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A FINE LINE FOR THE FED - BNY Mellon
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A FINE
LINE FOR
THE FED
BY JOHN VELIS
BY THE
NUMBERS
2%
The Fed’s target inflation rate over the medium term*

2.2%
The Fed’s projection of inflation in both 2022
and 2023, as of September 2021*

4
Seats on the Board of Governors for which President
Biden will need to nominate candidates*

4.3%
Current inflation based on Personal Consumption
Expenditure**

5.2%
Unemployment rate as of September 2021, well above
the pre-pandemic low of 3.5% ***

4.7%
Consumer expectations of inflation in one year,
according the University of Michigan Survey of
Consumer Confidence

58.5%
Current percentage of persons in the U.S. employed,
well below recent historical norms**

$120 BILLION
Current rate of monthly asset purchases by the Fed
as part of its quantitative easing program*

SOURCES:
*Federal Reserve Board of Governors
**Bureau of Economic Analysis
***Bureau of Labor Statistics
THE U.S. FEDERAL RESERVE FINDS ITSELF
IN A DIFFICULT POSITION ON MULTIPLE
FRONTS, FROM RISING INFLATION AND WEAK
EMPLOYMENT GROWTH TO UNCERTAINTY
OVER ITS LEADERSHIP, ETHICS CONCERNS
AND BANK SUPERVISION QUESTIONS.

BY JOHN VELIS

             he U.S. Federal Reserve’s      policy of large-scale asset purchases that     In the background, inflation is

T            job in steering the
             economy and the health
             of the financial system
is often fraught with unforeseen chal-
lenges. But as we approach the second
                                            it is only now signaling the intention to
                                            wind down. As we write, policy deci-
                                            sion makers at its Federal Open Market
                                            Committee are discussing whether to
                                            initiate that taper as soon as November
                                                                                         creeping up to levels that have not been
                                                                                         seen since mid-2008, when core mea-
                                                                                         sures of inflation rose in a short-lived
                                                                                         burst. The Fed and many others have
                                                                                         argued that current inflation levels are,
year of the pandemic, it faces an unusu-    this year.                                   in the central bank’s language, “transi-
ally complicated set of issues even by        At the same time, on the macro-            tory” and likely to fade on their own.
central bank standards, without the         economic front, the U.S. economy is          We are more of the view that, after
bipartisan political support it needs       emerging from a deep recession that          decades of low and stable inflation, the
to address them.                            started with the COVID-19 pandemic.          pandemic and its aftermath have cre-
  The traditional remit of the Fed is to    The job market is healing slowly and         ated the conditions for a sustained bout
run monetary policy in a manner such        remains well short of the levels of          of inflation above the Fed’s target of 2%,
that the economy achieves low and           employment seen before COVID hit. Fed        which could last longer than the central
stable prices with maximum growth           Chair Jerome “Jay” Powell wants more         bank is bargaining for.
and employment. While the Fed has           than a job market at pre-pandemic levels;      The combination of inflationary pres-
wound down a series of special credit       he has stated that he wants to see broad-    sures picking up, and a labor market still
and liquidity facilities it used to quell   based gains across demographic groups,       well below its pre-pandemic norms,
market disturbance in early 2020, it has    particularly those which have suffered       could prompt the Fed to tighten mon-
kept in place an ultra-loose monetary       disproportionately from the pandemic.        etary policy to keep prices in check.
“Even Powell himself is beginning
  to acknowledge the stubbornness
  of supply-side inflation…and the
  labor market is not fully healed.”

