Access to the information contained on this website may be restricted by laws and regulations applicable to the user. Persons to whom such restrictions apply must not access the Henley portal.
Welcome to the Henley investor portal (“Investor Portal”).
These terms (“Terms”) govern access to and use of the Investor Portal. You may not access or use the Investor Portal if you do not agree to these Terms.
You represent and warrant that you are at least 18 years of age and you are authorized to accept these Terms on your own behalf or behalf of any entity where you access or use the Investor Portal or any of the services accessed through it on their behalf.
Who we are and how to contact us
The Investor Portal is a service provided by Henley Investment Management Ltd (“HIML”) and Henley USA LLC (“HUSA”) (together "we", “us”, "our" and “Henley”) to selected customers and is available at https://portal.henleyim.com/ or such other address notified by us from time to time.
The Investor Portal is operated and owned by Henley.
HIML is registered in England and Wales under company number 06246854 and has its registered office at 50 Grosvenor Hill, London, England, W1K 3QT.
HIML is regulated by the Financial Conduct Authority (of the United Kingdom) (the "FCA") (under firm reference number 943587).
HUSA is a Securities and Exchange Commission Exempt Reporting Adviser Securities and Exchange Commission (of the USA) (the "SEC") (SEC#: 802-126468) and is organized under the laws of the state of Delaware.
You may contact us through the Investor Portal “contact us” or by contacting your Investor Relations Manager.
Investor Portal
The Investor Portal provides a range of information relating to your investments with Henley.
This includes investment information, reports and any bank account information (as is required to be provided in respect of each investment for the purpose of receiving income and/or proceeds or otherwise set out in your user profile, in each case in accordance with the Product Terms) (“Account Information”) as well as other confidential information (together “Confidential Information”).
In the United Kingdom, this Investor Portal is only intended for users capable of being classified as Professional Clients or Eligible Counterparties as defined in the FCA rules, Certified and Self-Certified High Net Worth and Certified and Self-Certified Sophisticated Investors as defined in the FCA rules as defined in the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005. Users not capable of meeting one of the above classifications must not use this platform.
In the US, this Investor Portal is only intended exclusively at users capable of being Accredited Investors within the meaning of the US Securities Act of 1933.
If you do not meet the above eligibility conditions, then you should not access this portal.
Disclaimer
The information and reports accessible on this Investor Portal about investments is derived from sources considered reliable and solely represents Henley’s own assessment of the information available at the time but no warranty, expressed or implied, by Henley, its affiliates, their directors or employees is given as to its accuracy or completeness nor does any of the foregoing assume any responsibility for any losses suffered in reliance on information and reports provided on this Investor Portal or as a result of any omission from such information and reports. Henley and its affiliates have no obligated to notify you of changes to information contained in reports.
Financial projections contained or referenced in information and reports about investments are illustrative only; none of the projections or assumptions should be taken as forecasts or promises on the part of Henley nor should they be taken as implying any indication, assurance or guarantee that those assumptions are correct or exhaustive.
Your attention is drawn to the fact that information and reports accessible on this Investor Portal relate to investments which are likely to be held on a medium to long-term basis and be of an illiquid nature. Participation in such investments may expose you to a significant risk of losing all money invested. Past performance is not an indication of future results and there is no compensation in respect of poor performance.
This Investor Portal and the information contained herein or any prior or subsequent communications from or with Henley should not be construed as legal, tax or business advice.
No reliance should be placed on this information in any decision to acquire or dispose of shares in any investment referred to herein. This Investor Portal and the information contained herein do not constitute and should not be construed as an offering of advisory services or an offer to sell or solicitation to buy any securities or related financial instruments in any jurisdiction in which such offer or solicitation, purchase or sale would be unlawful under the securities, insurance or other laws of such jurisdiction. Use of this Investor Portal implies acceptance of this condition. Whilst we seek to keep this Investor Portal up-to-date, the information displayed is subject to change without notice.
Information about Children
The Investor Portal is intended for use only by those who are 18 years of age or older. If you are between the ages of 13 (or the equivalent minimum age in your jurisdiction) and 18, you agree you will only use the Investor Portal under the direct supervision of a parent or legal guardian who agrees to be bound by the Terms. If you are younger than 13 years old (or the equivalent minimum age in your jurisdiction), you must not use the Investor Portal, and any such use is an express violation of these Terms.
