Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision
In July 2021, the Tokyo Metropolitan Government (TMG) released the Revision (Draft) for the “Global Financial City: Tokyo” Visionand solicited a wide range of opinions from the public.

Thank you very much for all the valuable comments.
【Period and number of comments collected】
・Period: July 21 (Wed) to August 31 (Tue), 2021
※English version: August 2 (Mon) to August 31 (Tue), 2021

・ Total number of comments: 35 responses (including 6 in English), 89 comments (including 18 in English)※Counting method: The number of parts that are considered to be comments in each response were counted, their contents were summarized andreleased as follows【Overall】

Comments

TMG's Response

It is important to consider how to increase investment andfinancing from overseas to Japan, and how Japan can generate
profits from financial transactions from overseas rather than justconsidering how to increase transactions between Japanese,
investments in and financing to overseas countries by Japanese,and transactions to pay commissions to overseas financial
institutions. In order to become a global financial city by utilizing
1,900 trillion yen, it is necessary to increase the number of foreigncompanies listed on the TSE.

This vision aims to promote fund-raising (stock listings and JDRs)
by foreign companies on the Tokyo Stock Exchange in order to"increase fee income received from overseas customers forfinancial services provided by financial companies to overseas
customers," which will contribute to increasing Tokyo's GDP.
Through these and other efforts, the TMG aims to establish an
investment chain that links domestic and overseas capital needs
with funds from around the world as a global and Asian financial
hub.

1Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Overall】
Comments
The "Global Financial City: Tokyo" Vision is a very important initiative for the future
development of Japan as a whole, not only for Tokyo. I would like to express my deepest
gratitude to the TMG officials who are working on this project every day.
The data is rich and easy to understand.

TMG's Response
・Thank you very much for your comments in favor of the draft for the revision.
・In light of the changes in the international financial situation and the challenges facing
Tokyo, TMG will take various measures based on the three pillars of the vision, which are"Establishment of the robust financial market that helps solve social issues", "Digitalization offinance" and "Accumulation of diverse financial players."
・Through these and other efforts, we will achieve sustainable recovery and become a worldleading global financial city.

This is a well-organized document that covers the key issues. In particular, the focus onsustainability is highly appreciated.
The revised "Global Financial City: Tokyo" Vision, which has just been formulated,systematically clarifies the international and social background of the initiative and Tokyo's
strengths, sets policies based on these strengths, and provides concrete action plans torealize the vision thereby deepening our understanding of the vision. Would like to be actively
involved in and cooperate with the action plans to realize Tokyo as a global financial city.
Against the backdrop of the prolonged political turmoil in Hong Kong, expectations for therevival of Tokyo as a "global financial city" have become even higher. In this context, it is verysignificant that the TMG has come up with the draft for the revised " Global Financial City:
Tokyo" Vision.
The three pillars of this vision are important projects, and I agree with the purpose of thisvision. I would like the TMG to actively promote them.
Overall, the draft for the revision is highly commendable as it is timely and comprehensively
takes into account changes in the situation such as green finance, COVID-19 pandemic, anddigitalization.
Overall, the revised vision is well thought out. It covers key issues of interest to would-be
asset managers, including business conditions, digitalization, taxation, and sustainability.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Overall】
Comments

TMG's Response

For Tokyo and Japan to become the world's major financial services hubs, theyneed a large and successful global banking, securities, and insurance industry
infrastructure like that of London and New York.
It would be better if a description of the role of conventional financial
institutions (banks, securities, insurance, etc.) is added to the vision.

・This vision aims to develop Tokyo as a global financial city where "funds
intermediaries (asset managers, financial institutions, etc.)" are active;"domestic and foreign investors (individuals, corporations, institutional
investors, etc.)" supply ample funds to "domestic and foreign investees(companies, projects, financial products, etc.)"; "comprehensive urban
functions and infrastructure" support these activities, thereby creating avirtuous cycle of investment and return, and contributing to the growth of thefinancial industry itself, the growth of investee companies, and ultimately the
GDP and sustainable economic growth of Tokyo and Japan as a whole.
・In order to realize the ideal state of such a city, the role of financial
institutions such as banks, securities companies, and insurance companies,
which are responsible for the global and large-scale financial infrastructure, isalso very important, and we will continue to work closely with them.

The draft does not mention any relationship with the so-called "threemegabanks" and major securities companies nor any efforts to promote theactivities of such financial institutions in the Tokyo market. However,consultations and discussions with major domestic financial institutions
should be considered in order to expand the finance market.

It is difficult to understand which markets the revised vision is targeting. Givena global financial city, a clear vision of the stock market and foreign exchange
market should be included.

・This vision aims to build an investment chain that connects domestic andinternational capital needs with global funds, and does not target any specificmarket.
・In order to develop sustainable finance as a whole, TMG will expand efforts
to other areas, such as social finance, which aims to solve social issues, while
keeping in mind a wide range of financial products such as bonds, loans andequity, with green initiatives as the first step.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Image of a global financial city that Tokyo should aim for】
Comments

TMG's Response

I agree with the policy of aiming for a "Real economy backed-type" and combining it with an"Information/knowledge intensive-type" like London. Furthermore, in light of the current
trends in Hong Kong, it may worth considering aiming for a "Financial intermediary-type" or
a "Gateway-type" as well.

・As a "real economy-backed type" global financial city, this vision aims to establish
an investment chain that links domestic and international capital needs with global
funds as a financial hub for the world and Asia, backed by substantial domestic
capital demand based on the existence of various companies and projects in Japanand domestic capital supply capacity.
・It is also deemed important to have various functions in the future, by combining
the functions of a "information/knowledge intensive-type" global financial city whileaiming to become a "real economy backed-type" global financial city.
・We will use the comments we received for future reference.

