8309008 Informal Interpretation

Dana Abrahamsen



September 28, 1983

Dana Abrahamsen, Esq.
Premerger Notification Office
Federal Trade Commission
Washington, D.C. 20580

Re: Letter of September 14, 1983

Dear Mr. Abrahamsen:

During our telephone conversation yesterday, in which we discussed my September 14, 1983 letter, you stated that the substance of subsection (a) accurately reflects your informal advice. As for subsection (b), you again stated that its substance was accurate but agreed with me that replacing the world exceeds with the words is less than resolved any ambiguity. Accordingly, subsection (b) now reads:

The fee Company A earns through its collection of Company Bs receivables should be treated as consideration only to the extent that the fee is less than the fair market value for such service.

Thank you.

Sincerely yours,


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Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

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