BLOG OF KNOWLEDGE

Reuters Available at http://arabnews.com/?page=6&section=0&article=128269&d=9&m=11&y=2009&pix=business.jpg&category=Business

KUALA LUMPUR: Islamic law should prevail over secular law when a Malaysian court hears Shariah finance matters, a religious scholar said, responding to uncertainty in the industry about how to deal with legal disputes. Dispute resolution is expected to be a key area for the $1 trillion Islamic finance sector as a fragmented regulatory framework and untested court systems push legal wranglings into unchartered territory.

The ability of civil court judges to adjudicate on Shariah matters and possible contradictions between secular and Islamic law are some issues that the industry is grappling with. Shariah adviser Engku Rabiah Adawiah Engku Ali said a Malaysian law requiring judges to refer Islamic law issues to national level Shariah advisers “should be indicative that the Shariah principle should prevail.” But Malaysian law does not make it clear that the Shariah should prevail in the event of a conflict with secular law, resulting in some uncertainty, she said. “That should be clarified by the legislative,” she said on the sidelines of a Shariah scholars conference recently.

Malaysia has the world’s largest Islamic bond market and is seen as a leading center for Shariah banking, alongside the Middle East. The relationship between Islamic and secular law is unclear. This is reflected in a 2004 case involving Shamil Bank of Bahrain where an English court refused to apply Islamic law to a murabaha contract, reasoning that two systems of law cannot govern one contract. Kuwait’s Investment Dar said in May it had defaulted on a $100 million sukuk registered in Bahrain and in the United States a court case is ongoing involving the sukuk issued by oil firm East Cameron.

Best Regards
ZULKIFLI HASAN
DURHAM, UNITED KINGDOM

Oslo, Norway.

By Zulkifli Hasan, Business Islamica Magazine. Available at: http://www.islamica-me.com/article.asp?cntnt=204

Malaysia has a very unique legislative framework consisting of mixed legal systems, namely common law and the Shariah. Common law principles are applied in the civil courts in almost all legal matters. Islamic law is practiced in the Shariah courts and only pertains to family matters and inheritance law. The Federal Constitution places Islamic banking matters under the jurisdiction of the civil court. Malaysia has achieved tremendous growth in developing the Islamic banking industry locally as well as internationally. This achievement is due to the comprehensive approach of the authorities as well as Islamic banking players, especially in legal aspects. The growth and development of the Islamic banking industry are supported through good governance and a comprehensive legal framework. It is essential to have a standard law of practice which harmonizes Shariah and civil law in the context of Islamic banking.

Finding Agreement

Common law originated in England. It is a system based on precedent derived from judgments by judges. Shariah refers to rules of Islamic law. Shariah governs many aspects of day-to-day life, including politics, economics, banking, business law, contract law and social issues. In Arabic, harmonization is known as Tawfiq, which means to bring one thing into harmony or agreement with another (two or more different types of ideas). In Malaysia, this can refer to the integration of Islamic and common laws. It is interesting to note that the issue of harmonization arose out of the negotiation leading to the formation of Malaysia in 1963. With a diverse historical, racial and cultural background, the process of harmonization in the country was carried out through modification of existing laws. Harmonization of Shariah and common law in the context of Islamic banking does not mean combining these two systems without taking Shariah principles into consideration; it refers to the implementation of common law principles which are not contrary to Islamic law. The existing laws that are in line with Shariah principles can be integrated to further strengthen the legal infrastructure of Islamic banking.

Reasons for Harmonization

Harmonization is more of a process than a goal. It is not combining Shariah and common law across the board, but only harmonizing certain disparities in selected areas. Harmonization is particularly necessary in the case of Islamic banking, especially when there are disputes between two or more parties that are brought to court. These disputes are heard in the civil court according to Schedule Nine, List 1 of the Federal Constitution. Since Islamic finance takes its place alongside conventional finance, there are many procedural laws and substantive legislation based on common law principles that relate to Islamic banking. A number of these existing laws are in line with Shariah principles and we do not need to enact new ones. In fact, a study performed by Pakistani scholars revealed that only a small portion of Pakistani civil law (which is quite similar to Malaysian law) is considered to be unIslamic. The process of harmonization of Shariah and common law in Malaysia relating to Islamic banking involves several elements:

