Analysis of Draft ESCerts Trading Regulations

OPEN ACCESS

February 2016

Volume - 59

Wind Facilitator of the Year & REC Facilitator of the Year 2015

From Management‘s Desk

The main article reviews draft regulations published by CERC. Its an impor-

tant part of the Perform, Achieve, and Trade (PAT) mechanism for Energy

Efficiency is the ‘trading’ aspect. PAT Cycle I was completed last year and

the next logical step in the process is the trading of Energy Saving Certifi-

cates (ESCerts). The actual ‘trading’ may soon become a reality as CERC re-

cently came out with draft regulations that will govern such trading on

power exchanges. The draft regulation describes the guidelines and the re-

sponsibilities assigned to the regulatory bodies in the issuance and ESCerts.

Other notable regulatory updates during the month were UERC’s determi-

nation of Levelised tariff for Rooftop and Small Solar PV Power Plant,

Analysis of Draft Regulations on Forecasting and Scheduling of Wind and

Solar Generating Stations – Rajasthan and NLDC’s proposal for bi-monthly

REC Trading Session. We have also included a brief analysis if the key

budget provisions relating to the renewable energy industry. All these are

discussed in detail in this volume of the newsletter.

RECs demand has shown significant improvement over last month trading

session. Non Solar REC’s and Solar REC’s traded this month were 70%

higher and 57% higher respectively, compared to trading session of January

2016 . On a YTD basis (April to February) this year, as compared to last year,

trading volumes are up 1.45 times for Non-solar and 2 times for solar

(excluding the multiplier effect). All eyes will now be on the March trading

session. As the last trading session of the compliance year, significant trad-

ing volumes are expected.

We hope you will find this volume an insightful read, and as always, look

forward to your feedback.

-Team Reconnect

CO

NT

EN

T

CERC (Terms & Conditions

for ESCERTS) Regulations,

2016

Regulatory Updates

REC Trade Results

REC Project Stats

Green News

RPO Table

About REConnect

CERC (Terms and Conditions for Exchange of ESCerts) Regulations, 2016

Perform Achieve &

Trade Scheme RPO Map Green News REC Project Stats REC Trade Report Regulatory Updates

www.reconnectenergy.com Page 1

38%

REC Market

Share

PAN

India

Presence

2.5 GW

Projects under

management

Managing REC

Projects in

16

States

Background

An important part of the Perform, Achieve, Trade

(PAT) mechanism for Energy Efficiency is the

‘trading’ aspect. PAT Cycle I was completed last year

and the next logical step in the process is the trad-

ing of Energy Saving Certificates (ESCerts). For a

detailed analysis of the PAT scheme, see our News-

letter Vol. 47 January 2015.

The actual ‘trading’ may soon become a reality as

CERC recently came out with draft regulations that

will govern such trading on power exchanges. A

brief analysis is below:

Draft Regulation:

The draft Regulations has proposed to assign the

responsibilities to BEE, CERC and POSOCO :

BEE: BEE shall discharge the role of Administrator of

ESCerts and shall provide assistance to the Com-

mission in the matters involving exchange of

ESCerts on Power Exchanges and shall coordinate

with the Power Exchanges and Registry for smooth

interface for Exchange of ESCerts

CERC : CERC would function as the Market Regulator.

In its role as Market Regulator, the draft Regulations

proposes to approve the procedure for interface activi-

ties between Power Exchanges and Registry, Adminis-

trator and Registry, and Registry and Designated Con-

sumer And monitor the operations and performance of

Power Exchanges with regard to exchange of ESCerts ;

POSOCO : During the introduction of Renewable En-

ergy Certificates ( RECs) , POSOCO was mandated to act

as the Registry. Ministry of Power has assigned the

function of Registry of ESCerts trading to POSOCO for

the exchange of ESCerts on the Power Exchanges . In

its capacity as the Registry for ESCerts, POSOCO is en-

visaged to discharge the following important functions :

:

Assistance in registration process of ESCerts includ-

ing crediting of ESCerts to DCs after approval from

MoP,

Guidance on dealing in the process of ESCerts trad-

ing/ exchange

Coordination and information dissemination with

DCs, Power Exchanges, BEE and Regulator (i.e. CERC)

¨

REC Trader

& Forecasting

Company of

the Year 2015

http://www.reconnectenergy.com/wp-content/uploads/2015/02/OPEN-ACCESS_Volume_47_Final.pdf

CERC (Terms and Conditions for Exchange of ESCerts) Regulations, 2016

Perform Achieve &



38%

REC Market

Share

PAN

India

Presence

2.5 GW

Projects under

management

Managing REC

Projects in

16

States

Issuance of ESCerts:

The DCs would be issued ESCerts in electronic

form in a cycle period for achieving specific en-

ergy consumption less than the energy con-

sumption norms and standards notified by the

Central Government for the cycle period, under

Energy Conservation Rules, and subsequent cy-

cles, who have held such certificates in Registry

accounts.

