Carbon Trading Training for
visiting Caribbean Group
Guglielmo Cioni - Senior Expert
London 6 October 2010
Today’s Agenda
9:00 - Module 1. - Introduction
Introduction to Climate Change
International treaties and EU legislation
Flexible Mechanisms: Clean Development Mechanism (CDM) and Joint Implementation (JI)
Carbon Credits Markets: Primary and Secondary Markets
10:30 – 10:45: Coffee Break
10:45 - Module 2. Origination of Carbon Credits
Project Cycle for CDM and JI
12:00 - Module 3. Primary Market
The transaction: ERPA – Emission Reduction Purchase Agreement
Cost evaluation for a typical CDM Cycle
Case Studies
13:00 – 14:30 - Lunch Break
14:30 – Module 4. The Secondary Market
Trading Carbon Credits and Allowances on Exchange Platforms and OTC
Carbon Primary and Secondary Pricing
16:00 – Questions and Exercises
17:00 - Workshop closing
ERANOVA CLIMATE
a Swiss company, constituted of high profile, skilled professionals with long
experience and proven track record in private equity with successful exits, project
finance, carbon origination and trading, banking and project management.
Consulting – helping clients (mainly financial institutions like large banks with
extensive commercial customer bases) understand, measure and manage the
business risks associated with climate change policy and regulation
Financial advisory – helping project organisations source and structure funding for
clean technology projects in emerging economies, notably Latin America and South
East Asia. Effectively, project development organisations who have viable projects
eg. wind farms or hydraulic power plant, which need funding will approach Eranova
for help with identifying and acquiring finance from banks, private equity firms,
hedge funds, etc
Investment fund management – setting up and managing innovative investment
funds focused on the clean technology and carbon trading sectors.
Module 1. - Introduction
1. Introduction to Climate Change
2. International treaties and EU legislation
3. Flexible Mechanisms: Clean Development Mechanism (CDM) and
Joint Implementation (JI)
4. Carbon Credits Markets: Primary and Secondary Markets
1.1 Introduction to Climate Change
Video:
A Global Climate Change
1.1 Introduction to Climate Change
IPCC says:
1. No more than 2° C increase!
2. That means: No more than: 450 ppm (0,045%) of CO2 in the atmosphere
The world CO2 concentration in the atmosphere:
Pre industrial Era: 280 ppm
Today:
1.1 Introduction to Climate Change
1.1 Introduction to Climate Change
Beware! Not only CO2!
Other important GHGs
Methane: 1t CH4 = 21 tCO2eq
N2O: 1t N2O = 310 tCO2eq
HFCs, PFC: 1t HFC23 = 11,000 tCO2eq
SF6: 1t SF6 = 22,000 tCO2eq
1.1 Introduction to Climate Change
How much is it?
3,000 Gt of CO2 on Earth
How much are we throwing in?
27 Gt of CO2/y
Is it a lot?
75,000 times the weight of Empire State Building in NY
1.1 Introduction to Climate Change
What shall we do
Source ETP 2010 - IEA
1.1 Introduction to Climate Change
Source ETP 2010 - IEA
1.1 Introduction to Climate Change
How much it is going to cost?
Source WEO 2009 - IEA
1.1 Introduction to Climate Change
How much it is going to cost?
Source WEO 2009 - IEA
1.1 Introduction to Climate Change
Who is going to pay?
If we don’t do it
Everyone
The Stern Report (Sir N. Stern 2006) forecasts losses of 5 to 20%
of the World’s GDP due to Climate
Change Effects
Source WEO 2009 - IEA
1.1 Introduction to Climate Change
Who is going to pay?
Developed Nations Pledges:
100 USDbn/y until 2020 devoted to mitigation and adaptation measures
So far no clear evidence of such funding: Public? Private? Instruments?
Carbon Markets are the most tested tool to finance mitigation actions
Module 1. - Introduction
1. Introduction to Climate Change
2. International treaties and EU legislation
3. Flexible Mechanisms: Clean Development Mechanism (CDM) and
Joint Implementation (JI)
4. Carbon Credits Markets: Primary and Secondary Markets
1.2 International Treaties and
EU legislation
Under the UN Framework Convention on Climate Change negotiated at
the 1992 Earth Summit in Rio de Janeiro, nations committed to developing and
implementing climate protection measures "appropriate for the specific conditions of
each Party." In addition, industrialized ("Annex I") countries agreed to voluntarily
reduce their GHG emissions to 1990 levels by 2000. The Convention entered into force
in May 1994 and has been ratified by 186 countries including the United States. Very
few industrialized countries, however, have met the voluntary target. For instance, U.S.
