Development of Ukrainian Depository System: Current Problems and Their Solutions
Stock market is a necessary element of market economy, which is in its turn one of the most important part of economic infrastructure. By using it, the capital naturally flows from one industry into another (and back), which means that development of economy is regulated automatically. Along with harmonious development of the stock market, its developed infrastructure, established legal groundwork for mechanisms of its players protection, it becomes a powerful drive of economic development of any country.
In its turn, depository system is the most important segment of the securities market infrastructure, being an integral part of assurance mechanisms for the rights of security holders.
Depository business is a provision of security lodging services (irrespective of issuance form), opening and operating of securities accounts, handling account operations (including clearing and settlements under securities agreements), handling issuer transactions with issued securities.
Clearing is a non-cash settlement for delivered or sold goods, securities and rendered services, performed by means of setting-off subject to balance of payments. In such procedure subject of clearing acts as an intermediary, taking the role of buyer and seller in this transaction in order to provide performing of transaction between two parties.
There is an established depository system in Ukraine so far. It works well, but its efficiency still needs to be enhanced. Its direct and indirect participants are in the process of constant development, while relevant regulatory support remains insufficiently regulated and requires significant improvement. The environment of depository service rendering and using as such also needs corresponding regulation.
DEPOSITORY System of Ukraine: History of Creation and Development
June 18, 1991 is generally thought to be a starting point in the formation process of civilized securities market in Ukraine. On this day Verkhovna Rada adopted the Law of Ukraine On Securities and Stock Exchange, which became a first official legislative, regulating this field of activity. In 1992-1993 first Ukrainian stocks and first securities dealers appeared. At that time, players of Ukrainian stock market appeared to be financial intermediaries, represented by trust institutions, investment funds, and commercial banks.
By the end of 1995 – beginning of 1996, Ukraine objectively faced long-felt need in the creation of a centralized system of securities and settlements depository accounting under securities transactions. At that time, a stage of “mass privatization” was just coming to an end, and a system of stock accounting was formed, based on maintenance of registers by independent registrars. However, such system did not meet needs of professional players of the stock market. A group of enthusiasts undertook the work at the variants of creation of the central depository, to determine its functions, business legal structure and working methods etc. In May 1997, a depository OJSC “Interregional Stock Association” (ISA) was founded by the National Bank of Ukraine (NBU) and a group of large domestic banks, investment companies and securities dealers (in total 57 founders). Active technical and financial support for this depository was provided by the United States Agency for International Development (USAID) and the World Bank. The main task of ISA was to provide security lodging and dealing, as well as provision of clearing services and payments under securities agreements.
In parallel with it, Verkhovna Rada was going through a really difficult process of adopting the Law of Ukraine On National Depository System and Special Features of Electronic Circulation of Securities in Ukraine. Though ISA was founded prior to the adoption of this law, “Interregional Stock Association” depository conformed fully to the requirements of relevant legislation. It ought to be noted that initial draft law suggested existence of several depositories in Ukraine, but at the last moment deputies put forward and legislated a proposal to create the National Depository, having provisioned government funding for the development of national depository system.
Founders of ISA and players of the stock market of Ukraine rightly supposed that this particular organization would become a central depository. Meanwhile, in May 1999 upon an initiative of Viktor Ivchenko, the then member of Securities and Stock Market State Commission (SSMSC), OJSC “National Depository of Ukraine” (NDU) was created on the bases of mentioned Law of Ukraine On National Depository System…, in which it was stated that the government creates a depository according to its financial possibilities.
Therefore, depository system of Ukraine was represented by two depositories – NDU and ISA.
– NDU, exclusive functions of which include standardization of depository accounting and document flow for the securities dealing, codification of securities, issued in Ukraine in accordance with international standards, establishment of constant cooperation relations and organization with depository institutions of other countries, tried to position itself as some regulating body, which sets various standards and norms.
– In the meantime, ISA was the only really functioning depository, which was developing by efforts of the stock market players and with the assistance of international endowment organizations.
Some years ago a situation came about in such a way that neither ISA not NDU could not take the functions of the central depository, since NDU didn’t have credibility of the stock market players, and ISA has an internal corporate conflict. Merger of ISA with “Ukrainian Securities Depository” (USD) (on basis of the latter) made it possible to achieve termination of internal corporate conflict on the one hand, and established a powerful player on the domestic depository services market on the other hand.
