1706004 Informal Interpretation

1
Haynes, Lanea
Subject: 	FW: Item 5 response for a natural person
From: Carson, Timothy
Sent: Wednesday, June 14, 2017 5:28 PM
To:
Cc: Walsh, Kathryn E.; Gillis, Diana L.; Whitehead, Nora; Berg, Karen E.; Sheinberg, Samuel I.; Shaffer, Kristin
Subject: RE: Item 5 response for a natural person
,
If the hedge fund or partnership pays the individual interest or dividends, then that is reported in Item 5.
Regards,
Timothy (Ty) Carson
Bureau of Competition
Federal Trade Commission
400 7 th Street, SW
Washington, DC 20024
202.326.2627
tcarson@ftc.gov
From:
Sent: Tuesday, June 13, 2017 5:21 PM
To: Carson, Timothy
Cc: Walsh, Kathryn E.; Gillis, Diana L.; Whitehead, Nora; Berg, Karen E.; Sheinberg, Samuel I.; Shaffer, Kristin
Subject: RE: Item 5 response for a natural person
Dear Ty:
In a filing by an individual, I understand that item 5 reflects interest and dividend income, not capital gains or
employment revenue( assuming he or she does not control any other entity that derives revenue).
If the individual invests in a hedge fund or partnership that he/she does not control, would any revenue from such
investments be reflected?
I believe that if there are no distributions, but that the “account value” is just reflected in reports to the individual, there
would be no income to report from that activity.
Is there any other revenue that should be reported?
Thank you.

2
From: Carson, Timothy [mailto:tcarson@ftc.gov]
Sent: Wednesday, May 31, 2017 10:17 AM
To:
Cc: Walsh, Kathryn E.; Gillis, Diana L.; Whitehead, Nora; Berg, Karen E.; Sheinberg, Samuel I.; Shaffer, Kristin
Subject: RE: Item 4b
Yes, stipulate in response to item 4(b) in this situation.
Timothy (Ty) Carson
Bureau of Competition
Federal Trade Commission
400 7 th Street, SW
Washington, DC 20024
202.326.2627
tcarson@ftc.gov
From:
Sent: Tuesday, May 30, 2017 5:02 PM
To: Walsh, Kathryn E.; Gillis, Diana L.; Whitehead, Nora; Berg, Karen E.; Sheinberg, Samuel I.; Carson, Timothy; Shaffer,
Kristin
Subject: Item 4b
The instructions to Item 4(b) note that a natural person should not supply personal balance sheets or tax returns. But, if
a natural person does not have an entity they control, what would they provide, if anything, in response to 4(b)—just a
stipulation?