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Do issuers need to publish a final prospectus by the subscription date, or can borrowers subscribe for a loan based on the “red” prospectus, and deliver the final prospectus at a later date?

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Do issuers need to publish a final prospectus by the subscription date, or can borrowers subscribe for a loan based on the “red” prospectus, and deliver the final prospectus at a later date?

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On the subscription date, the primary dealer must provide the custodian with the CUSIP numbers and prospectuses/offering documents of all collateral expected to be pledged against the TALF loans. If the CUSIP number corresponds to a new issuance, the prospectus/offering documents submitted on subscription date may be preliminary, but the final prospectus/offering documents must be provided to the custodian no later than 12 noon three business days prior to the applicable TALF loan settlement date.

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