How long can the Fed tolerate higher-       but it often comes at the price of a       bottlenecks would eventually clear up,
than-target inflation, with the economy     slower economy and weak employ-            the “base effects” from the post-lock-
below full employment?                      ment growth. Conversely, a central         down reopening would fade, and infla-
  The tradeoff between inflation and        bank might be tempted to run a looser      tion would return to sustainably low
under-employment takes place while          monetary policy with the objective of      levels in a matter of time.
the Fed comes under increasing scrutiny     allowing economic growth to run hotter       Nevertheless, as the current episode
on other fronts. A number of Federal        and create more jobs, while risking        of strong inflation now stretches out
Reserve Board of Governor seats are up      higher inflation.                          longer and longer, (core inflation as
for nomination and confirmation by the        Currently, U.S. inflation is run-        measured by the Consumer Price Index
Senate; congressional members have          ning well above the Fed’s stated goal      (CPI) has been over 4% every month
criticized the Fed’s record on a number     of 2% per year. The most recent data       since April), the Fed has acknowledged
of issues ranging from financial system     indicated that personal consumption        that these supply chain bottlenecks are
regulation to global warming and ethics     expenses – through August – are 4.2%       persisting longer than it had initially
concerns involving senior Fed officials.    higher than they were a year ago. We       expected, and that inflation may stay
  Chair Powell is having to navigate        know that households have also regis-      higher for longer than anticipated.
these pressures while at the same time      tered a dramatic increase in their per-      Even Powell himself is beginning
striving to achieve an appropriate mon-     ceptions of inflation over the next 12     to acknowledge the stubbornness of
etary policy setting for the unprece-       months. For example, the University of     supply-side inflation, saying recently
dented economic conditions present          Michigan Consumer Sentiment Survey         during a central banking forum: “It's
in a post-COVID world.                      of inflation one year from now is cur-     …frustrating to see the bottlenecks
                                            rently 4.7%, its highest reading since     and supply chain problems not getting
NO PLAYBOOK                                 a brief period in mid-2008 (when oil       better, in fact at the margin apparently
Since 1913, the Fed’s number one job        prices were at a record high). Before      getting a little bit worse.”
is to conduct monetary policy uti-          that, one must look back to the early        T h e F e d ’s o w n S u m m a r y o f
lizing a limited set of tools to optimize   1980s – the end of the postwar, high-in-   Economic Projections, most recently
the tradeoff between low inflation          flation era in the U.S. – to find such     updated in late September, see infla-
and full employment.                        pricing data.                              tion ending this year at 4.2%, and
  Keeping money supply tight is often         Chair Powell and the Fed do not seem     2.2% in both 2022 and 2023. These
the policy prescription for getting         too spooked by this. They have contin-     levels would be above the Fed’s stated
and keeping inflation under control,        uously declared that these supply-side     goal of 2% inflation. However, under
LABOR PAINS
                                      Employment dropped precipitously during the onset of the COVID-19 pandemic
                                             1997    Total: 1,060
                                      66%

                                      64%
U.S. Employment to Population Ratio

                                      62%

                                      60%

                                      58%

                                      56%

                                      54%

                                      52%

                                      50%

                                                                                                                                                                                  21
                                                                                                                                           07

                                                                                                                                                09

                                                                                                                                                      11

                                                                                                                                                            13

                                                                                                                                                                       17

                                                                                                                                                                             19
                                        71

                                              73

                                                    75

                                                          77

                                                                    81

                                                                         83

                                                                              85

                                                                                   87

                                                                                                                                                                 15
                                                               79

                                                                                         89

                                                                                               91

                                                                                                    93

                                                                                                         95

                                                                                                                    99

                                                                                                                         01

                                                                                                                              03

                                                                                                                                     05
                                                                                                               97

                                                                                                                                                                                  20
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                                                                                                                                                20

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                                                                                                              19

