Structured Thoughts - Volume 2, Issue 16 - December 15, 2011


In this issue: Proposed Amendments to OCC Regulations; Taxation of Financial Instruments; FINRA Sweep Letter; Circuit Breaker Proposals; ISDA/SIFMA Challenge Position Limits; and SEC Extends Comment Period for Conflict of Interest Rules.

Excerpt from "Proposed Amendments...":

In November 2011, the U.S. Office of the Comptroller of the Currency (the “OCC”) proposed amendments to Part 16.6 of its securities offering rules. These rules govern the exemption from OCC registration of certain types of offerings of bank notes. The proposed rules are designed to remove the references to credit ratings in Part 16.6.

Bank notes enjoy an exemption from registration under Section 3(a)(2) of the Securities Act of 1933 (the “Securities Act”). However, national banks and U.S. federal branches and agencies of non-U.S. banks are subject instead to the OCC’s registration rules, which require OCC registration of bank note offerings unless an exemption is available. A widely used exemption from OCC registration is Part 16.6, which is applicable for offerings of non-convertible investment grade debt.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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