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Letter Summary:
While withdrawal rights empower shareholders and we are of the view that security holders should generally be permitted to withdraw their shares, we agree that in the narrow circumstance related to securities deposited under a partial take-over bid prior to take-up permitting withdrawal rights could defeat the purpose of the 10 day extension period and could possibly result in a failed bid.
Overview of the Council’s Comments:
We do not have a view as to whether any changes to market activity or trading of offeree issuer securities will result from the Proposed Amendments. If market participants wish to try to profit from price discrepancies or otherwise they will likely continue to do so within the regulatory framework regardless of the final form of the rules.