                                                                                                                                          SOURCE: U.S. BUREAU OF LABOR STATISTICS

                                      FIGURE 1

                                      the Fed’s new policy framework of                   Normally, the Fed’s response would be           pre-pandemic. The economy is indeed
                                      “average inflation targeting,” the cen-           to raise interest rates, tightening mon-          reopening and of the more than 22 mil-
                                      tral bank will allow inflation to run             etary policy and slowing the economy              lion jobs lost in the immediate aftermath
                                      above 2% for some time to help offset             to get inflation under control. However,          of the great lockdown, 17 million have
                                      those earlier periods we have wit-                that model relies on the idea that excess         been regained. Yet that still leaves the
                                      nessed during which inflation had been            demand is causing inflation – more                economy 5 million jobs shy of where it
                                      under its target.                                 goods and services being consumed                 had been. The unemployment rate, at
                                        At BNY Mellon, we have been arguing             than the economy can produce when                 5.2%, remains well above the pre-pan-
                                      for quite a while that inflation was going        it is at full employment of its resources,        demic low of 3.5%.
                                      to be higher and longer lasting than              labor force, and technological capabil-              Furthermore, the employment-
                                      the Fed’s sanguine view had asserted.             ities. As we have described above, cur-           to-population ratio, a measure of how
                                      COVID-19 represents a global shock                rent inflation is primarily supply-side           many people in the country are working,
                                      impacting everything from shipping                driven. What the recipe is to rein in             is at 58.5% (see Figure 1), a level last seen
                                      and materials prices to the availability          price increases in such an environment,           in the aftermath of the Global Financial
                                      of semiconductors and natural gas.                is still up for debate, but it certainly          Crisis and before that, in the early 1980s.
                                      In addition, multi-decade-long forces             doesn’t include the loose monetary                Not coincidentally, the latter period
                                      of global disinflation, including the             policy setting on which the economy is            corresponded to a recession engi-
                                      internationalization of production and            currently running.                                neered at the end the 1970s, when the
                                      supply chains, off-shore manufacturing,             On the other side is, of course, the            Fed raised interest rates to extraor-
                                      and just-in-time logistics, are beginning         labor market. Total employment in the             dinarily high levels to combat high
                                      to retreat.                                       economy remains far below levels seen             and persistent inflation. By 1982,
PURSE STRINGS
                               Median household income was rising steadily, until the pandemic

                               66,000

                               64,000

                               62,000
Real Median Household Income

                               60,000

                               55,000

                               50,000

                               45,000

                               40,000
                                    68

                                         70

                                              72

                                                   74

                                                             78

                                                                  80

                                                                       82

                                                                            84
                                                        76

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                                                                                                     94

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                                                                                                                                               SOURCE: U.S. CENSUS BUREAU

                               FIGURE 2

                               unemployment had reached 10.7%.                   inflation now comes as America is only            “A DANGEROUS MAN”
                                 Powell has placed a great deal of               slowly getting back to work.                      In addition to the economic tradeoffs
                               importance not just on getting the                  This is the essence of the Fed’s policy         between inflation and employment,
                               labor market back to full employment,             dilemma: Inflation is above its target            the Fed is navigating politically fraught
                               which he says is “a long way off,” but            and the labor market is not fully healed          waters. How to craft policy to address
                               also making sure that future employment           (see Figure 3). Powell himself recently           the inflation-employment tradeoff, with
                               gains are well distributed across demo-           bemoaned this situation: “This is not the         the composition of the Fed’s leadership
                               graphic, gender, and income groups.               situation that we have faced for a very           likely to change, both on the Board of
                               This requires keeping monetary policy             long time and it is one in which there is         Governors as well as the wider Federal
                               loose, possibly at the expense of higher          a tension between our two objectives.”            Open Market Committee (FOMC), is an
                               inflation. The pandemic has disrupted               Congress, the Fed’s overseer, is now            open question.
                               the labor market and it may take years            involving itself in the policy debate. For          Powell’s term as chair expires on
                               to match unemployed workers with jobs.            example, Senator Joe Manchin (D-WV)               February 5, 2022. His renomination by
                               We wrote about this “reallocation shock”          has circulated a memo in which he                 President Biden and confirmation by
                               during the pandemic.                              requires the Fed to “end quantitative             the Senate is not a foregone conclusion.
                                 Long-running economic forces have               easing” as one of the conditions for him          And the terms of two other key mem-
                               kept a lid on real earnings for decades           to vote for President Biden’s “soft infra-        bers of the Board of Governors are set
                               now. Only around five years ago did               structure” package. This is a challenge           to expire. Vice Chair Richard Clarida’s
                               median real household income in the               to the Fed’s statutory independence in            term expires in September of next year,
                               U.S. begin to rise (see Figure 2). Higher         conducting monetary policy.                       while Vice Chair for Supervision Randy
“Dramatic changes in personnel at the top
  of the central bank—as well as among the
  Board of Governors—could upset markets,
  especially if continuity in monetary policy
  looks likely to be threatened.”