The DC’s whose specific energy consumption

shall be more than the prescribed energy con-

sumption norms and standards specified for a

cycle period and subsequent cycles and who

wish to comply with the prescribed energy con-

sumption norms and standards using ESCerts in

lieu of implementing energy conservation and

energy efficiency improvement measures shall

be entitled to purchase the ESCerts to meet

compliance with the norms and standards pre-

scribed under

The Certificate issued to eligible entities by the

Government on the recommendations of the

Bureau could be transacted on any of the Power Ex-

changes by the ESCerts holder.

Its important to note that BEE has proposed that

ESCerts have no floor or forbearance price. Pricing will

therefore be determined purely through demand and

supply of ESCerts.

Initial analysis suggests that there will be significant

oversupply of ESCerts, leading to low prices. However,

its important to note that companies have the choice to

‘bank’ ESCerts to the next cycle – this feature may have

the effect of a floor price as if the trading price is lower

than the cost of achieving energy savings, the company

will be better off banking the certificates rather than

trading them.

The regulation can be accessed here.

REC Trader

& Forecasting

Company of

the Year 2015

http://www.cercind.gov.in/2016/draft_reg/EM.pdf

Regulatory Updates

Perform Achieve &



38%

REC Market

Share

PAN

India

Presence

2.5 GW

Projects under

management

Managing REC

Projects in

16

States

Analysis of Draft Regulations on Forecasting and

Scheduling of Wind and Solar Generating Sta-

tions – Rajasthan

CERC had notified forecasting and scheduling (F&S)

regulation for inter-state sale of power a few

months back. Subsequently, the Forum of Regula-

tors (FoR) had come up with model regulations for

forecasting and scheduling at the intra-state level.

Rajasthan has published the draft forecasting and

scheduling regulations

in line with the FoR model Regulations. Rajasthan is

the fourth state to do so in recent days – MP, Kar-

nataka and Tamil Nadu are the others.

Executive Summary:

The regulations will be applicable on all wind

and solar generators with individual or com-

bined capacity of 5MW and above that are con-

nected to the state grid

Deviation will be calculated on the basis of avail-

able capacity

Settlement with the buyer will be on the basis of

actual generation

Qualifying Coordinating Agency (QCA) will play

a key role in the total process. QCA will be

responsible for forecasting, telemetry, scheduling and

settlement of deviation.

The draft regulations are in-line in every aspect with the

model F&S regulations released by FoR earlier. How-

ever, the model FoR regulations had proposed a 10%

deviation band for new projects and 15% for existing

projects. Rajasthan has proposed a 15% band for all

projects.

Detailed Analysis:

Forum of Regulators have recently come up with model

regulation for forecasting and scheduling and deviation

settlement mechanism. The primary objective is two

fold :

a) facilitate large-scale grid integration of solar and

wind generating stations, and b) maintaining grid sta-

bility and security.

Highlights of the regulation are below: -

All solar and wind generators connected to State

grid have to provide day-ahead and week-ahead

schedule - Revisions can be made on a one-and-half

hourly basis.

Payment for generation shall be as per actual gen-

eration (this is different from the inter-state

REC Trader

& Forecasting

Company of

the Year 2015

Regulatory Updates

Perform Achieve &



38%

REC Market

Share

PAN

India

Presence

2.5 GW

Projects under

management

Managing REC

Projects in

16

States

regulation, where payment is on the basis of sched-

uled generation).

The deviation slab has been kept as (+/-)15% for

all generators at Intra-state level.

Penalty is calculated at fixed amounts per unit

(whereas, for Intra-state it is calculated as a per-

centage to PPA rate) -

RPO accounting can continue as per existing ar-

rangement, and needs no change.