GHG emissions have climbed nearly 15 percent since 1990
The 1997 Kyoto Protocol would significantly strengthen the Convention,
establishing binding emission targets for industrialized countries and establishing a
range of mechanisms to encourage cost-effective compliance. The emission targets, for
the period 2008 - 2012, average 5.2 percent below 1990 levels and range from 8
percent below (European Union) to 10 percent above 1990 levels (Iceland). The target
for the United States is 7 percent below 1990 levels.
1.2 International Treaties and
EU legislation
The Kyoto Protocol:
1. Commitments. The heart of the Protocol lies in establishing commitments for
the reduction of greenhouse gases that are legally binding for Annex I countries,
as well as general commitments for all member countries.
2. Implementation. In order to meet the objectives of the Protocol, Annex I
countries are required to prepare policies and measures for the reduction of
greenhouse gases in their respective countries. In addition, they are required to
increase the absorption of these gases and utilize all mechanisms available, such
as joint implementation, the clean development mechanism and emissions
trading, in order to be rewarded with credits that would allow more greenhouse
gas emissions at home.
3. Minimizing Impacts on Developing Countries by establishing an adaptation fund
for climate change.
4. Accounting, Reporting and Review in order to ensure the integrity of the
Protocol.
5. Compliance. Establishing a Compliance Committee to enforce compliance with
the commitments under the Protocol.
1.2 International Treaties and
EU legislation
Kyoto Protocol
Annex I parties and commitments
Source: UNFCCC
1.2 International Treaties and
EU legislation
Kyoto Protocol
Caribbean Countries
Participant
Signature
ANTIGUA AND
BARBUDA
16 Mar 1998
Ratification
Acceptance (A)
Accession (a)
Approval (AA)
Entry into force
3 Nov 1998
16 Feb 2005
BAHAMAS
9 Apr 1999 a
16 Feb 2005
BARBADOS
7 Aug 2000 a
16 Feb 2005
26 Sep 2003 a
16 Feb 2005
30 Apr 2002
16 Feb 2005
DOMINICA
25 Jan 2005 a
25 Apr 2005
DOMINICAN REPUBLIC
12 Feb 2002 a
16 Feb 2005
GRENADA
6 Aug 2002 a
16 Feb 2005
HAITI
6 Jul 2005 a
4 Oct 2005
28 Jun 1999 a
16 Feb 2005
8 Apr 2008 a
7 Jul 2008
BELIZE
CUBA
15 Mar 1999
JAMAICA
SAINT KITTS AND
NEVIS
SAINT LUCIA
16 Mar 1998
20 Aug 2003
16 Feb 2005
SAINT VINCENT AND
THE GRENADINES
19 Mar 1998
31 Dec 2004
31 Mar 2005
7 Jan 1999
28 Jan 1999
16 Feb 2005
TRINIDAD AND
TOBAGO
1.2 International Treaties and
EU legislation
Kyoto Protocol
Caribbean Countries
Emissions
Tot. 132 Mt CO2
(Million Metric Tons of Carbon Dioxide)
Country
2005
Bermuda
0.63
Antigua and Barbuda
0.65
Aruba
1.13
Bahamas, The
4.91
Barbados
1.53
Belize
0.97
Cuba
28.62
Dominica
0.09
Dominican Republic
17.46
Grenada
0.25
Guyana
1.69
Haiti
1.76
Jamaica
11.24
Netherlands Antilles
10.82
Saint Kitts and Nevis
0.14
Saint Lucia
0.38
Saint Vincent/Grenadines
0.20
Suriname
1.97
Trinidad and Tobago
39.25
2006
0.66
0.66
0.93
5.00
1.49
0.99
28.64
0.10
17.42
0.27
1.65
1.79
12.03
10.90
0.14
0.38
0.20
2.01
47.23
Source EIA - USA
1.2 International Treaties and
