Global Guidelines. As early as 2004, an employee in Western Union’s Corporate Security Department prepared a set of “draft” Global Guidelines for discipline and suspension of Western Union Agent locations worldwide that processed a materially elevated number of reported fraud transactions. In these guidelines, the Corporate Security employee proposed mandatory review of any Agent location that paid 10 CFRs within 60 days. The Corporate Security employee further proposed automatically suspending any Agent location that paid five or more transactions reported as fraud within 60 days of a review. In other words, the Corporate Security employee proposed automatically suspending any Agent location that paid 15 CFRs within 120 days. Western Union did not approve or implement the proposed Global Guidelines.
Global Guidelines. All assets deposited into the trusts required by the Reinsurance Agreement shall be invested in eligible assets subject to the following global asset class investment guidelines. For the purposes of applying the global limits set forth below, the assets shall be aggregated across the two trusts required by the Reinsurance Agreement. If the global guidelines set forth below are more restrictive than those set forth in Section A of this Exhibit A, then the provisions of this Section B will govern. Asset Class Single Position Limit(as a percentage of total assets in both trusts) Hard Limit(as a percentage of total assets in both trusts) High Yield 1.5% 10.0% MBS-non-agency 1.0% 15.0% Commodities (through ETF and Equities) 0.5% 5.0% Equities 1.5% 15.0% IG Corporate Obligations 3.0% 75.0% Commercial Real Estate 2.0% 15.0% CLOs (A, BBB) 1.0% 7.5% ABS / Secured Obligations of US Corporations See below 37.5% US Government Obligations N/A N/A US Municipal Obligations 3.0% 25% Derivatives (Hedging-only) Per Treaty
Global Guidelines. All assets deposited into the trusts required by this Reinsurance Agreement shall be invested in eligible assets subject to the following global asset class investment guidelines. For the purposes of applying the global limits set forth below, the assets shall be aggregated across the two trusts required by this Reinsurance Agreement. If the global guidelines set forth below are more restrictive than those set forth in Section A or B of this Exhibit C, then the provisions of this Section C will govern. Conversely, if the regulations set forth in Section A of this Exhibit C preclude certain assets classes below, then they may only be present in the Supplemental Trust Account. Asset Class Single Position Limit(as a percentage of total assets in both trusts) Hard Limit(as a percentage of total assets in both trusts) High Yield 1.5% 10.0% MBS-non-agency 1.0% 15.0% Commodities (through ETF and Equities) 0.5% 5.0% Equities 1.5% 15.0% IG Corporate Obligations 3.0% 75.0% Commercial Real Estate 2.0% 15.0% CLOs (A, BBB) 1.0% 7.5% ABS / Secured Obligations of US Corporations See below 37.5% US Government Obligations N/A N/A US Municipal Obligations 3.0% 25% Derivatives (Hedging-only) Per Treaty
Global Guidelines. If the restrictions/guidelines set forth below are more restrictive than those set forth in Section A of this Exhibit A, then the provisions of this Section B will govern. All assets deposited into the trusts required by the New York Reinsurance Agreement shall be invested in eligible assets subject to the following asset class investment restrictions/guidelines. For the purposes of applying the limits set forth below, the allocations must be followed, individually, for each of the two trusts required by the New York Reinsurance Agreement. Asset Class Single Position Limit(as a percentage of total assets in the trust) Hard Limit(as a percentage of total assets in the trust) High Yield 1.5% 25.0% MBS-non-agency 1.0% 15.0% Commodities (through ETF and Equities) 0.5% 5.0% Equities 1.5% 15.0% IG Corporate Obligations 3.0% 75.0% Commercial Real Estate 2.0% 15.0% CLOs (A, BBB) 1.0% 7.5% ABS / Secured Obligations of US Corporations See below 37.5% US Government Obligations N/A N/A US Municipal Obligations 3.0% 20% Derivatives (Hedging-only) Per Treaty
Global Guidelines. All assets deposited into the trusts required by this Reinsurance Agreement shall be invested in eligible assets subject to the following global asset class investment guidelines. For the purposes of applying the global limits set forth below, the assets shall be aggregated across the two trusts required by this Reinsurance Agreement. If the global guidelines set forth below are more restrictive than those set forth in Section A or B of this Exhibit C, then the provisions of this Section C will govern. Conversely, if the regulations set forth in Section A of this Exhibit C preclude certain assets classes below, then they may only be present in the Supplemental Trust Account.
