Legal Interpretations
Margin Requirements - 1997 Letters
December 4, 1997
To Mr. Robert Kecseg stating that, under the definitions of Regulation T (12 CFR 220.2), any security listed on the Boston Stock Exchange is a "margin security" for purposes of Regulation T.
August 29, 1997
To Mr. Kevin Moynihan concerning the application of Regulation T (12 CFR 220.8) to a same-day purchase and sale transaction in the cash account portion of a customer's asset management account. If the customer has sufficient money market fund value in the account on trade date to cover the purchase, the firm need not redeem the money market fund shares to pay for the purchase and then reinvest the sale proceeds in money market fund shares. This opinion supercedes two previous opinions, dated June 12, 1987 (FRRS 5-615.951), and April 7, 1988 (FRRS 5-615.954), to the extent they are inconsistent.
July 31, 1997
To Mr. Peter Knoll concluding that a bank loan meets the definition of "purpose credit" under Regulation U (12 CFR 221.2), because the loan is to acquire all shares of a corporation whose principal asset is 57 percent of the shares of a company whose stock is margin stock; thus the ultimate purpose of the loan is to acquire the margin stock owned by the target corporation.
June 10, 1997
To Messrs. Goldman and Smith, concerning loans to be extended by U.S. banks and other lenders to finance the acquisition of a United Kingdom company whose securities are registered on the New York and London stock Exchanges. The staff's opinion was that, based on the facts presented, these transactions would not be presumed to be indirectly secured by the margin stock of the target under the Board's 1986 Interpretation under Regulation G (12 CFR 207.112), regarding "Purchase of debt securities to finance corporate takeovers"
April 7, 1997
To Mr. David Russoff regarding the application of Regulation T (12 CFR 220) to a broker-dealer who accepts a customer's bank-issued credit card as payment for the purchase of securities.
February 25, 1997
To Mr. Kevin Hiniker regarding the margin status of purchasers of certain privately-placed notes; specifically, whether the notes are "indirectly secured" by margin stock pursuant to section 207.2(f) of Regulation G.