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3/18/98 Advised writer that sale of subject assets did not appear to constitute the disposition of an “operating unit”. Since seller was remaining in the mortgage servicing business, the transaction...

Agree 3/16/98

Called (redacted) 3/13/98. Does not meet the size-of- transaction test. I concur with this letter

called 3/13/98 I concur with this letter

3/12/98 Confirmed w/ writer that same procedure should be followed, namely that(redacted) does not have to file, but filing may be made by (redacted) and (redacted).

3/11/98 Confirmed w/ writer that acquisition of new franchises would be looked at as a separate transaction from previously filed transaction and thresholds would be applicable. If acquisition did not...

3/6/98 Advised writer that shareholders of B do not have to report for the taking of the same % ( or lesser) shares in Newco since Newco is the successor to B and only holds B as a sub. Also on p.6...