There are other terms that apply to you
These Terms cover your use of the Investor Portal. All products and services provided by members of Henley group and each of your investments have their own terms and conditions (“Product Terms”). You must read and accept these Terms. To the extent that the Product Terms conflict with these Terms then the Product Terms will prevail.
These Terms refer to the following additional terms which also apply to your use of the Investor Portal:
• Our Privacy Policy, which provides additional information about you as an investor and how we may process your personal data.
• Our Cookie Policy, which sets out information about the use of cookies on the Investor Portal.
We may make changes to these Terms
We amend these Terms from time to time. All changes are effective immediately upon posting on our website. You can determine when the Terms were last revised by referring to the “Last Updated” notation above. Where we have valid email contact details for you we will notify you of any material change to these Terms. Every time you wish to use the Investor Portal, please check these Terms to ensure you understand the specific terms that apply at that time.
If you use the Investor Portal after the amended Terms have been posted, you will be deemed to have agreed to the amended Terms. By continuing to use the Investor Portal you accept the latest version of these Terms. If any of the provisions of these Terms are not acceptable to you, your sole and exclusive remedy is to discontinue your use of the Investor Portal.
We may make changes to the Investor Portal
We may update and change the Investor Portal from time to time. However, we have no duty to do so.
We may suspend or withdraw the Investor Portal
We do not guarantee that the Investor Portal will always be available or be uninterrupted. We may suspend or withdraw or restrict the availability of all or any part of Investor Portal for business and operational reasons. We will try to give you reasonable notice of any restriction, suspension or withdrawal.
In particular, we may restrict or withdraw the Investor Portal to prevent fraudulent or suspected fraudulent use.
The Investor Portal is provided on an "as is" basis. Henley makes no representation or warranty regarding the accuracy, reliability or completeness of the Investor Portal or any information provided through it.
Henley disclaims all terms not expressly set out in these Terms to the maximum extent permitted by law, including any term of non-infringement, quality, performance, merchantability, satisfactory quality, fitness for a particular purpose, security or accuracy.
How you may use material available through the Investor Portal
Ownership: The Investor Portal and its entire contents, features, and functionality (including, but not limited to, all information, software, text, displays, images, video, and audio, and the design, selection, and arrangement thereof) (“Content”) are owned by us, our licensors, or other providers of such material and are protected by United States and international copyright, trademark, patent, trade secret, and other intellectual property, or proprietary rights laws and treaties.
Intellectual Property: The trademarks used in connection with our business and/or displayed on this Investor Portal are owned by Henley and are protected by U.S. federal trademark laws and various international laws. You may not use or register, or otherwise claim rights in any Henley trademark, including as or as part of any trademark, service mark, company name, trade name, username or domain registration. The contents of this website, including the reports, surveys, commentary, letters, research, data analysis, written materials, testimony, photographs, videos, and other audio-visual materials, are also protected under U.S. copyright laws and various international laws and treaties. We actively enforce our intellectual property rights, and any unauthorized use of its intellectual property is strictly prohibited. Our trademarks or copyrights may only be used with our express written permission. Henley may revoke permission to use our trademarks or copyrights at any time.
Prohibited Uses: You are not permitted to reproduce, publish, transmit, distribute, display, modify, create derivative works from, sell or participate in any sale of, or exploit in any way, in whole or in part, any such content for commercial use. You will not use, or encourage or permit others to use, our Investor Portal except as expressly permitted in these Terms. You will not:
• Access or use the Investor Portal in any manner or for any purpose that infringes, misappropriates, or otherwise violates any intellectual property right or other right of any third party, or that violates any applicable local, state or federal law or regulation, or is prohibited by these Terms.
• License, sublicense, sell, resell, transfer, assign, distribute or otherwise commercially exploit or make available to any third party the Investor Portal or related materials in any way.
• Take any action or use the Investor Portal in any manner which could damage, destroy, disrupt, disable, impair, overburden, interfere with, or otherwise impede or harm in any manner our Investor Portal or any content, in whole or in part.
