Question
March 16, 1992
Mr. Patrick Sharpe,
Premerger Notification Office
Â鶹´«Ã½ 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 Â鶹´«Ã½ 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)