KopenTech in the Press
On September 1, 2016, the SEC issued a no-action letter to Sancus Capital Management LP clarifying that a proposed "applicable margin reset" mechanism built into certain notes issued in a CLO transaction would not constitute an offer and sale of asset-backed securities by an issuing entity within the meaning of Regulation RR (17 C.F.R. Part 246).
The staff of the Division of Corporate Finance of the U.S. Securities and Exchange Commission issued an interpretive letter to Sancus Capital Management LP and its affiliates in response to a letter from Dechert LLP on behalf of Sancus Capital on September 1, 2016.
The SEC releases a no action letter allowing Applicable Margin Reset transactions to take place in the CLO market.