Question
March 16, 1992
Mr. Patrick Sharpe,
Premerger Notification Office
Federal Trade Commission
Pennsylvania Avenue at 6th Street NW,
Washington, D.C. 20580
Dear Patrick:
This letter is to confirm our telephone conversation on the afternoon of March 9, 1992 in which you informed me that the Premerger Notification Office of the Federal Trade Commission concurs with my position that the below-referenced transaction is exempt from filing pursuant to 16 C.F.R. 802.64.
As I explained to you, we are counsel to two public money market funds X and Y registered under the Investment Company Act of 1940. In a tax free reorganization, X intends to acquire the assets of Y in exchange for stock of X. After the acquisition, each shareholder of X will hold the same number of shares of stock X with the same value it held of X or Y, respectively, prior to the acquisition.
Thank you for your prompt response to this matter.
Very truly yours,
(redacted)