CONSULTATION ON PROPOSEDCORPORATE EVENTSMETHODOLOGICAL CHANGESOCTOBER 2017

© 2017 MSCI Inc. All rights reserved.
Please refer to the disclaimer at the end of this document.

SUMMARY OF PROPOSALSMSCI opens a consultation on a proposal around its Corporate Event Methodology andrelated treatment with regards to the following:
1)

UNIVERSAL THRESHOLDS FOR IMMEDIATE IMPLEMENTATION OF CORPORATE EVENTS

2)

NEW TREATMENT FOR SECURITIES UNDER PROLONGED SUSPENSION (EX-CHINA)

3)

ENHANCED TREATMENT FOR SPIN-OFFS WITH DELAYED PAY-DATE

4)

NEW TREATMENT FOR ACQUISITIONS INVOLVING THE ISSUANCE OF TENDERED LINE
OF SHARES

Selected Topics:‒ Accelerated rights issues in Australia‒ Number of shares/float updates for M&A‒ Cross-Border Acquisition*Note that this consultation may or may not result in the implementation or adoption of any or all of the proposed changes contained inthis document. In addition, consultation feedback will remain confidential. MSCI may publicly disclose feedback if specifically requested by
specific market participants. In that case, the relevant feedback would be published together with the final results of the consultation.
2

PROPOSED UNIVERSAL THRESHOLDS FORIMMEDIATE IMPLEMENTATION OF
CORPORATE EVENTS© 2017 MSCI Inc. All rights reserved.
Please refer to the disclaimer at the end of this document.

BACKGROUND AND RATIONALE FOR PROPOSALCurrently, the thresholds to determine if a corporate event qualifies for immediate
implementation in the MSCI Indexes vary depending on the event type, the country
and the size segment of the company.



The implementation timing can vary as well depending on the event type.



This may result in index changes being more difficult to anticipate for institutional
investors.

With the below proposals, MSCI aims to adopt simpler thresholds and maintain low
index turnover while continuing to reflect significant changes in a timely manner.

1) MSCI proposes one new set of universal thresholds to determine immediate
implementation of corporate events.
2) MSCI proposes to compare the size of the corporate event alone (without including
number of shares or float updates) with the proposed thresholds to determine theimplementation timing.

3) MSCI proposes that all qualifying corporate events (as described above) are
implemented at the time of the event.
4

CURRENT THRESHOLDS AND PROPOSAL
Proposals Summary across all event types and regions• Standard thresholds to remain at or become 5% of the pre-event number of shares• Small Cap thresholds to increase to 10% of the pre-event number of shares• Micro Caps threshold to remain or become 25% of the pre-event number of shares
Event Types
Public Offerings
Private Placements
Secondary Offerings (US)Acquisition of OTC/ listed non-index constituentsResults of Dutch Buyback
Results of Rights Issue
Conversions
Results of fixed tender offer buyback/partial acq.
Subscription Receipts in Canada1
Block Sales/Sec. Offerings (ex US)
Acquisition of Private3

Current Thresholds

Proposal

IMI/Micro

Standard/Small Cap/Micro Cap

5% - 25%
5% - 10% - 25%
0%
USD 1 billion impact for DM2
USD 500 million impact for EM2
10% Standard/50% Small & Micro

1 Conversion of subscription receipts are implemented at the next regularly scheduled Index Review.
2 Including number of shares and float updates.
3 Acquisition of Unlisted Securities are implemented at the next regularly scheduled Index Review, except for China

5

PROPOSED AND CURRENT TREATMENT
STANDARD

Event Types

Current

Proposal Volume
5%
ChangeSMALL CAPSMICRO CAPS%
Proposal
Current
Change10%

VolumeChange%Proposal Volume%
Current
Change25%
Change Change

Partial acquisitions

174
24
36
5
7

174
24
36
1
5

0
0
0
(4)
(1)

0%
0%
0%
-71%
-28%

184
232
80
27
18

152
152
60
8
17

(32)
(80)
(20)
(19)
(1)

-17%
-34%
-25%
-69%
-6%

88
72
0
11
2

88
72
0
6
2

0
0
0
(5)
0

0%
0%
0%
-45%
0%

Block Sales/Sec. Off (ex US) -Event

30

362

6

+20%

3

1022

99

1067%

0

82

8

100%

Block Sales/Sec. Off (ex US) 1 - QIR

22

0

(22)

-100%

86

0

(86)

-100%

44

0

(44)

-100%

Block Sales/Sec. Off (ex US) -Total

52

362

(16)

-31%

89

1022

13

15%

44

82

(36)

-82%

Acquisition of Private1

7

8

1

14%

7

25

18

257%

0

02

0

0%

Subscription Receipts (CA)1

3

3

0

0%

11

10

(1)

-9%

3

3

0

0%

Acq. of OTC/ listed non-const.