The SLDC will also conduct a forecast of its own

with the primary purposed of ‘secure grid op-

erations by planning for the requisite balancing

resources.

Applicability of Regulations

All wind and solar generators connected to the

State grid are covered:

Having capacity of 5MW and above individually

or in aggregate.

Regardless of date of commissioning,

Including those connected via pooling stations

Selling power within or outside the state. De-

tailed Mechanism defined for Deviation

Settlement calculation or Intra-state sale of power is as

follows:

Detailed Mechanism defined for Deviation Settle-

ment

Deviation calculation or Intra-state sale of power is as

follows:

*Available Capacity would ideally be the Installed Capacity, unless any of

the turbines are on outage. Similarly for solar panels.

In case of Intra-State transmission, Penalty Mechanism

for existing generators :

The Draft Order can be accessed here.

REC Trader

& Forecasting

Company of

the Year 2015

New Regulation 2015

Error (%) = 100 X (Scheduled Generation – Actual Generation)

Available Capacity*

http://rerc.rajasthan.gov.in/cnpl/PDFs/F&S%20Regulations.pdf

Regulatory Updates

Perform Achieve &



India’s largest REC Trading Company Clickpower.in: India’s first Green Energy Marketplace

NLDC Invites Comments for bi-monthly REC Trad-

ing Session

NLDC has invited comments and suggestions, on the

REC Procedure considering bi-monthly REC trading

sessions. The following modification has been pro-

posed for the “Procedure for Redemption of REC’s”:

All valid RECs excluding the RECs applied for Self-

retention shall be traded on the second and last

Wednesday of every month.

The eligible entity shall exclude the RECs applied

for self-retention in the particular month, if appli-

cable, for dealing on Power Exchange.

It’s a much needed step by NLDC as it enhances the

platform for a better market price discovery. This

change would be beneficial for the generators and to

the obligated entities, since if the RECs are not traded

in the current month, they would not have to wait for

an entire month.

Also it would promote the developers to meet their

RPO as we have seen many regulatory actions coming

up in the form of compliance orders and proceedings

in several states like Orissa, Kerala, MP and Maharash-

tra recently. We also feel that it could be intensified if

quarterly or at least half yearly compliance of RPO is

made compulsory . This would push the obligated en-

tities more to gear up and fulfill their obligation and

thus benefit the REC market.

The article can be accessed here.

Key provision for Renewable Energy industry in

the Union Budget 2016

The Union Budget 2016 was a mixed bag for the RE

industry. The key provisions that will impact the in-

dustry are:

Reduction in accelerated depreciation (AD) on RE

investment – the rate of AD will be reduced from

80% to 40% from April 1, 2017. AD has been his-

torically an important driver of investment in the

RE sector. However, off-late IPPs (who generally

do not use AD benefits) have become the key

driver of investment in the sector. Nevertheless,

this change will reduce demand for RE invest-

ment. FY 2016-17 is likely to see a spurt in invest-

ment under AD as investors rush to complete

projects before the lower rate becomes effective.

Increase in coal cess – Coal cess has been dou-

bled from Rs 200/ ton to Rs 400/ ton. The pro-

ceeds from this cess fund the National Clean En-

ergy Fund (NCEF). NCEF is used for a variety of

reasons like Ganga Rejuvenation, proposed pay-

ments to states for deviation resulting from wind

and solar, and is often not used at all (absorbed

by the government to meet fiscal deficit targets).

Allocation of funds to MNRE has increased from

http://clickpower.in/

http://www.business-standard.com/article/news-ians/gurgaon-hq-of-new-international-solar-alliance-roundup-116012501133_1.html

Regulatory Updates

Perform Achieve &



38%

REC Market

Share

PAN

India

Presence

2.5 GW

Projects under

management

Managing REC

Projects in

16

States

Rs 262 crore in FY 15-16 to over 5,000 crore in FY

16-17. These will potentially kick-start large pro-

jects.

* 1Article titled “Govt uses green energy fund for fiscal

balancing”, dated April 21, 2015, Mint newspaper .

The article can be accessed here.

