| Letters Released June 12-23: |
Date: |
Position: |
| Chase Manhattan Corp. |
6/15/00 |
Chase would like to see an expansion of the exemptions as well as a number of details with regard to dates, values of stocks and clarity of phrasing. |
| Salomon Smith Barney Inc. |
6/13/00 |
This broker-dealer would like to see larger safe harbors and proposes a few changes to the way the safe harbors would work. Salomon would also like to see exemptions to accommodate corporate clients in their relationships with financial conglomerates. |
| Bond Market Ass'n. |
6/12/00 |
BMA would like to add a number of exemptions to this rule for issuers with substantial bargaining power and unrelated service provided by affiliates of an underwriter. BMA would also like to extend safe harbors and allow special securities to be given to underwriters. |
| Securities Industry Ass'n. |
6/9/00 |
SIA argues that there should be an exemption from the rule for larger transactions. This letter also offers specific suggestions for improving safe harbors. |
| Morrison & Foerster L.L.P. |
5/26/00 |
This law firm has a number of concerns with respect to compensation and the inclusion or exclusion of fees. The firm also would like clearer definitions of certain terms and clear examples of how stock conversion relates to and effects actions under this rule. |