| B01 — A/U |
Purpose uncertain. If proceeds replenish funds already used to buy margin stock, timing and economic purpose can matter. C007–C009, C102; S002 §§221.2, .101, .108, .114, .116. |
Original and ultimate use; debt being carried; timing of any increase. |
“Working capital” or a signed nonpurpose label conclusively decides purpose. |
How do §§221.101 and .116 distinguish genuine nonpurpose use from replenishment within a purchasing arrangement? |
| B02 — A/U |
Nonpurpose borrowing against securities. A genuinely nonpurpose loan can escape the purpose-credit ceiling while retaining administrative duties. C006, C063, C069–C071; S002 §221.3. |
Purpose, lender category, security, thresholds and exceptions. |
Every securities-backed loan is limited to 50%; or nonpurpose means U is wholly irrelevant. |
Which paragraphs of §221.3 apply independently of a purpose finding? |
| B03 — A/U |
Stock classification unknown. Apply all margin-stock categories and fund exclusions. C014–C016; S002 §221.2; S001 §78c(a)(11)–(12). |
Category predicates, conversion/right features, fund qualification. |
Every stock, bond, fund, option, or exchange-traded item necessarily has the same treatment. |
Which generic definition or incorporated SEC rule governs the unresolved category? No issuer/security lookup. |
| B04 — A/U |
Direct security. A direct margin-stock pledge invokes the security element independently of the indirect-security exclusions. C017–C018; S002 §§221.1–.2. |
Whether direct security exists; its scope. |
The 25% indirect-arrangement exception defeats an otherwise direct pledge. |
What does §221.2’s “such an arrangement” limitation cover? |
| B05 — A/U |
Indirect restrictions. A disposal restriction or possible acceleration can establish indirect security. C017, C094; S002 §§221.2, .113. |
Restriction, acceleration terms, practical restraints and applicable exclusion. |
No conventional lien means no U security. |
Which complete §221.113 circumstances must be reconciled with the present definition? |
| B06 — A/U |
25% asset-composition exclusion. The post-proceeds arrangement-asset denominator matters. C018; S002 §221.2 “Indirectly secured” (2)(i). |
Assets actually subject to arrangement; reasonable values after proceeds. |
Use loan amount, entire net worth, or pre-proceeds values as denominator. |
What does the definition include in assets subject to the arrangement? |
| B07 — A/U |
Cross-default exception. The other lender must be unaffiliated. C019; S002 §221.2. |
Other-credit relationship and affiliation predicates. |
Any cross-default clause automatically creates—or automatically avoids—indirect security. |
Which bank/nonbank affiliate definition is the relevant incorporated rule? |
| B08 — A/U |
Custody/trustee exception. Custodial capacity and good-faith nonreliance must both be assessed. C020, C093; S002 §§221.2, .112. |
Capacity in holding stock; role in extending credit; reliance. |
Every trustee is exempt, or every custody holding is collateral. |
How does §221.112 distinguish lending as trustee from nonrelying custody? |
| B09 — A/U |
Other nonreliance. Financial strength may be relevant but is not conclusive. C021–C022; S002 §§221.2, .117. |
Actual reliance, maturity structure, credit circumstances. |
Fixed maturity or a strong balance sheet alone proves exclusion. |
What evidence does §221.117 treat as relevant, without converting it into a safe harbor? |
| B10 — A/U |
Bank versus nonbank. The U definitions govern. C010–C012; S002 §§221.2–.3. |
Legal category and ordinary-business predicate. |
A business label, charter shorthand, or absence from a roster settles coverage. |
Which statutory inclusion or express U exclusion remains to be interpreted generically? |
| B11 — A/U |
Covered credit versus exception. Test the complete applicable exception and its documentation conditions. C023–C025, C047–C062; S002 §§221.1, .4–.6. |
Qualification, financed activity, duration, recourse, required statements. |
Every broker loan, short-term advance, employee loan, or hardship loan is exempt. |
Which exact subsection supplies the claimed exception, and what nested condition limits it? |
| B12 — A/U |
Threshold base or period unknown. Quarter flow, peak outstanding, six-month outstanding, and customer form thresholds are distinct. C063–C070; S002 §221.3(b)–(c); S007–S010. |
Relevant totals, period, peak, commitment/draw treatment. |
Quarter-end balance substitutes for peak outstanding; collateral value substitutes for credit amount. |
What do the current generic instructions say about extended versus outstanding credit and undrawn commitments? |
| B13 — A/U |
Single credit and sequence. Same-customer purpose credit, sequencing exceptions, and syndication must be distinguished. C032–C035; S002 §221.3(d). |
Customer/joint action, sequence, relationship of transactions, syndication. |
Separate notes defeat aggregation, or every prior unsecured loan must be fully re-margined. |
How do (d)(1)–(3) interact with the anti-splitting interpretation? |
| B14 — A/U |
Mixed collateral. Sum applicable loan values; keep purpose/nonpurpose allocation distinct. C029–C035; S002 §§221.3(d), .7; S005 III.C. |
