This week, the Staff of the Division of Corporation Finance of the Securities and Exchange Commission granted our no-action letter modernizing and expanding the framework established with the issuance of the 1996 Morgan Stanley no-action letter (“MS Letter”). This no-action letter relief confirms the application of the abbreviated disclosure approach described in the MS Letter for the offer of debt securities registered under the Securities Act of 1933, as amended, referencing the performance of certain underlying securities to registered debt securities referencing the performance of a broader selection of underlying equity assets (such debt securities, “Structured Notes”).
