1301016 Informal Interpretation

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.

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