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Advisory Opinion Subpage

Informal Staff Advisory Opinion 97-9

… to your client's proposed dealership arrangement. In particular, you ask whether an option agreement enabling your …
This staff advisory opinion is issued in response to your recent request for our views concerning the applicability of the Federal Trade Commission's Franchise Rule, 16 C.F.R. Part 436, to your client...
Advisory Opinion Subpage

Informal Staff Advisory Opinion 99-1

… opinion is issued in response to your request for a clarification of Informal Advisory Opinion 98-5 (June 24, …
This staff advisory opinion is issued in response to your request for a clarification of Informal Advisory Opinion 98-5 (June 24, 1998). In that advisory, we addressed whether the payment of a share...
Advisory Opinion Subpage

Informal Staff Advisory Opinion 98-6

This staff advisory opinion is issued in response to your request for advice on whether your client's proposed affiliation program is covered by the Franchise Rule and, if it is, whether the program...
Advisory Opinion Subpage

Informal Staff Advisory Opinion 98-1

This staff advisory opinion is issued in response to your request for advice concerning the applicability of the Franchise Rule, 16 C.F.R. Part 436, to a vending machine locator. I. INTRODUCTION In...
Advisory Opinion Subpage

Informal Staff Advisory Opinion 98-3

This staff advisory opinion is issued in response to your recent request for advice concerning the Commission's Franchise Rule. 16 C.F.R Part 436. Specifically, we will address whether a secured, non...
Advisory Opinion Subpage

Informal Staff Advisory Opinion 96-5

This staff advisory opinion is issued in response to your request dated August 22, 1996, for our views concerning the possible retroactive application of the minimum payment requirement of the...
Advisory Opinion Subpage

Informal Staff Advisory Opinion 02-4

This advisory opinion addresses the preparation of financial statements under the FTC's Franchise Rule. In its request, the California Department of Corporations asks whether franchisors are required...
Advisory Opinion Subpage

Informal Staff Advisory Opinion 02-2

This staff advisory opinion is issued in response to your request for our views on whether a not-for profit 501(c)(3) organization satisfies the definition of a franchise under the Franchise Rule. I...
Advisory Opinion Subpage

Advisory Opinion to Allison (02-23-98)

… Brooks & Smith, LLC Suite 2400 230 Peachtree Street, N.W. Atlanta, Georgia 30303-1557 Re: Section 603(h) of the Fair … that enters into a bona fide independent contractor relationship with an individual must comply with the …
February 23, 1998 Mr. Herman L. Allison Contangy, Brooks & Smith, LLC Suite 2400 230 Peachtree Street, N.W. Atlanta, Georgia 30303-1557 Re: Section 603(h) of the Fair Credit Reporting Act Dear Mr...
Advisory Opinion Subpage

Advisory Opinion to Buchman (03-02-98)

… Opinion Subpage March 2, 1998 John A. Buchman, Esq. Holland & Knight 2100 Pennsylvania Ave., N.W. Suite 400 …
March 2, 1998 John A. Buchman, Esq. Holland & Knight 2100 Pennsylvania Ave., N.W. Suite 400 Washington, D.C. 20037 Re: Section 604 of the Fair Credit Reporting Act Dear Mr. Buchman: This responds to...
Advisory Opinion Subpage

Advisory Opinion to Schieber (03-03-98)

… Division of Credit Practices Bureau of Consumer Protection Clarke W. Brinckerhoff Attorney (202) 326-3224 March 3, 1998 Paul H. Schieber, Esq. Blank Rome Comisky & McCauley One Logan Square Philadelphia, PA 19103 Dear Mr. Schieber: … Advisory Opinion to …
Division of Credit Practices Bureau of Consumer Protection Clarke W. Brinckerhoff Attorney (202) 326-3224 March 3, 1998 Paul H. Schieber, Esq. Blank Rome Comisky & McCauley One Logan Square...
Advisory Opinion Subpage

Advisory Opinion to Goeke (06-09-98)