Quarles’s term expires this year on          portfolio includes supervision) as too      – despite key progressive opposition
October 13. In addition, there is a still-   lax in its approach and overly solici-      like Warren’s – is another attraction.
vacant governor’s position that needs        tous of large banks’ preferences, par-      Bloomberg has reported that Treasury
to be filled.                                ticularly in relation to crafting stress    Secretary Janet Yellen, the Fed Chair
  This is a high degree of potential turn-   tests, supervising and implementing         preceding Powell, is supportive of his
over and an opportunity for President        capital requirements, and supervising       renomination. Does Biden heed the
Biden to reshape the Board’s makeup.         commercial lending.                         powerful Senator Warren, or his top
The politics of nominating and con-            If Biden were to renominate Powell,       economic policymaker Yellen?
firming each of these positions are          he would likely have bipartisan support       Other potential nominees who
daunting, and in the current environ-        for confirmation on both sides of the       could wind up being nominated if
ment, quite delicate.                        aisle in the Senate, although several key   Powell were not to go forward include
  Key members of Congress and others         senators are thought likely to oppose       current Governor Lael Brainard, the
have pushed for more gender and racial       him. In particular, at a recent hearing     only Democrat on the Board. She was
diversity, both on the Board itself and      of the Senate Banking Committee,            considered by Biden for the Treasury
within the broader Federal Reserve           Senator Elizabeth Warren (D-MA),            Secretary role, which ultimately
System, including the leadership of          called him a “dangerous man” and            went to Yellen. She has served on
the regional Federal Reserve banks.          declared her opposition to a potential      the Board since 2014, was nominated
Furthermore, five of the six current gov-    second Powell term. Committee Chair         by Obama, and previously worked
ernors are registered Republicans, four      Sherrod Brown (D-OH) has not made his       in key posts in the executive branch
of whom were appointed by former             views on a Powell renomination known,       under Obama (Under Secretary for
President Donald Trump. Powell, a            nor used such incendiary language, but      International Affairs), as well as under
Republican, was first appointed to           has explicitly voiced his objection to      President Clinton in various advisory
the Board in 2012 by then-President          Quarles, going as far as to say that “he    roles in the White House. A potential
Barack Obama and elevated to Chair           should not be there after October.”         Brainard nomination could be a very
in 2017 by Trump.                              By many accounts, it is thought that      close vote in the full Senate, with most
  In addition to the diversity issue,        President Biden would like to renomi-       Republicans likely to oppose.
banking supervision is a major source        nate Powell, striving for continuity in       Raphael Bostic, the current pres-
of concern. Progressives in Congress         such a key economic policy position at      ident of the Atlanta Fed, is another
regard the current Fed, and in par-          a delicate point in the economic cycle.     potential nominee to the Board. He is
ticular Vice Chair Quarles (whose            Powell’s broad bipartisan support           widely respected for his leadership of
COST CENTER
                                Prices are creeping higher, but we are not reaching an inflation scare

                                16%

                                14%
                                                                                                                                   Consumer Price Index
Inflation, year over year (%)

                                12%
                                                                                                                                   Personal Consumption Expenditure

                                10%

                                8%

                                6%

                                4%

                                2%

                                0%

                                -2%

                                                                                                                                            07

                                                                                                                                                 09

                                                                                                                                                      11

                                                                                                                                                           13

                                                                                                                                                                     17

                                                                                                                                                                          19

                                                                                                                                                                               21
                                      71

                                           73

                                                75

                                                     77

                                                               81

                                                                    83

                                                                         85

                                                                              87

                                                                                                                                                                15
                                                          79

                                                                                     89

                                                                                          91

                                                                                                 93

                                                                                                       95

                                                                                                                   99

                                                                                                                         01

                                                                                                                               03

                                                                                                                                      05
                                                                                                             97

                                                                                                                                           20

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                                                                         19

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                                                                                          19

