WHAT COMES NEXT FOR "MEME" STOCKS - BNY Mellon

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WHAT
COMES
NEXT FOR
“MEME”
STOCKS
BY PETER MADIGAN
BY THE
NUMBERS
300%
Increase in average daily orders through one retail
equities brokerage in Q1, 2021 vs. Q1, 2019

24.4 BILLION
Total number of shares traded across U.S. equities
exchanges on January 27, 20211

600,000
New downloads on the Robinhood Markets trading
app on January 29, 20212

3 MILLION
Number of new account openings on Robinhood in
the first four months of 20203

13 MILLION
Number of users on the Robinhood Markets trading
platform by February 20214

SOURCES:
1.   CBOE Global Markets
2.   JMP Securities
3.   CNBC Squawk Box, October 27, 2020
4.   Congressional Testimony before U.S.
     House of Representatives Subcommittee on
     Financial Services, February 18, 2021
RETAIL INVESTORS HAVE BEEN MOVING
MARKETS, THANKS TO PANDEMIC-RELATED
DAY TRADING AND COMMISSION-FREE
EXECUTION. DESPITE A RECENT PULLBACK,
EXPERTS SAY THERE IS NO END IN SIGHT.

BY PETER MADIGAN

                      hen millions of       anywhere on a mobile phone; and a            Instead, cult-like trading among an

W                     individual stock
                      pickers took on
                      Wa l l S t re e t —
leading transaction volumes to surge
in January—some didn’t see it coming.
                                            pandemic that has caused a spike in
                                            day-trading. Some have seen huge
                                            windfalls; others crushing losses.
                                            Several investors in both camps have
                                            been reluctant to cash out.
                                                                                       expanded set of retail investors is a
                                                                                       sign that equity markets are changing
                                                                                       rapidly, and that perhaps the shift will
                                                                                       be permanent. At the same time, bro-
                                                                                       kers, exchanges and regulators are
Now that the new generation of traders        Moreover, the retail participation is    trying to determine what to make of
is driving so much of today’s equity        much broader than initially reported,      the phenomenon and how to tamp
flows, established industry players are     according to market participants. The      down on any concerning, specula-
asking what their participation means       activity has already targeted dozens       tive activity that might exacerbate the
over the long haul.                         of stocks across multiple sectors.         price swings.
  The galvanization of these “retail”       It involves large numbers of retail
investors has captured the market zeit-     investors who have opened zero-com-        MULTI-PLAYER MODE
geist in recent months, as huge vol-        mission brokerage accounts. And the        Much of the heightened activity has
umes of trades were effectively crowd-      activity has been underway far longer      been attributed to so-called “meme”
sourced from social media chat rooms.       than many might suspect.                   stock trading, when retail investors
Their activity has prompted eye-pop-          First-quarter trading volumes would      surge into popular low-priced equities,
ping moves across dozens of low-priced      have been the most compelling story        in many cases after seeing fundamental
stocks that were either thinly traded or    for stocks in a generation, had it not     analysis posted online.
virtually moribund.                         been for last spring, when U.S. equities     The poster child for this trend is,
  Fueling the behavior are discount         plunged from all-time highs into bear      of course, U.S. video game retailer
brokerages now offering commis-             market territory in just 15 trading ses-   GameStop (GME), which began to be
sion-free trading; technology that          sions due to the panic surrounding the     promoted as an undervalued security
is making it easier to transact from        COVID-19 pandemic.                         in mid-2020 on Reddit’s WallStreetBets
“Around August 2020, principal dealers
  began to receive a lot of order flow from
  retail investors looking to buy stocks trading
  below $5, whereas that kind of activity was in
  the low single digits pre-COVID.”
  ADAM INZIRILLO, CBOE GLOBAL MARKETS