0

0

0

0%

5

2

(3)

-60%

0

02

0

0%

Results of Rights Issue

1

1

0

0%

3

2

(1)

-33%

22

22

0

0%

Conversions

1

1

0

0%

3

3

0

0%

1

1

0

0%

287

214

(73)

-25%

Private Placements
Public Offerings
Secondary Offerings (US)Buybacks

Grand(37) and are-10%635 annualized
(113)
-15%
NOTE:Total
All data are based between 362
Jan 2014325
to Jan 2016
shown748
on an averagebasis.

1 Block sales of intermediate sizes, acquisition of Unlisted Securities, conversion of subscription receipts are implemented at the next regularly scheduled Index Review.
2 Estimated number

NOTE: Current treatment of block sales/secondary offerings (ex-US) can be found in the appendix.
Data collected on 2015 and 2016, reflected on annualized basis.

6

IMPACT OF THE PROPOSALMSCI would use one unique threshold per size segment across all event types and regions
to determine the implementation timing of a corporate event.

The 5%-10%-25% proposal would decrease the number of events being implemented at
the time of the event for Standard securities (-10%), Small caps (-15%) and for Micro caps(-25%).



MSCI would not take into account number of shares and float updates to determine if it
qualifies for immediate implementation. Note that if the size of the event alone is above
the relevant threshold, any number of shares and float updates would be implemented
simultaneously.



As a consequence of the point above, consecutive block sales for the same company
would no longer be considered cumulatively but independently.



Block sales above thresholds would be implemented at the time of the event, whereas
ones below thresholds would be implemented at the next May Semi-Annual Index Review.
MSCI would no longer use the QIR thresholds highlighted on appendix 1.

Qualifying acquisitions of private companies and subscription receipts in Canada would be
implemented intra quarter and not coincide with the next Index Review.
7

DISCUSSION POINTS

Do you agree with the new set of thresholds per size segment (i.e. Standard, Small
Cap and Micro Cap) applicable across regions and event types?

Do you believe the resulting smaller volume of qualifying events for immediate
implementation is appropriate?

Do you agree that the qualification for immediate implementation should only bebased on the size of the event excluding number of shares or float updates?

Should MSCI continue to have a second set of thresholds for smaller block sales tobe implemented at the quarterly Index Reviews?

Do you agree with the proposal that qualifying acquisitions of non-listed companies
and subscription receipts in Canada should be implemented intra-quarters insteadof postponed to the next Index Review?



Should MSCI continue to implement intra-quarter changes for selected event types
but at regularly scheduled - weekly or monthly - intervals?
8

APPENDIX© 2017 MSCI Inc. All rights reserved.
Please refer to the disclaimer at the end of this document.

1) BLOCK SALES CURRENT TREATMENT SUMMARY
Currently, block sales/secondary offerings (ex-USA), depending on their size (in USD), areimplemented at different timings.
 The largest ones are implemented at the time of the event based on the below thresholds1:- At least USD 1 billion FIF market capitalization impact for DM (event + any float updates)- At least USD 500 million FIF market capitalization impact for EM (event + any float updates) The intermediate ones are implemented at the following Index Review based on the below
thresholds2:- At least USD 1 billion FIF market capitalization impact for USA (event + any float updates)- At least USD 500 million FIF market capitalization impact for DM (event + any float updates- At least USD 200 million FIF market capitalization impact for EM (event + any float updates)- At least 3 FIF bracket change (event + any float updates) The smallest ones are implemented as part of the annual full float review at the May SemiAnnual Index Review3.
Note that in cases of large number of shares update done as part of Quarterly Index Reviews, MSCI would
also review the security’s float4.
1 As per section 4.1.2.1 of the Corporate Events methodology book
2 As per section 3.2.4 of the GIMI Methodology book
3 As per section 3.1.7 of the GIMI Methodology book
4 As per section 3.2.5 of the GIMI Methodology book102) COMPARATIVE VOLUMES WITH THE ALTERNATIVETHRESHOLD FOR SMALL CAPSSMALL CAPS
Event Types

