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New Five Business Day Timeline for Debt Tender or Exchange Offers

On January 23, 2015, the Staff of the US Securities and Exchange Commission issued a no-action letter (the “No-Action Letter”) providing that it would not recommend enforcement action with respect to a five business day timeline for tender or exchange offers for non-convertible debt securities meeting certain criteria. This no-action position supersedes the prior no-action letters of the SEC relating to abbreviated offering periods in non-convertible debt tender offers.

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