2845. Interpretive Opinion Request.
(a) A request for an interpretive opinion pursuant to Section 10236 of the Code shall be addressed to the Headquarters
Office of the Bureau to the attention of Chief Counsel.
(b) An interpretive opinion request shall satisfy each of the following conditions:
(1) The request shall clearly state that it is a request for an interpretive opinion pursuant to Section 10236 of the
Code.
(2) The request shall be addressed to a specific transaction or transactions or to a narrowly-defined course of conduct
or business practice. The persons or entities on whose behalf the request is made shall be identified. If the persons
or entities cannot be identified by name at the time of the request, they must be identified by their capacities in the
transaction, course of conduct, or business practice. If the person requesting the opinion knows of persons other
than those on whose behalf the request is made who intend to engage in a transaction, course of conduct, or business
practice in reliance upon the opinion, such information shall also be included in the request for opinion.
(3) The nature of the transaction, course of conduct, or business practice, the capacities of parties to the transaction,
and relevant details about it shall be described. Instruments, or other documents that will be used in the transaction,
course of conduct, or business practice, completed in illustrative form to explain the transaction, course of conduct,
or business practice, shall be appended to the request.
(4) The question or questions central to the opinion request shall be specifically and narrowly framed.
(c) Attorneys at law seeking interpretive opinions on behalf of clients shall include with the opinion requests, their own
analyses of the issues presented by the request, their views with respect to the issues presented and citations of legal
authority in support of those views.