discussion board. GameStop’s price           Charles Schwab survey.                     onset of COVID-19 creating a larger
climbed steadily through late 2020             Individual trade flow at the start       population of day traders, who could
before exploding to $347 a share on          of the year neared record levels. On       buy and sell from their mobile phones,
January 27, an 8,575% increase on the        January 27, there were 24 billion shares   trade algorithmically, or even use
stock’s $4 valuation six months ear-         traded, versus around 10 billion shares    large amounts of borrowed money.
lier. By late March, it traded around        traded daily as of mid-April. Analysis     Retail flow has played a large part in
$181 and remains volatile at the             from Bloomberg Intelligence estimates      driving the price action in U.S. equi-
time of writing.                             23% of all U.S. equities off-exchange      ties ever since, although participation
  The noteworthy aspect of this is not       trading volume in the first quarter of     has been outsized since the middle
GameStop, or AMC Entertainment,              this year came from retail investors, up   of 2020. Lately, it has spread even to
No ki a , Bl a ckB e r r y or any ot h e r   from 20% in 2020 (see figure 1).           cryptocurrencies, as evidenced by the
hyped-up name, however. It is what             The proportion of retail flow on equi-   interest surrounding Coinbase Global,
the phenomenon tells investing pro-          ties exchanges is thought to be higher     a cryptocurrency exchange, which
fessionals and regulators about the          still. Last July, Joseph Mecane, Head      conducted a direct listing in April.
changing makeup of equit y mar-              of Execution Services at broker dealer       “The psychology and sociology of
kets, namely that retail investors can       Citadel Securities, told Bloomberg         this relates to the pandemic and mom,
move markets.                                that retail investors accounted for as     pop and millennials having access to
  These investors are a mix of first         much as 25% of U.S. equity trading         institutional technology,” Ron Hooey,
timers with new accounts, and indi-          on busy days, up from 10% in 2019.         Head of Institutional Equities Sales at
vidual “mom and pop” investors               A spokesman for Citadel, which han-        BNY Mellon. “It was the perfect storm
who have been trading more actively          dles approximately 40% of U.S.-listed      for all of this retail frenzy to occur, and
during the pandemic while working            retail volume, declined to provide an      it’s going to impact transparency.”
from home, in many cases armed               updated figure, stating that recent          Much of the commentary on meme
with stimulus checks. Some 15% of            trading “was too volatile [and] likely     stocks has portrayed the group of retail
retail investors trading today started       an aberration.”                            investors as a relatively small group of
only last year, according to a recent          The trend started last year, with the    activist millennials, using social media
RETAIL SHOPPING
                                                           Individual investors’ estimated share of U.S. equities trading volume is on the rise

                                                           20%
Percentage participation of U.S. equity trade volume (%)

                                                           15%

                                                           10%

                                                           5%

                                                           0%

                                                                      2010      2011       2012       2013       2014       2015       2016       2017       2018       2019       2020

                                                           Note: 2020 data are for January through June.                                                      SOURCE: BLOOMBERG INTELLIGENCE

                                                           FIGURE 1

                                                           to successfully squeeze hedge funds          volumes for traditional retail passive      LOW BARRIERS TO ENTRY
                                                           out of their short positions. But data       investing vehicles such as exchange-        A number of obscure names that have
                                                           from Cboe show that retail trading is        traded funds (ETFs) and mutual funds.       drawn the attention of retail investors
                                                           much broader.                                In the fourth quarter of 2019, ETFs         in the sub-$5 range have seen their val-
                                                                Participation is not concentrated       accounted for about 12% of total U.S.       uations explode this year as a result
                                                           solely in the 15 or so headline-grabbing     equities volumes, but by the fourth         of retail interest. Relatedly, they have
                                                           names that initially dominated the           quarter of 2020, they had fallen to         sparked interest in stocks priced below
                                                           coverage. It has evolved to cover at         about 6%, according to Cboe.                $1 – the so-called “penny” stocks.
                                                           least 50 names, based on the number               As the second quarter gets                  “Around August 2020, principal
                                                           of companies in which online bro-            underway, retail investors appear to        dealers began to receive a lot of order
                                                           kerage Robinhood Markets restricted          be taking a breather (see figure 2),        flow from retail investors looking to
                                                           trading on January 29 at the height of       perhaps because there are now more          buy stocks trading below $5, whereas
                                                           the meme stock mania.                        distractions with restaurants opening       that kind of activity was in the low
                                                                Many hedge funds were shor t            back up and COVID-19 vaccines being         single digits pre-COVID,” says Adam
                                                           GameStop — Melvin Capital                    rolled out. Average daily volumes           Inzirillo, Head of North American
                                                           Management, most transparently — but         of shares transacted as of mid-April        Equities at Cboe.
                                                           once the potential to execute a short        have fallen 38% from their 15.6 billion          The breadth and extent of the
                                                           squeeze in the position became widely        January average, according to Cboe.         interest goes beyond U.S. equities, too,
                                                           known, institutional money flooded           Despite this pullback, experts say the      taking in stocks such as U.K.-based
                                                           into GME too.                                new set of traders are more educated        Critical Metals and Canada-based
                                                                The surge in meme stock investing       on investing and will remain a force        Sundial Growers. Cboe observes that
                                                           has not been reflected in trading            in markets.                                 overseas retail flows have entered the
“If you added a charge of 0.1% on to the cost
 of a transaction, that would be enough to
 discourage the zero-com­mission day-trading
 retail speculators.”
  TERESA GHILARDUCCI, NEW SCHOOL

