Pages from LSTA Blockchain Memorandum - Milbank Draft 5.17.19

This memorandum analyzes whether tokens or other similar digital assets (“Tokens”) representing interests in syndicated term loans as currently formed and traded would be considered “securities” for purposes of the definitions contained in the Securities Act of 1933 (“Securities Act”) and the Securities Exchange Act of 1934 (“Exchange Act,” and together with the Securities Act and the regulations issued under each Act, the “securities laws”).


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