February 18, 2005
Rosanne Notaro To: [ ]
Subject Re: [ ]
Dear [ ],
In the email you forwarded below as well as our subsequent telephone conversations, you inquired whether there would be any applications or notices to, or approvals required of, the New York State Banking Department for [ ] Capital Markets to have a marketing or representative office in New York. You indicated that [ ] Capital Markets is a separately incorporated [ ] broker dealer subsidiary of the [ ]. [ ] Capital Markets seeks to have a marketing office in New York City. This office would not promote business of the [ ] and would not have any relations (e.g. personnel, financial, etc.) whatsoever with [ ] operations in the U.S. or in [ ]. The purpose of the proposed marketing office would be to promote the services of [ ] Capital Markets.
Based on this understanding, it is our position that there would be no application or notice to, or approval of any kind required of the New York State Banking Department for [ ] Capital Markets to establish the proposed marketing office.
I trust that this is helpful.
First Assistant Counsel - Banks