing representations made by those AIFs as to their counterparty classification post EMIR Refit. Those AIFs and their managers should consider undertaking that analysis at their own initiative and updating their status representations as necessary.

Non-EU AIFs currently categorised as NFC– will probably be impacted, becoming required to post margin on all OTC derivatives entered into with any EU FC or NFC+. Those FCs and NFC+s will in turn need to ensure that their margin agreements are EMIR compliant. This will be difficult to achieve by 17 June 2019, particularly where no margin arrangements are already in place voluntarily.

The industry is unhappy that it has been given just 20 days to meet the requirements flowing from the expanded definition of an FC and is lobbying for regulatory forbearance to be exercised by national regulators for a significant period. The unexpectedly short period is ironic given EMIR Refit was designed to diminish disproportionate burdens and simplify EMIR.


[1] Regulation (EU) 2019/834 of the European Parliament and of the Council of 20 May 2019.

[2] It is worth noting that the European Parliament's ECON Committee indicated in May 2018 that amendments under EMIR Refit should take effect no sooner than five months after coming into force.

[3] Directive (EU) 2011/61 of the European Parliament and of the Council of 8 June 2011.

[4] The clearing thresholds are €1 billion in gross notional value for each of credit and equity OTC derivatives and €3 billion in gross notional value for each of OTC interest rate derivatives, OTC FX derivatives, OTC commodity derivatives, and other OTC derivatives. However, EMIR Refit empowers ESMA to review the clearing thresholds periodically and update them where necessary.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Morgan Lewis | Attorney Advertising

Written by:

Morgan Lewis

Morgan Lewis on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.