1907006 Informal Interpretation

Date:

Tags:

Rule:
801.21
Staff:
Nora Whitehead
Response/Comments:

Confirmed.

Question

From: Whitehead, Nora


Sent: Friday, July 19, 2019 1:08:25 PM (UTC-05:00) Eastern Time (US & Canada)


To: [Redacted]

Cc: [Redacted]


Subject: RE: restricted cash question

Confirmed.

From: [Redacted]


Sent: Friday, July 19, 2019 12:19:51 PM (UTC-05:00) Eastern Time (US & Canada)


To: [Redacted]


Cc: [Redacted]


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

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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