EU legislation
Kyoto Protocol
National communication
Example of emission data
Jamaica
National Focal Point
Country
Person
Ministry/Organiz
Address
ation
Jamaica
Ms. Sylvia
McGill, Director
Ministry of Health
and
Environment
P.O. Box 103 65
¾ Half Way Tree
Road Kingston
10
Phone
(1-809)960-8990
Fax
(1-809)960-8989
Email
wxservice.dir@c
wjamaica.com/me
tja@infochan.com
1.2 International Treaties and
EU legislation
EU Legislation: The EU ETS – Emission Trading Scheme
1.2 International Treaties and
EU legislation
European Union (EU)
• Within EU
–
–
•
27 Member states
23 countries have Kyoto
targets as “Annex B” parties,
Malta and Cyprus do not have
targets
Original 15 EU Member States
have
– Collective Kyoto target of (8%
below 1990 levels), but
– Differentiated responsibilities
under the EU Burden Sharing
Agreement
1.2 International Treaties and
EU legislation
EU Burden Sharing
Agreement
1.2 International Treaties and
EU legislation
EU Climate Change Policy
Overall EU Goal: Reducing its overall emissions to at least 20%
below 1990 levels by 2020
•
EU is using a portfolio of policies to meet goal across all sectors through the EU Climate
Change Program (ECCP)
–
–
–
–
•
Cross-cutting cap and trade
Regulation
Incentives
Voluntary approaches
Updated goals and binding measures for ECCP portfolio announced January 23, 2008:
–
–
–
Energy supply measures: increase share of renewable energy to 20% by 2020
Energy demand measures: 20% reduction in energy consumption through energy efficiency
Transportation, buildings, agriculture: reduce emissions 10% below 2005 levels
•
•
–
Commitments by car makers to reduce CO2 emissions rate from new passenger cars by 25% below 1995
levels by 2008/2009
Increase share of sustainable biofuels to 10% of overall petrol and diesel consumption
Improved EU ETS
Source: Point Carbon, European Climate Change Program, http://ec.europa.eu/environment/climat/eccp.htm
1.2 International Treaties and
EU legislation
• The EU ETS is one of the policies to tackle
climate change
• Why Emissions Trading?
– Way of reducing emissions at least cost to industry
– offers industry more flexibility than ‘traditional’
regulation
– Offers incentives for industry to go beyond what is
expected of them
– Overall environmental impact the same
1.2 International Treaties and
EU legislation
EU and the Kyoto Protocol
• EU as whole is a Party to the Kyoto Protocol and agreed to 8%
reductions
• In 1998 the then EU 15 agreed a burden sharing agreement
• All 27 MS have ratified Kyoto, 23 have emission targets as
Cyprus and Malta are non-Annex 1 Parties
• Ranging from a 21% reduction for Germany, 12.5% reduction
in the UK and a 15% increase for Spain
• Most new Member States have set a target of 8% below base
level, with the exception of Hungary and Poland – 6% below
1.2 International Treaties and
EU legislation
Relevant EU Decisions
•
•
•
•
EU Emission Trading Directive
Registry Regulation
Linking Amendment (CDM and JI)
Monitoring Mechanism (Kyoto Reporting and
Registries)
• Monitoring Guidelines
1.2 International Treaties and
EU legislation
How does the EU ETS work?
