Due to the fact ban pertains to people extension away from borrowing or arrangement out of borrowing from the bank “truly otherwise indirectly
“their chairman, one vice-president . . . accountable for a principal organization unit, section or means (instance conversion process, government otherwise financing), all other officer just who functions an insurance plan making form, or any other individual that performs equivalent coverage and come up with functions to own the fresh [issuer]. Executive officers out-of subsidiaries is considered manager officials of [issuer] whenever they would including policy making attributes toward [issuer].”
Before SEC brings then explanation (in the event it does), the latest ban to your fund should therefore be viewed just like the extending so you’re able to administrator officials of subsidiaries. The definition of “or the equivalent thereof” within the Part 402 is not laid out, but appears to extend the prohibit to people doing properties similar so you can directors and you will manager officers to own issuers that are not agencies (like in public traded partnerships).
. . so you’re able to or for” a director or executive manager, it appears and to expand in order to money and other arrangements made in order to instant family of administrators or executive officers (especially if the partner life towards the director or exec officer) as well as to firms and other organizations controlled by brand new manager or exec officer, for as long as the financing otherwise arrangement might be considered to be good “consumer loan.”