• Disrupt, interfere with, violate the security of, or attempt to gain unauthorized access to our Investor Portal or any computer network.
• Bypass, breach, avoid, remove, deactivate, impair, descramble, or otherwise circumvent any security device, protection, or technological measure implemented by us or any of our service providers to protect our Investor Portal.
• Remove, delete, alter, or obscure any trademarks, specifications, warranties, or disclaimers, or any copyright, trademark, patent, or other intellectual property or proprietary rights notices from our Investor Portal or any content made available to you on or through our Investor Portal.
• Copy, duplicate, download, store in a retrieval system, publish, transmit or otherwise reproduce, transfer, distribute, store, disseminate, aggregate, use as a component of or as the basis for a database or otherwise use in any form or by any means any data, text, reports, or other materials related to our or third-party content from the Investor Portal; or
• Encourage or enable any other individual to do any of the foregoing.
Permissible Uses: The Terms permit you to use the Investor Portal and its Content for only your personal use or your business’s internal use. You must not copy, reproduce, distribute, modify, create derivative works of, publicly display, publicly perform, republish, download, store, or transmit any of the material on our Investor Portal, except as follows:
• You may copy, reproduce, download, store, or transmit the financial information specific to your account, which was accessed through the Investor Portal.
• You may print or download one copy of a reasonable number of pages of the Investor Portal for your own personal use or your business’s internal use, and not for further reproduction, publication, or distribution.
• You may download or print or share content from this Investor Portal or social media features or take such actions as are enabled by such features, provided you link or refer to our original content.
• If we provide desktop, mobile, or other applications for download, you may download a single copy to your computer or mobile device solely for your own personal use or internal business use, provided you agree to be bound by our end user license agreement for such applications.
• You must not modify copies of any materials from our Investor Portal; use any illustrations, photographs, video, audio sequences, or any graphics separately from the accompanying text; or delete or alter any copyright, trademark, or other proprietary rights notices from copies of materials from this Investor Portal. In addition, you must not access or use any part of our Investor Portal, services, or materials available through the Investor Portal for commercial purposes.
• If you wish to make any use of the materials on the Investor Portal other than that set forth in this Section, please address your request through the Investor Portal: “contact us”.
You must keep your access details safe
If you choose, or you are provided with, a user identification code, password or any other piece of information ("Password") as part of our security procedures, you must treat such information as confidential. You must not share this information with or disclose it to any third party.
We have the right to disable any Password, whether chosen by you or allocated by us, at any time, if in our reasonable opinion you have failed to comply with any of the provision of these Terms.
If you know or suspect that anyone other than you knows your Password, you must promptly notify us at Investor Portal “contact us” or by contacting your Investor Relations Manager.
We will not be liable for any loss due to stolen or hacked passwords or for any access to Confidential Information or use of the Investor Portal by any person who gains access to your password.
Access
Access to the Investor Portal is restricted to you and to those you give access to in accordance with the written instructions you may give us to this effect through the Investor Portal “contact us” or by e-mail to your Investor Relations Manager. You acknowledge and agree that where you give access to the Investor Portal to one or several persons (each a “Delegate”), each such Delegate will be able to obtain your Confidential Information and allowed to amend your Account Information if you have opted to confer this right to the Delegate including the right to associate an account with one or several investments (“Account Association”). Henley and its affiliates shall not be liable for any access or amendment to or modification of your Confidential Information including Account Association or use of the Investor Portal by any Delegate or person given access by a Delegate or person given access by a person claiming to be a Delegate.
Except as set out above, you and your Delegates are expressly prohibited from providing access to the Investor Portal to any other person and you must not provide your access details and passwords to any other person.
We are not responsible for websites that are linked to through the Investor Portal
Where the Investor Portal contains links to other websites, services and/or resources provided by third parties, these links are provided for your information only. Such links should not be interpreted as approval by us of those linked websites or information you may obtain from them.
We have no control over the contents of those websites, services or resources.
Our responsibility for loss or damage suffered by you
We do not exclude or limit in any way our liability to you where it would be unlawful to do so. This includes liability for death or personal injury caused by our negligence or the negligence of our employees, agents or subcontractors and for fraud or fraudulent misrepresentation.