• “Cap and trade” system with Carbon dioxide as the
only Green House Gas
• First phase runs until December 31st 2007
• 2nd phase in line with 1st Kyoto Protocol
commitment period, 2008-2012
• Mandatory for certain activities as energy activities,
ferrous metals, mineral industry and pulp and paper
• Allowances freely tradable throughout EU
• One allowance = one tonne of CO2e
1.2 International Treaties and
EU legislation
Monitoring and reporting
• Calendar year reporting of emissions
• 28th February each year - each participant receives
allocation of allowances (year X)
• End of March final report of Emissions (X-1)
• By end of April following year- each participant must
surrender number of allowances equal to annual
reportable emissions (X-1) these allowances then
cancelled
• Operator needs sufficient allowances in account to
cover emissions
1.2 International Treaties and
EU legislation
Options for Participants
• Annual emissions exactly equal to the number of
allowances given each year
• Decrease emissions and sell surplus
• Let emissions remain high and buy extra allowances
needed to cover the gap
• Penalty per tonne of excess emissions
– €40 (2005-2007)
– €100 (2008-2012)
• Still have to bring account into compliance
1.2 International Treaties and
EU legislation
Transactions in the EU ETS
1.2 International Treaties and
EU legislation
EU ETS Market
• Price volatility
• Prior to 2005 driven by political dimension
• First Phase Market to understand and come
into line with fundamentals
• Uncertainty regarding CDM credits, EU
connection to ITL and EU Phase II
1.2 International Treaties and
EU legislation
Review of EU ETS Directive
• Commission Review to improve function and design post 2012
• Priority areas include
–
–
–
–
–
–
expansion to other sectors and gases
the most appropriate process for setting the cap;
harmonised allocation methodology (including CHP);
linking to other schemes at national and regional level;
robust compliance;
streamlining – small emitters and harmonised definitions
• Report from the EU Commission, surveys and papers
1.2 International Treaties and
EU legislation
EU Trading Directive
EU-25
UK
Trading
sector
Non
trading
sector
Sweden
Non
trading
sector
EUA
Trading
sector
1.2 International Treaties and
EU legislation
Linking Directive
Annex I countries ratified the
Kyoto protocol
EU-25
JI
JI
Non-annex I countries ratified
Kyoto protocol
CDM
Countries that haven’t ratified
the Kyoto protocol
EUA
ERU
CER
1.2 International Treaties and
EU legislation
Kyoto Transactions
Module 1. - Introduction
1. Introduction to Climate Change
2. International treaties and EU legislation
3. Flexible Mechanisms: Clean Development
Mechanism (CDM) and Joint Implementation (JI)
4. Carbon Credits Markets: Primary and Secondary Markets
1.3 CDM and JI
1997: Marrakech Accords
Flexible Mechanisms
CDM
Clean Development Mechanism
JI
Joint Implementation
Goals of CDM
1. Facilitate the transfer of clean practice and technology to developing countries
2. Incentive for developed countries to invest in Emission reduction projects in
developing countries
3. Streamline financial flows to project activities that reduce emissions
4. Allow for cost efficiency in emission reductions
5. Build a rigorous regulatory architecture for the generation of Carbon Credits
6. Build a knowledge base for projects and policies
1.3 CDM and JI
CDM IN SHORT
Monitoring
&Verification
Emission Reduction
Project in a Non
Annex I Country
CDM Procedure
Eligibility
Sale of CERs
Entity in Annex
I Country
CERs
1.3 CDM and JI
CDM: Figures
More than 5,000 CDM Projects in Pipeline
More than 8 USDbn worth of primary transactions
More than 2,300 CDM Projects Approved
182 Methodologies
Around 1 bn CERs expected to be generated before 2012
1.3 CDM and JI
CDM Project Types and Methodologies
Methane
CO2
Renewable Energy
Energy Efficiency
Landfill Gas
Associated Gas (oil fields)
Animal Manure
Industrial Gases
N2O destruction from Adipic acid and Nitric
acid production plants
HFC destruction in Cooling gases plants or
poliurethane injection plants
1.3 CDM and JI
CDM Program of Activities
Replacement of
Light bulbs with
CFL in cities and
districts
Replacement of electric
engines with more efficient
ones in industrial sectors
Distributed renewable
energy production in houses
and buildings
Very complicated and under
development
1.3 CDM and JI
CDM Projects in the Caribbean
6 project registered: OK!
3 Terminated: Too Bad!
6 at validation: we’ll see…
Title
Pine Ridge Landfill Gas to Energy Project
Energas Varadero Conversion from Open Cycle to Combined Cycle
Methane capture and destruction on Calle 100 landfill in Havana and
Cabo Engaño Wind Project
Juancho – Los Cocos wind farm project, 100 MW
El Guanillo wind farm in Dominican republic
Bionersis project on La Duquesa landfill, Dominican Republic
CEMEX Dominicana. Blended cement project.