U.S. market though international retail      had been removed.                         number of shares transacted and the
brokerages such as Interactive Brokers         Marry that with the electronifica-      trade volume surged. But even as valu-
and Webull Financial                         tion of markets, proliferating chatter    ations began to sharply recover, activity
  Analysts attest that the recent prolif-    on social media sites and a global        was consistently north of 10 billion
eration of zero-commission trading was       pandemic, and the result was crowd-       shares traded daily.
the primary catalyst for the eruption in     sourced trading ideas that could build      A significant part of this heightened
retail stock picking (see figure 3), along   quickly in different corners of the       activity was coming from retail inves-
with a fear by day-traders of missing out    internet simultaneously.                  tors and still is. “Our average daily
on a quick win. While Robinhood intro-         Robinhood added 3 million new           orders were up 302% compared to
duced commission-free trading in 2015,       users in the first four months of 2020    2019, and the majority of that increase
Charles Schwab became the first of the       alone, according to Co-Founder and        was coming from retail accounts,” says
large established retail brokerages to       Chief Executive Vladimir Tenev. By        one director on a retail equities bro-
eliminate its commission fee in October      February 2021, the platform boasted 13    kerage desk in New York.
2019. Within weeks, TD Ameritrade,           million users with as many as 600,000       Options were another reflection of
E*Trade and Fidelity Investments had         new downloads of the Robinhood            their participation. Single-contract
done the same, and a few months later,       app on January 29, the height of the      options trades in December consti-
Vanguard followed suit.                      GameStop trading frenzy.                  tuted 8% of all options in the U.S., with
  Previously, brokerages had typi-             The impact that these millions of       much of those trades driven by retail,
cally offered only commission-free           new retail participants were having in    according to Cboe.
trading in their own families of passive     the U.S. equity market soon became
investing products such as ETFs and          apparent. In the first two pre-pandemic   ALL POWERED UP
mutual funds. But as 2020 dawned,            months of 2020, the total number of       As 2021 began and the meme stock
retail investors stood on the preci-         shares transacted across U.S. equities    trading mania kicked into high gear, the
pice of a new decade in which, for           exchanges held steady at between 7.8      number of shares traded hovered close
the first time, even the most cursory        billion and 8.3 billion, according to     to the 15 billion mark on U.S. equities
hurdle to speculating in single stocks       Cboe. Then, in March 2020, both the       exchanges, while the total trade count
OFF PEAK
                                   Equity trade volumes in April have fallen from their January peak

                                   20
                                                                                                 1Q21 ADV OF 14.7BN SHARES
                                   18

                                   16                                                  15.6                 15.3
Average Daily Volume (Billions)

                                   14                                                                                             13.4

                                   12
                                                                     10.9

                                   10                                                                                                                  9.7

                                   8
                                                   7.0

                                   6

                                   4

                                   2

                                   0

                                                   2019              2020             JAN- 21              FEB - 21             MAR - 21           APRIL - 21TD*

                                  *April data are through 4/14/21                                                  SOURCE: CBOE GLOBAL MARKETS AND PIPER SANDLER & CO.

