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ARTICLE · 09 SEPTEMBER 2009

OCC Issues Three Interpretive Letters Concerning Collective Investment Funds

Goodwin Procter LLP
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The OCC released three interpretive letters concerning collective investment funds established pursuant to 12 C.F.R. § 9.18.

United StatesFinance and Banking

Developments of Note

  • OCC Issues Three Interpretive Letters Concerning Collective Investment Funds
  • FinCEN Issues Guidance On Determining Eligibility For Exemption From Currency Transaction Reporting Requirements
  • FASB Proposes Updates To Fair Value Disclosures
  • ERISA Stock Drop Claims Dismissed Against Citigroup Where Plan Mandated Investment In Sponsor Stock

DEVELOPMENTS OF NOTE

OCC Issues Three Interpretive Letters Concerning Collective Investment Funds

The OCC released three interpretive letters concerning collective investment funds established pursuant to 12 C.F.R. § 9.18.

OCC Interpretive Letters 1119 And 1120

Interpretive Letters 1119 and 1120 are addressed to the same bank (the "Bank"), a trustee for index and model-drive collective investment funds established pursuant to 12 C.F.R. § 9.18. An affiliate (the "Affiliate") of the Bank proposed to acquire a business that provided various fixed-income indices. The Bank requested confirmation

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