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SEC Provides Interpretive Guidance regarding Rule 144 Holding Periods

The SEC issued a no-action letter providing interpretive guidance on the application of Rule 144 to the exchange of units in an umbrella partnership for shares of the parent real estate investment trust ("REIT"). The no-action letter stated that the holding period for the REIT securities commenced upon the acquisition of the operating partnership units and not the exchange of those units for REIT securities.

Primary Sources

  1. No-Action Letter to Bank of America, N.A., Merrill Lynch, and Pierce, Fenner & Smith Inc.
  2. Banks' Incoming Letter to SEC

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Tags

Regulated Activities
Distribution Procedures
Sub-Activity
SA Rule 144 and Rule 145
Regulated Entities
Traders / Investors / Counterparties
Body of Law
Securities Law
Jurisdiction
US - Federal
Organization
SEC