Question
From: :(redacted)
Sent: Friday, April 15, 2005 4:03 PM
To: Verne, B. Michael
Subject: credit cards
Mike, thanks for your voicemail yesterday concerning HSR treatment of the sale and purchase of a credit card business. Iunderstand the PNO's position to be that, even if theseller is staying in other kinds of loan activity, if the seller is exiting thecredit card business entirely the ordinary course exemption will not apply andan HSR filing will be required.
I wanted to see what the PNO's position would be on a transaction inwhich the seller retains some of its credit card business and sells part. Wouldthis transaction qualify for the exemption?