Subject: Re: Country/State of Incorporation
From: [email-masked]
To: [email-masked]
Cc: [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked], [email-masked]
Date: Fri, 17 Sep 1999 06:23:00 -0700 (PDT)

I think Jeff like myself has been out of the office so I am responding from 
the US tax side. Jeff please correct the following as appropriate.

When the US tax group reviewed the original matrix they identified 
counterparties as being unable to trade US financials where those parties 1) 
were not incorporated in the US, and 2) there was no US withholding tax 
documentation on file. Where on the matrix it was not clear where an entity 
was incorporated it was assumed for this purpose NOT to have been 
incorporated in the US.

Thus if the review establishes that in fact some of these entities are 
incorporated in the US, the prohibition on these entities trading US 
financials can be lifted.

Jeff was in the process of reviewing the matrix. 

Regards
Janine

Mary Solmonson
16/09/99 15:41
To: Bob Shults/HOU/ECT@ECT
cc: Justin Boyd/LON/ECT@ECT, Mark - ECT Legal Taylor/HOU/ECT@ECT, Jeff 
Blumenthal/HOU/ECT@ECT, Janine Juggins/LON/ECT@ECT, Debbie R 
Brackett/HOU/ECT@ECT, David Weekes/LON/ECT@ECT, David Forster/LON/ECT@ECT, 
Arfan Aziz/LON/ECT@ECT, Frank L Davis/HOU/ECT@ECT, Amita Gosalia/LON/ECT@ECT 
Subject: Re: Country/State of Incorporation  

For U.S. based counterparties, State of Incorporation is fairly readily 
available from Dun & Bradstreet - if they are in fact incorporated entities.
 We have only recently requested a full extract of this information from D&B 
for our counterparties (because this is also required for SAP).
 Because of difficulties in matching our records to D&B - their names are NOT 
always the exact legal name - we have only been able to obtain
 roughly 7365 out of the more than 11,400 records we have (65%).  Of the 7365 
records matched, not all have State of Incorporation either because 
 1) They are not U.S. parties or 2) They are not incorporated entities or 3) 
D&B is missing the information (990).

 We recently obtained a list of state of incorporation for companies from 
Legal which is the source we were going to use to populate this information 
for the  ones we were missing.  We hired temps to do this, but were then 
requested to stop this activity by Frank Davis.

 For Foreign entities, the country of incorporation has been difficult to 
find as it is not readily available from D&B.  Any knowledge or suggestions 
would be appreciated.

We are changing our procedures to request this information when we call the 
counterparty to collect information for setup.

In reviewing the counterparty matrix of 9/8, we can assist with providing 
some of the state of incorporations for parties in Sections 2,3, and 4.  I 
have asked IT to extract this information from GCP for you.  Country of 
Incorporation for non-U.S. does not yet exist in GCP - this is currently 
under development with a target production date of mid-October therefore, 
this cannot be provided.  I think however, that the London Credit system has 
Country of Registration (same as Incorporation) that could possibly help.

As soon as the values we have for State of Incorporation are populated in the 
counterparty matrix, I will forward to you.

Bob Shults
09/16/99 05:06 AM
To: Justin Boyd/LON/ECT@ECT, Mark - ECT Legal Taylor/HOU/ECT@ECT, Jeff 
Blumenthal/HOU/ECT@ECT, Janine Juggins/LON/ECT@ECT, Mary Solmonson, Debbie R 
Brackett/HOU/ECT@ECT, David Weekes/LON/ECT@ECT
cc: David Forster/LON/ECT@ECT, Arfan Aziz, Frank Davis, Amita Gosalia 
Subject: Country/State of Incorporation

The objective of EnronOnline is to trade with as many people as possible in 
as many product types as possible.  

Both the legal and tax reviews that I have seen thus far have included 
non-trade status customers that I understand may or may not be eligible to 
trade if we had the country/state of incorporation.  Apparently our records 
are not very robust relative to this piece of information.  

If possible I would like to get a better understanding of all the issue 
surrounding country of incorporation so that we can determine the best course 
of action for obtaining this information if we determine that it is 
essential.  In addition to ensure that we collect this information each time 
we add a new counterparty.

Short of having this information it is my understanding that US tax has 
completed its review of the counterparty matrix and 

Questions:

Is anyone aware of an easy way of obtaining country/state of incorporation?

If we had country/state of incorporation how many counterparties would be 
affected?  (That is if we had country/state of incorporation it might allow 
us to take a counterparty from non-trade status to trade status.)

Can we identify the counterparty names (on the customer matrix which was 
e-mailed on 08/09/99 copy attached) which might be affected by having 
country/state of incorporation?

Is this the only remaining issue impacting the tax review of the counterparty 
matrix dated 08/09/99.  If so are Jeff and Janine ready to sign off on the 
matrix? Can I get a copy of your completed matrix for upload?