Proposed Exemption for Certain Prohibited Transactions Involving Hawai'i Pacific Health and Its Subsidiary, Straub Clinic & Hospital Located in Honolulu, Hawaii

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The Department of Labor (the Department) is considering granting an exemption that would permit the Hawai[revaps]i Pacific Health Retirement Plan (the Plan) to sell a parcel of improved real property (the Property) to Straub Clinic & Hospital (Straub) for at least the greater of $16,247,000 or 10% over the Appraised Value of the Property as of the date of the sale (the Sale). As discussed in the Summary of Facts and Representations section below, absent an exemption, the Sale would be prohibited by the Employee Retirement Income Security Act of 1974 (ERISA) and/or the Internal Revenue Code of 1986 (the Code).