India's highest ranked regulatory firm by Asialaw - Finsec Law Advisors

 We’re delighted to share that Finsec Law Advisors has been ranked “Outstanding” in asialaw Rankings 2025 — the highest recognition in India for our Regulatory Practice.

This honour reflects our unwavering commitment to excellence in securities, investment and financial law, and our deep partnerships with clients navigating India’s evolving financial landscape.

 

Our heartfelt thanks to our clients, colleagues, and peers who continue to trust and inspire us on this journey ~ Sandeep Parekh and Anil Choudhary

Easing investments via IFSC

I have a piece in today's Financial Express with Aniket Singh Charan on easing investments via the GIFT city and how recent regulatory changes will help that. 

On August 12, 2025, the International Financial Services Centres Authority (IFSCA) released a circular titled “Regulatory Framework for Global Access Providers”. The circular marks a key step towards clarifying the regulatory framework around Global Access Providers (GAPs) and sets the tone for the next phase of investments through IFSCs.

Historically, Indian investors relied on foreign brokers operating outside the purview of domestic regulators to invest in foreign securities thereby raising concerns over transparency and investor protection. To address this, the IFSCA introduced the concept of GAPs in 2021. GAPs are intermediaries authorised to facilitate access to global financial products and services through regulated international exchanges and foreign brokers. Initially, only IFSCA-registered broker-dealers and recognised stock exchanges could access overseas markets, either via cross-border arrangements with regulated entities or by registering as trading members of foreign exchanges (limited to proprietary trading). For broker dealers, such access required a no-objection certificate from the recognised IFSC exchange.

On April 17, 2025, the IFSCA (Capital Market Intermediaries) Regulations, 2025 were notified thereby revamping the framework for the regulation, registration, and supervision of capital market intermediaries operating in IFSCs. Consequently, the IFSCA chose to further deliberate on how entities in IFSCs provide global access and whether the status quo should be maintained. 

Thereafter, on May 08, 2025 the IFSCA released a consultation paper seeking public comments on certain proposals in relation to GAPs (CP 1). The key objective of CP 1 was to introduce clear rules on the registration of GAPs, provide operational modalities, detail permitted products and responsibilities of broker-dealers, define client disclosures, KYC/AML/CFT compliance, code of conduct, periodic reporting, fee structures, and other regulatory requirements. 

CP 1 faced criticism for its narrow eligibility criteria for GAP registration. It allowed only subsidiaries of recognised stock exchanges or foreign brokers with IFSC subsidiaries to act as GAPs, effectively excluding IFSCA-registered broker-dealers. This created an uneven playing field. While foreign brokers with group entities holding overseas memberships could offer market access directly, IFSC-based broker-dealers without such memberships would be forced to route access through other GAPs. The framework was thus seen as restrictive and disadvantageous to domestic participants.

To rectify these defects, on May 30, 2025 the IFSCA published a revamped consultation paper (CP 2) that introduced several key changes. The most significant change was that the definition of GAPs was broadened to allow IFSCA-registered broker-dealers to seek registration as GAPs, provided they enter into formal arrangements with foreign brokers that are trading members of a foreign stock exchange to facilitate global market access. This significantly widened participation and would have the effect of creating greater opportunities for investors to diversify globally through regulated channels.

CP 2 was subject to further comments from the public. In this regard, industry participants identified a major issue concerning the selection of foreign brokers with whom GAPs could enter into agreements. As per CP 2, a GAP was permitted to enter into an agreement only with a foreign broker who was registered as a trading member of a stock exchange in the relevant foreign jurisdiction and who complied with the applicable regulatory requirements of that jurisdiction for providing access to stock markets. This regulatory approach created several challenges, particularly when compared with international practices. For instance, in jurisdictions such as the United States of America, the concept of a “broker-dealer” is distinct from that of a “trading member.” A broker-dealer is primarily licensed to engage in securities trading and investment services for clients, whereas a trading member (often referred to as a member of an exchange) is focused on direct participation in the exchange for execution of trades. A broker-dealer is capable of providing multi-dimensional access to the markets in a foreign jurisdictions through tie ups with various trading members. For example, a FINRA-registered broker-dealer could have tie ups with trading members on NYSE, NASDAQ etc. and could act as a single point of contact in the concerned foreign jurisdiction for the GAP, however, it was effectively excluded from entering into agreements with GAPs. 

