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Are tender offers reportable?

April 26, 2017offers reportable tender

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Are tender offers reportable?

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Sales of bonds from bondholders directly to the issuer or third party purchaser pursuant to a public tender offer effected in accordance with SEC rules are not reportable transactions. In such a tender offer, a FINRA member that acts as a dealer manager/agent for the issuer or third party purchaser would not have a reporting obligation. However, a FINRA member that acts as principal and purchases bonds and then resells them to the issuer/third party purchaser or a member that acts as agent for the seller would have a reporting obligation with respect to purchases from the bondholder.