9101003 Informal Interpretation

(redacted)

January 4, 1991

Mr. Dick Smith
Premerger Notification Office
Bureau of Competition
Federal Trade Commission
600 Pennsylvania Avenue, NW, Room 303
Washington, D.C. 20580

Dear Mr. Smith:

I am writing to confirm our telephone conversation of yesterday, in which you stated that the sale of (redacted) by the Resolution Trust Corporation as described in my letter of December 20, 1990, is exempt from the application of the Hart-Scott-Rodino Act. Subsequent to that letter, I advised you that the buyer will acquire (redacted) through purchase of the companys stock. Yesterday you indicated that Mr. John Sipple, the head of your department, has concluded that the transaction falls within the Acts Section 7A(c)(4) exemption for transfers to or from a federal agency. This conclusion is in agreement with the initial opinion you gave me during our first conversation on December 19 and as reflected in my December 20 letter.

If this does not accurately reflect your understanding of our conversation, please let me know.

Very truly yours

cc: (redacted)