In this report we highlight two governance risks at HAL Trust: 1) the headquarters of HAL Holding and HAL Trust seem to be nothing more than letterbox entities at tax havens like Curaçao and Bermuda and 2) the complicated layering of BoDs and supervisory boards combined with overlapping members provide little protection for minority investors in the stockCombining both factors, we expect HAL Trust's discount to structurally widen over time vs. it's long-term average of ~10%. Today, the firm is trading closer to our old target discount of 25%. With that hurdle nearly reached, and the governance risks at hand,