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See below 3/11/94 Advised writer that a REITs purchase of the assets or voting stock of another REIT is exempt under 7A(c)(1). However, the acquisition of the voting stock of a REIT by someone other...

See below 3/3/94 Advised writer that transactions described in this letter would result in no reportable events. R.B. Smith

See below 3/1/94 Called writer and advised that no filing need be made for the acquisition of Company C since it is not engaged in manufacturing, has sales less than $100 MM and its last regularly...

See below 3/1/94 Advised writer that if grantor names itself as beneficiary of trust (and paragraph 3(b) seems to clearly establish such), then SBP of 7/31/78 at 33459 states that the settlor is...

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See below This escrow arrangement is OK. RS concurs.

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See below 2/28/94 Advised writer that no filing is required. Exempt under interpretations the PNM Office has given regarding re-incorporations under 802.10 or the fact that the acquiring persons...

2/18/94 - advised author of letter that, based on the facts presented, no filing need be made for the sale and purchase of the (redacted). RBSmith

See below Writer advised that change to a fiscal year basis had not been done to avoid filing for sale of Subsidiary B. I advised that, since B had opted to switch to a fiscal year basis, the PMN...

No response provided.

2/8/94 The transaction is exempt under (c)(6). Although filings by telecommunications carriers are submitted under HSR (perhaps due to time constraints w/FCC), parties filing w/ the FCC would be...

with clarifications noted, I concur-called 2-2-94 - [note 1-right to 85% of assets upon dissolution]-[note 2-This was not structured this way to avoid filing under H-S-R.]-[note 3-bona fide lease not...

I concur. PS. See letter to RS 8-13-93 that supports this position. Called (redacted) 2-2-94