This is a very well organized vision document.
Considering the declining birthrate and aging population, Tokyo needs to respond to new
business models and diversification. Thus it is appropriate for Tokyo to aim for a hybrid
model combined with other "types" rather than limiting itself to the "Real Economy backedtype."
Tokyo, with its ample domestic funds, actual financial transactions, and concentration of
information, including academia, could be a " hybrid " city, combining an "Information andknowledge intensive-type" and a "real economy backed-type" like New York and Shanghai.

Regarding "as a financial hub in Asia" on page 2, "real economy backed-type" orientation isstated on page 9. When combined with the following "investment chain", it should be"intermediary type" or "gateway type".

On the second page, it says, "Amid an intensified competition with other cities, such asSingapore and Hong Kong." Given that these cities have unique strengths that differ from
Tokyo's, and that there could be a "cooperative" relationship, isn't it important to mention"cooperation"?

・In 2017, the TMG signed a Memorandum of Understanding (MoU) with the City of
London Corporation in the U.K. to further deepen exchanges and cooperation in thefield of financial services and to hold events and seminars in the financial sector andpromote financial education programs and green finance so that these two global
financial cities can mutually develop and grow together.
・We will use the comments we received for future reference.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Image of a global financial city that Tokyo should aim for 】
Comments

TMG's Response

In page 2, it states that Tokyo's strengths include personal financial assets of
1,900 trillion yen. Tokyo's strengths could be more broadly expressed byreferring to the number of international banking, securities, insurance, andother financial services firms in Tokyo.

・Tokyo is home to a financial ecosystem that includes financial companies
such as banks, securities firms, asset management firms, and insurancecompanies, as well as law firms, auditing firms, universities, and research
institutions supporting such companies. The financial industry accounts fornearly 10% of Tokyo's GDP. This situation is summarized in the vision as "thefinancial industry is a local industry in Tokyo."・We will use the comments we received for future reference.

Since the amount of cash and deposits is increasing year by year, it may benecessary to propose a mechanism (product image) to ensure the liquidity of
cash and deposits.

・To promote the utilization of savings to investment, financial seminars andbasic courses on asset formation at the Open University of Tokyo
Metropolitan University will be held to improve the financial literacy of Tokyo
residents based on this vision.
・In addition, as part of our efforts to "attract individual investors" to green
finance, we will improve the environment to make it easier for individuals toparticipate in sustainable finance by urging the government to include ESG
indexes in the reference indexes for Tsumitate NISA.
・We will use the comments we received for future reference.

・In expanding the function of the Tokyo market as "funds intermediaries," itis necessary to steadily shift the 1,900 trillion yen in personal financial assets
from savings to investment, which has been an issue for many years. To
realize this goal, it will be necessary to develop products that allow forinvestments in Asian growth "over a long period of time at a moderate level ofrisk." This will require incorporating such product development into thepolicies of major Japanese financial institutions as well.
・It would be appreciated if you could add the term "investment chain" to theglossary to make it easier to understand.

・In response to the comments we received, we have added the term
"investment chain" to the glossary.

5Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Establishment of the robust financial market that helps solve social issues】
Comments

TMG's Response

The positioning of the ESG investment as one of the three key pillars in thedraft for the revised vision is desirable for resolving Japan's issues.
However, it seems that the actual measures proposed in the draft do not go
into detail enough. The TMG should consider efforts to expand the scope offunding. It is hoped that the TMG will take proactive steps to diversify thescope of funding, as described below.
・The TMG, as an investor, should participate in a fund that invests in the
new areas mentioned above, thereby attracting other investors to provide
funds.
・Support to encourage financing from financial institutions for non-FIT
power sources, large-scale power storage plants, household renewableenergy assets (solar power and storage batteries), etc. (See examples below.)・Improvement of economic efficiency of projects through subsidies fordevelopers of non-FIT power sources and large-scale power storage plants
・Enhancement of project predictability through subsidies for long-term
electricity purchase contracts from non-FIT power sources and large-scale
power storage plants
・Lowering the investment hurdle for investors by providing rating support fordiversified pools of household renewable energy assets
・Improvement of economic efficiency by providing interest rate support toprojects for new investment targets
・Dissemination of advanced case studies
・Efforts to improve investors' literacy
・Initiatives to deepen public understanding of the importance of promoting
renewable energy assets for industrial and residential use

・TMG has been promoting projects through Public-Private Partnership
Funds by utilizing private sector capital and know-how with TMG's investment
as a catalyst.
・In the current fiscal year, TMG will establish a new Sustainable Energy
Fund (tentative name) to promote the development of clean energy bases andrenewable energy power plants.
・We will use the comments we received for future reference.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Establishment of the robust financial market that helps solve social issues】

Comments

TMG's Response

There is no doubt that the promotion of the TGFI will become an
important factor in strengthening competitiveness against othercountries.
It seems that we are now at a phase where the government needs
to exercise appropriate control, as in the case of green washingregulations, rather than blindly promoting an increase in thebalance of sustainable investments.

・Under this initiative, the TMG will disclose ESG-related
initiatives and information on companies, held by the TMG in a
way that is easily accessible to all, while taking into account movesby the national government and the Japan Exchange Group toestablish an information infrastructure and certification frameworkfor green bonds, with the aim of further promoting ESG investment
by institutional investors.
・We will use the comments we received for future reference.

In developing a market using the 1,900 trillion yen, we should aim
to increase the issuance of green bonds, especially those issuedby overseas companies and projects, i.e. samurai bonds. For thispurpose, it is desirable that Japanese securities companies
improve their ability to arrange international green bonds; and that
asset management companies investing in green bonds areconcentrated in Tokyo.

・The vision aims to build an investment chain that links global
funds to domestic and international capital needs, including green
funds, by drawing on domestic capital supply capacity as a global
financial city that Tokyo aims to become.
・It also aims to attract and foster a wide range of relatedcompanies, including asset managers with expertise in ESG
finance and fintech startups.
・We will use the comments we received for future reference.

Regarding "The nation's financial assets will be supplied to growth
sectors," we need a mechanism that will allow for shifts fromsavings to investment by the elderly. Specific measures should be
proposed and implemented, keeping in mind the fact that the mainmarket for green finance is in Europe.

