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Date
Rule
15 USC 18a(c)(1) 7A(c)(1)
Staff
Michael Verne
Response/Comments
As long as the seller is no exiting the credit care business this can be ordinary course.

Question

From:(redacted)

Sent:Tuesday, October 17, 2006 4:11 PM

To:Verne, B. Michael

Cc:(redacted)

Subject:HSR Advice

DearMike - I am hoping that you can confirm that the PNO still holds the positionthat the acquisition of credit card receivables would be exempt under theordinary course exemption if only the receivables and not the underlyingbusiness are being acquired in the transaction. I look forward to hearingfrom you.

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