1. All policies, directives, guidelines, orders, or similar records related to the submission of requests for the deregistration of pension funds administered by Liberty and made by Liberty Corporate, or parties contracted by Liberty Corporate, to the FSB between 2007 and 2014.
2. Copies of any and all records, or part of records related to Liberty’s accounting for financial provisions for dormant and/or inactive pension funds of which Liberty was the administrator.
3. Copies of any and all insurance policies issued by Liberty to wholly underwritten pension funds of which Liberty was the administrator.
4. A copy of the report dated 8 February 2012 by KPMG on its investigation into the merits of the allegations made by Michelle Mitchley to the FSB in 2011 in regard to the conduct of Liberty employees and contractors and FSB employees;
5. A copy of each report by Liberty to the FSB/FSCA on the conduct of Liberty’s
‘Backlog Project’.