Current

Proposal
10%

VolumeChange% Change

Alternative
15%

VolumeChange% Change

Private Placements
Public Offerings
Secondary Offerings (US)Buybacks
Partial acquisitions

184
232
80
27
18

152
152
60
8
17

(32)
(80)
(20)
(19)
(1)

-17%
-34%
-25%
-69%
-6%

96
112
28
4
14

(88)
(120)
(52)
(23)
(4)

-48%
-52%
-65%
-85%
-22%

Block Sales/Sec. Off (ex US) -Event

3

102

99

100%

42

39

0%

Block Sales/Sec. Off (ex US) 1 - QIR

86

0

(86)

-100%

0

(86)

-100%

Block Sales/Sec. Off (ex US) -Total

89

102

13

+15%

42

(47)

-53%

Acquisition of Private1

7

25

18

257%

22

15

100%

Subscription Receipts (CA)1

11

10

(1)

0%

7

(4)

-30%

Acq. of OTC/ listed non-const.

5

2

(3)

-60%

2

(3)

-60%

Results of Rights Issue

3

2

(1)

-33%

2

(1)

-33%

Conversions

3

3

0

0%

3

0

0%

Grand Total

748

635

(113)

-15%

374

(371)

-50%

1 Block sales of intermediate sizes, acquisition of Unlisted Securities and conversion of subscription receipts are implemented at the next regularly scheduled Index Review

NOTE: Data collected on 2015 and 2016, reflected on annualized basis.

11.

PROPOSED NEW TREATMENT FOR SECURITIES UNDERPROLONGED SUSPENSION (EX-CHINA)© 2017 MSCI Inc. All rights reserved.
Please refer to the disclaimer at the end of this document.

BACKGROUND AND RATIONALE FOR PROPOSAL The current treatment of prolonged suspension in the MSCI Indexes takes into account
whether or not the suspended securities are pending a corporate event.
 There is currently no trigger to delete suspended index constituents pending a corporate
event from the MSCI Indexes, which can lead to maintaining suspended index
constituents for extensive period of time creating potential replication issues.
 MSCI proposes to delete suspended securities as soon as suspension reaches 50 businessdays for IMI securities (100 business days for Micro caps), even if the security has any
pending corporate event.
 MSCI also proposes to assess prolonged suspensions on a daily basis instead of a monthly
basis*.
 MSCI would delete suspended securities at the lowest system price giving two fullbusiness days notice.
NOTE: This is aligned with the conclusions of the prolonged suspensions treatment for companies
classify on China.
* This would result in delaying by 15mins the delivery of the World ACE file from 4:15PM ET to 4:30PM ET.

13

PROPOSAL OVERVIEW
Beyond below proposed thresholds, MSCI would delete the securities under prolonged
suspension with two full business days notification at the lowest system price of 0.0001.
Prolonged suspension with no pending corporate events
IMI#
deletions

Micro
Caps

#
deletions

Assessment
frequency

Current

50 days24

100 days

35

Monthly

Proposal

50 days24

100 days

35

Daily

Prolonged suspension with pending corporate events
IMI#
deletions

Micro
Caps

#
deletions

Assessment
frequency

Current

NA

0

NA

0

NA

Proposal

50 days14

100 days9

Daily

 With current thresholds, 24 IMI
securities (ex-China) and 35 Micro
Caps have been deleted from the
MSCI Indexes in 2 years due toprolonged suspension without
pending corporate event.
 With pending corporate event, 14
IMI and 9 Micro Caps securities
have been suspended for periodsof 50 and 100 days or more
respectively in the past two years.

NOTE: Effective Dec 1, 2017, MSCI will start implementing the same thresholds and assessment frequency
for prolonged suspension for Chinese listed securities where 95% of prolonged suspensions occur.
Note: Data based on years 2015 and 2016.
14

DISCUSSION POINTS

Do you agree that MSCI should delete securities under prolonged suspension even if
they are pending a corporate event?

Do you agree with a distinct threshold between IMI securities (50 days) and Microcaps (100 days)1?

