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A Letter to the HM Treasury

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Oct 21st, 2023
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  1. Dear HM Treasury,
  2.  
  3. I trust this message finds you well.
  4.  
  5. As a shareholder, I am writing to express a vested interest in the ongoing work of the UK Digitisation Taskforce, particularly concerning the proposed changes to the securities management system.
  6. The recent interim report has generated significant attention and raised substantial concerns among shareholders worldwide. Given the potential impact on ownership structures and shareholder rights, many of household investors are eager to be actively involved in the ongoing discussions and decision-making processes.
  7.  
  8. I acknowledge the complexity of the taskforce's mandate and appreciate the efforts to modernise the securities framework. However, the proposed shift to a Central Securities Depository (CSD) model, with the transfer of legal ownership to a nominee, has sparked widespread debate and scrutiny, signalling concern across the globe. To provide absolute clarity, shareholders express their strong preference against the envisioned shift and emphasis their desire to maintain hold of their legal assets in their name. The proposed changes as put forward in this proposal are not favoured by shareholders.
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  10. The implications for legal ownership, data privacy, and overall shareholder empowerment are substantial, and want to ensure shareholder concerns everywhere are thoroughly addressed.
  11. Again, it is essential to highlight that the proposed model contradicts shareholders' desire to retain the right to hold shares in their name on the company ledger.
  12.  
  13. Importantly, the impact of the UK's Digitisation Proposal extends beyond national boundaries- it serves as a potential blueprint for the erosion of global shareholder rights everywhere. The proposal raises apprehensions about the potential seizure of legal ownership of assets, posing risks to property rights worldwide. Therefore, as shareholders, it is deemed crucial to be part of an open and transparent conversation about these proposed changes.
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  15. In seeking updates on the progress of the UK Digitisation Taskforce's work, the request reaches beyond mere information. Collectively, investors are interested in understanding the taskforce's comprehensive engagement plan, detailing the steps envisioned to actively involve shareholders. Clarity on the avenues for our participation in discussions, sharing insights, and providing feedback is crucial. Additionally, insights into the projected timeline and the sequential steps in the engagement process would allowing investors to plan their involvement thoughtfully.
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  17. It is essential to emphasise the importance of a deliberate and thorough exploration in the digitisation of share handling. There is a shared advocacy for a well-examined process that considers diverse perspectives, mitigates potential risks to shareholders and their assets. I equally, and kindly, request an assurance that the process will not be rushed, emphasising the need for a careful and meaningful examination of proposed changes. There must be advocation for a well-examined process that considers diverse perspectives, mitigates potential risks to shareholders and their assets, and builds a foundation of trust.
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  19. To reiterate this position, shareholders are against any alterations to primary legislation that would involve the transfer of ownership of our shares to a nominee at any point in the process. Preserving this fundamental aspect of our ownership rights is of paramount importance to investors everywhere.
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  21. It is proposed that this dialogue remains a public and inclusive conversation. Shareholders are eager to understand how their feedback will be considered, and believe that their collective insights can contribute to the development of a more robust and equitable proposal.
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  23. Given that the HM Treasury operates as a government-mandated organisation funded by UK taxpayers, I trust that there is a shared interest that lies in ensuring effective communication channels are curated and maintained. As civil servants, your commitment to serving the public aligns with the expectations of those who contribute to the funding. I am confident that maintaining open lines of communication will remain a priority for all parties involved.
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  25. I appreciate your attention to these matters and look forward to your response. I believe that a collaborative and inclusive approach will contribute to the success of this initiative and ultimately serve the best interests of all stakeholders.
  26.  
  27. Thank you for your time and consideration, and await your response.
  28.  
  29. Sincerely,
  30.  
  31. An Invested Shareholder.
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