VZMD was shocked and appalled to see that “the Government of the Republic of Slovenia treats thousands and thousands of minority shareholders only as “deficiency and inconsistency” on the financial instruments market. By way of the proposed amending act, the Government of the Republic of Slovenia is committed to definitively eradicating all remaining minority shareholders that managed to survive on the financial instruments market - following the exodus triggered by the inconceivable abolishing of the registry accounts - only through the “Share SUPPORT” organized by VZMD.«

For this reason, VZMD would like to call on all recipients not to become a part of the trivial and narrow interest-driven campaign of the “financial industry” and the Securities Market Agency (ATVP) which has taken actions against thousands of minority shareholders by misusing the legislative procedures and to abide by their principles which guided them to adopt the highest possible amounts which may be charged to the minority shareholders by the financial industry and which were applied during the adoption of the authentic interpretation which has revalidated such strong will and decision a little while ago.

At the same time, VZMD would like to raise the following concerns: “Is the ATVP also going to propose even the wording of the act forbidding VZMD and everyone working with VZMD to use legal means normally available to everybody else?! How far have the Government and the National Assembly of the Republic of Slovenia been ready to go while participating in the fight against and prevention of the universally useful mission?!”

As stated by the VZMD President in the letter, the twelve-year long promotion of minority shareholders and investors, their rights and interests, as well as wider public interests and interests of companies to keep minority shareholders in their ownership structures has been widely known. During the abolishment of registry accounts and revisions of the Book Entry Securities Act (ZNVP), all those efforts were reflected also in the extended transfer deadline for natural persons, in abolishment of court deposit costs for those with lowest portfolio values, in limitation of the amounts charged by financial intermediaries to their clients, and most of all in the most advantageous option to survive on the market through the “Share SUPPORT” organized by VZMD in the long run.

The idea of the Share SUPPORT stems from the use of a trust account for securities (that is, collective ownership of securities), which was not introduced in the Republic of Slovenia until the Financial Instruments Market Act (ZTFI) was passed in 2006 in order to provide large (foreign) financial intermediaries with such kind of ownership. In fact, the idea of the Share SUPPORT has been much more self-restricted than the trust accounts of foreign financial intermediaries as the ownership of shares on a trust account of a foreign financial intermediary allows for transactions and hidden changes to ownership, whereas the Share SUPPORT scheme allows for none of this - but, in case of transactions, requires previous transfer of securities to a separate trading account of the owner).

According to Mr. Verbič, this was the first blow of the kind given by the ATVP to which VZMD responded with a solution which, however, inevitably raised the price of the Share SUPPORT scheme to a certain extent, but did provide for its establishment nevertheless: this was the case of attracting a distinguished lawyer to whom the ATVP could not deny the opening of a trust account for securities. “The financial industry” - headed by the ATVP - responded to this possibility by proposing the amendment to the fourth paragraph of Article 255 of ZTFI. In accordance with the proposed amendment, the possibility of a trust account for securities would be restricted only to persons performing custodial activities as part of their line of business or profession whereby managing securities on a trust account must not be the reason why the person and client enter into a legal relationship. Therefore, the securities might have been managed on a trust account only by those who would not have a legal relationship with the client on these grounds!Despite the fact that VZMD is the owner of a trust account and renders custodial services for its clients in this regard, the ATVP deployed all efforts to prevent opening of the trust account once VZMD wanted to open a trust account for securities in the first half of 2015. Such action by the ATVP was taken despite clear wording of the fourth paragraph of Article 255 of ZTFI, which stipulates the possibility of a trust account for all persons rendering custodial services as part of their line of business or profession.

This was the second blow given by the ATVP. And this blow, according to the VZMD President, was targeted highly imprecisely as the conditions that you must not have a relationship with clients in regard to what you do for them cannot be met by anybody. Therefore, the ATVP was prepared to block everyone, including foreign financial intermediaries only to block the Share SUPPORT as well.”

Numerous protests were definitely effective and that is why the ATVP tried their luck for the third time. But now, the ATVP convinced Ministry of Finance of the Republic of Slovenia and the Government of the Republic of Slovenia - as it seems - with the proposal that lawyers and public notaries must not offer managing of securities on a trust account as an independent service. In this context, an independent offer of managing a trust account is considered an independent service by a lawyer or a public notary if their clients call on the owners of book-entry securities to transfer their book-entry securities to that account.

This is the third of blow of such kind given by the ATVP which is not much more lucid than the previous one. The question whether a lawyer or a public notary offers the managing of trust accounts as an independent service does not depend on actions of a lawyer or a public notary, but on those of their clients, which is an oxymoron.