・In addition to creating an environment that facilitates the entry
of individuals into sustainable finance, this vision aims to improve
the financial literacy of Tokyo residents.
・We will use the comments we received for future reference.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Establishment of the robust financial market that helps solve social issues】
Comments

TMG's Response

Promoting the TGFI is an unavoidable step for the realization of a world-classglobal financial city in light of global trends. I would like to see it promotedwith a sense of speed.

・Based on the Tokyo Green Finance Initiative (TGFI), which is a strategic
initiative for the development of green finance in Tokyo, we will implement avariety of initiatives with a sense of speed to create a virtuous cycle between
the "environment "and the "economy" from Tokyo, and simultaneously
promote the green transformation of Tokyo's "urban system" and "financial
system."As the draft states about activation in SMEs, we recognize that creating green
loans that are easy for SMEs to use is a important issue for financial
institutions to address in the future.

・In addition to encouraging SMEs to invest in decarbonization and disclose
ESG-related information, the vision will also promote the development ofsustainable finance for SMEs in cooperation with regional financial
institutions, etc., and consider measures to support transitions.

I would like to see efforts to incorporate ESG assessment and engagement
into investment decisions for green loans in indirect finance.

・We will use the comments we received for future reference.

While large corporations with ample funds and manpower are making
progress in ESG measures, SMEs (unlisted companies) may find it difficult todo so. I think the efforts to support SMEs so that they are not left behind areimportant.
We would like to see consideration of various other incentives for real estatesthat are excellent in terms of decarbonization and energy conservation,
including various types of financial appreciation as described in the draft for
the revised vision.
We would like to see studies on measures to support the dissemination of
information and to receive appreciation in financing for initiatives such as theregional decarbonization roadmap, which is clearly stated as a measure by
the government.

・Under this vision, we will study how to effectively disclose information sothat real estate with excellent performance in decarbonization and energy
conservation can be appreciated in terms of finance.
・We will use the comments we received for future reference.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Establishment of the robust financial market that helps solve social issues】
Comments

TMG's Response

With regard to the statement on page 16, from the perspective of realizing a wellbeing
society, I would suggest that the statement be changed to " While taking the lead ingreen (E) initiatives, the TMG will expand its initiatives to other areas, such as social (S)initiatives, which aim to solve social issues such as the realization of a wellbeing society,while keeping in mind a wide range of financing forms, including bonds, loans, and equity,
for the development of sustainable finance as a whole.

・The development of "impact investment," which aims to achieveboth social results and economic benefits by investing to solve socialand environmental issues, will greatly contribute to the promotion of"sustainable recovery."・In order to establish a financial market that contributes to solvingsocial issues, research and study on new financial methods, such as
impact investment, will be conducted from the perspective of trends
in the national government and the private sector, as well as theroles that local governments are expected to play.
・In addition, for the "Establishment of the robust financial market
that helps solve social issues" - Promotion of the TGFI -, efforts willbe also made for other areas, such as social (S) finance, which aims
to solve social issues, while keeping in mind a wide range of financeforms such as bonds, loans, and equity, in order to develop
sustainable finance as a whole, with green (E) initiatives taking thelead.
・We will use the comments we received for future reference.

In terms of "ESG finance", the focus of this proposed revision on resolving social issues
through private equity and impact investment is a positive sign that the TMG itself has
expressed its intention to create dynamism, which is deemed favorable. This move isalso in line with the direction of the global financial industry as a whole, and there should
be much that can be done in cooperation with the Japanese financial community. I hopethat the TMG will lead the world by taking prompt actions through its initiatives.
How about promoting social (S) as well as green (E) simultaneously?
When structuring financing schemes for the construction of homes for the elderly or
facilities for people with disabilities that aim for coexistence with them, the TMG caninvest the equity portion and act as a catalyst, making it easier for private funds to invest
and for financial institutions to provide loans, thereby promoting sustainable investment
and facilitating the spread of such facilities.
As a result, the TMG will play a major role in promoting the realization of a society where
diverse human resources can play an active role and coexist in harmony (S).
It is important to implement measures for ESG finance in general, such as social andsustainable finance, as well as green finance, at the same time.

9Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Establishment of the robust financial market that helps solve social issues】
Comments

TMG's Response

It could be a viable option to introduce new tax incentives such as income tax
deductions for individual investors who hold ESG corporate bonds that havebeen endorsed by an external evaluation body designated by the government,
and tax exemption for interest and gains on transfer.

・In order to create an attractive business environment, this vision will
identify the needs of stakeholders and request the government to review thenecessary taxation and regulations, including those related to green finance.
・We will use the comments we received for future reference.

Since domestic financial institutions lack the correct knowledge and knowhow about ESG, it is necessary for the public and private sectors to work
together to share the appropriate approach with the support of the TMG. I
would like the TMG to lower the threshold and give knowledge, know-how,and vitality to SMEs, which are the foundation of the ESG sector, throughsolid cooperation with financial institutions, and the public and private sectors,
without being bound by the framework of the government.

・It is important that industry, government, and academia share a sense ofcrisis and work together with a sense of speed to address the major crisis ofclimate change facing the world.
・This initiative aims to encourage SMEs to invest in decarbonization and to
disclose their own ESG-related information by providing information on global
trends related to SDGs and ESGs and the finance that supports them to SMEs
through seminars and workshops.
・In addition, with the aim of attracting individual investors, TMG will
disseminate information on global trends related to SDGs and ESGs in aneasy-to-understand manner for Tokyo residents through seminars andsymposiums, in order to improve their literacy with regard to green finance.
・We will use the comments we received for future reference.

The draft says, "The TMG has embarked on actions to achieve 'Carbon-Half'by 2030 and 'Zero Emission Tokyo’ strategy by 2050." However, people may
have become complacent about the need for energy saving since 2011, andthe TMG should make more efforts to encourage people to save more energy.

