1301012 Informal Interpretation

us-ftc-hsr-informal-interpretations-24705ebc61759ff6cd095fbc6b9817fb1301012 Informal InterpretationGuidance

Date
Rule
Form Item 4(c)
Staff
Michael Verne
Response/Comments
Both required regulatory filings and voluntary presentations are not responsive.

Question

From:

(Redacted)

Sent:

Wednesday, January 16, 2013 8:14 PM

To:

Verne, B. Michael; Walsh, Kathryn

Subject:

4(c) and Regulatory Presentations

Mikeand Kate,

Whatis the current position regarding 4(c)/(d) responsiveness of presentations madeto other U.S. regulators? Back in the day, I recall the PNO's position was thatrequired regulatory filings were not responsive to 4(c) but voluntarypresentations to other regulators could be responsive if they had 4(c) content.But are such presentations now considered in the same (non-responsive) categoryas public-facing documents, rating agency presentations, lender presentations,etc.? I wasn't able to find any recent informal opinions on this question.


Complete printed PDF page 1

Complete printed PDF page 2

Continue your research in ChatGPT or Claude

Connect Omnilex to search the legal corpus from your AI assistant.