... person is carrying on a regulated activity, taking into account the full factual context and totality of the interactions which the person has with policy holders or potential policy holders. The question which needs to be asked, therefore, is whether a reasonable observer taking account of all the...

... person is carrying on a regulated activity, taking into account the full factual context and totality of the interactions which the person has with policy holders or potential policy holders. The question which needs to be asked, therefore, is whether a reasonable observer taking account of all the...

... ventures 3 , special purpose vehicles (“SPVs”) and investments (which may expose the supervised group to providing implicit support to the SPVs/investments, or to potential legal actions against the supervised group by investors in securities issued by the SPVs/investments) that are held, directly or...