“Is the ATVP for the fourth time going to propose even the wording of the act forbidding VZMD and everyone working with VZMD to use legal means normally available to everybody else?! How far have the Government and the National Assembly of the Republic of Slovenia been ready to go while participating in the fight against and prevention of the universally useful mission,”  is the question posed by the VZMD President in the letter as he continues:

“For what reason, is it imperative to follow and please particular interests of the ATVP, which in the last year clearly positioned itself as the protector of the financial industry of the influential and economically strong financial market players, from payments the ATVP is financed from and is seen only as a club atop of the minority shareholders, who “imagine” themselves to be equal to the big ones? Is merely more than a month really enough to forget about the scandalous speeches of the representatives of the ATVP  and the Ministry of Finance of the Republic of Slovenia in the National Assembly of the Republic of Slovenia when they were advocating for higher charges in the financial industry and opposing the authentic interpretation of Article 48 of the Book Entry Securities Act (ZNVP-1)? Is it really possible to overlook how these same representatives even today still fail to apply ZNVP-1 for all brokerage companies in a manner which would be in accordance with the authentic interpretation?! Is it really possible to blindly follow the proposals of those who have failed disastrously in attempts to protect the minority shareholders and individual investors (recall only the million gap in Moja delnica d.d. last year)?”

VZMD is still wondering how a couple of hundred of shareholders who - after having been let down by the state following a (never truly convincing) decision to abolish the registry accounts at KDD - were later on able to survive on the market under the shield of the Share SUPPORT, would accept the fact that the state once again intends to change the law in order to deprive them of this possiblity as well

Other Related International Activities:

EUROPEAN CENTRAL BANK - official letter by the Slovenian MEP about serious issues regarding the unjustified calculations on which the expropriations and nationalization of all Slovenian systemic banks were based - again no actual answer!

vzmd.newswire.com – Do the Slovenian authorities really only react to referendum initiatives?! - Due to complete disregard by the Government of the Republic of Slovenia, the VZMD is forced to continue the internationalization of the unique(!) bail-in restructuring of Slovenian banks together with mass expropriation and enormous damage to all taxpayers

THE SUPREME COURT - the highest ordinary court of law in Slovenia also bolstered the position of the VZMD: the law with which the self-proclaimed "domestic troika" nationalized as many as six of our banks is unconstitutional!

CALL FOR IMMEDIATE ACTION due to alarming advertising by financial intermediaries and detrimental effects of abolishing registry accounts which could lead to disappearance of 200,000 small investors and bring about catastrophic consequences for the issuers (public limited companies) and the entire capital market

vzmd.newswire.com – in view of the disregard of the Government and financial authorities in the Republic of Slovenia, the VZMD is compelled to point out to the burning issues of the bail-in restructuring of Slovenian banks along with the expropriation of shareholders and bondholders through international media

LUXEMBOURG - The reasoned opinion published today by the Advocate-General of the European Court of Justice reaffirm the arguments made by VZMD and the expropriated investors

EU Commission & Slovenian Government - European warnings due to detrimental consequences of expropriation and a call to resolve the untenable situation as soon as possible

BANKIA – a success of Spanish minority shareholders encourages also the expropriated share and bond owners in Slovenia – invitation to obtain compensation

PARIS – the highest representatives of European investors' associations were very interested in hearing the in-depth presentation by Mr. Kotnik and Mr. Verbič regarding the 'bail-in' procedures in the EU, and were extremely surprised by the unique and radical, downright disastrous violations and expropriations in the Republic of Slovenia

PARIS – in the General meeting of the European Federation of Investors, Mr. Kotnik and Mr. Verbič acquainted prominent international participants with the scandalous expropriation of shareholders and bondholders of Slovenian banks, activities and endeavors of the VZMD - PanSlovenian Investors' & Shareholders' Association

LUXEMBOURG – on Tuesday it was the first time for Slovenia to stand before the Grand Chamber of the European Court of Justice due to the expropriation of shareholders and bondholders of Slovenian banks

Slovenian EUR 264 million to pay off investors in shares and bonds of Greek banks as well – Slovenian authorities continue to thumb their nose at expropriated investors in Slovenian banks and their own taxpayers - BUT FOR HOW LONG!?!

EU COURT - prior to the pending public hearing in Luxembourg, new shocking facts have come out in regard to the background of the (dual) plunder of holders of shares and bonds of Slovenian banks and at the same time the plunder of all Slovenian taxpayers which rampantly keeps going on!