Dual Banking System and Moderate Approach

Malaysia decided to introduce a dual banking system in which existing conventional banking is practiced side by side with the Islamic banking system. Malaysia Berhad started its operations as Malaysias first Islamic bank in 1983, beginning what can be considered the first phase of Islamic banking in Malaysia, which lasted until 1993. In 1993, the Central Bank of Malaysia introduced an interest-free banking scheme which allowed conventional banks to offer Islamic banking products through windows. Many conventional banks set up Islamic windows once this was introduced. This was the beginning of the second phase of development for Malaysian Islamic banks, which continues today as the country liberalizes its Islamic banking policies so as to enable us to lead the sector. These phases have been facilitated and supported by legal infrastructure built through several laws and directives, particularly the Islamic Banking Act 1983, the Banking and Financial Institutions Act 1989, the Central Bank of Malaysia (Amendment) Act 2003, other relevant statutory legislation, the Central Bank of Malaysias directives and court developments.

Federal List

In Malaysia, separate Islamic legislation and banking regulations exist side by side with those of the conventional banking system. Islamic banking was put under the Federal List since it refers to commercial dealings, although Islamic banking actually falls under the purview of Islamic law.

Islamic Banking Laws

The legal basis for the establishment of Islamic banks was the Islamic Banking Act (IBA) of 1983. The IBA gives the Central Bank of Malaysia power to supervise and regulate Islamic banks as it does other licensed banks. However, the IBA, with 60 sections divided into eight parts, is obviously very brief and it is regulatory rather than substantive in nature. Although the IBA is general and noncomprehensive, which has led to various interpretations, it does allow flexibility for Islamic financial institutions in their operations. For example, Section 2 of the IBA defines “Islamic banking business” as “banking business whose aims and operations do not involve any element, which is not approved by the Religion of Islam.” This section can be interpreted negatively or positively. The negative view is that the IBA does not stipulate how the section is to be understood in the context of Islamic banking. On the other hand, it could be understood that the purpose of such a general provision is to create a flexible approach to the implementation of Islamic banking. As a result, Islamic financial institutions in Malaysia may offer various banking products under multiple modes of financing based on Shariah principles. Malaysia has the distinction of being first in several issuances of Islamic bonds, including the first to issue a global sovereign Sukuk. Many Islamic banking products have been introduced in a range of sectors, such as financing for personal consumption, small to medium entrepreneurs or huge corporations. The increasing demand for Islamic products has driven tremendous growth in the Islamic banking sector. Moreover, non-Muslims have also been attracted to the Islamic products offered on the market. In responding to the demands of conventional banks to open Islamic counters, Section 124 of the Banking and Financial Institutions Act 1989 (BAFIA) was introduced, which allowed conventional banks to do Islamic banking business. They are required to establish Shariah committees to advise them on any matter related to Islamic banking or finance.

Amendment and Review of Laws

As the Islamic banking sector develops, there should be continuous revision of relevant laws. The Central Bank of Malaysia has several committees to review existing legislation, with the aim of removing impediments to the efficient functioning of the Islamic financial system.Apart from the IBA and the BAFIA, the Central Bank of Malaysia (Amendment) Act 2003 (CBA) has played a major role in terms of supervising and monitoring Islamic banking. The CBA mandates the National Shariah Advisory Council (SAC) as the sole authority for the civil courts pertaining to Islamic banking and finance. Section 16B (1) of the CBA 1958 provides that banks can establish an Advisory Council which would be the authority on Islamic law for the purposes of Islamic banking, finance and development finance, Takaful or any other business which is based on Shariah principles and is supervised and regulated by the Central Bank of Malaysia. The effect of the amendment is to ensure that any deliberation of the SAC will be binding in the court and should be followed by all Islamic financial institutions in Malaysia. Section 16 B (8) provides that, in any proceedings relating to Islamic banking or financial business before any court or arbitrator, if any question arises concerning a Shariah matter, the court or arbitrator may refer such question to the SAC. Rulings made by the SAC must be taken into consideration by the court, and if the reference was made by an arbitrator, be binding on the arbitrator. Another significant law in the implementation of Islamic banking is the Hire Purchase Act 1948 (HPA). The HPA only governs certain types of vehicles and it contains an element of interest. Due to the obstacles to meeting the requirement of the HPA, some Islamic banks opt to offer financing for vehicles based on the concept of Bay Bithaman Ajil. This creates problems for the bank in terms of repossession of vehicles in the case of default. Under the concept of Bay Bithaman Ajil, the bank cannot simply repossess the vehicle without a court order, while under the HPA, the bank may do it through notice of repossession. It is reported that the Central Bank of Malaysia has set up a working committee to study the requirements of an Islamic Hire Purchase Act. This act would cover not only vehicles but also financial leases of immovable property. Islamic banking products, especially for debt financing, involve trading transactions, while conventional banking products may only involve a loan transaction. Basically, this concerns the financing of houses, motor vehicles, land, consumer goods, cash line facilities, education financing packages and personal consumption. Trading transactions require two separate agreements, purchase agreements and selling agreements, and this results in double taxation. In order to stimulate the growth and development of the Islamic banking sector, the government introduced incentives for Islamic financial institutions through tax exemption. Any legal documentation that involves trading transactions will only incur normal tax, as provided under the Stamp Act 1948. This incentive is very effective and, in fact, debt financing is the biggest contributor in terms of growth and profit to Islamic financial institutions in Malaysia.

