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EXHIBIT 99.4
IRVING L. FAUGHT FRANK KEATING
GOVENOR
[Seal of the State of Oklahoma]
STATE OF OKLAHOMA
DEPARTMENT OF SECURITIES
December 15, 2000
D. Joe Rockett
Andrews Davis Legg Bixler Milsten & Price
500 West Main, Suite 500
Oklahoma City, OK 73102-2275
Re: Paceco Financial Services, Inc.
ODS File NA-2021920
Dear Mr. Rocket:
You have requested that the Administrator of the Oklahoma Department of
Securities (the "Department") issue a no-action position regarding activities of
Paceco Financial Services, Inc. ("Paceco") in the state of Oklahoma. We
incorporate herein the following documents by reference to the extent each
document was not subsequently amended or superseded:
1. The Notice of Depositors [of Paceco] dated October 10, 2000;
2. Your initial request for a no action letter dated October 26, 2000;
3. The Supplemental Notice to Investment Certificate Holders of Paceco
Financial Services, Inc., dated November 3, 2000;
4. Your amended request for a no action letter dated December 14,
2000;
5. The final Put Agreement as filed with the Department of
December 15, 2000;
6. The final Trust Agreement as filed with the Department on
December 15, 2000;
7. The Second Supplemental Notice to Investment Certificate Holders of
Paceco Financial Services, Inc., as filed with the Department on
December 15, 2000;
Such incorporated information constitutes the plan of Paceco for redeeming its
outstanding passbook savings and time certificates (the "Plan").
Based upon the information thus incorporated, the Department will not
take action against Paceco, or its officers, directors, shareholders, employees
and agents so long as the Plan is implemented as proposed and all certificate
holders have received payment of their outstanding principal balances plus
accrued interest by December 31, 2004.
In rendering this position, the Department did not conduct an
independent investigation to determine the accuracy or completeness of the
information provided in the request. Different
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facts or conditions from those represented might require a different
response. This expresses the Department's position on enforcement action only
and does not purport to express legal conclusions on the issues presented.
This position is furnished solely for the benefit and use of the persons
described herein.
Should you have any questions or comments, please contact the
undersigned.
Respectfully,
Iriving L. Faught
Administrator
/s/ Z. Faye Martin Morton
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by: Z. Faye Martin Morton
Registrations Counsel
ZFMM:
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