Slovenian EUR 264 million to pay off investors in shares and bonds of Greek banks as well – Slovenian authorities continue to thumb their nose at expropriated investors in Slovenian banks and their own taxpayers - BUT FOR HOW LONG!?!

EU COURT in Luxembourg should hold oral proceedings in the process of preparing responses for the Constitutional Court of the Republic of Slovenia - the motion of expropriated holders of subordinated bonds and shares of Slovenian Banks represented by VZMD put forward

BRUSSELS – European Federation of Investors (BETTER FINANCE) presented the only(!) objective Report on the real return of pension savings funds – the PanSlovenian Investors' & Shareholders' Association (VZMD) also actively espousing reforms of the pension savings and funds systems in the EU

EUROPEAN COMMISSION officially bolstered the position of VZMD stating that its »Banking Communication« is not a legally binding act - the Bank of Slovenia and Slovenian financial authorities insist on the exact opposite and in fighting against their own citizens they disgrace themselves by trying to apologize for scandalous measures and fallacies

THE NATIONAL ASSEMBLY unanimously responded to the VZMD's rationale and appeal - significant cost reduction for all minority shareholders and investors (approximately 400,000 citizens) with the new amendment to the amending act of the Book Entry Securities Act

THE COALITION'S AMENDMENT to a large extent follows the VZMD proposals to alleviate the catastrophic impact of the amending act of ZNVP-1, however yesterday VZMD sent a constructive opinion and another appeal to the National Assembly to make slight additional efforts in reaching an optimal solution

ANOTHER 260,000 EXPROPRIATED – VZMD has attempted to alleviate the abolishment of registry accounts by amending the Book Entry Securities Act through the COMPROMISE AMENDMENT AND APPEAL to the National Assembly of the Republic of Slovenia

The District Court and the Higher Court officially acknowledge VZMD arguments concerning the unconstitutionality of expropriations, however the proceedings have been suspended until the final decision has been reached by the Constitutional Court of the Republic of Slovenia, which contacted the EU Court in Luxembourg - VZMD has provided written standpoints thereto after a world-class EU law expert joined the team

ATTENTION - unveiling evidence against the unlawfulness of Slovenian banks valuations and the overblown "bank gap" as a foundation for billion euro damage to the state and its citizens, based on unlawful actions by Bank of Slovenia and its Emergency measures decisions

Is the European Commission attempting to obstruct the investigation and protect the responsible persons?! The unprecedented provocation opens plethora of grave issues about processes, structure and perspectives of the EU -

»PLUNDER OF THE CENTURY« - VIDEO CONFRONTATION & disclosure of misleading statements of the Bank of Slovenia, the previous Slovenian government and other protagonists of the highly questionable 2013 bank restructuring, involving mass expropriation of citizens

EU PARLIAMENT & COUNCIL – VZMD contended with the progress & results of harmonization of the Proposed directive for encouraging long-term shareholder engagement, but warns of completely different practices as well as catastrophic repercussions of the Slovenian proposed amendment to the Book Entries Securities Act which is linked to the same Directive

CONSTITUTIONAL COURT - VZMD also lodged a proposal for the temporary decree for PROHIBITING THE SALE OF Nova KBM bank - to prevent direct damage to the Republic of Slovenia and its citizens

BANK OF SLOVENIA – »a year later« with a new secret resolution continues the destructive policy, on the basis of an already stipulated »calculation« of negative capital - the deletion of all subordinated bonds and stocks, also in Slovenia's sixth bank

STRESS TESTS – new and obvious proof of the extremely unequal adjudication of Slovenian banks – are they guilty in Brussels or Ljubljana, and what are their motives? The PanSlovenian Shareholders' Association (VZMD) has called on the Bank of Slovenia (BA) and the European Central Bank (ECB) to explain, why only in Slovenia are we left to use »static« and extremely pessimistic assumptions, while in other countries and banks of the EU fresh data and »dynamic« valuations are used and even allow for

WARSAW - the evening award ceremony, the second day of the »Warsaw Capital Market Summit 2014« international conference and beginning of the conference organized by International Monetary Fund and National Bank of Poland with active participation of VZMD through investo.si and investo.international programs (Warsaw, October 2014)

BANK OF SLOVENIA / NLB - unprecedented deceit of renowned international financial companies and investors - VZMD informed them of concealed facts, in its endeavor of protecting investors, and called for inacting supervision, proper sanctions of those responsible, alleviation of consequences, and thus preservation of the remaining reputation of the Republic of Slovenia (Ljubljana, September 2014)