                                   FIGURE 2

                                  bounced around 80 million. This was         with 24.5 billion shares traded during          held hearings at which policymakers
                                  up from 8.4 billion and 43 million          that session across 126 million trades,         raised concerns about the “gamifica-
                                  respectively, a year earlier. The lion’s    according to Cboe (see figure 4).               tion” of investing and the potential
                                  share of these were driven by retail          As extraordinary as those num-                risks to novice retail investors.
                                  investors.                                  bers are, the continuation of elevated            Many questions were focused on
                                        Not only was the flow notable         trading activity through February and           the “payment for order flow” busi-
                                  because of its origins, but the compo-      into March was even more meaningful.            ness model used by retail brokerages,
                                  sition of the order flow was markedly       Ten of the busiest days for electronic          arrangements in which brokerages
                                  different from the names that had tra-      order flow into the retail equities desk        receive compensation for directing
                                  ditionally been the most active, such       occurred in January and February of             client order flow to a particular market
                                  as Tesla or Facebook, Amazon, Apple,        this year, for example.                         maker. The theory is that there could
                                  Netflix and Google (FAANG stocks).            “Despite all the focus on the market          be a conflict of interest there: If the
                                        “The orders for the FAANG-type        action at the end of January, the story         broker is being paid for order flow, it
                                  names that have typified retail order       that the market data is telling us is           might be more concerned with nur-
                                  flow in recent years were supplanted        clear: this retail investing surge is far       turing those relationships than main-
                                  for days, running. On many days, GME        from over,” says Cboe’s Inzirillo.              taining high execution quality for retail
                                  was the number-one name that we               The meme stock phenomenon has                 customers.
                                  were executing,” recalls the retail equi-   already attracted the attention of leg-is-        At a hearing of the Senate Banking
                                  ties director.                              lators and regulatory authorities, who          Committee on March 9, senators
                                        January 27 — the day of GME’s all-    have expressed some interest in                 questioned whether commission-free
                                  time high — was by far the busiest day      structural reform. In February, the             trading is actively encouraging amateur
                                  for activity on U.S. equity markets,        House Financial Services Committee              investors to speculate on meme stocks,
Notes: E*Trade definition of DARTs adjusted in November 2019 to reflect all customer-directed
                       trades. Schwab monthly value estimated from weekly client trading activity report (13 weeks).
                       Schwab value includes revenue, asset-based, and other trades (See The Charles Schwab Corporation
                       Recent Client Trading Activity Report for more detail). Interactive Broker values based on
                       Monthly Brokerage Metrics report. TD Ameritrade values based on latest Monthly Metrics report.
                       Data from January 2019 through December 2020. As of October, 2020, Morgan Stanley
                       acquired E*Trade and Charles Schwab acquired TD Ameritrade. TD Ameritrade DARTs not reported for
                       August 2020.

                          NEW ORDER
                          Daily average trades by major retail brokerages*

                          6,000K                   Charles Schwab
                                                   Charles Schwab + TD (Pre-Acquisition)
                                                   Charles Schwab + TD (Post-Acquisition)
                          5,000K
                                                   E *Trade
                                                   Interactive Brokers                                                                                                       ROBINHOOD ANNOUNCES
Daily Average Trades

                                                                                                                                                                             4.3M DARTS IN JUNE
                          4,000K                   Robinhood
                                                    TD Ameritrade

                          3,000K                                            BROKERAGES GO TO
                                                                            ZERO-COMMISSION

                          2,000K

                          1,000K

                               0K

                                                04/01/19                    08/01/19                    12/01/19                    4/01/2020                    08/01/2020                12/01/2020

                           SOURCE: COMPANY FILINGS/REPORTS, NASDAQ ECONOMIC RESEARCH

                          Notes: E*Trade definition of DARTs adjusted in November 2019 to reflect all customer-directed trades. Schwab monthly value estimated from weekly client trading activity report (13
                          weeks). Schwab value includes revenue, asset-based, and other trades. (See The Charles Schwab Corporation Recent Client Trading Activity Report for more details.) Interactive Broker
                          values based on Monthly Brokerage Metrics report. TD Ameritrade values based on latest Monthly Metrics report. Data from January 2019 through December 2020. As of October 2020,
                          Morgan Stanley acquired E*Trade and Charles Schwab acquired TD Ameritrade. TD Ameritrade DARTs not reported for August 2020.

