Pension Benefit Guaranty Corporation 75-39 October 8, 1975 RE FERENCE: [*1] 402 1(b)(9) Plans Covered. Substantial Owner Plans OP INION: Th is letter is in response to your lette r of August 29, 1975, (enclosed) and in confi rmation of a conversation betweenyou an d a member of my staff, * * * on September 9, 1975.