1304006 Informal Interpretation

Date:
Rule:
15 USC 18a(c)(2) – 7A(c)(2)
Staff:
Michael Verne
Response/Comments:

Exempt.

Question

From: (Redacted)
Sent: Friday, April l2, 2013 2:20 PM
To: Verne, B. Michael
Subject: Commercial MBS

Hi Mike,

1 hope you are well. I am wondering if commercial mortgage backed securities might be an exempt asset for HSR purposes, given that mortgages are an exempt asset. Two entities are forming a JV LLC and contributing these CMBS to it.

About Informal Interpretations

Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

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