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The 15-year exclusion wasupheld by the ALJ. They then appealed to HHS' Departmental Appeals Board, which reducedthe exclusion period to 12 years but upheld the exclusions, finding that the three exe...
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the Rule include recommendations that amounts to "calls to action" irrespective of whether they result in a transaction or reference particular se- curities.14 For example, recommendations that a client use margin, liquefy home equity or enga...
also effectively excluded all public companies from the definition of eligible portfolio companies.9At the time Congress enacted the 1980 Amendments, it recognized that changes in the financial environment could require that the cat- egories of eligible portfolio companies be ...