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Email On January 23, 2015, the Staff of the U.S. Securities and Exchange Commission (the “SEC”) issued a no-action letter that allows certain tender offers for non-convertible debt securities to remain open for five business days, as opposed to the 20 business day period specified in Rule 14e-1 under the Securities Exchange Act of 1934 (the “Exchange Act”). The no-action letter supersedes several prior no-action letters that had established market practice for abbreviated tender offers for nearly 30 years. https://www.cadwalader.com/resources/clients-friends-memos/sec-issues-guidance-for-shorter-debt-tender-offers