On July 17, 2015, the SEC published a no-action letter
addressing the effect on the sponsor's credit risk retention
requirement of the refinancing of one or more tranches of existing
CLO debt, an issue which has been of considerable interest to the
CLO sector as it directly affects the utility of the refinancing
option in transactions done before the adoption of the credit risk
retention rules. In response to a request submitted by
Crescent Capital Group LP, the SEC indicated that under the terms
and conditions described in the request, such a refinancing of
collateralized loan obligations priced prior to the December 24,
2014 publication of the final credit risk retention rules would not
trigger the application of the credit risk retention requirement to
the CLO. In order to be entitled to such treatment, among
other things, (i) the refinancing must be completed within four
years of the original closing date, (ii) the interest rate of the
refinancing notes must be