Collateral categories, allocation, values, duplicate use. |
Give every asset 50%, give every other asset 100%, or revive the deleted mixed-loan segregation rule. |
What exactly did the 1998 III.C amendment remove, and what did (d)(4) retain? |
| B15 — A/U |
Percentage/base and good-faith value. Use the appropriate collateral base and valuation convention. C027–C030; S002 §§221.2, .7. |
Applicable category, date, valuation method, credit judgment. |
50% is a percentage of debt; good-faith means automatic full market value. |
Which supplement category and §221.2 valuation alternative apply generically? |
| B16 — A/U |
Additional advance versus maintenance. An older market deficiency and a supported new advance are distinct. C036–C037; S002 §221.3(a),(d),(f); S012 5-951.24. |
Initial compliance, cause of deficiency, additional collateral, increase. |
Market decline forbids every new advance; or maintaining permission authorizes an unsupported increase. |
What are the exact limits of 5-951.24 when read with present §221.3? |
| B17 — A/U |
Commitment versus later draw. A supported binding commitment differs from later lending needing collateral. C026, C038–C039, C072; S002 §§221.102, .3(c)(2); S012 5-900.16. |
Binding date, facility structure, initially pledged collateral, amendments. |
Every draw uses either the original value or a fresh value regardless of structure. |
Which branch of the published revolving-credit interpretation matches the generic legal arrangement? |
| B18 — A/U |
Withdrawal/substitution. Apply event-date loan values and the no-new/no-increased-excess test. C040–C041; S002 §221.3(f)–(g). |
Event, values, applicable credit grouping and any exchange qualification. |
A partial repayment automatically releases a proportional amount of collateral. |
How does (f) operate when an existing excess remains, and does (g) change classification temporarily? |
| B19 — A/U |
Falling market value. Maintaining permission does not itself impose a regulatory call. C036–C040; S002 §221.3(a)(2),(f). |
Original compliance and whether a new event is occurring. |
A fixed percentage market loss universally triggers a U violation, call, or forced sale. |
Does the event concern mere maintenance, a new extension, or a withdrawal under the actual text? |
| B20 — A/U |
Initial constraint versus private maintenance. U does not supply the held contract terms. C028, C036, C045, C080, C087. |
Actual agreement and applicable non-U law, all excluded. |
Regulatory permission to maintain compels the lender to maintain; or a broker rule governs every U loan. |
What does §221.3(a)(2) permit, and what does it leave outside its subject? |
| B21 — A/U |
Required form versus explanatory worksheet. Match the event and lender to the actual prescribed category. C043, C050, C062, C069–C077; S006–S011. |
Lender category, threshold, purpose, exception, original documentation event. |
This worksheet substitutes for U-1/G-3; all forms are filed; every field is required in every case. |
Which exact instruction makes the form, part, amendment, certification, or field mandatory? |
| B22 — A/U |
Borrower/broker/lender regimes. Each regime has a different regulated role and trigger. C003–C005, C079–C083; S001–S004. |
Legal role, regulated activity, borrower status and willfulness. |
Lender noncompliance automatically proves borrower violation or all brokers qualify as exempt borrowers. |
Which statutory subsection and current regulatory definition govern the generic role? |
| B23 — A/U |
Foreign extension. U’s bank exemption and X’s borrower selection must both be read. C058, C082–C085; S002 §221.6(c); S004 §§224.1–.3. |
Location, status/control, security nexus, annual foreign-credit totals. |
Outside-US extension ends the analysis; or U-1’s $100,000 test is X’s test. |
Which §224.3(a) route and §224.1(b) exemption apply as legal categories? |
| B24 — A/U |
Lawful extension versus enforceability/collection. A regulatory classification does not complete a remedy analysis. C045, C087; S001 §78g; S002 §221.3. |
All debt, contract, remedy, jurisdiction and litigation facts are held. |
Compliance proves collectability; violation proves cancellation, settlement entitlement, or an available defense. |
In scope: what conduct does the selected credit provision regulate? Any remedy investigation remains parent-held. |
| B25 — A/U |
Loss of exempted-borrower status. Further draws/renewals require a fresh current-regime assessment. C023–C024; S002 §§221.2, .3(e). |
Annual qualification, loss date, notice, later credit event. |
Previously exempt status lasts for the entire facility regardless of change. |
How does §221.3(e)(2) qualify ordinary maintenance/renewal treatment? |
| B26 — P/U |
Current form discrepancies. Preserve rule/form differences and the unverified G-4 unit. C065–C068, C076–C077, C101; S002, S008–S011. |
Authoritative generic reconciliation and inspectable form imagery. |
Rewrite a certification, pick a reporting unit, or infer regulatory invalidity from an inconsistency. |
Does a current approved generic instrument, correction, or published Board explanation reconcile the exact boundary, unit, or routing text? |