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Guidelines from the Loan Syndications and Trading Association Not Intended to Apply to All LSTA Members

January 11, 2005

By Christopher H. Craig and A. Jeff Ifrah

The new Guidelines provide a valuable tool to assist all LSTA members in the navigation of the complicated regulatory atmosphere created in the aftermath of the USA Patriot Act. The purpose of this Stay Current alert is to remind certain LSTA memberssuch as private finance companies, hedge funds and unregistered investment companiesthat the Guidelines recommendation regarding the adoption of a Customer Identification Program is limited only to certain LSTA members.

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