Legal Interpretations
Margin Requirements - 1996 Letters
September 25, 1996
Concerning applicability of the Board's margin regulations (Regulations G, T, U and X) to a broker-dealer registered with the SEC, in transactions of foreign stock involving the parent company, a foreign broker-dealer not registered with the SEC; where some of the transactions may involve U.S. customers. 12 CFR §§ 220.13, 220.15, 220.18(a), 220.18(c), and 220.18(e).
August 30, 1996
To Mr. Michael Becker opining that it is not necessary for investors who purchase notes in a transaction in compliance with SEC Rule 144A to register as Regulation G lenders. 12 CFR 207.3(a)(1). Published at FRRS § 5-385.35
August 15, 1996
Opinion that it is not necessary to collateralize a forward purchase agreement to repurchase issuer's own stock. 12 CFR 221.3(a)(1). Published at FRRS § 5-942.25
July 17, 1996
To Mr. George Simon concerning extensions of credit in excess of the fifty percent margin pursuant to the exception in section 221.6(f) of Regulation U. 12 CFR 221.6(f). Published at FRRS § 5-884.71
May 30, 1996
To Mr. Roger Blanc confirming that a non-U.S. person with a U.S. investment adviser or other fiduciary is a foreign person for purposes of section 220.16(b) of Regulation T. 12 CFR 220.16 (b).
February 20, 1996
To Mr. Bruce Czachor regarding the applicability of the Board's margin rules (Regulation T) to a proposed offering, on an installment basis, by the Province of Saskatchewan of common shares of a Canadian mining company. 12 CFR §§ 220.5(a) and 220.8(b)(1).
February 13, 1996
Concerning the withdrawal of margin stock, where the issuer's own stock is pledge to support a forward purchase by issuer of its own stock from a seller to address shareholder dilution issues. 12 CFR 221.3(f). Published at FRRS § 5-963
February 9, 1996
To Mr. Michael Avidon stating that a proposed revolving credit facility for National Securities Clearing Corporation (NSCC) would be exempt from Regulation U (12 CFR 221.6(f)) because stock collateral would be liquidated promptly (unless to do so would create a disorderly market), meeting the condition that the loan be repaid in the ordinary course of business upon completion of the transaction. Published at FRRS § 5-884.7