| http://www.w3.org/ns/prov#value | - The Division's position is based upon all of the facts and representations in your letter, including your representations that: (1) TPC and the Program Trust are separate companies for purposes of analysis under the 1940 Act;1 (2) TPC is not, and does not hold itself out to be, engaged primarily in the business of investing, reinvesting, or trading in securities; (3) TPC does not and will not own
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