UERC determines Levelised tariff for Rooftop

and Small Solar PV Power Plant

Uttarakhand Renewable Energy Development

Agency, had filed a petition seeking determination

of Levelised tariff for Rooftop and Small Solar PV

Power Plant as per the revised subsidy scheme noti-

fied by MNRE. While fixing the tariff for FY 2015-16

in respect of Rooftop and Small Solar PV Power

Plants, the Commission had considered applicable

level of subsidy of 30% in accordance with the RE

Regulations, 2013. Later MNRE vide its notification

dated 03.08.2015 reduced the subsidy level for such

plants to 15% suspending the earlier notification.

Finally MNRE revised the level of subsidy for these

plants based on category of project developers as

given in the table below.

Developers getting 60% subsidy from GoU over and above 30% subsidy

from MNRE

Considering the benchmark capital cost for FY 2015-16

the Commission has determined the applicable tariffs

corresponding to level of subsidy for Grid-Connected

Rooftop and Small Solar PV Power Plants given in the

graph :

The order can be accessed here.

REC Trader

& Forecasting

Company of

the Year 2015

Sr. No. Category of de-

veloper

Earlier

Subsidy

Revised Sub-

sidy

1 Private Sector No Subsidy No Subsidy

2 Public Sector 70% 70%

3 Developers 30% 90%*

http://cleantechnica.com/2016/02/22/indian-ministry-renewable-energy-seeks-1-5-billion-budget-allocation/

http://www.uerc.gov.in/orderspetitions/orders/Misc/2016/feb16/Order%20dt.%2011.02.2016%20on%20determination%20of%20levelised%20tariff.pdf

Clickpower.in Market Update

Perform Achieve &


India’s largest REC Trading Company

Telangana Sell: 25 MW

Buy: 32.6 MW

Price: Rs. 5.85/Unit*

Sell: 62.6 MW

Buy: 135.81 MW


Sell: 92.91MW

Buy: 293.19 MW


Sell: 8 MW

Buy: 3.994 MW

Price: Rs. 6/Unit*

Sell: 198.2 MW

Buy: 207.773 MW

Price: Rs. 6/Unit*

* Lowest Price as on 02.10.2015

AP Sell: 17 MW

Buy: 28.95 MW

Price: Rs. 6/Unit*

Clickpower.in: India’s first Green Energy Marketplace

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is now open for Consumers and Generators to register and ex-

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volumes and price shown below for respective states. Feel free

to register till the offer of free registration is open. Explore and

discover the best deals of power online.

Call: +91 8088732732 for more details and assistance.


Clickpower,in In News: Bangalore Mirror


http://www.bangaloremirror.com/bangalore/others/Industries-bulk-consumers-can-directly-buy-power-online/articleshow/49120934.cms?

REC Trade Report - January 2016

Perform Achieve &

Trade Scheme RPO Map Green News REC Project Stats REC Trade Report

Regulatory

Updates



Non Solar RECs

Clearing ratio in exchange stood

at 3.89% and 4.75% in IEX and PXIL respectively for Non Solar REC’s. A total of 586,501 were traded as

compared to 344,519 RECs traded in January, but much lower than the volume cleared in December trad-

ing session.

For past trading history - CLICK HERE


For more details please visit our blog-post here.

8.31%

2.16%

3.89%2.22%

3.12%

4.75%

0.00%

1.00%

2.00%

3.00%

4.00%

5.00%

6.00%

7.00%

8.00%

9.00%

Dec-15 Jan-16 Feb-16

IEX

PXIL

Non Solar Clearing %

1382922613699278 13869254

392095 551202 392095898439344519 586501

0

2000000

4000000

6000000

8000000

10000000

12000000

14000000

16000000


Available

Issued

Redeemed

Non Solar RECs

http://www.reconnectenergy.com/letest-rec-trade-results/

http://reconnectenergy.com/blog/tag/iex/


http://reconnectenergy.com/blog/2016/01/rec-trade-results-january-2016/

REC Trade Report - January 2016

Perform Achieve &

Trade Scheme RPO Map Green News REC Project Stats REC Trade Report

Regulatory

Updates



Solar RECs

Clearing ratio stood good at 2.14% and 3.58% in

IEX and PXIL respectively, with total clearing volume of 90,236, as compared to 57,420 last month. The in-

crease is significant, with much better performance expected next month.

Trading volumes are expected to increase signifi-

cantly during March trading session, as most obli-

gated entities will want to fulfill their obligation for

the FY. This trading session results are encouraging,

considering last month performances, riding on

higher demand on both exchanges. However, com-

pared to the trading session of February 2015, where

Non-Solar and Solar clearing volume stood at

747,487 & 44,869 respectively, the performance of

Non-Solar RECs was below par whereas Solar RECs

demand more than doubled.