                                                                                               19

                                                                                                      19

                                                                                                                  19

                                                                                                                        20

                                                                                                                              20

                                                                                                                                      20
                                                                                                            19

                                                                                                              SOURCES: U.S. BUREAU OF LABOR STATISTICS, U.S. CENSUS BUREAU

                                FIGURE 3

                                the regional Fed bank and his views                personal securities transactions they                   A DELICATE TENSION
                                on monetary policy are well-regarded               made during the pandemic, which                         With the Fed caught in a monetary
                                among mainstream economists. He                    although compliant with ethics rules                    policy dilemma, as well as confronting
                                is also the only African American and              in each bank, have come to be seen                      wide-ranging leadership changes –
                                openly gay member of the Federal Open              as black marks on the Federal Reserve                   even if Powell gets renominated and
                                Market Committee. Another potential                System’s public standing.                               confirmed - markets will have a lot to
                                pick if Biden were to go in another                  R e g i o n a l Fe d p r e s i d e n t s a r e        contemplate. For example, the presi-
                                direction would be Roger Ferguson,                 appointed by the Board of Directors of                  dent of the Boston Fed, whenever the
                                a former vice chair of the Fed, who is             each bank, subject to the approval of the               person is placed in that position, will
                                most recently on the Board of Directors            Board of Governors in Washington, D.C.                  be replacing a fairly hawkish member
                                of Alphabet, the parent company                    There is no presidential or congressional               in Rosengren.
                                of Google.                                         involvement in the appointments, but                      The FOMC rotates voting members
                                     In addition to the Chair and three            with the scrutiny that Rosengren and                    every year among the regional Fed
                                other Board of Governors’ positions                Kaplan have come under, as well as the                  presidents, and Boston becomes a
                                (see Figure 4), two vacancies in the               Fed's recent congressional and public                   voting bank in 2022. Will the new pres-
                                regional Fed banks have suddenly                   perception issues, these appointments                   ident stay true to Rosengren’s hawkish
                                become open. Eric Rosengren (former                will be equally delicate – key members                  leanings or bring a much more dovish
                                president of the Boston Fed) and Robert            of C ongress have extolled the                          perspective to the committee? If Powell
                                Kaplan (former president of the Dallas             need for diverse leadership at the                      is replaced by Brainard, we think the
                                Fed) have come under criticism for                 regional Feds as well.                                  FOMC could take an overall dovish
FOLLOW THE LEADER
 The current makeup of the Fed's board of governors has several officials’ terms
 expiring around the same time

                         RANDY QUARLES                       JEROME POWELL                      RICHARD CLARIDA
                         Vice-Chair for Supervision          Chair                              Vice-Chair

                         OCTOBER 13, 2021 *                 FEBRUARY 5, 2022 *                  SEPTEMBER 17, 2022 *

        JANUARY 31, 2024                    JANUARY 31, 2026                    JANUARY 31, 2030                  JANUARY 31, 2034

                                                                                CHRISTOPHER                        MICHELLE
        VACANT                              LAEL BRAINARD                       WALLER                             BOWMAN
        Governor                            Governor                            Governor                           Governor

FIGURE 4                                                                    *Clarida's term as Governor ends on January 31, 2022
                                                                                Powell's term as Governor ends on January 31, 2028
                                                                                Quarles's term as Governor ends on January 31, 2032

