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The computer leasing transactions were generally structured
with the use of an intermediary company between FSC, the leasing
company, and IRA, the investor/owner/purchaser. The intermediary
company would purportedly buy the equipment from FSC and sell it
to IRA, and IRA would then lease it back to FSC. O.P.M., Horizon
Leasing Corp. (Horizon), Pluto Leasing Corp. (Pluto), and Knight
were corporations purportedly engaged in the buying, selling, and
leasing of computer equipment, both new and used, and served as
intermediaries in some of the subject transactions.
The provisions of the Agreement of Lease between the leasing
entity and any intermediary generally coincide with the
provisions of the Agreement of Lease between IRA and the leasing
company, or IRA and an intermediary, except for minor variations
in the amounts of rent specified in the schedule thereto. With
respect to the equipment leasing transactions entered into by
FSC/FSAM and IRA, the payments made by the leasing company (FSC)
to the owner/purchaser, IRA, and the payments from the
owner/purchaser, e.g., IRA to the leasing company (FSC), coincide
or may be only slightly different for the 96- or 108-month
duration of the lease obligation between the owner and the
lessee.
The long-term notes in each of the leasing transactions
contained provisions with respect to the manner and amounts of
interest prepayments and amounts of the monthly installments
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