Some initial disagreements with some stock market players – ISA shareholders – were successfully settled thanks to reached compromises.
From October 12, 2003, USD took up rights and obligations, related to servicing of ISA clients, by legal succession, and proceeded with depository business and clearing and settlement activities.
Nowadays there is a decentralized depository system in Ukraine, in which USD and NDU services corporate securities and local loan securities, and NDU provided depository services for the government securities placement and circulation. On January 01, 2011, the structure of client servicing in the Ukrainian depository services market is following:
– USD – 86.2%
– NDU – 13.8%
Main Depository Services Market Operators of Ukraine
OJSC “National Depository of Ukraine” (NDU)
NDU was founded in May 1999 upon an initiative of Viktor Ivchenko, the former member of SSMSC, who initially chaired the Council, in 2000-2006 chaired the Board of Directors, and from 2006 is chairing the Supervisory Council of the depository. Statutory fund of NDU makes up 30 mln. UAH, with 86% of shares held by the state (and regulated by SSMSC) and remaining 14% belonging to 29 legal entities. Viktor Ivchenko holds himself more than 10% shares in NDU through accountable companies. He said about them in the interviews with media many times.
The national budget of 1999 provided UAH 3 850 mln. for “financing of immediate measures relating to establishing of the National Depository” (quotation from the Law of Ukraine On National Budget for 1999). As a matter of fact, Ukrainian government allocated UAH 5 million. Excess UAH 1.15 mln. were received from the reserve fund of the Cabinet of Ministers. Attitude of the stock market players to creation of NDU was clearly demonstrated by the fact that they subscribed only for 10% of the statutory fund during declared emission in spite of certain administrative pressure.
In the following years, audits of the Main Control and Revision Office of Ukraine regularly revealed “improper use of budget resources” in the activities of NDU. In 2006, Accounting Chamber of Ukraine underlined in its report: “National Depository did not become fully valid defender of the rights of investors and professional players of the stock market for those years that passed since its founding. For the past 6 years, activities of the National Depository yielded losses in the amount of over UAH 10 mln.” Moreover, according to report of the Control and Revision Office of Ukraine, it detected violations in the activities of NDU in the amount of UAH 6.2 mln.
It should be noted that on January 25, 1999 (i.e. at the time of NDU creation) governments of Ukraine and USA, involving the World Bank, signed a special Memorandum of Understanding, with the main purpose to create a single central depository, belonging mainly to the stock market players and controlled by them. Moreover, the parties didn’t protest against creation of the NDU, having yet negotiated that till year 2010 (term of the Memorandum) it would not perform any commercial functions, including keeping registers of securities holders, depository business, and clearing and settlement activities, but it would only engage in the codification, standardization, and international relations.
On January 18, 2006, the Cabinet of Ministers headed by Yu. Yekhanurov enacted the Regulation No. 31, terminated the above mentioned Memorandum. Besides, it was done without any prior consultation with the US government, representatives of USAID and the World Bank, and without taking into consideration opinion of the stock market players. USAID criticized this decision in harsh terms: “We were disappointed by decision of the Ukrainian government to unilaterally terminate the Memorandum. Situation, when SSMSC holds controlling share in a clearing and settlement organization, would mean dangerous conflict of interests. We are concerned about the fact that these unilateral actions of the government could undermine the market and investors, including non-governmental pension funds”.
In the same year, NDU obtained licenses of SSMSC for depository business of a securities depository and for clearing and settlement activities for a 10 years period, which enabled it to perform operating activities – securities lodging and circulation servicing on the securities accounts, and issuer’s operations relating to the issued securities. By the end of 2006, share of NDU on the depository services market made up 0.75%, while ISA took almost 99%, working in parallel.
The following fact also stands out. In December 2005, Viktor Ivchenko chaired the State Agency of Ukraine for Investment and Development, created upon his initiative with the purpose of government control over reforms in the stock market of the country. Especially for NBU (we remind that its Supervisory Council is headed by Viktor Ivchenko), the Agency prepared the State Program of Development of Ukrainian National Depository System for the Period till 2011, approved by the Cabinet of Ministers in December 2007 and cancelled it a year later. Study of this document by the independent experts showed low professionalism of its drawers and unconcealed lobbying of NDU interests. There is an impression that there was no national depository system in Ukraine before and it needed to be created “from scratch”. For this, the Program provisioned allocation of UAH 2 bln. for NDU (including UAH 900 mln. from the state budget), organization of special blue phone line, as well as chargeless transfer of some objects in the Autonomous Republic of Crimea. To put this in perspective, annual allowance for ISA made up approximately UAH 3 billions, while total amount of their serviced assets in 2004 constituted UAH 50 bln., and total amount of performed settlements under agreements was UAH 30 bln.