It is extremely significant that the TMG is taking the lead in promoting thedevelopment of a global financial city with green finance as a starting point. In
order to achieve decarbonization, it is essential to raise the awareness of not
only corporations but also Tokyo residents. Measures that will encourage
Tokyo residents to actively participate in the TMG's initiatives and raise theirawareness will help to stimulate this vision.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Establishment of the robust financial market that helps solve social issues】

Comments

TMG's Response

Incentives for issuers to encourage further development andexpansion of green finance, for example, would include simplifying
application procedures for obtaining external reviews, etc., andproviding benefits (subsidies, etc.) based on the amount andnumber of green finance procured, the proportion of green financeto interest-bearing debt, etc.

・In this vision, measures to reduce the burden of obtaining
external reviews, etc., which are required when issuing green
bonds, etc., will be implemented in order to develop the green
bond market.
・We will design the system so that it will impose as little burden
as possible on the applicants.
・We will use the comments we received for future reference.

Since the benefits to investors of investing in green finance arelimited to investment statements (public relations), it would be
worthwhile to consider providing practical benefits compared toregular corporate bonds. It is also worth considering the possibilityof encouraging disclosure of target figures, such as investing acertain percentage of the portfolio in green finance.

・Under this vision, TMG will disclose ESG-related initiatives andinformation on companies, etc. held by the TMG in a way that is
easily accessible to all, to enable investors to actively engage ingreen finance.
・We will use the comments we received for future reference.

The proportion of sustainable finance-related financial products intotal investments is still small. Focusing on this area may reduce
the size of the target market and delay the progress of the "Global
Financial City: Tokyo" vision.

・With the growing need to address the climate crisis, sustainablefinance has become a global trend. This vision will focus on thisarea in order to enhance Tokyo's position as a global financial city.
・We will use the comments we received for future reference.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Establishment of the robust financial market that helps solve social issues】
Comments

TMG's Response

It is stated global trends related to SDGs and ESGs, etc. will be disseminatedto Tokyo residents in an easy-to-understand manner to enhance theirfinancial literacy, but it is difficult to understand the relationship between
dissemination and enhancement of financial literacy.

・The global trends related to SDGs and ESGs, etc. will be disseminated toTokyo residents through seminars and symposiums in order to attract
individual investors, thereby improving the financial literacy of Tokyo
residents with regard to green finance, which has become a global trend.

I understand that the TMG issued the first social bond in early July 2021, andlook forward to further social bond issuance by the TMG.

・In July of this year, TMG became the first local government in Japan toissue social bonds in the amount of 30 billion yen. A second issuance isplanned during this fiscal year. The TMG will continue to work towards theissuance of social bonds.

With regard to the TGFI strategy, "Stimulation of green loans for SMEs" is an
initiative that should be promoted to realize a green city, and it is necessary tofurther publicize Tokyo's specific support measures and make them widely
known to Tokyo residents.

・To encourage SMEs to save energy and decarbonize their operations, wewill collaborate with local financial institutions and effectively disseminate
information on specific initiatives.

If "sustainable recovery" means "the sustainable recovery of people inaddition to climate change countermeasures during the social recovery fromCOVID-19 pandemic", I do not understand how this achievement leads to a
global financial city. A recovery does not make a city attractive. We need amechanism to attract funds that will lead to new investments. Moreover,green finance is not new, and the only main product is bonds.

・This vision positions the stimulation of green finance, which is becoming
increasingly important as Tokyo aims to become a global financial center, as away to accelerate decarbonization efforts and contribute to sustainable
recovery, leading to sustainable economic growth for Tokyo and, ultimately, tothe realization of affluent lifestyles for Tokyo residents.
・We will use the comments we received for future reference.

Green finance is already outdated, so it should not be pushed to the front.
Instead, it should be a small part of the vision.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Digitalization of finance】
Comments
It is difficult to get a clear picture of the launch of a fund that supports fintech.

TMG's Response
・In FY2021, a public-private partnership fund will be established with investment
from TMG to provide financial and managerial support to fintech startups.
・We will use the comments we received for future reference.

As for the "creation of new services in collaboration with financial institutions throughTMG funds", if the cost burden on the financial institutions is removed, it will bemuch easier to move forward. In addition, if the TMG plays a consulting role in thecreation of services, the collaboration would be accelerated further.
The draft includes various measures to attract foreign financial companies and tosupport the establishment and growth of fintech companies, greentech companies,
asset managers, etc. These measures are expected to contribute not only to thefinancial sector but also to the strengthening of Tokyo's international
competitiveness. I would like to see the TMG further strengthen its ties with
developers and VCs who are providing such support in the private sector. Moreflexible measures are expected to meet the needs of the private sector, such asproviding individual consultations in advance for opening new offices as part of the
TMG's efforts to support startups, or allowing the conversion of floors used forcontributing to national strategic special zones into startup support facilities.
One of the Tokyo's strength as a market, for example, is the depth of its market thatcan realize IPOs of startups like TSE Mothers. I would also like to see Tokyo actively
promote its strength as a place that facilitates the promotion of open innovation, andswiftly attract foreign companies, investors, and accelerators to the market. Building
a strong support system, with the TMG taking the initiative, would help to highlightTokyo's uniqueness (hybrid characteristics) as a city that can possess features of a"hybrid-type" global financial city, which is a combination of a "real economy backedtype" and an "information/knowledge intensive-type" global financial city.

・This vision calls for Tokyo to become a "real economy backed-type" global financial
city. It is important to encourage the creation and growth of startups, which will be asource of innovation, through organic cooperation among industry, government, andacademia in order to create excellent companies and technologies in Tokyo that will
become investment targets for domestic and foreign investors.
・In January 2020, with the aim of promoting the formation of an ecosystem that
supports the creation and growth of startups, the "Startup Ecosystem Tokyo
Consortium" was established with the participation of a wide range of entities,
including companies, economic organizations, universities, research institutions,venture capitalists, and local governments. Under this vision, we will work together
with the consortium to provide support for promoting the growth of SMEs andstartups possessing excellent technological capabilities and ideas.
・We will use the comments we received for future reference.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Digitalization of finance】
Comments

TMG's Response

As we enter the era of VUCA, Tokyo's strengths can be maximized bycollaboration of large corporations and financial institutions with FinTech
companies; understanding the initiatives of large corporations and financial
institutions in order to further strengthen the trend of open innovation;
working together with the private sector to consider what kind of society canbe realized by injecting the power of FinTech into these initiatives; andstepping into and supporting the projects themselves.