The circular issued on August 12, 2025, identified the issues surrounding this restriction and eased the same considerably. A GAP may now enter into an agreement to provide access with any foreign broker that is duly regulated or registered as a broker (by whatever name called) in its home jurisdiction, provided that such broker offers access to global markets in compliance with applicable laws. Thus, the requirement for the foreign broker to also be a trading member of a stock exchange in the concerned foreign jurisdiction has been done away with. Importantly, foreign brokers are now permitted to further extend access to multiple jurisdictions through their own arrangements, thereby enhancing flexibility and broadening the scope of market access available to investors.

The evolution of the framework around GAPs reflects the progressive approach adopted by the IFSCA. This steady regulatory deepening highlights IFSCA’s dual commitment - to ensure adequate supervision while simultaneously promoting and developing IFSCs as a global investment hub.

The benefits of this revamped approach are significant. First, it is likely to encourage more Indian entities to establish broker-dealer operations within IFSCs, thereby deepening the ecosystem and positioning India as a credible player in cross-border financial services. Second, it provides Indian investors with a transparent, reliable, and regulated alternative for accessing global markets, moving decisively away from earlier unregulated routes. Third, the framework enhances regulatory oversight over the deployment of funds overseas, thereby strengthening investor protection and reducing risks. Finally, by aligning with global best practices, the framework is expected to improve service standards, enhance investor experience, and foster higher quality intermediation in outbound investment channels. 

Only time will tell how much capital will be channelled through GAPs, but industry response so far has been largely positive. The hope is that this framework will encourage greater investment through a regulated and supervised route. Its ultimate success, however, will depend on how IFSCA shapes the regulatory framework going forward, striking the right balance between ease of doing business and investor protection.

Reforms in Focus: SEBI’s Push for Market Efficiency and Safeguards

I have a piece with Navneeta Shankar and Yash Vardhan discussing the outcomes of the recent SEBI board meeting on various topics in today's Financial Express. 

The Securities and Exchange Board of India (SEBI) has long been tasked with walking a careful line between deepening capital markets and protecting investor confidence. Over the past decade, its approach has gradually shifted from a prescriptive, one-size-fits-all rules toward scale-based, proportional regulation and digital facilitation. The decisions announced by SEBI at its board meeting held on September 12, 2025, reflect this evolution. The measures range from easing IPO norms for large issuers to recalibrating related party transaction (RPT) thresholds, streamlining foreign investor access, and broadening mutual fund participation in alternative asset classes. Taken together, they signal a regulator conscious of market realities and willing to fine-tune compliance without diluting oversight.

One of the most consequential reforms is the proposed amendment to the Securities Contracts (Regulation) Rules, 1957 relating to the minimum public offer and minimum public shareholding requirements for large issuers. Under the revised framework, issuers with a post-issue market cap between Rs. 50,000 crore and Rs. 1,00,000 crore may list with a public float as low as 8% (subject to a floor of Rs. 1,000 crore), while those above Rs. 5,00,000 crore may list with just 1% public offer (subject to a minimum dilution of 2.5% and a floor of Rs. 15,000 crore). Timelines for achieving 25% public shareholding have also been extended, up to 10 years for the largest issuers.

This bifurcation of thresholds represents a more calibrated approach to different issuer sizes. Forcing very large companies to dilute aggressively at listing could result in oversupply, weak valuations, and potential instability. The revised norms ease compliance while still maintaining significant market float over time. A balance must be struck between accommodating market absorption capacity and preserving genuine public participation.

In parallel, SEBI has amended the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018, to broaden anchor investor participation in IPOs. Previously divided into two categories based on allocation size, anchor investors will now form a single class with participation rules tied to issue size. The anchor portion has been raised to 40% of the institutional book, with one-third reserved for domestic mutual funds and the remainder for insurers and pension funds. Undersubscription in the insurer and pension fund tranche can be reallocated to mutual funds.

These changes are expected to diversify anchor books and provide structured opportunities for long-term institutional investors. Broader participation by foreign portfolio investors (FPIs) operating multiple funds also becomes easier, aligning India with global practices. While such reservations improve stability and credibility in the anchor book, the regulator must ensure they do not restrict issuer flexibility. Expanding the overall pool of eligible institutions may achieve the same objective without rigid segmentation.