turn, meaning it could be less inclined        congressional scrutiny to not run              upset markets, especially if continuity
to tighten monetary policy in favor            afoul of its overseers. Independence           in monetary policy looks likely to be
of letting the economy run “hot” to            enshrined by Congress can be eroded            threatened. Higher inflation that per-
address the labor market slack.                by Congress, and the Fed as an institu-        sists could usher in a world of higher
  Overall, the Fed risks becoming              tion has been strategic in staying on the      borrowing costs, while a slowing
much more politicized, caught between          right side of the legislature.                 economy could menace the economy.
competing interests in Congress, and             On monetary policy, however, the                Either outcome would probably sub-
President Biden’s ability to reshape           realities of the post-pandemic economy         ject the Fed to even more scrutiny from
the board, all subject to senatorial con-      have crystalized the inflation-employ-         Congress and/or the executive branch.
firmation. We have written about the           ment tradeoff to a high degree. How            This too would roil the markets as the
threats to central banks’ independence         the Fed tries to run an optimal policy         Fed’s credibility and independence
around the world and remind readers            in the face of high inflation and a weak       could be further weakened.
that former President Trump put enor-          labor market will be a challenge to
mous public pressure on Chair Powell           financial markets as well as the real
before the pandemic to maintain                economy and the citizenry that forms           John Velis is an FX and macro strategist
easy money policies.                           the Fed’s constituency.                        at BNY Mellon Americas.
  The Fed’s independence has been                Dramatic changes in personnel at             Questions or comments? Write to
granted by Congress, and throughout            the top of the central bank – as well as        John.Velis@bnymellon.com or reach out
the years, it has had to navigate              among the Board of Governors – could           to your usual relationship manager.
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Brussels with company number 0806.743.159,               BR014361. The Bank of New York Mellon SA/NV,               as to whether the referenced products or services
whose registered office is at 46 Rue Montoyerstraat,     London branch is authorized by the ECB (address            are appropriate or suitable for you. This material
B-1000 Brussels, Belgium, authorized and regulated       above) and subject to limited regulation by the FCA        may not be comprehensive or up to date and there
as a significant credit institution by the European      (address above) and the PRA (address above).               is no undertaking as to the accuracy, timeliness,
Central Bank (“ECB”) at Sonnemannstrasse 20, 60314                                                                  completeness or fitness for a particular purpose of
Frankfurt am Main, Germany, and the National Bank        Regulatory information in relation to the above            information given. BNY Mellon will not be responsible
of Belgium (“NBB”) at Boulevard de Berlaimont/de         BNY Mellon entities operating out of Europe can            for updating any information contained within this
Berlaimontlaan 14, 1000 Brussels, Belgium, under         be accessed at the following website: https://www.         material and opinions and information contained
the Single Supervisory Mechanism and by the Belgian      bnymellon.com/RID.                                         herein are subject to change without notice. BNY
Financial Services and Markets Authority (FSMA) at                                                                  Mellon assumes no direct or consequential liability for
Rue du Congrès/Congresstraat 12-14, 1000 Brussels,       The Bank of New York Mellon, Singapore Branch, is          any errors in or reliance upon this material.
Belgium for conduct of business rules, and is a          subject to regulation by the Monetary Authority of
subsidiary of The Bank of New York Mellon.               Singapore. The Bank of New York Mellon, Hong Kong          This material, which may be considered advertising,
                                                         Branch (a branch of a banking corporation organized        is for general information purposes only and is
The Bank of New York Mellon SA/NV operates in            and existing under the laws of the State of New York       not intended to provide legal, tax, accounting,
Ireland through its Dublin branch at Riverside II,       with limited liability), is subject to regulation by the   investment, financial or other professional advice
Sir John Rogerson's Quay Grand Canal Dock, Dublin        Hong Kong Monetary Authority and the Securities &          on any matter. This material does not constitute a
2, D02KV60, Ireland and is registered with the           Futures Commission of Hong Kong.                           recommendation or advice by BNY Mellon of any
Companies Registration Office in Ireland No. 907126                                                                 kind. Use of our products and services is subject to
& with VAT No. IE 9578054E. The Bank of New York         For recipients of this information located in              various regulations and regulatory oversight. You
Mellon SA/NV, Dublin Branch is subject to limited        Singapore: This material has not been reviewed by the      should discuss this material with appropriate advisors
