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ARTICLE · 02 APRIL 2009

Update on H-1B Issue for TARP/TALF Recipients

Mayer Brown
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On March 31, 2009, the Federal Reserve Board issued guidance stating that only the entity that directly borrows from a Federal Reserve Bank is a "recipient of funding."

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Originally published April 1, 2009

Keywords: update, H-1B Issue, TARP, TALF, Federal Reserve Board, FRB, recipient of funding, credit facilities, visa restrictions

On March 31, 2009, the Federal Reserve Board issued guidance stating that only the entity that directly borrows from a Federal Reserve Bank is a "recipient of funding." If the borrower is a special purpose entity, then any entity that owns or controls 25 percent or more of the equity of the special purpose entity is also a "recipient." The guidance also describes who is a "recipient of funding" under various credit facilities operated by the Federal Reserve. The guidance can be found at http://www.federalreserve.gov/monetarypolicy/files/eawafaq.pdf.

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