SEC Staff Agrees Transferable Custody Receipts Can Be Sold in Australia to U.S. Market Makers

The SEC Division of Corporation Finance (the "Division") agreed that Transferable Custody Receipts (described in the no-action letter as the Australian equivalent of American Depository Receipts) could be sold in Australia to U.S. market makers without registration under the Securities Act. The Division's decision was made on the basis that the transactions taking place outside the United States were generally in accordance with Regulation S.