SEC Issues No-Action Relief for Refinancing Certain Legacy CLOs

On July 17, the staff of the Division of Corporation Finance of the Securities and Exchange Commission issued a no-action letter to Crescent Capital Group LP in response to a letter from Cleary Gottlieb on behalf of Crescent Capital requesting relief from the risk retention requirements of Section 15G of the Securities and Exchange Act of 1934 that would otherwise apply to a refinancing of notes issued in a legacy collateralized loan obligation (CLO) transaction. To qualify for the no-action relief, the refinancing of CLO notes must satisfy the a number of conditions.