8403007 Informal Interpretation

John Sipple

Non-Reportable (no written notes)



March 22, 1984


Mr. John Sipple
Bureau of Competition
Federal Trade Commission
Room 392
Pennsylvania and 7th Avenues, N.W.
Washington, D.C. 20580

RE: Premerger Notification Exemption

Dear Mr. Sipple:

This is to confirm our phone call of March 16. (Redacted) a wholly-owned indirect subsidiary of (redacted) a bank holding company, plans to make a purchase of mobile home sales contracts. The purchase will be from (redacted). As of December, 1983, the Savings and Loan had total receivables in the amount of $274 million.

(Redacted) plans to purchase approximately 1,628 accounts for a net purchase price of $22,085,739. The customers reside in (redacted) and (redacted).

The Savings and Loan intends to cease financing mobile home sales. But, to our knowledge, they will use the proceeds to finance other types of credit transactions.

It is my understanding, based on our discussion, that this transaction will be exempt from the Hart-Scott-Rodino Premerger Notification filing. This is a purchase in the ordinary course of business of substantially less than all the assets of the selling company.

Please call me by March 29 if you have any further questions. We plan to close the transaction on or shortly after that date.

Very truly yours,



[Attachment: Chapter 11 - Securities and Exchange Commission]

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