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Agree

Agree. Any loan secured by real property is exempt under the mortgage provision in 7A(c)(2). N. Ovuka concurs.

Advised that 15 days is now correct

Advised that two filings are required in the exchange: A files to acquire the assets from the partnership (B is acquired) B files to acquire the assets A transfers to the partnership (A is acquired) A...

Advised that both scenarios would be viewed as an acquisition of the assets of the partnership by Partner 2. N. Ovuka concurs.

Agree note that the fair market valuation is of the underlying assets, not the membership interests.

Agree. N. Ovuka concurs.

Advised writer by telephone that transaction is not reportable. RS and PS concur.

None noted

This agrees with our discussions with CUNA representatives and counsel in various meetings. N. Ovuka concurs.

I concur. Called (redacted) and (redacted)

Agree the size-of-transaction is less than $50 MM. See attached. N. Ovuka concurs.

Advised that an allocation of the value of worldwide license rights must be made to determine the value of that portion that relates to the U.S. Only the value of the U.S. portion would count toward...