Hogan Lovells Publications | SEC Update | 15 March 2016

SEC Staff Issues No-Action Letter Facilitating Rule 144 Sales of REIT Shares Received in Exchange for Operating Partnership Units

On March 14, the staff of the SEC’s Division of Corporation Finance issued a no-action letter that will enable holders of shares of a publicly traded real estate investment trust (REIT) received in exchange for privately placed units of the REIT’s operating partnership to sell the shares under Rule 144 without having to start a new holding period for them. The staff issued the letter in response to a no-action request jointly submitted by Bank of America, N.A. and Merrill Lynch, Pierce, Fenner & Smith Incorporated and three law firms, including Hogan Lovells. The letter is captioned Bank of America, N.A., Merrill Lynch, Pierce, Fenner & Smith Incorporated and is available here.

Read more: SEC Staff Issues No-Action Letter Facilitating Rule 144 Sales of REIT Shares Received in Exchange for Operating Partnership Units

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