SEC Updates Compliance and Disclosure Interpretations for Legacy Deals

Orrick - Finance 20/20
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On September 16, the SEC  released its updated compliance and disclosure interpretations for the rules adopted under Regulation AB, the Securities Act and the Exchange Act. Among others, the updated interpretation clarified that securitizations for which offers are made prior to November 23, 2016 are not required to provide asset-level disclosures in the prospectus or on an ongoing basis with each Form 10-D. Compliance and Disclosure Interpretation.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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