1907006 Informal Interpretation

1
Sheinberg, Samuel I.
From:
Sent: 	Friday, July 19, 2019 1:08 PM
To: 	Walsh, Kathryn E.; Berg, Karen E.; Carson, Timothy; Sheinberg, Samuel I.; Six, Anne;
Olson, Eric
Subject: 	FW: restricted cash question
From: Whitehead, Nora
Sent: Friday, July 19, 2019 1:08:25 PM (UTC-05:00) Eastern Time (US & Canada)
To:
Cc:
Subject: RE: restricted cash question
Confirmed.
From:
Sent: Friday, July 19, 2019 12:19:51 PM (UTC-05:00) Eastern Time (US & Canada)
To:
Cc:
Subject: restricted cash question
Dear all,
We are writing to confirm whether restricted cash (money reserved for specific purposes) falls under 801.21 as cash or
cash equivalent. We’ve seen an old interpretation that supports this understanding but wanted to confirm. Thank you.
https://www.ftc.gov/enforcement/premerger‐notification‐program/informal‐interpretations/9201003