Therefore, there are grounds to make the following conclusion: NDU is an ineffective structure, which couldn’t reach status of legislative and regulatory framework of high quality for the years of its existence (since almost all programs and initiatives, developed by NDU, were not accepted by the market players and experts because of low quality of the drawn documents). NDU exists solely at the expense of annual budget subsidies, not even providing for its own self-sufficiency. NDU doesn’t have credibility of the stock market players as a depository.
Private Joint-Stock Company “Ukrainian Securities Depository” (USD)
It was founded by the stock market players in May 2008. NBU acted as one of USD shareholder and a guarantor of transparency of their operations (22.83% of the depository’s shares were controlled by the state through NBU). Other shareholders included 19 largest Ukrainian banks, Ukrainian Interbank Currency Exchange, the First Stock Trading System Stock Exchange, and securities traders and custodians. Statutory fund of USD upon merger with ISA makes up UAH 153.1 mln.
USD merged with ISA in 2009. It was aimed at the creation of reliable modern depository, which could be rightly transformed into the Central Depository of Ukraine. This step was supported by the World Bank and USAID, which technically and financially assisted the establishment and development of ISA as a first corporate depository in Ukraine. As a result, a high-tech company was formed, servicing the lion’s share of all issues of corporate securities, performing clearing for transactions of all exchanges, which exist in Ukraine, and performing cash settlements under such transactions.
Since 2010, USD is a member of Electronic Payment System of the National Bank of Ukraine, allowing quick and reliable servicing of cash flows for the securities transactions, performed on stock exchanges. On the average, monthly cash flows through USD make up approx. UAH 0.5 bln.
USD is the largest clearing and settlement depository in the country. It is famous for its developed infrastructure, state-of-the-art technologies of interaction with the stock market players, considerable experience and professionalism of specialists, clear observance of rules and procedures of depository accounting, which guarantees timely performance of depository operations and reliable protection of rights of securities holders. Besides, USD is an organization, which is primarily guided by needs of the stock market players in its activities.
Depository Systems of Leading Countries of the World
Depending on specificity of laws in a particular country, historical traditions and specific features of the stock markets formation , there are several types of depository system in the world. Their level of centralization/decentralization is determined by presence or absence of a single central depository and differences in the positioning of depository institutions. Nowadays, 95% of stock market in the developed countries is serviced by central depositories. There are about 30 central depositories in Europe and over 100 depositories in the whole world. Here are some examples.
In the USA, central depository for corporate securities is represented by DTCC, and for governmental securities its role is played by the Federal Reserve System. DTCC is a holding company, owned by the largest stock market players, which is a main company, performing clearing, settlement and depository services for shares, governmental, municipal and corporate debt instruments, mutual fund’s shares, money market instruments and other assets on the exchange-listed and off-exchange stock markets of the USA. It includes 1 depository company and 5 clearing companies, as well as Depository Trust Company (DTC), founded in 1973 and being the largest depository not only in the USA, but in the whole world. It is registered as a nominal holder in the holders of the issuer’s securities register, providing services for the lodged securities,
The American securities market is characterized by a clear split of functions of depository and custodian (“advanced depository”, providing a wide range of high-quality services, which goes beyond the scope of functional responsibilities of an ordinary depository), use of which is strictly mandatory in the USA and is formalized in legislation for institutional investors. Owing to this fact, reliability of custody and accounting of titles to the securities of collective investors (investment and pension funds, and trust companies) is increased.
Japan. All shares of Japanese corporations are registered securities. Issue of bearer shares was forbidden by amendments, made to the Commercial Code of the country in 1990. Register of securities holders is kept by the issuing companies or registrars. The shares may be registered both in the name of an owner, and in the name of a nominal holder.
