Foreign Bank Time Deposit Accounts Under the Securities Act of 1933: Wolf V
UCLA UCLA Pacific Basin Law Journal Title Foreign Bank Time Deposit Accounts under the Securities Act of 1933: Wolf v. Banco Nacional de Mexico, S.A. Permalink https://escholarship.org/uc/item/6gt821jb Journal UCLA Pacific Basin Law Journal, 1(2) Author Nitzkowski, Greg M. Publication Date 1982 DOI 10.5070/P812021891 Peer reviewed eScholarship.org Powered by the California Digital Library University of California CURRENT DEVELOPMENTS FOREIGN BANK TIME DEPOSIT ACCOUNTS UNDER THE SECURITIES ACT OF 1933: WOLF v. BANCO NA'CIONAL DE MEXICO, S.A. Greg M. Nitzkowski* In Wolf v. Banco Nacional de Mexico, S.A. I ("Wof"), the United States District Court for the Northern District of Califor- nia held that a time deposit account in a foreign bank is a "secur- ity" within the meaning of the term under section 2(1) of the Securities Act of 19332 because the plaintiff, a United States citi- zen and resident, was subject to a risk of devaluation in opening such an account. 3 In turn, the court held that defendant, Banco Nacional de Mexico ("Banamex"), which sold securities not regis- tered with the Securities and Exchange Commission 4 was strictly * Student, UCLA School of Law; A.B. 1979, Harvard University. 1. 549 F. Supp. 841 (N.D. Cal. 1982). 2. 15 U.S.C.A. § 77b(l) (West Supp. 1976), as amended by P.L. No. 97-303 (1982). The Act provides that unless the context otherwise requires-- (a) The term 'security' means any note, stock, treasury stock, bond, debenture, evidence of indebtedness, certificate of interest or par- ticipation in any profit-sharing
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