9011011 Informal Interpretation

(redacted)

November 27, 1990

Patrick Sharpe
Premerger Notification Office
Bureau of Competition
Federal Trade Commission
6th & Pennsylvania Avenue, NW
Room 303
Washington, D.C. 20580

Dear Mr Sharpe:

I write to confirm our conversation of November 26. I had asked about the following:

The Resolution Trust Corporation (RTC) is the receiver for a savings bank. That savings bank has an indirect, wholly-owned mortgage banking subsidiary. In the proposed transaction, assets of the subsidiary, as well as some assets of the parent bank, would be sold to a third party. The transaction will be approved by the RTC, which will also guarantee the subsidiarys indemnification obligations.

You stated that the FTC [note 1] views the RTC as a government agency, and accordingly, the transaction is exempt from the subsection (c) of the Act, 15 U.S.C. 18a(c)(4).

I trust that you will contact me if the above is inaccurate

Very truly yours,

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