Coordination Between the National Shariah Advisory Council and the Court

In Malaysia, Islamic banking cases are under the jurisdiction of the civil courts. The issue here is the judges in civil courts face difficulties in understanding certain concepts and terms of Islamic finance. To address this problem, the Central Bank of Malaysia, with the cooperation of the judicial body, agreed to set up a special High Court in the Commercial Division known as the Muamalah Bench. All cases under code 22A filed in the High Court of Malaya are registered and heard in the High Court Commercial Division 4. This special court deals exclusively with Islamic banking cases.

Governance of Shariah Committees

The Central Bank of Malaysia has issued guidelines to regulate the governance of Shariah committees of Islamic financial institutions. According to the guidelines, Shariah committee members must have qualifications or possess necessary knowledge, expertise or experience in Islamic jurisprudence or Islamic transaction or commercial law. The guidelines also state that the SAC has the authority to decide on the Shariah compliance of any issue in Islamic finance.

The Impact of Harmonization

The impact of Malaysias harmonization approach can be seen through the achievement and growth of the Islamic banking sector in Malaysia as well as the recognition of its products worldwide. This could not have been accomplished if there were no effective and comprehensive legal mechanism for governing the implementation of Islamic banking. As Malaysia operates within both Islamic and common law traditions, the harmonization process is one of the best approaches to facilitate Islamic banking transactions.

For full article, click here:

HARMONISATION OF SHARI’AH AND COMMON LAW IN THE IMPLEMENTATION OF ISLAMIC BANKING AND FINANCE IN MALAYSIA

By Habhajan Singh Available at the Malaysian Reserve, November, 3rd 2009.

The International Council of Fiqh Academy has to relook at its internal processes in coming out with pronouncements related to Islamic finance and other matters, said a much-sought after Shariah scholar. In a blunt statement, Bahrain-born Shariah scholar Sheikh Nizam Yaquby said that the academy has to retain its past practice of a thorough and meticulous decision making process. “My concern is not just the tawarruq fatwa of the Fiqh Academy. My concern is with the entire process by which the Fiqh Academy is going about now,” he told The Malaysian Reserve yesterday.

In May, the academy made news within the Islamic finance fraternity when it slapped a ban on organised tawarruq, a decision which led to an initial spate of debate and discussion, but was eventually ignored by a majority of the market players. Tawarruq is a Shariah concept widely used in the Middle East, particularly for cash financing. The contract began picking up steam in Malaysia in the last few years, with local Islamic banks using it to structure new products to make them acceptable beyond Malaysian shores. Tawarruq means purchasing a commodity on a deferred price, and later selling it to a third party with the objective of obtaining cash, according to a definition by Bank Negara Malaysia (BNM).

This is not the first time that Nizam had publicly expressed his disssatisfaction with the manner in which the Fiqh Academy went about the tawarruq fatwa which was announced after a five-day session which ended on April 30 in Sharjah, United Arab Emirates. “If the Fiqh Academy wants to be respected, as it was, it has to go back to the due process that it used to do. To the due diligence on each sensitive matter, whether it was biomedicine, social, political or economics,” he said. It is not clear if the issue indicates potential tension between the Fiqh Academy and the Accounting and Auditing Organisation for Islamic Financial Institutions (AAOIFI), a standard setting body for Islamic finance institutions based in Bahrain.