Leading role in the settlements under corporate securities and registration of share ownership in Japan is taken by a central depository (JASDEC), founded in 1984. Initially, it was created as a non-commercial organization, but in 2002 JASDEC was transformed into a joint-stock company (corporation), which shareholders were represented by professional securities market players. Since that time government doesn’t have a share in JASDEC. Paid statutory capital makes up JPY 42.5 bln. (approx. USD 408.7 mln.).
EU member states. Here we can notice high level of fragmentariness in the clearing and settlement infrastructure. Though, it is undoubtedly under consolidation, since number of various national and international organization, which provide clearing and settlement services, is still great (in no small measure, it is due to the complexity of integration and harmonization of county legislations). For instance, there are 19 central depositories and international central depositories, which provide various services and have different organizational structures. In some EU member states, clearing houses function separately from the central depositories, while in other countries clearing and settlements are combined within one organization. In some countries organizations, which provide centralized clearing and settlement services, are private, while in other countries they are state-owned. However, fair pursuit of integration of financial markets of EU countries has already became a result of emergence of transnational financial institutions, which provide centralized clearing and settlements for dealing in securities, which circulated on the national and European markets, with clear trend of non-governmental members prevailing in the capitals of depository organizations.
Chinese experience is also rather interesting. In this country, main trading facilities are Shanghai Stock Exchange, Shenzhen Stock Exchange, and Interbank Bond Market. Organizations, which perform securities accounting and settlement of transactions with them, are represented by China Securities Depository and Clearing Corporation and China Government Securities Depository Trust and Clearing Corporation. The former provides services for all types of securities, traded in the stock market, and the latter one services only interbank bond market.
We cannot ignore trends in the development of depository market in Russia. At the Annual Meeting on June 29, 2010, shareholders of MICEX Clearing House voted for consolidation with CJSC “National Depository Center”. New structure would have the status of “non-bank credit organization” and would be called “National Settlement Depository” (NSD), which actually accept responsibilities of a central depository of the Russian Federation. CJSC “MICEX” will be a principal shareholder of the new company, with a wide range of shareholders having one share and participating in the management of settlement depository using mechanism of shareholder agreement. The state does not have share in the capital of NDS.
Taking into account global experience, international organizations, including the World Bank, strongly recommend that Ukraine eliminate state financing in further development of depository system and directly suggest that a central depository be created in Ukraine on the basis of USD as a market-controlled structure.
If it comes to the development and propagation of “central depository concept”, then Report of Group of Thirty – international non-governmental group of experts on the international financial system – has become quite a push in this regard. In 1989, Group of Thirty published a report, containing 9 recommendations on the systems of clearing and settlements for securities dealing in the global financial markets. One of the recommendations was about creation of central depository on each national market. In the course of time, these recommendations were improved and amended, and in 1999 International Securities Services Association (ISSA) published new Group of Thirty Recommendations. They contained somewhat extended recommendation related to the central depository (Recommendation No. 3):
“Each country should have in place an effective and fully developed central securities depository, organized and managed to encourage the broadest possible direct and indirect industry participation. The range of depository-eligible instruments should be as wide as possible. Immobilization or dematerialization of financial instruments should be achieved to the utmost extent possible. If several central securities depositories exist in the same market, they should operate under compatible rules and practices with the aim of reducing settlement risk and enabling efficient use of funds and available cross-collateral”.
Variants of Creation of Ukrainian Central Depository
There are a lot of contradictions in the development of depository system in Ukraine. Meanwhile, according to experts, the Law of Ukraine On the National Depository System, regulating this area of business, “… principally corresponds to the trends and basic principles of creation of ownership accounting systems and trade settlement systems on the securities market, generally accepted in the developed countries. Though as for any law, it is a result of certain compromises, due to which it has some defects and discrepancies. Formation of effective depository system is a pre-requisite of securing of the whole complex of investor legal rights and interests, as well as a way of savings promotion and transformation of some saved funds into investment”.
Nowadays, stock market players and regulating government authorities in Ukraine have already formed an opinion on concept feasibility of a centralized two-level National Depository System.
First level is the Central Depository, which is to control corporate securities and municipal bonds, and NBU, functions of which include depository business with governmental securities to be submitted to the central depository in the course of time.
Second level is represented by custodians and registrars of registered owners. This structure should aim at securing of functioning of a single system of securities ownership accounting and at prevention of such ownership infringement. Its cornerstone would be represented by the Central Depository, or simply said, a single trustworthy “notary office” for the whole securities market, which is to service and guarantee proper ownership securing.