CEMEX Dominicana: Alternative fuels and biomass project at San
Steam Generation Using Biomass
Textile Offshore Site Dominicana Biomass Residues Cogeneration
Guyana Skeldon Bagasse Cogeneration Project
Blend increasing in the cement production of Caribbean Cement
Wigton Wind Farm Project (WWF)
Host country
Province / State
Bahamas
Grand Bahama
Island
Cuba
Matanzas
Cuba
Havana city &
Dominican
La Altagracia
Dominican
Barahona &
Dominican
Monte Cristi
Dominican
Santo Domingo
Dominican Republic
San Pedro de Macorís
Dominican
San Pedro de
Dominican
Santo Domingo
Dominican
Monseñor Nouel
Guyana
East BerbiceJamaica
Saint Andrew
Jamaica
Manchester
Status
At Validation
Type
Landfill gas
Registered
Registered
Validation
Validation
Registered
Registered
At Validation
At Validation
At Validation
At Validation
Registered
Validation
Registered
EE supply side
Landfill gas
Wind
Wind
Wind
Landfill gas
Cement
Cement
Biomass energy
Biomass energy
Biomass energy
Cement
Wind
Sub-type
Landfill power
Single cycle to combined cycle
Landfill power
Wind
Wind
Wind
Landfill flaring
Klinker replacement
Klinker replacement
Agricultural residues: rice husk
Agricultural residues: rice husk
Bagasse power
Klinker replacement
Wind
Module 1. - Introduction
1. Introduction to Climate Change
2. International treaties and EU legislation
3. Flexible Mechanisms: Clean Development Mechanism (CDM) and
Joint Implementation (JI)
4. Carbon Credits Markets: Primary and
Secondary Markets
1.4 Carbon Credits Markets
Buying and selling carbon credits
Credits: what credits?
Compliance Credits - CERs
Carbon Credits
Voluntary Credits - VERs
1.4 Carbon Credits Markets
Markets - what markets?
Primary non Guaranteed
Secondary non Guaranteed
Secondary Guaranteed
Usually offtake contracts
Delivery qty non guaranteed
No penalties for the seller
Seller is usually project owner or developer
Projects are early stage
From projects or portfolios
Delivery non guaranteed
Can be offtake or portions of
total delivery
Seller is sometimes the
developer or the primary
buyer
Contracts are for specified
guaranteed delivery quantity
Seller bears penalties
OTC or Exchange traded
1.4 Carbon Credits Markets
Who’s buying
Primary non Guaranteed
Who’s selling
Project Owners
Carbon Funds
Project Developers
Compliance buyers
Banks
Secondary non Guaranteed
Aggregators
Governments
Primary buyers
Banks
Carbon Funds
Carbon Funds
Secondary Guaranteed
and Aggregators
Banks
Industries
1.4 Carbon Credits Markets
What is a Carbon Fund
Technology
$
Technology
$
Finance
Investor
Companies
CO 2Equivalent
Emission Reductions
Carbon Fund
Finance
Project Owners in
Dev. Country or
Economies in
Transition
CO Equivalent
2
Emission Reductions
1.4 Carbon Credits Markets
Exchange Prices
1.4 Carbon Credits Markets
Exchange Prices – Historical
Origination of Carbon Credits
Project Cycle for CDM and JI
2. Project Cycle for CDM and JI
CDM project cycle
Average duration 18 months
Project
feasibility
assessment
Project
development
(PDD)
DNA
DOE
Host county
approval
Project
validation
Emission reduction projects must undergo
a rigorous process of documentation and
approval, in order to generate carbon
credits
Projects must follow a baseline and monitoring
methodology
 Development time for a new methodology:
over 1 year
Project additionality is key
Project
registration
Crediting period
DOE
Project
verification
Project
certification
CERs
 Ensures that the project would not be
implemented without carbon credits support
and does not create additional emissions
CDM project cycle is led by UNFCCC, while the
voluntary credits involves just DOEs
Kyoto Protocol comes to an end in 2012, yet post2012 Funds already exist, signalling confidence
in a future international regime
2. Project Cycle for CDM and JI
The Project Design Document (PDD)
• An official component of the CDM project cycle
• Official standardized template is available from the UNFCCC website
• Covers all the information essential for ‘carbon layer’ assessment
• Incorporates significant project thinking – project design, partnerships,
funding, revenue and cost forecasts, due diligence, sensitivity analysis, etc.