To the fullest extent permissible pursuant to applicable law, Henley and its affiliates shall not be liable to you for any claim, liabilities, losses, costs or damages under any legal or equitable theory, whether in contract, tort (including negligence), breach of statutory duty or otherwise, including, but not limited to, any indirect, punitive, special, incidental, or consequential damages, including lost profits, loss of data or loss of goodwill, service interruption, or system failure, or the cost of substitute products or services, in relation to these Terms or your use of the Investor Portal or any information or service obtained through the Investor Portal.
If, notwithstanding the other provisions of these terms, Henley or its associates are found to be liable to you for any damages or losses arising out of your use of, access to or inability to use the Investor Portal or any content provided by us or any third party, our liability shall in no event exceed U.S. One Hundred Dollars ($100.00 USD). Note that some jurisdictions do not allow limitations of liability or may place limitations on our ability to limit our liability to you, so the foregoing limitation may not apply to you.
Termination
We reserve the right to terminate your access to the Investor Portal without notice and at our sole discretion.
We are not responsible for viruses and you must not introduce them
We do not guarantee that the Investor Portal will be secure or free from defects, software errors or viruses.
You are responsible for configuring your information technology, computer programmes and platform to access the Investor Portal. You should use your own virus protection software.
You must not misuse the Investor Portal by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful. You must not attempt to gain unauthorised access to the Investor Portal, the server on which our site is stored or any server, computer or database connected to the Investor Portal. You must not attack the Investor Portal via a denial-of-service attack or a distributed denial-of service attack. By breaching this provision, you may commit a criminal offence under the Computer Misuse Act 1990. We may report any such breach to the relevant law enforcement authorities and we will
co-operate with those authorities by disclosing your identity to them. In the event of such a breach, your right to use the Investor Portal will cease immediately.
Which laws apply to any disputes?
As they relate to HIML, these Terms, their subject matter and their formation, are governed by the law of England and Wales. You and we both agree that the courts of England and Wales will have exclusive jurisdiction except that if you are a resident of Northern Ireland you may also bring proceedings in Northern Ireland, and if you are resident of Scotland, you may also bring proceedings in Scotland.
As they relate to HUSA, these Terms, their subject matter and their formation, are governed by the law of the state of Delaware. You and we both agree that the courts of Delaware will have exclusive jurisdiction over claims related to HUSA.
No waiver
No failure on our part to exercise or enforce any right or provision of the Terms shall constitute a waiver of such right or provision.
Interpretation
The headings and titles in these Terms are for convenience only and have no legal or contractual effect.
Copyright Infringement Claims
We reserve the right to remove any content or any other material or information available on or through our Investor Portal, at any time, for any reason. We otherwise comply with the provisions of the Digital Millennium Copyright Act (“DMCA”) applicable to Internet service providers (17 U.S.C. § 512, as amended), and responds to clear notices of alleged copyright infringement. If you have objections to copyrighted content or material made available on or through our Investor Portal, you may submit a notification to our Designated Agent
As set forth by Section 512(c)(3) of the Digital Millennium Copyright Act, your notification should contain the following information:
• A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;
• Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works at a single online site are covered by a single notification, a representative list of such works at that site;
• Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit the service provider to locate the material;
• Information reasonably sufficient to permit the service provider to contact the complaining party, such as an address, telephone number, and, if available, an email address at which the complaining party may be contacted;
• A statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent or the law; and
• A statement that the information in the notification is accurate and, under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
Section 512(f) of the Digital Millennium Copyright Act may impose liability for damages on any person who knowingly sends meritless notices of infringement. Please do not make false claims.
Henley (including other companies within our group) (“we” or “us”) is committed to protecting and respecting your privacy.
We collect, store and use information in accordance with the General Data Protection Regulation (the “GDPR”) and all other relevant legislation and regulations.
This policy sets out details of how we process data in relation to you. Some of the data we process will be personal data, which relates to and identifies you. Other data will be anonymous data. Please read this policy carefully to understand how we process both sorts of data.
For the purposes of the GDPR, we are the data controller of any personal data we process about you.
All changes to this policy will be posted here. You should visit this page regularly to stay up to date.
