8403006 Informal Interpretation

(redacted)

VIA FEDERAL EXPRESS

March 20, 1984

Dana Abrahamsen, Esq.
Bureau of Competition
Room 396
FEDERAL TRADE COMMISSION
Sixth & Pennsylvania Avenues, N.W.
Washington, D.C. 20580

RE: Exemption from Premerger Notification Filing-

Receivables Purchase

Dear Dana:

This will confirm our conversation of today. As I explained, (redacted) proposes to purchase additional accounts receivable from the same seller who recently sold (redacted) approximately $100 billion in receivables. The latter transaction was fully described in (redacted) letter to John Sipple of March 6 (copy enclosed), and the newly-proposed purchase is identical in all but two respects. First, the amount of the purchase is approximately $50 million. Second, another finance company will have a 50 percent participation in the purchase (thus (redacted) actual share of the receivables will be approximately $25 million). As I indicated, the $50 million in receivables represent approximately 3.58% of the sellers retail notes and lease financing and 1.98% of the sellers total receivables.

You agreed that under the facts as stated above, it would be unnecessary to make a premerger notification filing. If this is incorrect, please call me as soon as possible at (redacted).

Sincerely,

(redacted)