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impact on Mexico's economy (e.g., zero percent reflected the
greatest benefit and 25 percent reflected the least benefit). On
September 18, 1987, Mellon Bank (Mellon), selected by CMI-Texas
as the financial intermediary, paid US$1,115,500 (i.e.,
reflecting the prevailing market discount rate of 51.5 percent)
for an assignment of debt with a face value of US$2,300,000.
On October 1, 1987, the Mexican Government, CMI-Texas,
Industrias, and Mellon entered into a Purchase and Capitalization
Agreement (Agreement), which delineated the terms of the swap
transaction. On October 15, 1987, Mellon informed all parties
that the transaction would close on October 28, 1987. On October
21, 1987, CMI-Texas tendered US$1,125,000 (i.e., Mellon's cost of
the debt, US$1,115,500, plus a US$9,500 commission fee) to
Mellon.
On October 28, 1987, the parties simultaneously consummated
the following transactions: (1) Mellon sold to CMI-Texas, for
the previously tendered US$1,125,000, a 100-percent "undivided
interest" in U.S.-dollar-denominated debt (debt interest) with a
face value of US$2,300,000; (2) CMI-Texas transferred its debt
interest to Industrias as an equity contribution; (3) Mellon
canceled the debt interest and the underlying debt; (4) the
Mexican Government deposited Mex$3,206,085,431 in an interest-
bearing account on behalf of Industrias; and (5) Industrias
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