For past trading history - CLICK HERE

For more details please visit our blog-post here.

2864021 29900863160474

190530 227808 190530

13851 57420 616020

500000

1000000

1500000

2000000

2500000

3000000

3500000


Available

Issued

Redeemed

Solar RECs

2.62%

1.65%

2.14%

0.38%

2.34%

3.58%

0.00%

0.50%

1.00%

1.50%

2.00%

2.50%

3.00%

3.50%

4.00%


IEX

PXIL

Solar Clearing %

0

500000

1000000

1500000

2000000

2500000

3000000

3500000

FY 14-15(April to February)

FY 15-16(April to February)

NS REC TRADED

S REC TRADED

42.30%

424.91%

Includes impacts of

vintage multiplier


http://www.reconnectenergy.com/letest-rec-trade-results/

http://reconnectenergy.com/blog/tag/iex/

http://reconnectenergy.com/blog/2016/02/rec-trade-result-february-2016/

REC Project Status - As on 30th November, 2015

Perform Achieve &



Registered Capacity

4719 MW


Projects Registered

Source wise

All figures

in MW

I

Biomass

700

Solar PV

588

Wind

2213 Bio-fuel

Cogeneration

920


Small Hydro

291

Projects Registered State wise (MW)

2 26

11743 73

370

738

84 83

350

203

1,035

155

18

137

23

1,165

33 35 24 50

200

400

600

800

1000

1200

1400

Reg. Capacity (MW)


Green News - National & International

Perform Achieve &




Gamesa secures first orders for the G114-2.0 MW in India: it will install 184 MW at two wind farms

According to UNEP's 9th "Global Trends in Renewable Energy Investment 2015", the past year brought a rebound

of green energy investments worldwide with a surge of a solid 17% to $270 Billion. Brushing aside the challenge of

sharply lower crude oil prices this sudden increase reversed the investment dip of the past two years and was mainly

driven by investments in solar and wind energy.

Source : GLOBAL RENEWABLE NEWS

Government to unveil policy to promote manufacturing in solar energy

Four major railway stations in Southern Railway, including Chennai Central and Egmore, are set to glow with green

power by the end of 2016. This initiative is part of the Indian Railways Solar Mission to reduce dependence on fossil

fuels. Out of the target of 50 MW, 4 MW has been allotted to Southern Railway. Tenders will soon be awarded for

the installation of rooftop solar power plants at Chennai Central, Chennai Egmore, Moore Market Complex, Tiruchi

and Salem railway stations and buildings at an estimated cost of Rs. 32 crores.

Source : THE HINDU

Read More


Read More

States

2015-16 RPO

Obligation

(Non Solar)

2015-16 RPO Obli-

gation ( Solar)

Andhra Pradesh 4.75 % 0.25 %

Assam 6.75 % 0.25 %

Arunachal Pradesh 6.80 % 0.20 %

Bihar 3.25 % 1.25 %

Chhattisgarh 6.25 % 1.0 %

Delhi 7.30 % 0.30 %

Gujarat 7.5 % 1.5 %

Haryana 3.12 % 0.38%

Himachal Pradesh 11.00 % 0.25 %

J&K 6.0 % 1.50 % Jharkhand 3.00 % 1.00 %

Karnataka 10.00 % * 0.25 % *

Kerala 4.58% 0.25%

Madhya Pradesh 6.00 % 1.00 %

Maharashtra 8.50 % 0.50 %

Meghalaya 1.09 % 0.41 %

Odisha 6.70 % 0.30 %

Punjab 3.9% 1.0%

Rajasthan 8.20 % 2.0 %

Tamil Nadu 10.00 % 1.0%

Tripura 9.90 % 1.10%

Uttarakhand 8.00 % 0.10 %

Uttar Pradesh 5.00 % 1.00 %

West Bengal 4.80 % 0.20 %

Goa & UTs 2.70 % 0.85 %

Manipur 4.75 % 0.25 %

Mizoram 14.75 % 0.25 %

Nagaland 7.75 % 0.25 %

* BESCOM,MESCOM, CESC - 10 % + 0.25%,

HESCOM, GESCOM, Hukkeri Society - 7 % + 0.25%.

