No.

J. Richard Barnes, C.L.U. Commissioner of Insurance Division of Insurance State Office Building Room 106 Denver, Colorado 80203

Dear Mr. Barnes:

This opinion letter is in response to your letter of April 4, 1980 in which you ask whether business entities or individuals which share no common ownership and are not members of the same economic family may join together to form a pure captive insurance company under the Colorado Captive Insurance Company Act.

QUESTIONS PRESENTED AND CONCLUSIONS

Your request for an attorney general's opinion presents, initially, two questions:

1. Whether 10 or fewer…