RegAlert2002-11-13
Added · Updated
SEC Division of Corporation Finance no-action letter: Bank of America, N.A.
The Division of Corporation Finance states that royalty trusts comply with the certification requirements of Rules 13a-14 and 15d-14 of the Securities Exchange Act of 1934 if they provide a certification in the exact form submitted by Bank of America, N.A. as Trustee for Sabine, Williams, Permian Basin, Cross Timbers, Hugoton, and Dominion Resources Black Warrior Trusts. The Division further determines that these trusts are not required to provide the disclosure mandated by Item 307 of Regulation S-K. This position accounts for the pass-through nature of the trusts, their lack of principal executive or financial officers, and the absence of a board of directors.
SEC published 7 documents in the last 30 days — get each new one by email the day it lands.
Home | Previous Page
Securities Exchange Act of 1934 - Rules 13a-14 and 15d-14 Regulation S-K - Item 307
November 13, 2002
Response of the Office of the Chief Counsel Division of Corporation Finance
Re:
Bank of America, N.A. Incoming letter dated November 13, 2002
Based on the facts presented in your letter, it is the view of this Division that royalty trusts are in compliance with the certification requirements of Rules 13a-14 and 15d-14 of the Exchange Act of 1934, as applicable, if royalty trusts provide a certification in the exact form of the certification provided in your letter. In reaching this position, we considered in particular the pass-through nature of royalty trusts, the trusts' lack of principal executive or financial officers and boards of directors, and the fact that the trustee must rely in certain circumstances on information provided by the working interest owners of the underlying properties and managing general partners of the partnerships underlying the trusts. We further note the unique nature of the financial statements the trusts include in their Exchange Act filings.
Read the rest free, and get an email when SEC publishes again
Lineage: In force
Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
More like this from SEC
SEC published 7 documents in the last 30 days. We email you each new one the day it's published.