We may collect and process the following data about you:
Information you provide when you fill in forms on our website at www.henleyinvestments.com/investor-registration (“our site”), including information you provide when you register as a user, details you provide during the negotiations of a product or service(through call, email, post or on our website); copies of correspondence you send to us (including by post, email or through our site); your responses to surveys or questionnaires we ask you to complete; details of any transactions you carry out on or through our site; details of your visits to our site (including traffic data and data in relation to the resources you access); and information that we collect about your computer, including its IP address.
The majority of our processing of personal data is on the basis that it is necessary for the purposes of our legitimate interests. When you provide your personal details to us we use your information for our legitimate business interests to carry out our work and provide you with the latest information about our investment opportunities. Before doing this we have carried out a balancing test in order to carefully consider and balance any potential impact on you and your rights.
Where processing does not fall under legitimate interests we will store your data with the consent provided by you. Where you have actively given consent to us to process your information we will process the information for as long as necessary or until you withdraw your consent with us to process your data.
Where you have entered into an investment with us and we need to manage payments, fees and charges for you we will process this information under contractual basis and under the necessary legal obligation we are held to.
We use information held about you to:
Ensure the content of our site is presented in the best way for you and your computer; provide you with information about opportunities or services that you request or which we consider may be of interest to you (subject to the following section of this policy); perform our obligations under contracts between you and us; allow you to use the various features of our site; protect your account and limiting access to your account; and allow third parties to contact you about goods or services you might be interested in (subject to the following section of this policy).
Information we send you:
We send you information about our latest investment opportunities if you have requested this information or if you have entered into an investment with us or provided us with your information through the negotiation of a sale/service we provide.
You can opt out of receiving this information at any point either via unsubscribing directly on the information we send or by contacting subscriptions@henleyinvestments.com
We may aggregate information about you with information about other users of our site to create statistical data about users. This is anonymised statistical data that does not identify you and we may distribute any such aggregate information to third parties we work with.
We will only share personal information that we hold about you to third parties:
Who are companies within our group of companies; who provide services to us in connection with our site; to whom we sell or intend to sell any of our business or assets; or if we are legally obliged to disclose the information.
We will only retain personal data that we hold on you for as long as it is necessary for us to process the information. This length of time will depend on the purposes we hold the data for.
To determine the length of processing we consider the nature of the data, the sensitivity of the data, the potential risk/impact to you as the data subject and the purposes for which we are processing your data.
Please note that we are required to retain some information for up to seven years in order to comply with legal and regulatory requirements.
We have in place appropriate security measures on all systems where your data is held to prevent your data from being, accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We also limit access to your data only to those employees and appropriate third parties who have a legitimate business need to know.
We have in place appropriate procedures to deal with any data breaches to our systems and will notify you and all applicable regulators of a breach where we are legally required to do so.
1) Right to information
This right obliges us to inform you about what personal data we process and the rationale for such processing.
2) Right to access
This right entitles you to confirmation as to whether or not we are processing your personal data, and, where that is the case, with access to the personal data, as well as further specified information about the processing (such as the purposes for it, to whom the data have been or will be disclosed, and the right to lodge a complaint with the Information Commissioner's Office).
3) Right to rectification
This right provides you with the ability to ask for modifications to your personal data in case you believe that this personal data is not up to date or accurate.
4) Right to object
This right provides you with the ability to object to the processing of their personal data. Henley will stop processing personal data we hold on you, unless there are overriding reasons which mean it is necessary that we process this data.
5) Right to be forgotten
Also known as right to erasure, this right provides you with the ability to ask for the deletion of your data. This is not an absolute right, and there may be overriding reasons which mean that it is necessary to continue to hold the data.
6) Right to data portability
This right provides you with the ability to ask for transfer of personal data you have provided to us. As part of such request, you may ask for your personal data to be provided back to you or transferred to another controller. When doing so, Henley will provide your personal data in a machine-readable electronic format.
Cookies are small files placed on your device when you visit our site. We use cookies to recognise you and your preferences, improve the performance of our site and to create statistical data.
