0504011 Informal Interpretation

us-ftc-hsr-informal-interpretations-e59021e9576f610c698c2dc351a6ec600504011 Informal InterpretationGuidance

Open source
Date
Rule
15USC18a(c)(1) 7A(c)(1)
Staff
Michael Verne
Response/Comments
Yes a partial sale of a credit cared business could be exempted under 7A(c)(1).

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?


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