The fact that creation of a single securities depository accounting system was included in the Economic Reform Program for 2010-2014 of the President of Ukraine Viktor Yanukovich, as one of the steps required for growth and development of the stock market and financial services industry, speaks for utmost importance of this issue. Official authorities in Kiev committed to the International Monetary Fund (IMF) to optimize process of liquidation of regulatory and infrastructural “narrow spaces”, which prevent inflow of investments to Ukraine, having promised to closely cooperate with the World Bank and Organization for Economic Co-operation and Development (OECD). Here is what Memorandum, signed with IMF, says:
“In order to improve functioning of securities accounting and clearing system, increase market confidence and stimulate capital markets, we (Ukraine) intend to merge two existing depositories in 2011, thus creating a single Central Depository, which would completely meet the requirements of internationally agreed standards. The Central Depository would be regulated in the most transparent way, on the basis of generally recognized principles of corporate governance in order to provide representation of interests of the market players and the government. Government involvement would provide for creation of effective relevant legal environment and minimization of use of financing under governmental funds”.
Meanwhile, on February 05, 2011 Nikolay Azarov, the Prime-Minister of Ukraine, gave some instructions on creation of the central depository, which were contrary to the previously declared official position of Ukraine. It was done on the grounds of Viktor Ivchenko’s memo, submitted to the head of the government a day earlier. It should be noted that drawn document was based on some incorrect information, which was sometimes presented biased and fragmentarily. According to the expert conclusions, published in media, one cannot completely rule out the fact that the memo to the Prime-Minister of Ukraine was drafted with due account for business interests of this document’s initiator.
Main idea of the memo is represented by the proposal to create Central Depository by merging NDU (we remind that 10% of NDU belong to V. Ivchenko) and NBU Depository. Moreover, special emphasis was laid on the fact that “merger of all depositories existing in Ukraine can significantly complicate and hinder creation of the Central Depository”. At the same time, absolutely nothing was said about NBU Depository’s dealing only with the governmental securities, which makes its role quite specific, since its services are required by the stock market players only for domestic government bonds. Furthermore, NBU Depository does not even exist as a legal entity. According to the existing laws, the National Bank services government securities circulation, including depository business with such securities. To perform this function, a department of securities depository accounting was created in the NBU, being a part of the Department of Monetary Policy. Therefore, in fact Viktor Ivchenko proposed to merge joint-stock company (OJSC “NDU”) with one of the National Bank departments, saying that “such merger is organizationally easy, since it doesn’t require reorganization of depository institutions”.
In implementing of this variant, USD – the largest Ukrainian depository, occupying over 86% of the domestic market – is completely eliminated from the process of creation of the Central Depository. Viktor Ivchenko proposes to assign it to the role of a clearing and settlement institution, servicing the stock exchange market. Speaking of which, he said in his memo to the Prime-Minister that “up to the present moment clearing is not used in the Ukrainian stock market”, though NDU itself informs about provision of this service, not to mention USD, which performs over 220 thousand such transactions concluded on the stock market monthly.
Nowadays, there are only two legal entities in Ukraine – USD and NDU – which have licenses of the Securities and Stock Market State Commission to perform depository activities of the securities depository and clearing and settlement operations. It is entirely logical that creation of the Central Depository should be carried out on the basis of one of them. Let’s compare key performance of both companies, taken from their annual reports for 2010 (annual reports for the last year are not yet published). Thus, as of January 01, 2011 :
USD NDU
– total depositary assets (UAH bln.) 470,5 75,6
– total number of securities issues , 9001 2090
being serviced (pcs.)
Information on the Number of Securities Issues in USD and NDU as of January 01, 2011
Difference in key figures is 6.2 and 4.3 times accordingly in favor of USD. Nonetheless, the Central Depository is proposed to be created on the basis of a weaker organization (NDU) with low market share, loss-making operational activities, without the most state-of-the-art technologies. Implementation of this variant is going to turn into usual “signboard change”, supplemented by directive transfer of depository servicing of the Ukrainian stock market, including government securities market, to the company, which could not win the considerable market share. It is also planned to “improve NDU resource base”, which would be done at the expense of state budget.