Corporate governance remains another focal point. Amendments to the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, introduce scale-based thresholds for determining material RPTs. Instead of a flat numerical test, thresholds are now linked to company turnover, with higher bands for companies with turnover exceeding Rs. 20,000 crore and Rs. 40,000 crore. Subsidiary-level thresholds have also been harmonized with parent-level requirements to avoid arbitrage.

This shift toward proportionality is welcome, as fixed numerical triggers were arbitrary and often disproportionate. By tailoring thresholds to entity size, the framework becomes more rational. At the same time, audit committees must retain discretion to examine transactions beyond mere numbers, as governance risks often lie in qualitative context. Codifying omnibus approval validity periods and clarifying that a “holding company” means only a listed holding company also introduces consistency in industry practices and removes existing ambiguities.

Other decisions taken at the board meeting are reflective of SEBI’s effort to make it easier to do business in the securities markets by simplifying compliance and reducing procedures for participants. For instance, the introduction of the SWAGAT-FI (Single Window Automatic and Generalised Access for Trusted Foreign Investors) framework is designed to unify and streamline access for objectively identified low-risk foreign investors such as sovereign wealth funds, pension funds, and regulated retail funds. By offering benefits such as 10-year registration validity, exemptions from certain ownership restrictions, and simplified demat account structures, the framework reduces regulatory complexity while signalling India’s intent to attract stable, long-horizon capital.

Domestically, SEBI has broadened the scope for accredited investors and large value funds in the alternative investment space. Accredited investor-only schemes will enjoy flexibility on pari-passu treatment and tenure, while the threshold for large value funds has been reduced from Rs. 70 crore to Rs. 25 crore. These reforms recognize the sophistication of accredited investors and expand the potential investor base, though regulators must monitor whether such relaxations are used disproportionately by funds seeking to avoid standard compliance.

Perhaps the most significant reform is the reclassification of Real Estate Investment Trusts (REITs) as equity instruments for mutual fund investment purposes. Until now, both REITs and Infrastructure Investment Funds (InvITs) were treated as hybrid instruments. With the new classification, REITs will fall within equity allocation limits and become eligible for index inclusion, unlocking passive flows and lowering the cost of capital for real estate developers. This is aligned with global practice, where REITs are integrated into equity markets. 

Investor protection and financial inclusion were addressed through mutual fund reforms. Exit load caps have been reduced from 5% to 3%, distributor incentives have been revised to encourage inflows from beyond the top 30 cities (B-30 cities), and a new incentive has been introduced for onboarding women investors. These measures, though incremental, reflect a regulatory intent to democratize access to financial products and support underrepresented segments of the investor base.

SEBI has also cleared governance reforms for MIIs, requiring two executive directors in addition to the managing director, with defined roles in operations, compliance, risk, and investor grievances. While aimed at enhancing accountability, rigid role definitions may limit flexibility and a board-approved governance framework could have achieved the objective without such constraints. To SEBI’s credit, it did not bring about the most drastic changes that it had previously proposed by way of consultation paper.

Viewed in totality, SEBI’s decisions at its latest board meeting reflect a regulator that is increasingly pragmatic, adopting differentiated rules for different categories of issuers and investors, promoting digital facilitation, and seeking to harmonize with global standards. The reforms address both ends of the spectrum – mega issuers accessing public markets and small retail investors from B-30 cities.

Yet, execution will determine credibility. As India’s capital markets continue to expand in depth and global relevance, SEBI’s role will be to maintain this delicate balance – between growth and oversight; facilitation and vigilance. The task now is to ensure that facilitation does not outpace vigilance, and that in seeking to open doors, the regulator does not lower guardrails. Over a longer period of time, many of the details should be simplified from today’s positions.

9th Episode of 'Decoding with Finsec’

Delighted to bring to you the 9th Episode of 'Decoding with Finsec’ with  Anil Choudhary

where we discuss the recent SEBI Board meetin

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A Trillion-Dollar Opportunity: REITs and InvITs as equity instruments

I have a piece with Purva Mandale in today’s Economic Times that re-classifying REIT (Real Estate Investment Trusts) and InvITs instruments as equity would unlock a lot of capital to be directed towards real estate infrastructure.