Cookies generally fall into one of the following categories:
Strictly necessary cookies which are cookies that are essential to allow you to use a website and its features; performance cookies which collect information about how visitors use a website to create aggregated, anonymous information that does not identify the visitor; functionality cookies which allow the website to remember you and provide a more personalised service; and targeting or advertising cookies which are used to deliver adverts relevant to you.
Our site uses the following types of cookies: strictly necessary cookies, performance cookies and functionality cookies.
Our Investor Portal uses Reporting Cookies and Functional Cookies.
Some of our cookies remain on your device between your browsing sessions.
You can disable our cookies by changing the settings on your browser but doing so might mean you are unable to use certain features of our site.
We store your data on our CRM system Salesforce, we apply all appropriate security measure to this system to ensure your data is protected.
Data we collect from you may be transferred to and stored in destinations outside the European Economic Area (“EEA”) and may be processed by staff operating outside the EEA. Non-EEA countries may not offer the same level of data protection as the United Kingdom. However we will take reasonable steps to ensure that any of your data transferred outside the EEA will be treated securely and in accordance with this privacy policy. Salesforce’s data processing addendum incorporates binding corporate rules, the EU-U.S. Privacy Shield, and the European Commission’s standard contractual clauses. The processing addendum means that Salesforce has provided adequate safeguards.
We will take all steps reasonably necessary to keep your data secure. You should be aware that transmission of information via the internet is not entirely secure and we cannot guarantee the security of any data you transmit to our site via the internet.
Due to the potential for losses, the Financial Conduct Authority (FCA) considers this investment to be very complex and high risk.
What are the key risks?
1. You could lose all the money you invest
• If the business offering this investment fails, there is a high risk that you will lose all your money. Businesses like this often fail as they usually use risky investment strategies.
• Advertised rates of return aren’t guaranteed. This is not a savings account. If the issuer doesn’t pay you back as agreed, you could earn less money than expected or nothing at all. A higher advertised rate of return means a higher risk of losing your money. If it looks too good to be true, it probably is.
• These investments are sometimes held in an Innovative Finance ISA (IFISA). While any potential gains from your investment will be tax free, you can still lose all your money. An IFISA does not reduce the risk of the investment or protect you from losses.
2. You are unlikely to be protected if something goes wrong
• [The business offering this investment is not regulated by the FCA. Protection from the Financial Services Compensation Scheme (FSCS) only considers claims against failed regulated firms. Learn more about FSCS protection here. [https://www.fscs.org.uk/what-we-cover/investments/]] or
[Protection from the Financial Services Compensation Scheme (FSCS), in relation to claims against failed regulated firms, does not cover poor investment performance. Try the FSCS investment protection checker here. [https://www.fscs.org.uk/check/investment-protection-checker/]]
• [The Financial Ombudsman Service (FOS) will not be able to consider complaints related to this firm] or [Protection from the Financial Ombudsman Service (FOS) does not cover poor investment performance. If you have a complaint against an FCA-regulated firm, FOS may be able to consider it]. Learn more about FOS protection here. [https://www.financial-ombudsman.org.uk/consumers]
3. You are unlikely to get your money back quickly
• This type of business could face cash-flow problems that delay interest payments. It could also fail altogether and be unable to repay investors their money.
• You are unlikely to be able to cash in your investment early by selling it. You are usually locked in until the business has paid you back over the period agreed. In the rare circumstances where it is possible to sell your investment in a ‘secondary market’, you may not find a buyer at the price you are willing to sell.
4. This is a complex investment
• This investment has a complex structure based on other risky investments. A business that raises money like this lends it to, or invests it in, other businesses or property. This makes it difficult for the investor to know where their money is going.
• This makes it difficult to predict how risky the investment is, but it will most likely be high.
• You may wish to get financial advice before deciding to invest.
5. Don’t put all your eggs in one basket
• Putting all your money into a single business or type of investment for example, is risky. Spreading your money across different investments makes you less dependent on any one to do well.
• A good rule of thumb is not to invest more than 10% of your money in high-risk investments. [https://www.fca.org.uk/investsmart/5-questions-ask-you-invest]
If you are interested in learning more about how to protect yourself, visit the FCA’s website here. [https://www.fca.org.uk/investsmart]
For further information about minibonds, visit the FCA’s website here. [https://www.fca.org.uk/consumers/mini-bonds