                          FIGURE 3

                          and whether regulation is required to                         Affiliated Scholar with the Mercatus                            odds with their customers if their rev-
                          protect them from themselves.                                 Center at George Mason University,                              enue comes from wholesalers, not
                             Testimony from witnesses was con-                          argues that zero-commission trading is                          retail. At issue will be the question of
                          flicting, with some advocating for                            the result of a multi-year competition                          whether or not it can be demonstrated
                          restrictions to be imposed in this area,                      between brokerages to drive down                                that investors receive best execution —
                          and one senator questioning whether                           execution costs for the customer. He                            as demanded by U.S. law — and price
                          the design features of retail trading                         suggests that if the payment for order                          improvement under the payment for
                          apps should be regulated to combat the                        flow model was prohibited, broker-                              order flow model.
                          gamification appeal to young investors.                       ages would compete to eliminate fees                               Another likely area for scrutiny is the
                          “If you added a charge of 0.1% onto                           in other areas.                                                 amount of time it takes to settle trades.
                          the cost of a transaction, that would                             “Misleading market information,                             Currently, U.S. stocks settle on the
                          be enough to discourage the zero-                             misconduct — yes, regulate against                              second day after the trade is agreed,
                          commission day-trading retail specula-                        those behaviors. But you cannot regu-                           a convention known as T+2. If instead
                          tors, without negatively impacting long-                      late away the risk of losing money in                           the market moves to a single day, or
                          term institutional investors like pen-                        financial markets,” says Vollmer.                               T+1, it might reduce the trade settle-
                          sion funds,” says Teresa Ghilarducci,                                                                                         ment risk in the middle office to one
                          Professor of Economics and Policy                             ADMINISTRATIVE                                                  day of exposure from two, and help
                          Analysis at the New School in New                             PRIVILEGES                                                      discourage some of the more worrying
                          York, who testified before the Senate                         For now, payment for order flow has                             speculation.
                          Banking Committee.                                            attracted the most serious political                               Even if Congress does not enact
                             Other witnesses disagree with that                         and regulatory scrutiny, because it                             changes, it seems likely that incoming
                          assessment. Andrew Vollmer, Senior                            potentially puts retail brokerages at                           Securities and Exchange Commission
SCORING POINTS
                              Retail investors are contributing to a higher number of individual trades on U.S. equity exchanges

                               140

                               120

                               100
Number of Trades (Millions)

                               80

                               60

                               40

                               20

                               0

                                                                                                                                                                                                                                                  0                        0                        0
                                                20                   20                   20                   20                   20                   20                   20                   20                   20                   02                       02                       02                      21                  21                  21
                                       /   20               /   20               /   20               /   20               /   20               /   20               /   20               /   20               /   20               1   /2                   1   /2                   1   /2                      20                  20                  20
                                    /1                   /1                   /1                   /1                   /1                   /1                   /1                   /1                   /1                   0/                       1/                       2/                        1/                  1/                  1/
                                1                    2                    3                    4                    5                    6                    7                    8                    9                    1                        1                        1                        1/                  2/                  3/