・As part of this vision, pitch events, etc. will be held in collaboration withindustry organizations, incubation facilities, etc. to promote collaboration
between financial institutions and fintech companies.
・In addition, for companies that have excellent technologies or products but
have difficulty in disseminating information in English, we will provide support
such as advice on English information disclosure and translation of IR
materials into English.
・We will use the comments we received for future reference.

With regard to the attraction and support of overseas fintech companies,
concrete support for business creation with Japanese companies is needed inaddition to institutional support. For overseas fintech companies to enter theJapanese market, there are high barriers to entry in terms of regulations andcustoms in Japan, making it difficult in many cases to provide them withservices based on successful overseas models or models that are in demand.
Therefore, in addition to cost and business plan support and mentoring, it
would be helpful to have a support system that goes into how to apply andmatch the solutions of overseas companies with the pain points of Japanesecompanies.
Regarding pitches and business matching events to attract fintech companies,
it is necessary to understand the needs of Japanese companies well inadvance so as to make the events more effective and to support fintech
companies. At the same time, it is necessary to follow up on the Japanesecompanies to ensure that they do not just attend the events, and in somecases, provide language support and business matching support to allow
overseas fintech companies and Japanese companies to stay connected after
the events.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Digitalization of finance】
Comments

TMG's Response

At present, the TMG does not support/foster cyber security as a growthstrategy, but it may be possible to consider such an initiative as part of the"Global Financial City: Tokyo" Vision.

・We will use the comments we received for future reference.

The cashless system is a positive trend for better quality of life of Tokyo
residents, but the private sector is still uncomfortable with digital technology.
As for online applications to local governments, tax offices, and other public
institutions, it seems that the elderly are particularly concerned about support,
and few people actually use these services.
There may be new systems or emergency measures that can be facilitatedthrough digitalization. I would like to see a shift to digitalization to eliminate
cumbersome procedures.

・Under this vision, the current status and issues of the cashless system inTokyo will be grasped, and then measures to promote the cashless system
will be studied from various perspectives, including contribution to therevitalization of the domestic fintech market.
・We will use the comments we received for future reference.

Even if foreign fintech companies try to import their overseas businessmodels to Japan as they are, they may face legal regulations as the biggest
obstacle. The enhancement of a sandbox system, etc., in Tokyo exclusively foroverseas fintech companies will be the key to attracting them.

・As part of this vision, we will identify the needs of related parties andrequest the national government to review the necessary taxation system andregulations with a view to creating an attractive business environment.
・In addition, we will adopt excellent technologies and products of startup
companies at administrative sites, etc., and provide opportunities fordemonstration experiments to help these companies build their track records.
・We will use the comments we received for future reference.

While other major financial centers have started similar initiatives that arecovered in the Revision (Draft) for the “Global Financial City: Tokyo” Vision,
what is truly important is to create an environment for the continuous
development of growing FinTech companies.

・We will provide seamless support for various needs according to growthstage, from the establishment of a base in Japan for fintech companies
invited from overseas to the full-scale growth of their business, and from thestart-up of fintech companies in Japan to the full-scale development of theirbusiness.

15

Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Digitalization of finance】
Comments

TMG's Response

The TMG should promote the message, "Cashless payment is contactless andreduces the risk of infection especially during the COVID-19 times" morestrongly to both private businesses and users. "Reducing the risk of infection"
could be a power word to encourage the elderly to use cashless services.

・The development of a cashless society will contribute to greater
convenience for Tokyo residents and higher productivity of businesses, andcan be a driving force for the creation of new financial services. At the sametime, it will be in line with the needs for "non-face-to-face" and "contactless"services during the COVID-19 times.
・We will use the comments we received for future reference.

The adoption of global standards should be encouraged so that funds
intermediaries and fintech firms can minimize the unique adaptations of theJapanese market when introducing global digital solutions to the Japanesemarket.
If the global system could be adopted, the Japanese market would become
more attractive for fintech firms that support the digitalization of funds
intermediation.

・We will use the comments we received for future reference.

I agree with the goal of increasing the number of FinTech companies andasset managers.
The important issues to address in order to achieve this goal would include
building a system ahead of other prefectures so that even people without abank account do not have to worry about their daily lives, as is the case inother countries; and digitalization of tax payments, etc. by unifying theadministrative settlement system, instead of making them complicated andmultiple procedures,.

・This vision stipulates that the efforts will be made to accumulate and foster
fintech companies that will improve the convenience of life for the people ofTokyo and Japan, and also help to revitalize industries.
・The vision also states that requests will made to the national governmentand other relevant organizations to promote the further digitalization of
applications for financial licenses and various reports.
・Furthermore, TMG will urge the national government to make necessary
amendments to the systems in order to create a comfortable living
environment for highly-skilled foreign financial professionals.
・We will use the comments we received for future reference.

16

Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Digitalization of finance】
Comments

TMG's Response① Measures to increase the number of companies attracted:
Now that it has become clear that business can be conducted remotely to acertain extent, it is unlikely that the hurdles to entry will drop dramaticallyeven after the COVID-19 pandemic subsides. Therefore, it is important tocreate an opportunity for foreign companies to take the first step for themarket entry. The hurdle to entry may be lowered by providing temporary
office space, attending to foreign companies that are concretely considering
entry into the market (including bearing a certain amount of expenses), andstrengthening support for business matching during their visit to Japan.