… Advisory Opinion Subpage Division of Credit Practices Clarke W. Brinckerhoff Attorney 202-326-3224 June 9, 1998 Ms. Gail Goeke LATHROP & GAGE 2345 Grand Boulevard Kansas City, MO 64108 …
Division of Credit Practices Clarke W. Brinckerhoff Attorney 202-326-3224 June 9, 1998 Ms. Gail Goeke LATHROP & GAGE 2345 Grand Boulevard Kansas City, MO 64108 Re: Criminal records checks -- FCRA §...
Advisory Opinion Subpage

Advisory Opinion to Beaudette (06-09-98)

June 9, 1998 Mr. John Beaudette Operations Manager Employment Screening Services 6th Floor South 9 Washington Spokane, WA 99204 Re: Sections 603(d)(1), 604(b), 606, 607(e), 609, and 610 of the Fair...
Advisory Opinion Subpage

Advisory Opinion to Islinger (06-09-98)

… Esq.  Jackson, Lewis, Schnitzler & Krugman Courthouse Plaza 60 Washington Street Morristown, New Jersey 07960-6844 …
June 9, 1998 David G. Islinger, Esq. Jackson, Lewis, Schnitzler & Krugman Courthouse Plaza 60 Washington Street Morristown, New Jersey 07960-6844 Re: Section 603(d) of the Fair Credit Reporting Act...
Advisory Opinion Subpage

Advisory Opinion to Poquette (06-09-98)

June 10, 1998 Ms. Mary Poquette Verifications, Inc. 920 Second Avenue South Suite 610 Minneapolis, Minnesota 55402 Re: Section 603(d) of the Fair Credit Reporting Act Dear Ms. Poquette: This is in...
HSR Informal Interpretations

1610004 Informal Interpretation

… detail and analysis.  We agree with the analysis you lay out immediately below.   Timothy (Ty) Carson Bureau of … manufacturers produce the final product using the name and labels of Company A. A portion, but not all, of the products …
Rule
Item 5
In this tolling agreement scenario, Company A should report in Item 5 the revenue for any sales that appear on the books of the US business of Company A, and do so using a wholesale NAICS Code.
HSR Informal Interpretations

9009008 Informal Interpretation

… exploration and development of oil and gas, is purchasing a large block of horizontallyor stratigraphically-severed oil … deeper wells (or any other wells, for that matter), no plant, equipment or other personal property, and no current, …
Rule
7A(c)(1)
9/17/90 Will advise (redacted) when he calls that we agree with his analysis and conclusion that the transaction is exempt. TH
HSR Informal Interpretations

9012009 Informal Interpretation

… The (redacted) project is an approximately 874 acre master-planned residential golf course community with secured … in the unincorporated area of (redacted). The Master Plan for (redacted) provides for the development of … 1,312 single family homes, a championship 18- hole Jack Nicklaus Signature golf course designed by Jack Nicklaus (Golf …
Rule
802.1(a)
Conclusion correct, but not for reasons cited. Exempt as realty in the ordinary course. Income stream incidental to sale of property & business of partnership which isdevelopment. Golf course "turnkey...
HSR Informal Interpretations

9104008 Informal Interpretation

… University. This letter confirms your conclusion that this latest transaction does not require an additional filing … (redacted) 4/16/91 - J/S says if original transaction took place, no need to file now for merger of (redacted)(renamed … with (redacted) who said original transaction had taken place and (redacted) now appoints all of (redacted)s …
Rule
801.1(c)(8)
See below
HSR Formal Interpretations

Formal Interpretation No. 7

… of the exemption provided by § 7A(c)(8) of the Clayton Act ("Act"), 15 U.S.C. § 18a(c)(8), and § 802.8 of … with the Federal Reserve Board ("Board") irrevocable declarations that the companies, through divestiture of their … by January l, 1981. The staff has determined that the regulatory oversight exercised by the Federal Reserve System …
Type of Formal Interpretation
Acquisitions By Certain Bank Holding Companies
UNDER 16 C.F.R. § 803.30 CONCERNING ACQUISITIONS BY CERTAIN BANK HOLDING COMPANIES Commission staff have recently received several requests for interpretation of the exemption provided by § 7A(c)(8)...
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