NEW YORK – VZMD President invited to be a guest-speaker at the Annual Conference of the International Financial Litigation Network (IFLN) yesterday – shortly after a successful business delegation in Iran, he also participated in a discussion in the world's financial centre with some distinguished international lawyers and representatives from key law offices regarding the scandalous expropriation of the owners of shares and bonds at Slovenian banks - an alarming case indicating problems in the (New York, May 2014)

EUROPEAN COMMISSION – a reminder to the EU Commission President J.M. Barroso about the unequal treatment of Slovenia, and about the endangered financial, economic and social stability accompanying scandalous expropriation of share and bond owners at Slovenian Banks – a letter of the Civil Society Initiative and NKBM Section at VZMD to the EU Commission President is soon to be presented in the European Parliament as well (Brussels, March 2014)

EXPROPRIATION – VZMD has filed three more lawsuits, this time against the banks, because the entry of subordinated bonds and shares termination in the register has been established as null – further use of all legal remedies to protect the expropriated owners, the signatories to the VZMD Agreement, and granting authority to the law office (Ljubljana, February 2013)

Slovenian Constitutional Court acknowledges the legal interest of 293 initiators united by VZMD who demanded a constitutional review of the Banking Act (Ljubljana, January 2013)

CONSTITUTIONAL COURT acknowledged the legal interest of 290 initiators, united by VZMD who demanded constitutional review of the Banking Act; the Court has given priority to the two VZMD initiatives but suspension of the Act was rejected, due to misleading statements by the Government and the Bank of Slovenia - shares and subordinated bonds of 100.000 owners had been erased in the three biggest Slovenian banks! (Ljubljana, December 2013)

EXCLUSIVE VIDEO REPORT about the week of the MOSCOW-VIENNA-CAPETOWN conferences involving the following: active participation of the international business-investment VZMD programmes, signing a memorandum with the Russian Federation of Investors, and protection of rights of the Slovene and European shareholders at the Viennese conference »The Financial Repression of Savers and Investors« (Moscow, Vienna, Cape Town, October 2013)

NKBM = BANKIA – mass protests take place in front of The Central Bank of Spain (CBS) because of national fraud against 350,000 shareholders who are represented by the law firm that is attending, along with VZMD (Pan−Slovenian Shareholders’ Association), the international initiative at CBS. (Madrid, September 2013)

WORLD BANK – President of VZMD and EuroFinUse Board Member speaker of the first panel at the international conference about audit reform and the importance of audit committees (Bucharest, June 2013)

VIDEO REPORT – exclusively from the European Parliament: the EuroFinUse international conference and the Election Assembly, the announcement of the new President and Board of directors of this influential European association, into which a representative of Slovenia is also re-elected (Brussels, March 2013)

BRUSSELS – Slovenia with VZMD once more elected to the top of the European Federation of Financial Services Users – intensive international activities today continue with a conference in the European Parliament (Brussels, March 2013)

TOKYO – conclusion of the visit of Slovene economic and political delegation with Slovenian-Japanese Business & Investment Forum and the reception at Japanese investors’ association – the active role of VZMD with its international investors’ programs investo.si and investo.international(Tokyo, March 2013)

INDIA – visit of Slovenian government and business delegation – on the basis of Memorandum between ICPE and VZMD international investors' programs investo.si and investo.international also present (New Delhi, February 2013)

Memorandum of cooperation signed between the International Center for Promotion of Enterprises (ICPE) and VZMD, with additional expansion of activities within the framework of international investment programs investo.si and investo.international (Ljubljana, January, 2013)

EXCLUSIVE VIDEO REPORT of “International Conference on Benefits and Challenges of Public Private Partnerships for improving Energy Efficiency” – key statements of prominent participants (Ljubljana, October, 2012)

EXCLUSIVE VIDEO REPORT from EuropeanIssuers International Conference on »The future of European Equity Markets« at the Milan Stock Exchange – programs investo.si in investo.international also at the upcoming International Investors´ Conference in Wiesbaden (Milano, November 2012)

VIDEO REPORT - International Conference at the Brussels Stock Exchange Stimulated Investors' Representatives and Institutions to Participate at the Investors' Week 2012 in September in Slovenia(Brussels, March 2012)

www.vzmd.si – More on the VZMD – PanSlovenian Shareholders' Association

www.vzmd.tv and www.investo.tv – Over 300 videos from VZMD.TV and investo.tv

www.investo.si – More on the investo.si – Invest to Slovenia Program

www.investo.international – More on the network of 55 national organizations of shareholders and investors