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July 31, 1981

Re: ________: Statutory Violation

Dear Mr. ________:

This letter is in reference to the _______ line representing twelve (12) $75,000 loans to twelve (12) individual borrowers for investment in a real estate limited partnership listed as a violation of 1221(a) in our report of examination of January 8, 1981.

It is our opinion that loans made to individuals for investment in a limited partnership would not be considered loans for the benefit of the limited partnership if the loans are made to the individuals in good faith, if the individuals warrant the credit extended to them, and if the repayment of the loans to the individuals can be reasonably expected from the individuals from sources other than the partnership.

After reviewing all the information relating to this matter it appears that your loans satisfy this criteria; therefore, this line, in our opinion, is not considered a violation of 1221(a) of the Financial Code.

Very truly yours,

RICHARD M. DOMINGUEZ Superintendent of Banks

By

ROBERT B. CAMERON Deputy Superintendent of Banks

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