200604621L



April 21, 2006

**************
**************
**************

Dear **************:

Thank you for your April 4, 2006, letter regarding the franchise tax 
apportionment for your client, COMPANY.

You stated in your letter that COMPANY is a diversified financial service 
provider servicing consumers and institutions worldwide.  The client, as a 
mortgage banker, originates, sells, and services single-family residential 
mortgage loans.

COMPANY has had an impressive record of growth in Texas and represents the 
strong business friendly environment the state offers. You also noted that it 
appears that one feature of the Texas franchise tax, the apportionment of 
receipts related to loan servicing activities, treats your client differently 
from its chief competitors and could result in a disproportionate tax burden.

Upon review of your alternative proposals, we have determined the receipts from 
loan servicing, where the loans are secured by real property, should be sourced 
based on the location of the underlying real property.

If you have any additional questions, please contact me at 463-4444.  Thanks 
for all that you do for Texas.

Sincerely,


Carole Keeton Strayhorn
Texas Comptroller


c:  Mike Reissig, Director, Tax Administration



ACCESSION NUMBER: 200604621L
SUPERSEDED: N
DOCUMENT TYPE: L
DATE: 04/21/2006
TAX TYPE: FRANCHISE