The Fiqh Academy, an initiative of the Organisation of Islamic Conferences (OIC), is an influential international Islamic organisation. In the Islamic finance fraternity, though, the organisation commanding wider respect is the Accounting and Auditing Organisation for Islamic Financial Institutions (AAOIFI), a standard setting body for Islamic finance institutions based in Bahrain. Nizam, who is attending the Kuala Lumpur International Islamic Finance (KLIFF) 2009 conference, which began with the Islamic finance Shariah scholars’ muzakarah, sits on the Shariah supervisory board of AAOIFI. Locally, he sits on the CIMB Islamic Bank Bhd’s Shariah committee.

Fiqh Academy Meeting Nizam, who sits on Shariah boards of more than 40 banks globally, was present at the Sharjah meeting. It resolved that it is not permissible to execute both tawarruq (organised and reversed) because simultaneous transactions occur between the financier and the mustawriq, whether it is done explicitly or implicitly or based on common practice, in exchange for a financial obligation. This was done after the council reviewed research papers on tawarruq, its meaning and its type (classical applications and organised tawarruq), it had said.

Nizam viewed it differently, arguing that research on crucial matters, whether related to biotechnology, politics, social or Islamic finance, require time. “If a research paper, written hastily and introduced one hour before the session, how can people read it? There were 17 papers on tawarruq presented to the Fiqh Academy. “I have reviewed them now. Most of them say tawarruq is permissible. They are not against it. But there was no time to read and review it [during the session]. “Researchers were not even given time to explain. Those who wanted to discuss or debate the papers, they were not even given one minute each. “How can we reach a decision and bind the entire ummah, almost 1.5 billion people, on such a hasty decision?” he said. He added that the Fiqh Academy used to convene specialised conferences on each subject, allowing experts to give their views and suggestions, before issuing any decree. When asked about AAOIFI, Nizam said its standards go through a rigorous research. Elaborating the process, he said it begins with the preparation of a written research paper which is discussed at research committees. It is followed by a draft standard which goes to its 15-member Shariah council. “They study it carefully. It then goes back to public hearing. Each standard takes two to three years. This is the right way to do research,” he said.

Best Regards
ZULKIFLI HASAN
DURHAM, UK

Notes: It has been a long debate on the status of Tawaruq financing facility. Despite of its permissibility based on Shari’ah pronouncements made by respective Shari’ah boards including the AAOIFI, the Fiqh Academy of the Muslim World League has issued two resolutions at the 15th meeting on 31st October 1998 and 17th meeting on 13-17th December 2003 where the former approved all kinds of Tawarruq and the latter disapproved Tawarruq Munazzam. Finally, the Islamic Fiqh Academy of the OIC issued the final resolution on tawarruq at the 19th meeting in Sharjah, United Arab Emirates on 26-30th April 2009 which confirmed the impermissibility of tawarruq. Muhammad Nejatullah Siddiqi, a founding father of Islamic economic is of the view that Tawaruq is identical to interest based loans both from the functional and macroeconomic perspective and he concludes that tawaruq is a financial instrument whose mafasid (harms) are much greater than masalih (benefits) and therefore cannot be characterized as shari’ah-compliant. He listed down several mafsadah of Tawaruq and this includes creation of excessive debt; exchange of money with more money in future, which is unfair in view of the risk and uncertainty involved; debt proliferation, which is likely to gambling and speculation;greater instability in the economy; inflationary expansion;inequity in the distribution of income and wealth; inefficient allocation of resources. Another prominent Islamic economist, Munzir Kahf argues that tawarruq is worse than the practice of interest-based loan legally and economically. While I beg to differ with Sheikh Nizam Yaqubi on the issue of Tawarruq, I strongly affirm his view pertaining to the need of meticulous, rigorous and thorough research for any fiqhi verdicts.

With CEO of BMB Islamic, Dr. Humayon Dar.

Available at: http://gulfnews.com/business/banking/time-for-uae-to-rethink-dollar-peg-1.521680

It may be a good time now for the government to reassess the dollar volatility. The UAE should consider a fresh monetary policy, reducing its link with the US currency that has been declining in value.