                                                                                                                                                                                                                                                                                                    SOURCE: CBOE GLOBAL MARKETS

                              FIGURE 4

                              Chairman Gary Gensler will address                                                                         trade body issued a survey of its trading                                                                               during the dot.com bubble, I used to
                              the issue. The SEC and the Financial                                                                       committee members and exchange                                                                                          ask my undergrad students how many
                              Industry Regulatory Authority have                                                                         contacts in mid-April, asking them for                                                                                  were trading stocks [online], and they
                              longstanding mandates to protect retail                                                                    their thoughts on the “new normal” for                                                                                  would tell me how much they were
                              investors.                                                                                                 volatility and volumes, as well as “risks                                                                               making and how easy it all was,” says
                                   A s ke d a b o u t t h e m e m e s t o c k                                                            to markets.” SIFMA said in the note that                                                                                Michael Piwowar, executive director
                              phenomenon during his Senate con-                                                                          such responses would be of interest                                                                                     of the Milken Institute Center for
                              firmation hearing in March, Gensler                                                                        given the “difficulty in quantifying the                                                                                Financial Markets and former a SEC
                              offered only rhetorical responses.                                                                         levels of retail participation.”                                                                                        Commissioner.
                              “How do we protect investors using                                                                                Although retail volumes have fallen                                                                                    “That was in the days of having to
                              trading applications with behav-                                                                           from their recent peak, what’s clear                                                                                    pay $10 or $20 to make a trade. If it
                              ioral prompts designed to incentivize                                                                      is that many of those investors are                                                                                     was easy then, how easy is it now when
                              customers to trade more?” he asked.                                                                        moving in tandem - and with some                                                                                        there are no commissions?” he asks.
                                   How does the meme stock episode                                                                       analysis guiding them, they can build
                              end? With new $1,400 stimulus checks                                                                       momentum in the stocks they target.
                              being deposited into the accounts of                                                                       Whether their participation moving
                              hundreds of millions of Americans,                                                                         forward is frenzied or more muted,                                                                                      Peter Madigan is editor-at-large for
                              many analysts expect the trading craze                                                                     their rise has brought a lot of new                                                                                     BNY Mellon Markets.
                              to continue.                                                                                               traders to the marketplace who are                                                                                      Questions or comments?
                                   The Securities Industry and                                                                           now engaged in their finances in ways                                                                                   Contact ron.hooey@bnymellon.com
                              Financial Markets Association (SIFMA)                                                                      they never were before.                                                                                                 or reach out to your usual BNY Mellon
                              is on its own fact-finding mission. The                                                                           “When I was a finance professor                                                                                  relationship manager.
LIAM THE
                                GEN-Z INVESTOR

                                Liam Magrini, a 21-year-old music            Between Jan. 25 and Jan. 27, the
                                production student who lives with his      peak price of GME, his then-$922.26
                                mother in Brooklyn, saw the chatter        investment had risen to $5,553.19 (see         “GME was
                                about shares in GameStop (GME)
                                “going to the moon” on the Reddit
                                                                           figure 5). He decided not to borrow
                                                                           money from Robinhood on margin,
                                                                                                                            about to
                                WallStreetBets discussion board in         although it was offered to him, and              blow…and
                                early January and — against the advice
                                of friends — invested $100, when the
                                                                           cashed out on March 10, when the
                                                                           stock was at $265 and the position
                                                                                                                            ‘Diamond
                                stock was priced at $54.                   was worth $4,374.54.                             Hands’ was all
                                    Fellow Gen-Z investors were
                                encouraging people to hold on to
                                                                             He says it gave him a taste for more
                                                                           sophisticated investing. In February,
                                                                                                                            you heard.”
                                their positions, no matter how wild        he started investing in a 2x leveraged
                                the ride. “GME was about to blow and       oil and gas ETF offered by Direxion              LIAM MAGRINI,
                                Robinhood was on the front page of         (GUSH), which delivers twice the                 RETAIL INVESTOR
                                the App Store,” he recalls. “Diamond       daily gains or losses of the S&P Oil
                                Hands was all you heard, all the           and Gas Exploration & Production
                                time,” he adds, referring to a “meme”      Select Industry Index. “It just so hap-
                                culture phrase to applaud personal         pens I came in at the right time,” says
                                fortitude in holding a stock amidst        Magrini. “I don’t know too much, so I
                                volatile trading.                          don’t want to push my limits.”

                                A QUICK WIN
                                Liam Magrini, a retail investor, got into GME just before the stock price surged to its peak

                                400
                                                                            JAN 27, 2021
                                                       JAN 25, 2021                                                                  MARCH 10, 2021
                                                                            $5,553.19
                                                        $922.26                                                                      $4,374.54
Share price of GameStop (GME)

                                                                                                                                     (CASH OUT)
                                300

                                      JAN 15, 2021
                                200    $100
                                       (CASH IN)

