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None noted

OK - 6/6/88

The commissions are an expense, as indicated on the income statement and are not deducted. The total revenues are counted for purposes of determining revenues under 802.20(b).

Called author on June 2. Letter reflects the substance of our earlier conversation concerning these unique facts and the application of 802.51(b)(1)

None noted

OK 6-23-88

[note 1-$7.0 MM]

After further discussion with parties, the parties were advised that notification was not necessary if the Partnership A did indeed become a less than 50% holder of (redacted) as a result of the...

None noted

I confirmed my original advice. The caveat on pg 2 of the writer is incorrect - 5-4-88

OK 5-9-88

Confirmed my contention that filings are not required because the size transaction that is not met and the transaction appears exempt under 802.40

5-13-88-Noted also mergers & joint ventures in the form of a partnership are not exemptthere may be other possibilities that are not exempt.

There are three separate transactions for purposes of determining size of Holding Company according to Section 801.40 of the rules, Holding company is a $340.0 MM dollar person not a $90.0 MM dollar...

OK 5-19-88