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9/24/90 Called him back. Clarified that since the size-of-person test isnt met there is noneed to go to the exemption under 802.1 for realty. Its really a 2-step process: 1) do youhave to file under...

Advised that 801.1(c)(2) requires insurance company to include assets held in a separateaccount for size of person test. - JDahnke 9/20/90

9/18/90 Advised (redacted) that pursuant to Rule 801.11, the size of person test includesthe acquired person plus all entities it controls. He agreed and stated that the acquiredperson controls no one...

For purposes of the size-of person test for an individual, include the financials of all entitiescontrolled plus any other investment assets. Exclude personal assets such as a house or car. Include...

Sale - leaseback in ordinary course

I never received a letter dated 9-4-90But did have phone conversation

None noted

None noted

None noted

None noted

B controls A because B has the power to designate directors of A.

None noted

The formation of the companies are steps in a subsequent merger. Since it is a merger,801.40 cannot apply. If there were no merger, then it will be subjected 801.40.

As long as it does not meet the size of transaction test for the aggregate total of commercialproperty. Resident property can be carved out.

Confirmed that based on the facts presented the transaction appeared to be exempt per802.50(b). We also discussed the possible application of 802.63 - the exemption for the initial establishment of a...