Margin Requirements
1996 Letters
- September 25, 1996
- Concerning applicability of the Board's margin regulations
(Regulations G, T, U and X) to a broker-dealer registered with the SEC, in
transactions of foreign stock involving the parent company, a foreign broker-dealer not
registered with the SEC; where some of the transactions may involve U.S. customers. 12
CFR §§ 220.13, 220.15, 220.18(a), 220.18(c), and 220.18(e).
- August 30, 1996
- To Mr. Michael Becker opining that it is not necessary for investors who purchase notes in a
transaction in compliance with SEC Rule 144A to register as Regulation G lenders. 12 CFR
207.3(a)(1). Published at FRRS § 5-385.35
- August 15, 1996
- Opinion that it is not necessary to collateralize a forward purchase agreement to
repurchase issuer's own stock. 12 CFR 221.3(a)(1). Published at FRRS § 5-942.25
- July 17, 1996
- To Mr. George Simon concerning extensions of credit in excess of the fifty percent margin
pursuant to the exception in section 221.6(f) of Regulation U. 12 CFR 221.6(f). Published at
FRRS § 5-884.71
- May 30, 1996
- To Mr. Roger Blanc confirming that a non-U.S. person with a U.S. investment adviser or
other fiduciary is a foreign person for purposes of section 220.16(b) of Regulation T. 12 CFR
220.16 (b).
- February 20, 1996
- To Mr. Bruce Czachor regarding the applicability of the Board's margin rules (Regulation T)
to a proposed offering, on an installment basis, by the Province of Saskatchewan of common
shares of a Canadian mining company. 12 CFR §§ 220.5(a)
and 220.8(b)(1).
- February 13, 1996
- Concerning the withdrawal of margin stock, where the issuer's own stock is pledge to support
a forward purchase by issuer of its own stock from a seller to address shareholder dilution
issues. 12 CFR 221.3(f). Published at FRRS § 5-963
- February 9, 1996
- To Mr. Michael Avidon stating that a proposed revolving credit facility for National Securities
Clearing Corporation (NSCC) would be exempt from Regulation U (12 CFR 221.6(f))
because stock collateral would be liquidated promptly (unless to do so would create a
disorderly market), meeting the condition that the loan be repaid in the ordinary course of
business upon completion of the transaction. Published at FRRS § 5-884.7
Legal interpretations
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