- 54 - structure the BP-AIG notes in accordance with instructions received from the prospective client’s representative, and that, after issuance, AIG was willing to modify those notes in accordance with the purchaser’s wishes, even at a possible financial loss. We do not agree that any of the documents respondent refers to constitute evidence of an “arrangement” that would render the AIG notes marketable under section 731(c)(2)(B)(ii). AIG’s willingness to “consider” a modification or repurchase of the AIG notes does not constitute evidence of an “arrangement” to convert the AIG notes into cash or marketable securities at MP’s request, as it would be no more than standard business practice for a bank or financial institution to at least consider a customer’s request to modify the terms of its notes. Morever, respondent’s counsel has made no representations to the Court that she is able to get Mr. Nelson or anyone else on behalf of AIG to testify that it was AIG’s “practice” to renegotiate the terms of or to repurchase its notes. Nor did AIG’s willingness to structure and, subsequently, restructure the BP-AIG notes in accordance with the customer’s wishes at a probable overall loss (on account of transaction costs) indicate that the parties were not operating at arm’s length then or later in connection with the AIG notes. An e-mail from Mr. Nelson makes clear that that willingness (and, in particular, the willingness to modify the note terms) was aPage: Previous 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 NextLast modified: March 27, 2008