0205024 Informal Interpretation

From: (redacted)
To: 'Michael Verne' MVERNE@ftc.gov
Date: 5/22/02

Subject: (redacted)

Mike,

No problem (I had to call and find out...) The daily share account is somewhat akin to an interest bearing checking account. Technically it is money deposited by (redacted) with (redacted), (A corporate credit union to corporate credit unions) that returns an overnight rate. Its basically how (redacted) holds its money that has to be kept completely liquid (hence the overnight rate of return).

Please let me know if this is enough explanation.

-- - Original Message ----

From: Michael Verne [mailto:MVERNE@ftc.gov]

May 22. 2002 4:42 PM

What exactly are the "daily shares" in item 4a? Sorry, I don't profess to be a financial expert.

> 5/22/02 4:50 PM >

I meant to mention that I hadn't included all of the attachments. Attached is the detail for investments. Please review and call me if you have any questions.

Calculation Detail Excluded Assets Form 5310 Dated April 30, 2002

A. Total Assets 93,753,186

Line

1.a. $ 3,598,086

1.b. $ 9,007,505

1. i. $ 79,680,136

B. Total Excluded Assets $ 92,285,727

C. Total assets used in determining

whether size of transaction threshold

is met. (A- B) $ 1,467,459

(see table on original image of letter)