9108017 Informal Interpretation

August 20, 1991

Nancy Ovuka

Premerger Notification Office

Federal Trade Commission

6th and Pennsylvania Avenue, NW

Room 303

Washington, D.C. 20580

Dear Ms. Ovuka:

This is to confirm our conversation of August 19, 1991 in which you stated that the following transaction was not reportable under the Hart-Scott-Rodino Act. The acquisition we discussed was the purchase of realty by a retirement system. The seller is a bank. The realty does contain improvements, however, the acquisition is only of the underlying realty. The retirement system holds several other properties, and the sale of the realty does not constitute a sale of all or substantially all of the sellers assets. You concluded that this transaction is an acquisition of realty in the ordinary course of business, and is therefore exempt from the reporting requirements of Hart-Scott-Rodino. 16 C.F.R. 802.1.

Please let me know if my understanding is incorrect. My number is (redacted) Thank you for you assistance.

Sincerely,

(redacted)

(redacted)