                                100

                                0

                                                     LIVE             1D            1W               1M              3M             1Y                ALL

                                                                                                                                         SOURCE: LIAM MAGRINI
                                      FIGURE 5
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numbers FC005522 and BR000818) at One Canada             Copenhagen Branch, filial af The Bank of New York          and is not intended to provide legal, tax, accounting
Square, London E14 5AL and is subject to regulation      Mellon SA/NV, Belgien, and has its registered office       investment, financial or other professional advice
by the Financial Conduct Authority (“FCA”) at            at Strandvejen 60/5, 2900 Hellerup, Denmark. It is         on any matter. This material does not constitute a
12 Endeavour Square, London, E20 1JN, UK and             subject to limited additional regulation by the Danish     recommendation or advice by BNY Mellon of any
limited regulation by the PRA at Bank of England,        Financial Supervisory Authority (Finanstilsynet,           kind. Use of our products and services is subject to
Threadneedle St, London, EC2R 8AH, UK. Details           Århusgade 110, 2100 København Ø).                          various regulations and regulatory oversight. You
about the extent of our regulation by the PRA are                                                                   should discuss this material with appropriate advisors
available from us on request.                            The Bank of New York Mellon SA/NV operates in              in the context of your circumstances before acting in
                                                         England through its London branch at 160 Queen             any manner on this material or agreeing to use any of
The Bank of New York Mellon SA/NV, a Belgian             Victoria Street, London EC4V 4LA, UK, registered           the referenced products or services and make your
limited liability company, registered in the RPM         in England and Wales with numbers FC029379 and             own independent assessment (based on such advice)
Brussels with company number 0806.743.159,               BR014361. The Bank of New York Mellon SA/NV,               as to whether the referenced products or services
whose registered office is at 46 Rue Montoyerstraat,     London branch is authorized by the ECB (address            are appropriate or suitable for you. This material
B-1000 Brussels, Belgium, authorized and regulated       above) and subject to limited regulation by the FCA        may not be comprehensive or up to date and there
as a significant credit institution by the European      (address above) and the PRA (address above).               is no undertaking as to the accuracy, timeliness,
Central Bank (“ECB”) at Sonnemannstrasse 20, 60314                                                                  completeness or fitness for a particular purpose of
Frankfurt am Main, Germany, and the National Bank        Regulatory information in relation to the above            information given. BNY Mellon will not be responsible
of Belgium (“NBB”) at Boulevard de Berlaimont/de         BNY Mellon entities operating out of Europe can            for updating any information contained within this
Berlaimontlaan 14, 1000 Brussels, Belgium, under         be accessed at the following website: https://www.         material and opinions and information contained
the Single Supervisory Mechanism and by the Belgian      bnymellon.com/RID.                                         herein are subject to change without notice. BNY
Financial Services and Markets Authority (FSMA) at                                                                  Mellon assumes no direct or consequential liability for
Rue du Congrès/Congresstraat 12-14, 1000 Brussels,       The Bank of New York Mellon, Singapore Branch, is          any errors in or reliance upon this material.
Belgium for conduct of business rules, and is a          subject to regulation by the Monetary Authority of
subsidiary of The Bank of New York Mellon.               Singapore. The Bank of New York Mellon, Hong Kong          This material, which may be considered advertising,
                                                         Branch (a branch of a banking corporation organized        is for general information purposes only and is
The Bank of New York Mellon SA/NV operates in            and existing under the laws of the State of New York       not intended to provide legal, tax, accounting,
Ireland through its Dublin branch at Riverside II,       with limited liability), is subject to regulation by the   investment, financial or other professional advice
Sir John Rogerson's Quay Grand Canal Dock, Dublin        Hong Kong Monetary Authority and the Securities &          on any matter. This material does not constitute a
2, D02KV60, Ireland and is registered with the           Futures Commission of Hong Kong.                           recommendation or advice by BNY Mellon of any
Companies Registration Office in Ireland No. 907126                                                                 kind. Use of our products and services is subject to
& with VAT No. IE 9578054E. The Bank of New York         For recipients of this information located in              various regulations and regulatory oversight. You
Mellon SA/NV, Dublin Branch is subject to limited        Singapore: This material has not been reviewed by the      should discuss this material with appropriate advisors
additional regulation by the Central Bank of Ireland     Monetary Authority of Singapore.                           in the context of your circumstances before acting in
