Advisory opinion letter

September 8 , J 972

Dear Sir:

The American Oil Company, a wholly owned subsidiary of Standard Oil Company (Indiana) engaged in the refining, marketing, and transportation of petroleum products, currently evaluating the economic feasibility of establishing a subsidiary company to engage in the business of collecting consumer indebtedness.

It is contemplated that sucb a collection subsidiary would bc \vholly owned by American , that its directors would employees of American, but that it would operate independently of American and that its officers and employees would not be employees of American. The subsidiary would operate in all 48 contiguous states and would accept business from the public at large as well as from American. It is anticipated that, when 500(.. of itsestablished , this subsidiary \vould obtain no more than business from American Oil \vith the remaining 500/6 coming from unconnected outside chents. In the inHial stages some\vhat marc than 500/0 of its business may come from American. The subsidiary would be an autonomous business and \vould have to be self-sustaining.

I would like to solicit your advise on the following two issues. First, would operation of such a collection subsidiary without identifying American Oil as the owner thereof be considered an infringement of any of the Commission s Guides against Debt Collection Deception. Secondly, would operation of such a collection subsidian,T infringe the Assurance of Voluntary Compliance filed by Arnerican with the Commission on ADVISORY OPJNIO:-S AND REQUESTS THEREFOR 1939 September 13 1967 in which American declared that it would not represent that its receivables had been referred for col1ection to an independent agency or organization unless such receivables were so referred.

In accordance with 1.2 of the Commission s Procedures and Rules of Practice , I can assure you that a collection subsidiary is not presently owned or operated by American Oil nor does it form the basis for any investigation or other proceeding by the Commission or any other governmental agency. Thank you for your consideration of this matter. Very truly yours

/s/ RICHARD J. GOETSCH