Question
March 8, 2004
VIA FEDEX
Mr. Michael B. Verne
Premerger Notification Office
Federal Trade Commission
600 Pennsylvania Ave, NW
Washington, D.C. 20580
Re: Applicability of Hart-Scott-Rodino Act (the "HSR Act" to ReinsuranceTransactions
Mr. Verne:
Thank you for taking the time tospeak with me today. I am writing to confirm the oral advice you provided inour telephone conversation earlier today.
I understand that the PremergerNotification Office views "assumption reinsurance" transactions asbeing "acquisitions of assets," and therefore reportable events underthe HSR Actprovided they meet the size of transaction test. I further understand that thePremerger Notification Office views "indemnity reinsurance"transactions as not being "acquisitions of assets," andtherefore not reportable events under the HSR Act.
Please confirm via fax to (redacted)that the foregoing accurately reflects the advice you provided in our telephoneconversation today.