As a result, the UAE and other Gulf currencies that are pegged to the dollar are losing value. The UAE, the Arab world’s second biggest economy, is part of the six-member Gulf Cooperation Council. It was also part of a planned monetary union till May this year when it walked away over a dispute. The move frees up its monetary policy from certain obligations.

“It may be a good time now for the government to reassess the dollar volatility,” Hamad Bu Amim, Director-General of the Dubai Chamber, told Gulf News. “We always link our monetary and fiscal policies with the United States.” It’s time to revisit that link, he said. “The Central Bank is applying different monetary tools and is not blindly following US policies. “Having said that, the dollar peg has served us well for the last three decades.”

The weak dollar might have helped the US economy — but it has affected other economies, and hurt some. “Evidently, this hedging tool is losing steam, really,” he added.

Costs getting lower

The current economic situation provides a better business environment for investors who could benefit from low cost base in starting up businesses, Hamad Bu Amim, Director-General of the Dubai Chamber, said. “The current lower property prices and rents and flat inflation creates a good investment climate for new investors,” Bu Amim told Gulf News.

“They can start businesses with a much lower start-up capital. Doing business is much cheaper now than a few years ago. Besides the expanded infrastructure at the airport, roads and highways, the opening of Dubai Metro — all strengthens Dubai’s attractions as a global hub. “That’s why we are celebrating Dubai’s business diversity by inviting the who’s who of Dubai at our inaugural Dubai Business Gala,” he said. The gala event, to be held tomorrow, will be attended by leading businessmen, dignitaries and top government officials offering everyone the opportunity to network and talk business.

Best Regards
ZULKIFLI HASAN
DURHAM, UK

Note: The entire GCC Countries, most of OIC countries and some economists claimed that 1/3rd of the countries in the world pegged their currency to dollar that has been declined in value. This is serious issue that needs to be resolved prudently as the currencies which pegged to the dollar are losing value out of nothing. GCC Countries and other OIC Countries should reassess their monetary policy so as to find other alternatives for their currencies stability tools. I strongly affirm the motion made by the Director General of Dubai Chambers.

OXFORD UNIVERSITY

Available at the Malaysian Reserve, Oct, 19, 2009.

The Court of Appeal, in a written judgement on the Bai Bithaman Ajil (BBA) case presided earlier by High Court judgde Datuk Justice Abdul Wahab Patail, had found that the judge had erred when equating profit with riba, misinterpreted a key definition in the Islamic banking regulations and had side stepped earlier rulings made by the Supreme Court. The written judgment is for the March 31 unanimous decision when the Court of Appeal reversed the earlier High Court decision that BBA contracts were contrary to Malaysia’s Islamic banking regulations, providing a relief to local Islamic banks that had earlier feared a potential spike in defaults of Islamic contracts, especially for home financing.

In the judgment dated Aug 26 and signed off by Justice Datuk Md Raus Sharif, he wrote that “judges in civil court should not take upon themselves to declare whether a matter is in accordance to the Religion of Islam or otherwise”, further adding “whether the bank business is in accordance with the Religion of Islam, it needs consideration by eminent jurists who are properly qualified in the field of Islamic jurisprudence.”

The judgment by Justice Md Raus, who sat together with justices Datuk Abdull Hamid Embong and Datuk Ahmad Maarop in a three-men panel, brings to closure the much-debated Abdul Wahab’s judgment in 2008 which probably triggered Bank Negara Malaysia (BNM) into making it mandatory for the courts to refer to the central bank’s Shariah Advisory council (SAC) when deciding on Shariah matters in Islamic banking and finance cases.

In the new Central Bank of Malaysia Act (CBA) 2009, which was gazetted on Sept 3, it now makes it mandatory for courts to refer to SAC for rulings concering Shariah matters. Section 56 provides states that where ‘in any proceeding relating to Islamic finance business before any court or arbitrator any question question arises concering a Shariah matter’, the court or the arbitrator shall take into consideration SAC published rulings or refer such questions to the council for its ruling. On top of that, CBA’s Section 57 makes it clear that SAC rulings shall be binding on the Islamic financial institutions, the court or the arbitrator.

The judgment, in favour of plaintiff Bank Islam Malaysia Bhd (BIMB), was for nine BBA contract cases, including the case of Bank Islam Malaysia Bhd v Ghazali Shamsuddin & 2 Others. The Malaysian Reserve first reported on Abdul Wahab’s judgment on Sept 8, 2008.