additional regulation by the Central Bank of Ireland     Monetary Authority of Singapore.                           in the context of your circumstances before acting in
at New Wapping Street, North Wall Quay, Dublin 1,                                                                   any manner on this material or agreeing to use any of
D01 F7X3, Ireland for conduct of business rules and      For clients located in Australia:                          the referenced products or services and make your
registered with the Companies Registration Office in     The Bank of New York Mellon is exempt from                 own independent assessment (based on such advice)
Ireland No. 907126 & with VAT No. IE 9578054E.           the requirement to hold, and does not hold, an             as to whether the referenced products or services
                                                         Australian financial services license as issued            are appropriate or suitable for you. This material
The Bank of New York Mellon SA/NV is trading             by the Australian Securities and Investments               may not be comprehensive or up to date and there
in Germany through its Frankfurt branch “The             Commission under the Corporations Act 2001                 is no undertaking as to the accuracy, timeliness,
Bank of New York Mellon SA/NV, Asset Servicing,          (Cth) in respect of the financial services provided        completeness or fitness for a particular purpose of
Niederlassung Frankfurt am Main”, and has its            by it to persons in Australia. The Bank of New             information given. BNY Mellon will not be responsible
registered office at MesseTurm, Friedrich-Ebert-         York Mellon is regulated by the New York                   for updating any information contained within this
Anlage 49, 60327 Frankfurt am Main, Germany.             State Department of Financial Services and                 material and opinions and information contained
It is subject to limited additional supervision          the US Federal Reserve under Chapter 2 of the              herein are subject to change without notice. BNY
by the Federal Financial Supervisory Authority           Consolidated Laws, The Banking Law enacted                 Mellon assumes no direct or consequential liability for
(Bundesanstalt für Finanzdienstleistungsaufsicht,        April 16, 1914 in the State of New York, which             any errors in or reliance upon this material.
Marie-Curie-Str. 24-28, 60439 Frankfurt, Germany)        differs from Australian laws.
under registration number 122721.                                                                                   This material may not be distributed or used for the
                                                         The Bank of New York Mellon has various other              purpose of providing any referenced products or
The Bank of New York Mellon SA/NV operates in            branches in the Asia-Pacific Region which are subject      services or making any offers or solicitations in any
the Netherlands through its Amsterdam branch at          to regulation by the relevant local regulator in that      jurisdiction or in any circumstances in which such
Strawinskylaan 337, WTC Building, Amsterdam, 1077        jurisdiction.                                              products, services, offers or solicitations are unlawful
XX, the Netherlands. The Bank of New York Mellon                                                                    or not authorized, or where there would be, by virtue
SA/NV, Amsterdam Branch is subject to limited            The Bank of New York Mellon Securities Company             of such distribution, new or additional registration
additional supervision by the Dutch Central Bank         Japan Ltd, as intermediary for The Bank of New             requirements.
(“De Nederlandsche Bank” or “DNB”) on integrity          York Mellon.
issues only (registration number 34363596). DNB                                                                     Any references to dollars are to US dollars unless
holds office at Westeinde 1, 1017 ZN Amsterdam, the      The Bank of New York Mellon, DIFC Branch, regulated        specified otherwise.
Netherlands.                                             by the Dubai Financial Services Authority (“DFSA”)
                                                         and located at DIFC, The Exchange Building 5 North,        This material may not be reproduced or disseminated
The Bank of New York Mellon SA/NV operates in            Level 6, Room 601, P.O. Box 506723, Dubai, UAE, on         in any form without the prior written permission of
Luxembourg through its Luxembourg branch at              behalf of The Bank of New York Mellon, which is a          BNY Mellon. Trademarks, logos and other intellectual
2-4 rue Eugene Ruppert, Vertigo Building – Polaris,      wholly-owned subsidiary of The Bank of New York            property marks belong to their respective owners.
L- 2453, Luxembourg. The Bank of New York                Mellon Corporation.
Mellon SA/NV, Luxembourg Branch is subject to                                                                       The Bank of New York Mellon, member of the Federal
limited additional regulation by the Commission          Past performance is not a guide to future performance      Deposit Insurance Corporation (“FDIC”).
de Surveillance du Secteur Financier at 283, route       of any instrument, transaction or financial structure
d’Arlon, L-1150 Luxembourg for conduct of business       and a loss of original capital may occur. Calls and        © 2021 The Bank of New York Mellon Corporation.
rules, and in its role as UCITS/AIF depositary and       communications with BNY Mellon may be recorded,            All rights reserved.
central administration agent.                            for regulatory and other reasons.
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