1404008 Informal Interpretation



802.1. 15 USC 18a(c)(1) – 7A(c)(1)
Michael Verne

No - I don't see any section of 802.1 that applies. If they were unproductive, they could be covered by 802.2(c). 7A(c)(1) would not apply, because we have limited the use of the statutory exemption to acquisitions of portfolios of financial instruments (e.g., loans, leases, servicing rights, etc.) that are not specifically exempted by 802.1-802.5.


From: (Redacted)
Sent: Wednesday, April l6, 2014 10:06 AM
To: Verne, B. Michael; Walsh, Kathryn

Subject: 802.1and 802.3

Are acquisitions of oil/gas reserves etc. potentially within 802.1 if the reserves are producing and if they otherwise exceed the thresholds in 802.3?

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