Response to ①:
TMG implements the "Project for Temporary Office Allocation for Foreign
Financial Companies and Human Resources" to support foreign financial
companies and personnel who are considering opening a new office in Tokyo
to temporarily stay in Tokyo to conduct preliminary research for their businessexpansion.
In addition, through the "Financial One-Stop Support Service", TMG provides
comprehensive consulting services, including support for administrative
procedures in cooperation with the Financial Services Agency, referrals tofinancial experts depending on the content of the consultation, andassistance in finding business partners in Japan.

② Measures at the stage of attraction:
The TMG may be planning to provide opportunities such as pitch events andbusiness matching, but support is needed not only for holding such events but
also for ongoing follow-up after the events. Specifically, comprehensive
support is needed for the winners (subsidies, referrals to specialists/mentors,
and ongoing follow-up after matching events) and for the organizers (financial
support for hosting events and ongoing follow-up after the events).
③ Post-attraction measures:
Ongoing support and follow-up are needed to help foreign companies takeroot in Tokyo even after the attraction is complete. It is also necessary toestablish an ongoing support system and to give support to the communities
providing ongoing support.

Response to ② & ③:
The TMG provides seamless support for various needs of foreign financial
companies at each stage of their growth, from the establishment of a base inJapan to the full-scale growth of their business.
For measures to create business opportunities for fintech companies, we will
support their overseas promotion and collaborate with fintech industry
organizations and facilities accommodating startups.
In addition, we encourage collaboration between financial institutions andfintech companies by holding pitch events in cooperation with industry
associations and incubation facilities.
We will use the comments we received for future reference.

17

Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Accumulation financial players】
Comments

TMG's Response

Thank you for considering various measures. Green finance and ESG are allimportant. However, "income tax and inhabitant tax" should be lowered if
Tokyo is to truly become a global financial city. Otherwise, it will be extremely
difficult to attract competent personnel and funds from overseas.
Eliminating inheritance tax on overseas assets and treating carried interest as
financial income are positive steps that can be taken, but income tax andinhabitant tax are still too high. Incidentally, the number of people who canbenefit from carried interest seems to be very limited.

・In line with this vision, we will develop an attractive business environment
as a global financial city through identifying the needs of related parties andmaking requests to the national government for necessary taxation andregulatory revisions.
・We will use the comments we received for future reference.

The most important thing is to lower the personal income tax rates. Unless
Japan's tax rates are lowered, excellent financial professionals will not cometo Japan. Lowering the residential tax rates could be considered, but even if itwere done, it would not change the excessively high rate of 45% income tax
plus 2.1% earthquake reconstruction tax. The TMG should work closely with
the Japanese cabinet and the Diet to lower the 45% income tax rate tosomething more reasonable. Otherwise, Tokyo will never become a global
financial hub.
I don't think Japan is an attractive financial center because Japanese
regulations and securities companies stop trading foreign currencies andinterest rate derivatives for accounts in Japan. Deregulation is critical to makeTokyo a more attractive financial center.

18

Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Accumulation financial players】
Comments
It is difficult to understand the difference in the content of cooperation androles between the TMG's "Financial One-Stop Support Service" and the"Financial Market Entry Office" of the Financial Services Agency (FSA).

It is important to assist the appointment of staff with extensive experience inthe relevant private companies with a view to supporting business expansion
into Japan.

To succeed as a financial center, it is necessary to obtain professional andrational answers to regulatory questions from regulatory authorities, and to
make efforts to properly introduce companies and experts who can provide
local management resources in Tokyo.

Regarding page 4 " Accumulation of financial players", it is necessary toconsider companies, employees, families, schools, medical institutions, foodand daily necessities... the perspective of consumers in order to accumulate
them.

TMG's Response
・TMG's "Financial One-Stop Support Service" provides comprehensive
consulting services by counselors with many years of experience working for
financial institutions in Japan and abroad, including referrals to experts, etc.
according to the content of the consultation, assistance in finding business
partners in Japan, and provision of information on living environment.
・The FSA's "Financial Market Entry Office" mainly deals with administrative
procedures related to financial licenses, such as prior consultation onregistration of foreign financial companies entering the Japanese market andtheir registration procedures.
・TMG's "Financial One-Stop Support Service" and FSA's "Financial Market
Entry Office" have established a cooperative relationship and are prepared toprovide comprehensive support through cooperation between the two offices,
regardless of which office is consulted.

・This vision aims to accumulate foreign financial companies and personnel
through the development of a business environment by identifying the needsof those involved and requesting the national government review thenecessary taxation and regulations; and through the development of Tokyo’s
living environment by further enhancing international schools and promoting
the development of multilingual serviced apartments and medical facilities byutilizing the national strategic special zone system.
・We will use the comments we received for future reference.

19

Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Accumulation financial players】
Comments

TMG's Response

Improving the financial literacy of each and every citizen will result in promoting theprovision of sound, high-quality financial products and the effective use of household
financial assets, which will contribute to the realization of a fair and sustainable
society. In a society with a declining birthrate and an aging population, I agree with theneed for citizens to acquire sufficient knowledge of financial products and to promote
the shifts from "savings" to " investment" in order to build their assets. In addition, it isequally important to make the necessary preparations by utilizing private non-life
insurance to cope with the frequent natural disasters and diversification of risks inrecent years. Considering the financial literacy of Tokyo residents which is appropriate
for "Global Financial City, Tokyo" from such a perspective, it is desirable to improvefinancial literacy across the board of financial products, including private insurance,
without focusing exclusively on asset building. The themes of the basic course on
asset building for Tokyo residents should be expanded to include non-life insurance
and other private insurance in the curriculum.
Consideration should be made to securing time for high school students to learn about
non-life insurance at least a few times during their high school life, for example, byusing it in civics and home economics classes at metropolitan high schools.

