Skip to main content
Date
Rule
Form Item 5, NAICS
Staff
James Ferkingstad
Response/Comments
Agree

Question

April 7, 2005

VIA U.S. MAIL

Mr. James Ferkingstad
Premerger Notification Office
Bureau of Competition
Room 303; Federal Trade Commission
600 Pennsylvania Avenue N.W.
Washington, D.C. 20580

Dear Mr. Ferkingstad:

This letter is to confirm ourtelephone conversation on Tuesday, April 5, 2005. In particular, I would like to confirmthe following:

1. Insurance revenues are measured by netpremiums written as opposed to net premiums earned.

2. Insurance companies reporting under HSR shall report investment income in addition to any insurancerevenues under Item 5 of the form.

3. For each NAICS code in which revenuesare reported under Item 5 of the form, revenues should be aggregated for allentities included within the reporting person and not broken down per entity.

Thank you again for your timeand consideration on this matter. Please contact me if any of the above isincorrect.

About Informal Interpretations

Informal interpretations provide guidance from previous staff interpretations on the applicability of the HSR rules to specific fact situations. You should not rely on them as a substitute for reading the Act and the Rules themselves. These materials do not, and are not intended to, constitute legal advice.

Learn more about Informal Interpretations.