Do you agree with a daily assessment for securities under prolonged suspension (exChina) instead of the current monthly assessment and the resulting postponement by
15mins of the World ACE files delivery?

1 Having 50 days for Micro caps would have increased the number of deletions from 44 to 59 based on the past 2 years historical data.

15

PROPOSED ENHANCED TREATMENT FOR SPIN-OFFS
WITH DELAYED PAY-DATE© 2017 MSCI Inc. All rights reserved.
Please refer to the disclaimer at the end of this document.

BACKGROUND AND RATIONALE FOR PROPOSAL Currently, MSCI adds a “detached” security for corporate events, such as spin-off orpartial spin-off, where the pay date is at least 2 weeks after the ex-date even if the
spun-off security is trading on the ex-date.

 This can potentially cause replication issues for investors when the pay-date is lessthan 10 business days after the ex-date, as the distributed shares are alreadyreflected in the weight of the spun-off in the MSCI Indexes as of the close of the exdate but not yet received in the investor’s portfolio.
 MSCI proposes to add a “detached” security if the pay-date is 4 business days ormore after the ex-date instead of the current 11 business days or more to limit
potential replicability issues.
 The “detached” security would be temporarily added as of the close of the ex-date to
the MSCI Indexes where the parent security belonged and was deleted as of the closeof the pay-date. Simultaneously with the deletion, the impact of the distribution
would be reflected in the spun-off security.

17

PROPOSAL OVERVIEW It is typical that the pay-date takes place between -3 and +3 business days around the exdate depending on the country.
 Beyond 3 business days is rare with 9 occurrences in the last 2 years.

 The blue and green areas represent all the corporate events where MSCI would
temporarily add a “detached” security.
Delta between Pay-date and ex-date
Proposed change

Numberof events

15

10

No additionof “detached”
security

REGION REPRESENTATION

Existing methodology

Addition of “detached” security

Days

DM

EM

Total

4-5 Days2

2

6-10 Days

5

5

10+ Days

2

2

SIZE SEGMENT REPRESENTATION
50

Number-3 -2 -1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 .. 25 26 27
of daysBased on a sample of 52 corporate events in the past 2 years (Jan 2015 to Jan 2017)

Micro
Cap

Total

1

1

2

6-10 Days

3

2

5

10+ Days

1

0

2

Delta

Standard

4-5 Days

Small
Cap

1

18

PROPOSAL IMPACT & DISCUSSION POINTS With the current methodology, 2 corporate events with delayed pay-dates in 2 years
benefited from the temporary addition of a “detached” security in the MSCI Indexes.
 With the proposal of at least 4 business days difference, 9 corporate events would
have qualified to have a “detached” security temporarily added to the MSCI Indexes
between the ex-date and the pay date.

 Is at least 4 business days the right window to trigger the addition of a “detached”
security in the MSCI Indexes?

19

APPENDIX© 2017 MSCI Inc. All rights reserved.
Please refer to the disclaimer at the end of this document.

LIST OF PAST CORPORATE EVENTS UNDER NEW
PROPOSALPay Date (10+ Days)
Country

Securities

MarketSize Segment

Effective Date

Event Type

ImpactGB

GLENCORE / LONMIN

DMStandard/Small Cap

14-May-15

Spin OffUSD 210 million

CN

SINA CORP / Weibo Corp

EM

Small Cap

08-Sep-16

Spin OffUSD 356 million

Pay Date (6-10 Days)
Country

Securities

MarketSize Segment

Effective Date

Event Type

ImpactUS

LIBERTY GLOBAL CDMStandard/Small Cap

21-Jun-16

Spin OffUSD 1.5 billion

SG

TEE INTERNATIONALDM

Micro Cap

06-May-15

HK

ITC CORPORATIONDM

Micro Cap

18-Jan-17

AU

NATIONAL AUSTRALIA BANK/CYBG PLC

DM

Standard/Small Cap

03-Feb-16

Spin OffUSD 1.95 billion

GB

BHP BILLITON PLC (GB) / SOUTH 32

DM

Standard/Standard

18-May-15

Spin OffUSD 2.73 billion

Spin Off (Dvd inSpecie)Spin Off (Div in
Specie)<USD 10 million<USD 1 million

Pay Date (4-5 Days)
Country

Securities

MarketSize Segment

Effective Date

Event Type

ImpactCA

CANADIAN NAT RESOURCES

DM

Standard

01-Jun-16

Spin OffUSD 400 million

HK

MIDLAND HOLDINGDM

Micro Cap

06-May-15

Spin Off (Dvd in Specie)<USD 25 million

21

PROPOSED NEW TREATMENT OFACQUISITIONS INVOLVING THE ISSUANCEOF TENDERED LINE OF SHARES© 2017 MSCI Inc. All rights reserved.
Please refer to the disclaimer at the end of this document.

