2002-06-27

Added · Updated

SEC Division of Corporation Finance no-action letter: Grupo TMM, S.A. de C.V.

The Division of Corporation Finance will not recommend enforcement action if Grupo TMM, S.A. de C.V. completes its Reclassification and Exchange without registering under the Securities Act of 1933. This decision relies on the exemption in Section 3(a)(9) for exchanges with existing security holders where no commission is paid. The Division accepts the legal opinion that Grupo TMM is the issuer of the CPOs for exemption purposes, despite the interposition of the CPO Trust due to Mexican foreign investment laws. This position applies specifically to Grupo TMM based on the representations made in the request letter.

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Securities Act of 19331933Securities Exchange Act of 19341934SEC Division of CorporationFinance no-action letter: Gru…2002-06-27 · this document
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