Question
From:(redacted)
Sent:Monday, March 03, 2008 11:30 AM
To: Verne, B. Michael
Subject: Trailer parktransaction
Mike,
Iunderstand that the acquisition of trailer park property is exempt under802.2(d) as long as the homes are ownedby residents and the spaces are leased from the park. I have a situation wherethe target is a trailer park company where people can either (1) buy theholiday homes (trailers) from the operator, (2) rent the holiday homes from thepark operator or (3) rent pitches/land for RVs. I assume that 3 is exempt under802.2(d); 2 is exempt under 802.2 (d) or 802.2(e), and that 1 is not exempt. Ialso assume that under 802.4, as long as the purchase price or FMV attributedto the non-exempt assets is less than $63.1 million, the entire transactionwill be exempt.
Iwould appreciate you confirming that my above assumptions are correct. As always, thank you for your help.