We highlight how such a reform can:

• Remove outdated restrictions on MF investments;
• Recognise the economic similarities between REITs/InvITs and equity shares;
• Enable global best practices like index inclusion and performance-linked returns;
• Broaden investor participation, deepen liquidity, and mobilise capital for growth.

Below is the unedited copy of the piece:

In a pivotal move set to redefine India’s capital markets, the Securities and Exchange Board of India (“SEBI”) has proposed to reclassify units of Real Estate Investment Trusts (“REITs”) and Infrastructure Investment Trusts (“InvITs”) as ‘equity’ instruments. This proposal, detailed in SEBI’s April 2025 consultation paper, holds the potential to unlock significant capital flows into India’s foundational real estate and infrastructure sectors, crucial for driving the nation’s economic growth.  

Since their launch in 2014, REITs and InvITs have steadily gained momentum in India. As of March 2024, India has 5 registered REITs and 24 InvITs, out of which a majority are listed, collectively managing substantial net assets, what started as a trickle is now a substantial number. In the financial year 2024, InvITs have raised over ₹33,000 crore – a more than five-fold increase from the previous year – and REITs mobilized close to ₹6,000 crore in investments.

Despite this evident momentum, these instruments remain considerably underutilized. REITs currently constitute only 12% of India’s listed real estate market capitalization and a mere 0.35% of the global REIT index. This stands in stark contrast to mature markets like the U.S., Australia, and the U.K., where REITs account for over 90% of listed real estate market capitalization. With India's real estate sector projected to reach $1 trillion by 2030 and infrastructure requiring a staggering $4.5 trillion in investment over the same period, the question is no longer about the potential of REITs and InvITs, but rather, how best to unleash it further as a means of development and progress.

Under SEBI’s current regulations for Mutual Funds, REITs and InvITs are categorized as ‘hybrid’ instruments. This classification imposes significant limitations on mutual fund investments, capping exposure at 10% of a scheme’s Net Asset Value and 5% per issuer, thus limiting mutual fund inflows. While these restrictions were reasonable when introduced in 2017 to manage a nascent market liquidity and concentration risks, they are arguably outdated given the current maturity and scale of these markets.

Further, the ‘hybrid’ classification limits the inclusion of REITs and InvITs in benchmark indices and discourages passive investment. Thus, these factors collectively limit liquidity and stunt price discovery. Reclassifying these instruments as equity would dismantle these barriers, more accurately reflecting their true financial nature and unlocking their full market potential.

Economically and structurally, the units of REITs and InvITs bear similarities to equity shares. These units represent a proportional beneficial interest in the trust's assets and cash flows, fundamentally differing from fixed debt obligations. Further, the absence of fixed maturity date and requirement of principal repayment supports the cause. The mandatory distribution of at least 90% of net distributable income to unitholders is directly linked to the performance of the underlying assets, mirroring the nature of dividends, which are declared from a company’s profits, rather than contractual payments akin to debt interest.

Furthermore, REIT and InvIT units are publicly listed, traded, and settled on stock exchanges, leveraging the same infrastructure as equity shares, including identical mechanisms for price discovery and trading. Unitholders possess the right to vote on crucial decisions, including asset acquisitions, borrowings, and managerial appointments, directly paralleling the governance rights of equity shareholders. On the taxation front, the Income Tax Act, 1961, already aligns the tax treatment of long-term capital gains on REIT/InvIT units with that of equities. Notably, even SEBI, when establishing the original investment caps in 2017, explicitly acknowledged these inherent equity-like traits.

International experience consistently demonstrates that the equity classification of REITs is rooted in their economic substance, not merely their legal structure. Whether organized as corporations or trusts, listed REITs in major markets like the U.S., UK, Singapore, and Australia share core characteristics with traditional equity securities. These include robust market liquidity, residual risk-bearing by unitholders, and a direct alignment of returns with performance.

These global jurisdictions have seamlessly integrated REITs into mainstream equity indices. This integration has been vital in boosting institutional participation, significantly lowering the cost of capital, and enhancing secondary market liquidity. In the U.S., for instance, REITs are fully integrated into major equity benchmarks such as the S&P 500 and the MSCI US REIT Index, enabling over 150 million Americans to invest in REITs through retirement plans and mutual funds, underscoring their mainstream acceptance. In Singapore, S-REITs constitute 10% of the SGX market capitalization. Australia’s A-REITs, embedded in the S&P/ASX 200, represent a significant portion of the global REIT market. These examples demonstrate how equity classification enhances mainstream integration, fosters greater liquidity, and boosts investor confidence. These international experiences underscore that the equity classification of REITs is driven by economic substance and their functional role within capital markets, not merely by legal form.

