A foreign BD and its companion in the United States must follow the appropriate compliance procedures for the companion to fulfill its obligations if the confirmations and declarations sent by the foreign BD meet these requirements. If the confirmations and explanations sent by the foreign BD do not meet these requirements, the accompanying person must send separate confirmations and explanations that meet the requirements. Question 18: Does the definition of «large institutional investor in the United States» include companies wholly owned by other large institutional investors in the United States? 14 However, the General Staff observes that the position set out in this reply relates to the facts described in the question and does not alter any requirement or restriction which applies to trade in adRs under any existing law, regulation or legal interpretation, including the limitation to the definition of `foreign security` in Seven Firms` letter. See note 6 above. Answer: Yes. The General Staff interprets the definition of the concept of «large U.S. institutional investor,» as expanded by nine Firms Letter employees, to include all companies whose equity holders are all large U.S. institutional investors. In other words, any enterprise whose equity securities are wholly owned by one or more firms, including an investment advisor (whether registered or not under the Investment Advisers Act), which each individually owns or controls (or, in the case of an investment advisor), manages more than $100 million in aggregate financial assets) would itself be a significant institutional investor in the United States within the meaning of Section 15a- 6. The General Staff considers that this position is compatible with the Commission`s prior treatment of similar conditions.25 (NEW 14.04.2014) Question 12: Can a registered dealer broker serve as a companion to a foreign broker in accordance with Rule 15a-6 (a) (3) and can he rely on all the conditions of the Nine Firms Letter, where the registered dealer broker has actually entered into a fully disclosed transport agreement with another registered brok he has a dealer q Has ui agreed to abide by the rules of financial responsibility? So if you think about the underlying policy of protecting Boston firefighters, these rules are starting to make sense.