HasAlternate USSection12Registration Property

The property called HasAlternateUSSection12Registration exists to capture an interpretive update from A&O, which is outlined in Section 3.5(g) of the U.S. memo and in Question 101.03 of the SEC's Q&A on 13D and 13G reporting.

In summary, it is possible for non-U.S. securities that are traded outside of the United States to be disclosable under 13D/G if the particular class is held on deposit underlying an ADR which is section 12 registered. In addition, there are cases where a security (foreign or domestic to the U.S.) is registered under U.S. Section 12 by other means besides being listed on a U.S. National Securities Exchange. The A&O memo for the United States describes alternate means of registration in Section 3.5(a), 'Section 12 Registration', and related footnotes.

If you hold securities that are registered under Section 12 and are therefore reportable, please indicate this by setting HasAlternateUSSection12Registration to True.
Please note that since this is not an exclusionary property, we will require it to be set for every non-derivative instrument in your file. If you set a data override to "False", you will not receive missing data. Defaulting this to false will also ensure the 13D/G rules provide their checks as if this nuance wasn't yet taken advantage of by your firm. While this property is tricky, we discourage clients from defaulting it as we want them to think about it and set it purposefully.

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