Rule(s):

 Item 6(c)(i) & 6(c)(ii)

Staff:

Michael Verne

Response / Comments:

 09/14/2011 – Same for 6(c)(ii)

 

Original Image File

 

From         Verne, B. Michael
To:             (Redacted)
Subject:   Item 6(c)(i)

You would only report minority holdings of entities that have US sales in the same industry as the target If the entity only has non-US sales, even if in the same industry, you would not report it