Primary Delayed Compensation Protocol

The Protocol applies to a “Primary Allocation” which is an allocation of new money by a syndicate desk in connection with either (i) a new issue syndication or (ii) an amendment of an existing Credit Agreement.  In addition, the Protocol affects when-issued secondary trades by (i) changing what constitutes an Early Day Trade and (ii) creating a Post Funding Trade.

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Ellen Hefferan

Executive Vice President of Operations & Accounting

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