0504003 Informal Interpretation

April 7, 2005

VIA U.S. MAIL

Mr. James Ferkingstad
Premerger Notification Office
Bureau of Competition
Room 303; Federal Trade Commission
600 Pennsylvania Avenue N.W.
Washington, D.C. 20580

Dear Mr. Ferkingstad:

This letter is to confirm ourtelephone conversation on Tuesday, April 5, 2005. In particular, I would like to confirmthe following:

1. Insurance revenues are measured by netpremiums written as opposed to net premiums earned.

2. Insurance companies reporting under HSR shall report investment income in addition to any insurancerevenues under Item 5 of the form.

3. For each NAICS code in which revenuesare reported under Item 5 of the form, revenues should be aggregated for allentities included within the reporting person and not broken down per entity.

Thank you again for your timeand consideration on this matter. Please contact me if any of the above isincorrect.