To propel REITs and InvITs into India’s investment mainstream, a focused set of regulatory reforms is needed. The first and most foundational step is to formally recognize REITs and InvITs as equity instruments. This reclassification would align regulatory treatment with the true economic nature of these instruments, characterised by residual ownership, market-based valuation, and performance-linked returns, and harmonize India’s approach with international standards adopted in mature REIT markets like the U.S., U.K., Singapore, and Australia.

Secondly, equity recognition would enable the inclusion of REITs and InvITs in major equity benchmarks such as the Nifty and Sensex. This is not merely a technical adjustment but a market catalyst. Index inclusion would unlock automatic inflows from passive investment vehicles, such as Exchange Traded Funds (ETFs) and index-linked mutual funds, thereby deepening liquidity, improving price discovery, and strengthening investor confidence in these instruments. These inflows will automatically incentivise more people to monetise their real assets freeing up capital for further construction of projects.

Rationalising these limits will empower mutual funds to respond to market dynamics more effectively, facilitating broader participation and accelerating capital formation in the real estate and infrastructure sectors. SEBI’s proposed reclassification is a strategic pivot poised to shape the next decade of investment in India. With a compelling economic rationale, strong global precedents, and growing investor interest, the case for formal equity classification is a reform whose time has come.

 

RBI’s New Co-Lending Directions: Balancing Growth with Guardrails

I have a piece with Aniket Singh Charan and Pragya Garg in today’s Financial Express on the new RBI law on co-lending. 

On August 06, 2025, the Reserve Bank of India notified the RBI (Co-Lending Arrangements) Directions, 2025. At first glance, the Directions appear to be incremental changes to an existing framework. But a closer look reveals that they reshape the foundation of how banks, NBFCs, and fintechs will collaborate in extending credit. The new framework widens opportunities, imposes tighter risk-sharing obligations, and sets the tone for the next phase of India’s credit ecosystem.

Co-lending emerged in India as a hybrid model combining the best of both worlds. NBFCs and fintechs, agile in origination and distribution, could reach underserved borrowers in small towns, semi-urban centres, and niche segments. Banks, with their lower cost of funds, provided the balance sheet heft to finance these loans. In theory, both parties gained, NBFCs earned fee income and continued customer engagement, while banks got exposure to segments they struggled to reach.

RBI’s first attempt to formalise this model came in 2020, restricting it largely to priority sector lending or PSL. Soon, concerns were raised with respect to higher effective borrower rates, inadequate disclosures, and NBFCs acting mainly as originators with minimal balance sheet exposure. By 2023–24, the RBI was scrutinising whether such practices were resulting in regulatory arbitrage and systemic risk.

The  Directions are the regulator’s response, an attempt to mainstream co-lending arrangements (CLA) while curbing their excesses. .To begin with, co-lending is no longer confined to PSL. Any loan, secured or unsecured, can be originated under a CLA between regulated entities, not just banks and NBFCs. This opens the gates for broader participation, including housing finance companies.

Further, each co-lender must retain at least 10% of the loan exposure on its books. This “skin in the game” requirement ensures that lenders do not offload risks entirely to their partners. Additionally, the use of default loss guarantees or DLGs, where one party promises to absorb losses up to a cap, has been restricted to 5% of loans outstanding in respect of loans under CLA. This prevents an illusion of risk transfer and guards against hidden leverage.

The Directions mandate enhanced disclosures: quarterly and annual publication of co-lending partners, weighted average interest rates, fees charged and paid, and DLG details. Escrow accounts are compulsory for all collections, and tighter Know-Your-Customer rules have been prescribed. Loan transfer timelines are also specified, reducing scope for regulatory arbitrage. The originating regulated entity must ensure that any loan under a CLA is transferred only to the designated partner RE, as per the agreement and the Key Fact Statement at the time of sanction. If such transfer cannot be completed within 15 calendar days, the loan remains on the originating RE’s books and can only be transferred to other eligible lenders as per applicable directions. Moreover, any subsequent transfer of loan exposures originated under CLA, whether to third parties or between REs, must strictly comply with applicable directions and requires mutual consent of both the originating and partner REs. Collectively, these requirements signal that the days of opaque “back-to-back” loan originations are over.