Status of Regulation - Final for all states except -

Draft for Haryana and Telangana, Tripura & TN

( Draft Amendments of targets )

RPO on OA Users? - Yes for all states except West

Bengal.

Karnataka (5.00% RPO) - Yes (> 5MW).

RPO on CPP? - Yes for all states except West Ben-

gal.

Gujarat, Odisha, Haryana, Bihar, Jharkhand, Tripura,

Karnataka (5.00% RPO) - Yes (> 5MW).

RPO Penalty? - Yes (RECmax) for all the states.

West Bengal - Not Specified.

India’s RPO Table

http://www.livemint.com/Politics/niGJMpfxM3rsVAMj09BbLJ/India-plans-to-award-15000-MW-of-solar-projects-this-year.html

http://www.globalrenewablenews.com/detail_news.php?ID=565622&titre=Gamesa+secures+first+orders+for+the+G114-2.0+MW+in+India%3A+it+will+install+184+MW+at+two+wind+farms+&cat=88


http://www.thehindu.com/todays-paper/tp-national/tp-tamilnadu/green-power-to-light-up-4-major-railway-stations/article8282808.ece

http://www.livemint.com/Industry/IbKFsrcL2yahh1C98oRZAJ/Govt-to-unveil-policy-to-promote-manufacturing-in-solar-ener.html

About REConnect

Perform Achieve &



REConnect Energy is India’s leading renewable energy trading company. We provide end-to-end services

for projects in the Renewable Energy Certificate mechanism – from contract structuring, advisory to mone-

tization of RECs. We also work with power consumers to manage Renewable Purchase Obligation (RPO)

liabilities, and develop and execute their energy sourcing strategy. We are a knowledge focused company

that prides itself in providing premium services to our clients backed by in-depth research and analysis.

Our other prime area of focus is, facilitating Private PPAs (OTC) by bringing RE Generators and HT Con-

sumers onto a single platform called Clickpower.in, which we have developed specifically for this pur-

pose. It is India’s First Green Energy Marketplace.

REConnect is run by an experienced and professional team. The team consists of members with relevant

experience of working at IEX, L&T, JP Morgan, Arthur Andersen and Gensol. Key members of the team are

alumnus of IIT Bombay, Columbia University (an Ivy League university) and IIT Kharagpur.

For more details of services provided and profile of the management team, please visit our website.

India’s largest REC Trading Company Clickpower.in: India’s first Green Energy Marketplace

Contact Details

Bangalore:

Vishal Pandya

[email protected]

No. 2, Victor Mansion , 2nd floor, Kodi-

halli, Old Airport Road, HAL 2nd Stage

(PO), Bangalore—560008

O : 080 - 6547 3383 / 84

F : 080 - 30723571

New Delhi:

Vibhav Nuwal

[email protected]

C– 503, 5th Floor, Nirvana courtyard,

Nirvana Country, Sector 50,

Gurgaon 122018.

O : 0124 - 4103216

F : 080 - 30723571

Chennai:

Venkat Mutharasu (+919940177993)

[email protected]

# 18/1 (88), 2nd Floor, Aarya Gowda

Road, West Mambalam,

Chennai - 600 033.

Hyderabad:

Divya (+91 9441944866)

[email protected]

Solar Market:

Vibhav Nuwal

[email protected]

Mumbai:

Ram Kumar ( +919930359992 )

[email protected]

1013, 10th Floor,

Micro (Haware) Infotech Park,

Plot no. 16, Sector-30A, Vashi,

Navi Mumbai- 400705,

Maharashtra, India.

Renewable Purchase Obligation (RPO):

Chetan Singh Adhikari ( +91 9910772666)

[email protected]

Forecasting and Scheduling (F&S)

Siddhartha P. (+91 9916994349)

[email protected]

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Disclaimer:

All the information presented in this newsletter is from publicly available sources. REConnect does not warrant the accuracy and completeness of information available and therefore will not be liable for any loss incurred. The content provided here is for the general informational purposes only. REConnect shall not be responsible for damages resulting from the use of any information in this newsletter. Readers are advised to make appropriate analysis and take appropriate advise before acting on the contents of this newsletter.

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Analysis of Draft ESCerts Trading Regulations

Documents

Transcript of Analysis of Draft ESCerts Trading Regulations