Also, there is a hazard, pointed out by Robert Bond, Director of USAID project: “Creation of the Central Depository in Ukraine on the basis of NDU will bring Ukraine back to the times, when shareholders’ rights were violated”. USAID does not consider variant of creation of the Central Depository on the basis of NDU to be optimal. It is due to the current position of NDU, including low volumes of its business as a depository, low level of confidence of the stock market players, as well as lack of non-governmental resources for creation of the Central Depository on the basis of NDU.
In this situation, it is necessary to keep other path, and create the Central Depository on the basis of USD. First of all, nowadays USD is a powerful, financially and organizationally stable, dynamically developing structure, which has a serious client base, enjoys confidence of the Ukrainian and international stock markets.
Secondly, global experience shows that the majority of central depositories are non-governmental. The World Bank and USAID recommended that Ukrainian government minimize its role in the future Central Depository. The government, represented by NBU, owns 22.86% of USD and 86% of NDU. Accordingly, expenses for creation of the Central Depository on the basis of USD would be borne by the stock market players, while in the creation on the basis of NDU this burden will lie heavily on the tax payers. Ignoring of USD in creation of the Central Depository will lead to practical absence of the stock market players in the capital structure of the Central Depository.
Thirdly, attempt to actually forbid USD to carry out depository business, and transfer of this business to NDU will result in breakdown of valid and completely self-supporting model of functioning of the domestic accounting infrastructure, collapse in confidence of investors to the Ukrainian securities market. All efforts, knowledge and resources, invested by the securities market players and international endowment organizations, will be completely nullified.
Conclusion
Currently, there is a complex situation in the stock market of Ukraine. Necessary process of creation of the single Central Depository is tried to be replaced with an attempt to obtain profit and benefits for certain persons.
The structure, which could lead to many problems and disadvantages to the consumers of such services, is being artificially created on the depository services market. Process of its creation and further operation would be financed directly from the state budget, meaning additional unnecessary burden for it.
Formation of the Central Depository on the basis of NDU will result in disorganization of the domestic securities market and worsening of investment attractiveness of Ukrainian economics. Activity of the whole depositary system of the country will be complicated; pre-requisites and possibilities are provided for questionable redistribution of property. We cannot exclude the possibility of unjustified access to insider information. NBU may lose its rights to depository government securities servicing, placement, circulation and repayment.
The existing situation may again present Ukraine as an unreliable partner to the influential financial organizations. Failure to fulfill certain assumed obligation to IMF related to the conditions of creation and functioning of the Central Depository, stated in the signed Memorandum, will probably become a stumbling block in the consideration of disbursement of another loan tranche from IMF.
In terms of economic expediency, it would be right to solve this problem by acknowledging existing reality of the domestic stock market, fulfilling the obligations to IMF, applying positive global experience. Practically, it may be implemented in creation of the single Central Depository on the basis of USD.
Results of Expert Poll Conducted by the Center for Studies of Corporate Relations
Expert poll was conducted on March 14-28, 2011 in the course of preparation of analytical research “Current Problems of Development of Depository System of Ukraine and Their Solutions”. 22 companies – Ukrainian stock market players – took part in this poll.
Poll Results.
- Do you support creation of the Central Depository in Ukraine?
Answer – «yes» – 100%
Answer – «no» – 0%
- On the basis of what existing depository should the Central Depository be created?
Answer – USD – 81%
Answer – NDU – 19%
- Do you consider it necessary to use global experience, showing that generally government does not participate in the Central Depository, in creation of the Central Depository in Ukraine?
Answer – «yes» – 72%
Answer – «no» – 28%
- The World Bank recommended that Ukrainian government create Ukrainian Central Depository on the basis of USD. Do you agree with the recommendations of the World Bank?
Answer – «yes» – 76%
Answer – «no» – 24%
5. Are you satisfied with the quality of depository servicing in the Ukrainian Securities Depository (USD)?
Answer – «yes» – 83%
Answer – «no» – 17%
6. Are you satisfied with the quality of depository servicing in the National Depository of Ukraine (NDU)?
Answer – «yes» – 31%
Answer – «no» – 69%
- Do you think that role of government in the depository services market should mainly mean creation of regulatory base of high quality and control over its observance?
Answer – «yes» – 100%
Answer – «no» – 0%
- The Cabinet of Ministers supported creation of the Central Depository on the basis of NDU. Was opinion of the market players considered in making of such decision?
Answer – «yes» – 0%
Answer – «no» – 100%