at New Wapping Street, North Wall Quay, Dublin 1,                                                                   any manner on this material or agreeing to use any of
D01 F7X3, Ireland for conduct of business rules and      For clients located in Australia:                          the referenced products or services and make your
registered with the Companies Registration Office in     The Bank of New York Mellon is exempt from                 own independent assessment (based on such advice)
Ireland No. 907126 & with VAT No. IE 9578054E.           the requirement to hold, and does not hold, an             as to whether the referenced products or services
                                                         Australian financial services license as issued            are appropriate or suitable for you. This material
The Bank of New York Mellon SA/NV is trading             by the Australian Securities and Investments               may not be comprehensive or up to date and there
in Germany through its Frankfurt branch “The             Commission under the Corporations Act 2001                 is no undertaking as to the accuracy, timeliness,
Bank of New York Mellon SA/NV, Asset Servicing,          (Cth) in respect of the financial services provided        completeness or fitness for a particular purpose of
Niederlassung Frankfurt am Main”, and has its            by it to persons in Australia. The Bank of New             information given. BNY Mellon will not be responsible
registered office at MesseTurm, Friedrich-Ebert-         York Mellon is regulated by the New York                   for updating any information contained within this
Anlage 49, 60327 Frankfurt am Main, Germany.             State Department of Financial Services and                 material and opinions and information contained
It is subject to limited additional supervision          the US Federal Reserve under Chapter 2 of the              herein are subject to change without notice. BNY
by the Federal Financial Supervisory Authority           Consolidated Laws, The Banking Law enacted                 Mellon assumes no direct or consequential liability for
(Bundesanstalt für Finanzdienstleistungsaufsicht,        April 16, 1914 in the State of New York, which             any errors in or reliance upon this material.
Marie-Curie-Str. 24-28, 60439 Frankfurt, Germany)        differs from Australian laws.
under registration number 122721.                                                                                   This material may not be distributed or used for the
                                                         The Bank of New York Mellon has various other              purpose of providing any referenced products or
The Bank of New York Mellon SA/NV operates in            branches in the Asia-Pacific Region which are subject      services or making any offers or solicitations in any
the Netherlands through its Amsterdam branch at          to regulation by the relevant local regulator in that      jurisdiction or in any circumstances in which such
Strawinskylaan 337, WTC Building, Amsterdam, 1077        jurisdiction.                                              products, services, offers or solicitations are unlawful
XX, the Netherlands. The Bank of New York Mellon                                                                    or not authorized, or where there would be, by virtue
SA/NV, Amsterdam Branch is subject to limited            The Bank of New York Mellon Securities Company             of such distribution, new or additional registration
additional supervision by the Dutch Central Bank         Japan Ltd, as intermediary for The Bank of New             requirements.
(“De Nederlandsche Bank” or “DNB”) on integrity          York Mellon.
issues only (registration number 34363596). DNB                                                                     Any references to dollars are to US dollars unless
holds office at Westeinde 1, 1017 ZN Amsterdam, the      The Bank of New York Mellon, DIFC Branch, regulated        specified otherwise.
Netherlands.                                             by the Dubai Financial Services Authority (“DFSA”)
                                                         and located at DIFC, The Exchange Building 5 North,        This material may not be reproduced or disseminated
The Bank of New York Mellon SA/NV operates in            Level 6, Room 601, P.O. Box 506723, Dubai, UAE, on         in any form without the prior written permission of
Luxembourg through its Luxembourg branch at              behalf of The Bank of New York Mellon, which is a          BNY Mellon. Trademarks, logos and other intellectual
2-4 rue Eugene Ruppert, Vertigo Building – Polaris,      wholly-owned subsidiary of The Bank of New York            property marks belong to their respective owners.
L- 2453, Luxembourg. The Bank of New York                Mellon Corporation.
Mellon SA/NV, Luxembourg Branch is subject to                                                                       The Bank of New York Mellon, member of the Federal
limited additional regulation by the Commission          Past performance is not a guide to future performance      Deposit Insurance Corporation (“FDIC”).
de Surveillance du Secteur Financier at 283, route       of any instrument, transaction or financial structure
d’Arlon, L-1150 Luxembourg for conduct of business       and a loss of original capital may occur. Calls and        © 2021 The Bank of New York Mellon Corporation.
rules, and in its role as UCITS/AIF depositary and       communications with BNY Mellon may be recorded,            All rights reserved.
central administration agent.                            for regulatory and other reasons.

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