BACKGROUND & PROPOSAL In some tender offers, tendered shares may trade on a distinct line from the nontendered original line of shares.
 Generally, each line of shares trades until the offer closes or fails.
 Liquidity and performance may differ between the two lines of shares, which canpotentially create tracking error.

 For past events, mainly in Germany and Switzerland, MSCI applied a case by caseapproach.
 MSCI proposes a framework to determine if and when it is appropriate to switch thesecurity’s identifiers from the original non-tendered line of shares to the newly
created tendered line.

23

PROPOSAL OVERVIEW Conditions of implementation1:
MSCI would switch the target security’s identifiers from the original line of shares to the
newly created tendered line if at the end of the initial offer period:‐ The minimum acceptance level requirement is met (taking into account that theinitial threshold may be waived down) AND‐ The acceptance level is at least 50% AND‐ An additional offer period will be launched Announcement timing:
If both conditions above are satisfied, MSCI would send an announcement in “confirmed”
status shortly after the final results of the first offer period have been announced.
 Implementation timing:
MSCI would change the identifiers of the index constituent to the tendered line as of theclose of the last day of the additional offer period.

 What happens if the deal is cancelled:
MSCI would send an announcement in “confirmed” status to revert to the original line ofshares’ identifiers coinciding with the date the tendered share are re-booked to the regularshares
1 Applicable regardless the deal consideration (cash, cash and shares, shares).

24

PROPOSAL OVERVIEW Deletion price:
If the tender offer is deemed likely to be successful as per the criteria set in the section
2.2.2 of the MSCI corporate events methodology book or the completion date has been
publicly announced, MSCI will delete the target security from the MSCI Indexes. The
deletion price can be:‒ The tendered line of shares market price, if both conditions set in the previous slidewere satisfied.
‒ The regular line of shares market price, if the conditions set in the previous slide were
not satisfied at the end of the first offer period.
‒ The consideration of the offer, if the target security has been delisted prior to theeffective date of the deletion in the MSCI Indexes.
NOTE: MSCI would announce the implementation with at least two full business days
advance notification.

25

EXAMPLE OF PAST CASES
Two offerperiods?

Min.
acceptancelevels(original)

Acceptancelevel at theend of 1stoffer period

Acceptancelevel at theend of 2ndoffer period

ActualTreatment

Hypotheticaltreatment
under newproposal
Switch at theclose of 2ndoffer period

Date

Security Name(Country)

Nov
2014

UBS Group1(Switzerland)

Yes

67% (90%)90.4%

96.64%

Switch during 1stoffer period

Dec
2016

Gategroup(Switzerland)

Yes

0% (67%)63.6%

95.32%

No switch

Switch at theclose of 2ndoffer period

Jan
2017

Kuka
(Germany)

94.55%

No switch

Switch at theclose of 2ndoffer period

March
2017

Deutsche Boerse(Germany)

89.04%

Switch during 2ndoffer period

Switch at theclose of 2ndoffer period

May
2017

Syngenta(Switzerland)

Yes

67%

82.23%

94.68%

No switch

No switch –tender line stop
trading after 1stoffer period

Nov
2017

Linde
(Germany)Yes

60% (75%)

64.5%2?

TBA

Switch at theclose of 2ndoffer period

Yes

Yes

30%

60% (75%)

85.69%

63.35%

1 This was an exchange offer
2 As of October 24, 2017. 1st offer period is expected to end on November 7, 2017.

26

POTENTIAL IMPACT OF THE PROPOSAL & DISCUSSION
POINTS This proposal would provide clear rules for the treatment of corporate events
involving the creation of a new tendered line of shares.
 This would avoid potential miss-tracking for corporate events where the liquidity
shifts to the tendered line or the performance between the two lines differs.