The Directions will reshape the co-lending landscape, bringing both opportunities and challenges. On the positive side, they create a new growth avenue for NBFCs by allowing co-lending across all loan categories, helping them scale beyond the narrow PSL channel. This could unlock long-term growth potential while enhancing their credibility through greater transparency. Banks, in turn, benefit by leveraging the NBFC distribution network without having to build their own last-mile reach, which could expand access to formal credit in historically underserved regions. From a systemic perspective, the RBI’s insistence on risk retention and caps on DLGs ensures that no participant can fully distance itself from loan performance, thereby reducing moral hazard and encouraging a more balanced partnership.

The framework also introduces challenges: compliance with escrow accounts, IT upgrades, and detailed reporting which will raise costs, straining smaller NBFCs and driving industry consolidation. Additional costs may be passed on to borrowers thereby undermining the goal of financial inclusion. Further, operational frictions like system coordination and stricter timelines could erode the model’s fintech-driven efficiency by slowing down disbursements. .

Thus, while the framework strengthens resilience, it risks dampening the agility that gave co-lending its edge.

Globally, co-lending or collaborative lending models have taken diverse forms. In the United States, the Federal Deposit Insurance Corporation has promoted partnerships between large banks and Minority Depository Institutions to channel funds to underserved communities. These arrangements emphasise trust, governance, and community focus, elements RBI is now embedding through mandatory disclosures.

In Europe and East Asia, big techs often collaborate with banks wherein the latter provides low-cost funding while the former contributes towards underwriting models and distribution. The Bank for International Settlements has cautioned that such partnerships disproportionately benefit fintechs unless risk-sharing is properly designed. India’s insistence on a 10% retention echoes this learning, ensuring that originators cannot offload risk entirely.

The  Directions are neither overly liberal nor excessively restrictive. They represent a calibrated attempt to harness the promise of co-lending while putting guardrails around its risks. The framework’s success will depend on its execution particularly on whether lenders invest in technology to streamline compliance, whether costs are contained, and whether transparency indeed builds trust with investors and customers.

In the near term, smaller NBFCs may face pain, and credit costs could inch higher. But over the medium term, co-lending could evolve from a niche regulatory experiment into one of India’s primary channels of credit delivery, fuelled by banks’ balance sheets and NBFCs’ last-mile reach. The challenge for all participants will be to avoid viewing the new rules as a compliance burden alone. If treated instead as an opportunity to build transparent, resilient, and scalable lending partnerships, the Directions could mark the beginning of a more balanced, more credible era of joint lending in India.

How do Indian securities regulations and market infrastructure institutions compare to the US?

I have a podcast with Hansi Mehrotra (a Zerodha initiative on investor education), where we discuss the differences in approach of US and India with respect to investor protection and market infrastructure.  

How does India’s securities regulatory framework compare with the United States? The answer lies in their differing philosophies: proactive prevention vs. reactive correction. In the U.S., markets have historically been allowed to innovate freely, with regulation catching up only after systemic issues surface—subprime mortgages and crypto are prime examples. India, by contrast, cannot afford such shocks. Its framework is designed for pre-emption, prioritising investor protection and systemic stability from the outset. At the core stands SEBI (est. 1988/1992), empowered by statute to regulate markets, protect investors, and enforce compliance. Importantly, its toolkit includes both administrative penalties and criminal proceedings.

Supporting legislation:

• SCRA, 1956 – governs stock exchange integrity.

• Depositories Act, 1996 – enabled dematerialisation, ushering in transparency and efficiency.

In the U.S., investor recourse often takes the form of class-action lawsuits. India does not rely on this mechanism. Instead, SEBI directly steps into that role, acting as the primary enforcer of investor rights. Oversight is not unchecked. The Securities Appellate Tribunal provides an independent forum to review SEBI’s orders, ensuring due process and accountability. The result: India’s markets are governed by a preventive, statute-driven framework, while the U.S. leans on market-led innovation with corrective interventions. Each reflects its own economic context.

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