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Federal Register Notice

Notice of Roundtable to Aid Federal Trade Commission Staff Conduction a Study of the Accuracy and Completeness of Consumer Reports, Pursuant to Section 319 of the Fair and accurate Credit Transactions Act of 2003

… a Study of the Accuracy and Completeness of Consumer Reports, Pursuant to Section 319 of the Fair and accurate … a Study of the Accuracy and Completeness of Consumer Reports, Pursuant to Section 319 of the Fair and accurate … a Study of the Accuracy and Completeness of Consumer Reports, Pursuant to Section 319 of the Fair and accurate …
Date
HSR Informal Interpretations

0406001 Informal Interpretation

… contract acquisitionsfrom the sub-dealers meets the reporting threshold. However, Company A's … agreement and the ancillary trademark license is areportable event. You indicated that it is not because it … implies that Company A is acquiring any potentiallyreportable asset from Company B. You stated that it does …
Date
Rule
801.2
Agree
HSR Informal Interpretations

0405008 Informal Interpretation

… held in an existing sub, will be sold toC in a non-reportable transaction. Moments later, the remainder of H … as acquiring H?), and (2) the appropriateway for H Corp. to report its earnings in Item 5 of the Notification and ReportForm (should existing sub be included or excluded?). …
Date
Rule
801.2
910 H acquires 100% of L. (2) Backside acquisition of 54% of H by holding co. Apply continuum only step2 is reportable. N Ovuka concurs.
HSR Informal Interpretations

0405006 Informal Interpretation

… as to whether a contemplated transaction was subject to the reporting requirements of the Hart-Scott-Rodino Antitrust … acquisition of the Portfolio Assets would be subject to the reporting requirements of the Act. You advised me that such …
Date
Rule
7A(c)(1)
Agree. UPDATE: December 9, 2021: This no longer represents the positon of the PNO. Section 7A(c)(1) does not exempt the assets underlying the exempt financial instrument, such as a lease. Another...
HSR Informal Interpretations

0405002 Informal Interpretation

… yourinput regarding whether the following transaction is reportable: Two companies, A and B, entered intoa power … A or B. It is my view that thiscontractual exercise is not reportable because its a simple contractualassignment and …
Date
Rule
801.10
Stepping into an existing contract is the acquisition of an asset, but its only value is whatever premium is being paid to step in. Since there is no premium in this case, there is no value. N Ovuka...
HSR Informal Interpretations

0405001 Informal Interpretation

… B. Accordingly, if the acquisition of Sub is potentially reportable, Iwould have to aggregate the value of its voting …
Date
Rule
802.4
The minority v/s interest would not count toward the $50MM limitation for non-exempt assets under 802.4, but the partnership assets and contractual rights would. If the rights are valued at $25MM or...
Federal Register Notice

Related Identity Theft Definitions, Duration of Active Duty Alerts, and Appropriate Proof of Identity Under the Fair Credit Reporting Act - 16 CFR Parts 603, 613, and 614

… and Appropriate Proof of Identity Under the Fair Credit Reporting Act - 16 CFR Parts 603, 613, and 614 Federal … and Appropriate Proof of Identity Under the Fair Credit Reporting Act - 16 CFR Parts 603, 613, and 614 R411011 … and Appropriate Proof of Identity Under the Fair Credit Reporting Act - 16 CFR Parts 603, 613, and 614 …
Date
HSR Informal Interpretations

0404017 Informal Interpretation

… $50 million. Consequently, the transaction appears to be nonreportable.Since the transaction has the following … of an option to acquire voting securities isexempt from reporting, although the eventual exercise of the option ispotentially reportable (assuming the relevant size tests) is met and no …
Date
Rule
7A(c)(3)
Agree.
HSR Informal Interpretations

0404013 Informal Interpretation

… not view an indemnity reinsurance transaction as a reportableevent. This position is consistent with several … Commission viewsan assumption reinsurance transaction as a reportable event if the transactionmeets the "size of …
Date
Rule
801.10
Agree n Ovuka concurs.
Federal Register Notice

Disposal of Consumer Report Information and Records - 16 CFR Part 682

… Disposal of Consumer Report Information and Records - 16 CFR Part 682 Federal Register Notice Disposal of Consumer Report Information and Records - 16 CFR Part 682 R411007 040420disposalofconsumer.pdf … Disposal of Consumer Report Information and Records - 16 CFR Part 682 …
Date
Amicus Briefs

Cole v. U.S. Capital, Inc. et al.

… of the court, the FTC argues that, although the Fair Credit Reporting Act permits a business to obtain a consumer report if it provides the consumer with a firm offer of …
Date
Citation Number
03-3331
Federal Court
U.S. Circuit Court of Appeals for the Seventh Circuit
In this amicus brief, filed at the invitation of the court, the FTC argues that, although the Fair Credit Reporting Act permits a business to obtain a consumer report if it provides the consumer with...
HSR Informal Interpretations

0404005 Informal Interpretation

… weconcluded that filing of a Premerger Notification and Report Form will not berequired in this case. Termsof … that theacquisition would be exempt from the HSR Act reporting requirements as anacquisition in the ordinary … is how Company B describes its activities in SIC filingsand reports its earnings. Looking at the nature and substance of …
Date
Rule
802.1
Agree
HSR Informal Interpretations

0404007 Informal Interpretation

… Anticipated scenario. I think thistransaction would not be reportable. This is an LLC formation with thecontribution of … controlling interest in Target), the LLC formation isnot reportable under Formal Interpretation 15. The back end … that alternative scenario, the transaction stillis not reportable under Formal Interpretation 15. The formation of …
Date
Rule
7A(c)(3), 802.10
Agree with all except alternative ??? under proposed rules. As long as the shareholders take back interests in the new LLC pro rata to their holdings in target, the transaction would be exempt under...
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