 Do you agree with the conditions that need to be met to switch identifiers?
 Is the close of the second offer period the right timing to switch the identifiers to
the tendered line of shares?
 Should MSCI apply this proposed treatment to all countries? Or be more country
specifics where it is general market practice (e.g. Germany and Switzerland)?
 Should MSCI apply this proposal only for IMI securities?
 Should MSCI consider the volume traded on each line and/or the acceptance level totrigger the identifiers switch?
27

SELECTED TOPICS© 2017 MSCI Inc. All rights reserved.
Please refer to the disclaimer at the end of this document.

ACCELERATED RIGHTS ISSUES IN AUSTRALIA Australian companies’ trading is halted during the subscription period (“institutional
offering”) and resumes trading on the ex-date.
 Currently, MSCI implements Australian rights issues as per its global methodology i.e. a
Price Adjustment Factor (PAF) is applied on the ex-date and the number of shares isincreased as of the close of the ex-date for in-the-money rights issues.
 For in-the-money rights issues, shareholders who subscribed receive the new shares atthe open of the ex-date, whereas MSCI increases the number of shares only as of theclose of the ex-date, creating potential replication issues.
Discussion points:Do you participate in the institutional offering held during the suspension period?

 Do you face any issue in replicating MSCI’s current treatment?
 Is a change in treatment necessary in order to cater to the replicability issues
encountered for these specific Rights issues?
 If you would replicate Rights issue differently than the current treatment, what method
would you use to replicate the Rights issue?
29

SHARES/FLOAT UPDATES FOR M&AS
 Currently, MSCI implements pending number of shares and float updates at the time ofnon-market neutral corporate events (e.g. placements, acquisitions) qualifying for
immediate implementation.
 These updates make corporate events such mergers and acquisitions between IMI1
securities non-neutral.
Discussion points:
 Do you generally participate to tender offers between IMI securities?
 Would you prefer that MSCI systematically reflect number of shares and float updates aspart of regularly scheduled index reviews?
 Should MSCI introduce thresholds to reflect only significant updates at the time of theevent and postpone smaller ones to the index reviews?
 Should MSCI extend this idea to other non-market neutral event types?

1 “Investable Market Indexes” including large caps, mid caps and small caps.

30

CROSS BORDER ACQUISITION/SPIN-OFF
 Only a sub-set of cross-borders acquisitions/spin-offs are creating replicability issues.
 In the past 9 years, we identified 4 events that fell into the red scenarios below. i.e.
- The target security deleted at the offer price is in a time zone prior to the acquirer.
- The parent security is in a time zone prior to the spun-off security.
Past events falling in the red scenarios-

2008: Cadbury Schweppes (UK) spinning-off
Dr Pepper (US)-2014: Vodafone (UK) spinning-off Verizon (US)-2016: National Australia bank (AU) spinningoff CYBG PLC (UK)-2016: Ball Corp (US) acquiring Rexam (UK) for
cash and shares In these scenarios, options are to use either the previous day closing market price or todelay the products delivery.
 To enhance replicability, should MSCI delay the products for these red scenarios? Onlyfor Standard securities?
31

ABOUT MSCIFor more than 40 years, MSCI’s research-based indexes and analytics havehelped the world’s leading investors build and manage better portfolios.
Clients rely on our offerings for deeper insights into the drivers of
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For more information, visit us at www.msci.com.

32

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None of the Information constitutes an offer to sell (or a solicitation of an offer to buy), any security, financial product or other investment vehicle or any trading strategy.
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MSCI ESG Research LLC is a Registered Investment Adviser under the Investment Advisers Act of 1940 and a subsidiary of MSCI Inc. Except with respect to any applicable products or services from MSCI ESG Research, neither MSCI nor any of its products
or services recommends, endorses, approves or otherwise expresses any opinion regarding any issuer, securities, financial products or instruments or trading strategies and MSCI’s products or services are not intended to constitute investment advice ora recommendation to make (or refrain from making) any kind of investment decision and may not be relied on as such. Issuers mentioned or included in any MSCI ESG Research materials may include MSCI Inc., clients of MSCI or suppliers to MSCI, andmay also purchase research or other products or services from MSCI ESG Research. MSCI ESG Research materials, including materials utilized in any MSCI ESG Indexes or other products, have not been submitted to, nor received approval from, theUnited States Securities and Exchange Commission or any other regulatory body.
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