Similarities and differences exist between the
US Model X Forms and Europe’s LMA
Private placements have continued to offer a useful
financing alternative in both the US and European markets. The
development in the US of the American College of Investment
Counsel's (ACIC) model form note purchase agreements is
accepted as one of the contributing factors to the successful
standardisation and growth of the US private placement market.
The ACIC Model X Form No. 1 Note Purchase Agreement (Model X
Form 1) and Model X Form No. 2 Note Purchase Agreement (Model X
Form 2 and, together with Model X Form 1, the Model X Forms),
governed by New York law, have become industry standard in the
US market and are often adapted for use in cross-border
transactions. Historically, most investors participating in
these types of transactions have been US-based insurance
companies or pension funds. As a result,...