On January 23, 2015, the staff of the SEC’s Division of Corporation Finance issued revised guidance in connection with debt tender offers. Specifically, the guidance sets forth when a tender offer may be open for a period of fewer than 20 business days, as well as the number of days that must still remain in certain tender offers following a change to the consideration or terms of the offer. The new guidance modernizes a number of the SEC staff’s long-standing positions and impacts the terms and conditions of certain debt tender offers.

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