Replies to post #47668 on Lehman Brothers Financial SA (LEHNQ)

[Joe Stocks]

Joyce, I don't see the connection between a bankruptcy disclosure action 2019 rule, and the SEC's requirement to disclose holdings. There are some exceptions with the 13F filing but only for as long as you are accumulating shares, and then it is only very temporary.

Perhaps others have not mentioned because it is a poor attempt to to show one has something to do with the other. Rule 2019 has more to do with a group of creditors binding together to affect the outcome a bankruptcy action.

Generally, the rule requires disclosure of economic interests held by creditors or equity holders that are “acting in concert,” and “entities” that represent them. Under the rule, “represent” means to take positions in the bankruptcy court or solicit votes on a plan “on behalf of another.” Economic interests are defined very broadly and include claims, interests, liens, derivatives, options, participations and any “right or derivative right granting the holder an economic interest that is affected by the value, acquisition, or disposition of a claim or interest.” In sum, just about every interest must be disclosed if the rule is triggered.

Among other things, disclosures must include information about the formation of the group or committee, and the employment of the entity.

[ana177223]

thanks a lot