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Advisory Opinion Subpage

Informal Staff Advisory Opinion 98-6

… 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 qualifies for the fractional franchise exemption. 16 …
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 98-3

… we will address whether a secured, non-negotiable, promissory note due six months after the franchisee actually …
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 02-4

… Opinion Subpage This advisory opinion addresses the preparation of financial statements under the FTC's Franchise Rule. In its request, the California … of Corporations asks whether franchisors are required to prepare financial statements according to Generally Accepted …
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

… response to your request for our views on whether a not-for profit 501(c)(3) organization satisfies the definition of a …
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)

… with an individual must comply with the applicable provisions of the Fair Credit Reporting Act ("FCRA") …
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)

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)

… (03-03-98) Advisory Opinion Subpage Division of Credit Practices Bureau of Consumer Protection Clarke W. Brinckerhoff Attorney (202) 326-3224 …
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)

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)

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

9009008 Informal Interpretation

… 9009008 Informal Interpretation 9009008 Informal Interpretation (redacted) … of our view from the Federal Trade Commission ("FTC"). The facts are as follows: Our client, a private … considered unproved and undeveloped. We are aware that the FTC has consistently taken the position that transfers of …
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

… 9012009 Informal Interpretation 9012009 Informal Interpretation (redacted) December 14, 1990 Ms. Nancy M. Ovuka Compliance Specialist Federal Trade Commission Pre-Merger Notification Office Room 301 Sixth Street and …
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 Formal Interpretations

Formal Interpretation No. 7

… Formal Interpretation No. 7 Formal Interpretation No. 7 UNDER 16 C.F.R. … The status of such acquisitions is uncertain under the FTC's proposed regulations because it is unclear whether an … pursuant to section 4(c)(12).  Recommendation : The FTC should consider whether it should assert jurisdiction …
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)...
HSR Formal Interpretations

Formal Interpretation No. 14

… Formal Interpretation No. 14 Formal Interpretation No. 14 16 CFR Part 802 Premerger Notification: Reporting and Waiting Period …
Type of Formal Interpretation
Airlines (transactions between air carriers and others subject to HSR)
16 CFR Part 802 Premerger Notification: Reporting and Waiting Period Requirements AGENCY: Federal Trade Commission ACTION: Notice of Formal Interpretation SUMMARY: On November 14, 1988, the Federal...
HSR Formal Interpretations

Formal Interpretation No. 8

… Formal Interpretation No. 8 Formal Interpretation No. 8 BUREAU OF … the argument that I offered at AEI because I think that the FTC's responses that I see in BNA and have heard elsewhere … advice, presumably would not affect the result of the FTC investigation, but it could have a significantly …
Type of Formal Interpretation
Attorney-Client Privilege (assertion in Response to Information Required by the Form and in Response to a request for Additional Information or Documentary Material)
BUREAU OF COMPETITION September 13, 1979 John W. Barnum, Esquire White & Case 1747 Pennsylvania Avenue, N.W. Washington, D.C. 20006 Dear Mr. Barnum: This is in response to your March 1, 1979, letter...
HSR Formal Interpretations

Formal Interpretation No. 2

… Formal Interpretation No. 2 Formal Interpretation No. 2 BUREAU OF COMPETITION September 26, 1978 Mr. … Eighty Pine Street New York, New York 10005 Re: Formal interpretation of § 802.70 of the Hart-Scott-Rodino Antitrust …
Type of Formal Interpretation
Acquisitions Made Pursuant to an Order of Divestiture under §802.70
BUREAU OF COMPETITION September 26, 1978 Mr. Laurence T. Sorkin Cahill, Gordon & Reindel Eighty Pine Street New York, New York 10005 Re: Formal interpretation of § 802.70 of the Hart-Scott-Rodino...
HSR Formal Interpretations

Formal Interpretation No. 17

Type of Formal Interpretation
Banking and non-banking businesses under (c)(7) and (c)(8) as amended by the Gramm-Leach-Bliley Act
Premerger Notification: Reporting and Waiting Period Requirements AGENCY: Federal Trade Commission ACTION: Notice of Issuance of Formal Interpretation 17 SUMMARY: The Premerger Notification Office (...
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