• The PDD is validated by a Designated Operational Entity and describes the
baseline and monitoring methodology that must be carried out
• PDDs are public documents
2. Project Cycle for CDM and JI
The DNA and host country approval
• The Designated National Authority (DNA) is the legal entity authorised to sign a Letter
of Approval (LoA) for a CDM project
• Typically an inter-ministry agency (Environment, Economy, Energy, Meteorology, etc.)
with a small secretariat
• The DNA provides written approval that the CDM project assists in achieving the
country’s sustainable development
• The details of the approval procedure are up to each country
• Typically, 3 broad development criteria are employed:
Economic: the project has a positive effect on economic development
Environmental: the project leads to reduced pressure on the environment
Social: the project has positive effects on social development
2. Project Cycle for CDM and JI
Project validation
• A required ‘pre-approval’ step for CDM project registration
• Undertaken before the project crediting period, and (typically) before
implementation / construction of the project
• Requires assessment of the assumptions, calculations, methodologies and
justifications relating to the baseline scenario
Is the project truly additional?
Will the greenhouse gas emission reductions be monitored and
calculated appropriately?
2. Project Cycle for CDM and JI
Project validation
Undertaken by Designated Operational Entities (DOEs):
–
Essentially audit companies:
–
Confirm that the PDD conforms to CDM requirements and
correctly applies the baseline methodology and greenhouse
gas quantification procedures
–
Check calculations are accurate and assumptions are
reasonable in the PDD
–
Confirm that the project satisfies the additionality
requirement
–
Make the PDD available for public review
DOEs submit the PDD to the CDM Executive
Board for registration (together with Letter of
Approval from the DNA)
2. Project Cycle for CDM and JI
Project Verification
• Undertaken after the CDM project has been implemented and has started to
generate greenhouse gas reductions.
• Typically requires rigorous data collection, testing and evaluation of evidence
to present a complete audit trail
• Essentially, seeks to confirm two things:
1. that past greenhouse gas performance has been appropriately calculated and
reported
2. that the project has been executed in accordance with the validated PDD
• Verification is undertaken by a DOE – but not the one that performed the
validation
Verification can take place as often as the
project developer wishes – represents a
balance between cost and revenue
2. Project Cycle for CDM and JI
Certification and CER issuance
•
•
•
•
The DOE provides a verification report to the project participants and the
executive board. The report is made publicly available.
The verification report constitutes a request for issuance to the Executive
Board of CERs equal to the verified amount of reductions of anthropogenic
emissions by sources of greenhouse gases.
The issuance of CERs is considered final 15 days after the date of
receipt of the request for issuance. • The Executive Board then instructs the
CDM registry to issue the specified quantity of CERs in the CDM registry:
a. A Share of Proceeds (SOP-Admin) fee is deducted
b. 2% of the total CERs are deducted as a “SOP-Adaptation fee”
c. The remaining CERs are forwarded to the registry accounts of the project
participants involved
Module 3. Primary Market
1.
The transaction: ERPA – Emission Reduction Purchase Agreement
2.
Case Studies
3.
Cost evaluation for a typical CDM Cycle
3.1 The transaction: ERPA
Emission Reduction Purchase Agreement
The Transaction
Process
PIN
Term Sheet
Annual verification
Issuance of CERs
Due Diligence
Project Operation
Payment and transfer of CERs
To the Buyer
ERPA
PDD
Validation
Registration
3.2 Cost evaluation for a typical CDM Cycle
CDM Cycle Costs
PDD
Validation
CDM Project Management
Registration Fee (SOP Admin to EB)
Verification Report
Issuance (SOP Adaptation)
5,000 – 25,000 EUR
20,000-45,000 EUR
10,000-20,000 EUR
0.2 USD* CER/y
15,000 EUR
2% of issued CERs
…….
Contigencies, Intermediation, etc.
About 20% of above
3.2 Cost evaluation for a typical CDM Cycle
CDM Cycle Main Risks
Validation Negative
PDD
Validation
CDM Project Management
Rejection after Validation
Registration Fee (SOP Admin to EB)
Delays in the process
Delays in project implementation
Changes in project performance
UNDER DELIVERY
5,000 – 25,000 EUR
20,000-45,000 EUR
10,000-20,000 EUR
0.2 USD* CER/y
Price Vs. Risks/Uncertainities
GCERs
DISTANCE
NGCERs
Counterparty risks
PRICE DISCOUNT
Counterparty Risks
Project Risks
Regulatory Risks
Delivery Risks
Module 4. The Secondary Market
1.
Trading Carbon Credits and Allowances on Exchange Platforms and OTC
2.
Carbon Primary and Secondary Pricing
4.1 Trading Carbon Credits and Allowances on
Exchange Platforms and OTC