・Under this initiative, various efforts will be made to "improve the financial literacy ofTokyo residents" for each target.
・Brochures for teachers will be compiled that describe examples of lesson plans andteaching tips that can be used when conducting financial education in civics and home
economics classes at high schools.
・The "Financial Seminar for Tokyo Residents" will carried out during the "Tokyo
Sustainable Finance Week" with financial planners and other financial personnel as
instructors concerning the basics of finance and investment practices; and a basic
course on asset building for Tokyo residents will be offered at the Open University ofTokyo Metropolitan University.
・Concerning the development of human resources who will be responsible for the
next generation, we will collaborate with many universities and research institutes inTokyo to develop highly-skilled financial professionals.
・To develop an attractive business environment, we will assess the needs of relatedparties and make requests to the national government for necessary revisions to thetax system and regulations.
・We will use the comments we received for future reference.

Securing and nurturing human resources who will be responsible for the next
generation is also an important for Tokyo to grow as a global financial city. To this end,
the TMG, academia, the national government, and the financial community need towork together to strengthen financial and economic education, as well as to promote
the understanding of the aforementioned open innovation and attractive
startups/advanced technologies. In addition, it is necessary to consider thedevelopment of an environment that allows for business demonstration experimentsfrom various aspects, including deregulation. Such a broad and integrated approach
will be important in realizing the "Global Financial City: Tokyo" Vision.

20

Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Accumulation financial players】

Comments

TMG's Response

There is no doubt that "Accumulation of asset managers and otherdiverse financial players" is important. However, there is no mentionof players, such as advisors, other than asset managers in the
Direction of Measures. The accumulation of advisors who practicecustomer-oriented business such as "investment advisory andagency business" and other financial players who provide newservices should be clearly stated in the pillars of the measures, theDirection of Measures, and KPIs.

・For "Accumulation of asset managers and other diverse financial
players“ in this vision, we will also focus on peripheral industries
that are involved in the business development of asset managers,
etc.
・We will use the comments we received for future reference.

As "advisors" is omitted from the Direction of Measures, it should be
revised as follows:

Original: Establishment and growth support for asset managers
After the revision: Establishment and growth support for asset
managers, etc.
Concerning KPI items, it is suggested that the revision be made as
follows:

Original: Number of asset managers in Tokyo, Number of fintech
companies in Tokyo
After the revision: Number of asset managers in Tokyo, Number offinancial service providers in Tokyo

21

Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Accumulation financial players】
Comments

TMG's Response

To succeed as a financial center, it is important to provide referral andfacilitation programs and to sanction businesses that imitate other businesses
based on clear criteria (zero tolerance policy), while understanding that thevolume of business available is an incentive for foreign companies to expand
their business to Tokyo.

・This vision aims to create business opportunities for asset managers byholding seminars for the purpose of information exchange and businessmatching between domestic and overseas asset managers and institutional
investors, as well as by taking into account the perspective of fostering
emerging asset managers when recruiting managers for the funds in which
TMG will invest.
・In addition, with the aim of creating business opportunities for fintech
companies, TMG will support their overseas promotion and collaborate withindustry organizations, facilities accommodating startups, etc.
・We will use the comments we received for future reference.

There is still insufficient quantity of high-class hotels and other accommodation
facilities, serviced apartments, and hospitals that can provide medical service
for foreigners. It is requested that the TMG be actively involved in and support
the construction and operation of facilities that can offer services to a wide
range of foreigners.

・This vision aims to develop an attractive living environment by further
enhancing international schools in Tokyo, and promoting the development ofserviced apartments, medical facilities, etc. with multilingual support by utilizing
the National Strategic Special Zone System.
・Additionally, the Business Development Center TOKYO provides informationnecessary for foreign employees and their families to lead a comfortable life inTokyo.

Some people say that fear of earthquakes is also an obstacle to attracting
overseas human resources. Thus, further education, support and information
dissemination on BCP and DCP are extremely important measures.

・We will use the comments we received for future reference.

22

Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Accumulation financial players】
Comments

TMG's Response

In financial education at high schools, it is desirable to disseminate information
about the concentration of the financial industry in Tokyo through the TMG'smedia and other media.

・Under this vision, information on the attractiveness of the "Global Financial
City: Tokyo" will be disseminated by selecting the contents and media so thatthe necessary information can be delivered to the target audiences.
・We will use the comments we received for future reference.

・I agree that Tokyo's primary strength lies in its abundant personal financial
assets/cash and deposits. While the fund management needs of institutional
investors are deemed to be largely met mainly by major players that are alreadybased in Japan, there is still a lack of players that can fulfill the potential needsof those responsible for the management of personal financial assets.
・While existing major players are fully capable of managing publicly tradedassets such as listed stocks, there is a shortage of "funds intermediaries" inJapan who can connect domestic and foreign private assets to investors inJapan and abroad. In particular, sufficient investment opportunities have notbeen provided to Japanese retail investors.
・The global financial city: Tokyo can be developed through accumulating
financial players and creating synergies among them to connect Japan'sabundant personal financial assets, including green finance, with high-quality
privately held assets in Japan and abroad.

・With regard to asset managers and fintech companies, we will promote
initiatives for both attracting overseas companies and supporting their start-up
and growth in Japan.
・We will use the comments we received for future reference.

In the current vision, one of the pillars of the policy is the development ofbusiness and living environments; but in the draft for the revised vision, it has
been integrated into the development of players, giving the impression of being
easier to understand.

・We appreciate your comments in favor of the draft for the revised vision.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Accumulation financial players】

Comments

TMG's Response

Would like to request that the draft for the revised vision include
the followings: a clear statement of the philosophy of creating afiduciary marketplace where consumers and investors areprotected; incorporating consumer and investor protection as partof corporate cultures and policies in all processes from the designof the products and services offered to the post-sales process;clearer statement of the development of compliance humanresources, which is also stated in this draft; consideration of ideal
ways to educate consumers so that consumers who cannot keep
up with DX, etc. are not excluded from the marketplace, which isalso referred to in this draft; and inclusion of consumersorganizations, consumer centers, etc. to the organizations todeepen cooperation with.