PROFIT AND RIBA
In one of the salient points in the 31-page judgment, Justice Md Raus said that Justice Abdul Wahab was plainly wrong when he equated the profit earned by BIMB as being similar to riba or interest.
“We have no hesitation in accepting that riba or interest is prohibited in Islam. But the issue at hand is whether such comparison between a BBA contract and conventional loan agreement was appropriate.
“With respect, we do not think so. This is because the two instruments of financing are not alike and have different characteristics. BBA contract is a sale agreement whereas a conventional loan agreement is a money lending transaction. The profit in BBA contract is different from interest arising in a conventional loan transaction. The two transactions are diversely different and indeed diametrically opposed,” he writes.

He also noted that the law applicable to BBA contracts is no different from the law applicable to loan given under the conventional banking.
“The law is the law of contract and the same principle should be applied in deciding these cases. Thus, if the contract is not vitiated by any vitiating factor recognised in law such as fraud, coercion, undue influence, etc. the court has a duty to defend, protect and uphold the sanctity of the contract entered into between the parties,” he said.

REWRITING CONTRACT
The justices also commented on Justice Abdul Wahab’s attempts to replace the sale price under the Property Purchase Agreement with an ‘equitable interpretation’ and substituting the obligation of customer to pay the sale price with a ‘loan amount’ and ‘profit’ computed on a daily basis, as Justice Abdul Wahab had expounded in Affin Bank Bhd. v Zulkifli Abdullah (Supra).
This, in the views of the Court of Appeal, was the act of “rewriting the contract for the parties”.
“It is trite law that the Court should not rewrite the terms of the contract between the parties that it deems to be fair or equitable,” writes Justice Md Raus.

WHAT IS ISLAMIC BANKING?
The judgment then commented on Abdul Wahab’s interpretation of ‘Islamic banking business’ in section 2 of the Islamic Banking Act (IBA) 1983 where the High Court judge had argued that if a facility is to be offered as Islamic to Muslims generally, regardless of their mazhab, then the test to be applied by a civil court must logically be that there is no element not approved by the Religion of Islam under the interpretation of any of the recognised mazhabs.
Here, Justice Md Raus writes that it is our view that judges in civil court should not take upon themselves to declare whether a matter is in accordance to the Religion of Islam or otherwise.
“As rightly pointed out by Suriyadi J (as he then was) in Arab-Malaysian Merchant Bank Bhd [2005] 5 MLJ 210 that in the civil court ‘not every presiding judge is a Muslim, and even if so, may not be sufficiently equipped to deal with matters, which ulamak take years to comprehend’.
“Thus, whether the bank business is in accordance with the Religion of Islam, it needs consideration by eminent jurists who are properly qualified in the field of Islamic jurisprudence,” he said.

PRECEDENTS
The Court of Appeal judgment also noted that the questions raised by Wahab Patail on the validity and enforceability of the BBA contracts is not novel and that it had been raised in previous cases and had been ruled upon.
It cited the case of Adnan bin Omar v Bank Islam Malaysia Berhad (unreported) where the Supreme Court upheld the validity and enforceability of the BBA contract. In that case, the Supreme Court accepted as correct and affirmed the judgment of Ranita Hussein JC.

Subsequently, it added that the validity and the enforceability of BBA contracts was again decided by this court in Datuk Hj Nik Mahmud Nik Daud v Bank Islam Malaysia Bhd [1998] 3 CLJ 605, and Bank Kerjasama Rakyat Malaysia Bhd v Emcee Corporation Sdn Bhd (Supra).
“From the above cases, it is clear that the validity and enforceability of the BBA contract had been ruled upon by the superior courts. It is trite law that based on the doctrine of stare decisis, a decision of a superior court is binding on all courts below it. The importance of this principle must not be taken lightly,” writes Justice Raus.

Best Regards
ZULKIFLI HASAN
DURHAM, UK

Note: Most predicted judgement by the Court of Appeal. Slight release to Islamic finance industry but continuous nightmare to Islamic banks’ customers. Despite of the High Court judgement was overruled by the Court of Appeal, the decision made by the learned judge at least effectively highlighted several significance issues on the actual implementation of BBA and signalled a strong message about the status of some controversial Islamic financial products.

Stratford, Birthplace of William Shakespeare