・TMG, as part of the "development of highly-skilled financial
professionals," will study measures to develop legal andcompliance personnel in the financial sector; and promote theenhancement of financial literacy among Tokyo residents byholding financial seminars for them.
・In order to create an environment where Tokyo residents canmake investments without anxiety, we are promoting "efforts toensure customer-oriented business operations (fiduciary duty)"
inline with the "Global Financial City: Tokyo" vision formulated in
November 2017. This will also be clearly stated in the draft for therevised vision.
・We will use the comments we received for future reference.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Dissemination of information on each initiative (promotion)】
Comments

TMG's Response

Websites consolidating support information should be developed separately for"young people" and "the middle-aged and seniors." The attractiveness of Tokyo
as a global financial city should be highlighted by advocating the building of new
assets for young people and the continuous asset management for the middleaged and seniors.

・Under this vision, we will disseminate information on the attractiveness ofthe "Global Financial City: Tokyo" by selecting content and media so that thenecessary information can be delivered to the target audiences.
・We will use the comments we received for future reference.

I would like the TMG to provide incentives and motivations for companies todisseminate information to overseas markets.

・Concerning "Support for companies to disseminate information in English" aspart of this vision, we will work together with the FCT to provide support suchas advice on English information disclosure and translation of IR materials into
English for companies that have excellent technologies and products but havedifficulty in disseminating information in English.
・We will use the comments we received for future reference.

There are a variety of media that actively disseminate information on theattractiveness of Japan and Tokyo. These media can disseminate suchinformation to a very large number of people overseas by making these media
coping with multiple languages.

・This vision aims to encourage the activities to promote the attractiveness ofTokyo as a global financial city, both domestically and internationally, incooperation with FinCity.Tokyo, JETRO, etc.
・We will also communicate information on Tokyo's attractiveness andbusiness opportunities from the perspective of third parties, including experts
and celebrities active in the financial sector and the business communities offoreign residents in Japan.
・We will use the comments we received for future reference.

There seems to be a lack of information dissemination. It is necessary toconsider how to send out information to attract attention.
It is important to actively promote the efforts to revive Tokyo as a global financial
city both domestically and internationally, and to have intentions to create
dynamism widely understood. I strongly hope that the release of the vision thistime will have a great impact on various actors at home and abroad.

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Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【Structure to realize the “Global Financial City: Tokyo”

Vision】

Comments

TMG's Response

Tokyo is not being able to take advantage of features of Tokyo as a city that can becharacterized as a "hybrid-type" global financial city, which combines a "real economybacked-type" and "information/knowledge intensive-type" global financial cities. In addition,
the financial market entry by foreign companies and investors has not made progress. As
the reasons for these situations, there are a wide range of challenges, such as the issues
related to language, information disclosure, taxation, lack of market products, and Japanesepeople's literacy toward foreign companies. Under such circumstances, it is difficult torevive Tokyo as a global financial city only by the TMG, and it is necessary to create asystem, which is easy to understand for foreign companies and investors and facilitates
their entry into Tokyo, in collaboration with the Financial Services Agency and otherministries and agencies. I would like to ask the TMG to consider specific improvement
measures to solve theses issues and to further encourage the relevant authorities.

・We are aware that there are various issues to be addressed for the further accumulationof foreign financial companies and human resources, such as the improvement of thebusiness and living environments, including language and taxation issues.
・In order to solve these issues, TMG will work together with related parties such as thenational government, FinCity.Tokyo, private businesses including the financial industry,
universities and research institutes, and the City of London in the U.K.

Successful financial centers are working with the financial industry to actively support joint
proposals for human resource development programs aimed at linking them with universities
in their countries and selected world-class technical universities.

・For the "Nurturing of high-level financial professionals, etc." under this vision, we will
collaborate with a number of universities and research institutes in Tokyo to develop
highly-skilled financial professionals, data scientists as well as legal and complianceprofessionals related to finance to support them.
・We will use the comments we received for future reference.

It is very commendable that the positioning as the vision linked to the real economy is moreclearly emphasized. I strongly hope that this will be the starting point to link up with thepolicies of the national government, other local governments, and the TMG's industrial
policies, and provide an opportunity for all Japan to strengthen its competitiveness.

・TMG will work more closely with the FSA and other government agencies, FinCity.Tokyo,
the private sector including the financial industry, universities/research institutes, and theCity of London in the U.K. to implement the specific measures set forth in this vision.
・We will use the comments we received for future reference.

・It is worth considering collaborative measures to consult and discuss with major Japanesefinancial institutions on the possibility of increasing and expanding the number of products,
balances, and transaction volumes in the Tokyo market, and increasing the number of Asiancurrency-denominated securities transactions in the professional market and the TOKYO
PRO-BOND Market (professional bond market) of the TSE.

26

Results of Public Comment on the Revision (Draft) for the “Global Financial City: Tokyo” Vision【KPIs】

Comments

TMG's Response

・I suggest the adoption of and KPI to evaluate whether investment
amount by individual investors has been successfully increased
through education, etc.
・I suggest that the TMG set a KPI that measures "improvement in
the quality and impact of firms (at least new entrants)" rather than"the number of asset managers in Tokyo."・In this vision, target management using KPIs will be conducted toverify the degree of achievement and deepen the initiatives.
・The KPIs are set based on the items that help to understand theprogress toward the realization of the Ideal state of the “Global
Financial City: Tokyo" in the vision taking into accountmeasurability (quantitative, continuous, and low-costmeasurement), etc.
・We will use the comments we received for future reference.

I suggest setting KPIs for such indicators as "increase in revenue and
AUM of asset managers" and "number of new financial products
available to Japanese investors.

27

These translations are not official texts, since they are not officially translated and fixed, andare not the finalized versions. The original and official text is the Japanese version.
These translations are courtesy translations, and are to be used solely as reference materials
to aid in the understanding of Japanese version.
The Tokyo Metropolitan Government is not responsible for the accuracy, reliability of thesetranslations, and not responsible for any consequences resulting from use of these translations.

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