SEC Company Response from Ares Management (ARES) — Apr 28, 2014
Ares Management Corp
Date: April 28, 2014 · CIK: 0001176948 · Accession: 0001104659-14-031359
AI Filing Summary & Sentiment
File numbers found in text: 333-194919
Letter
J.P. MORGAN SECURITIES LLC
383 Madison Avenue
New York, New York 10079
MERRILL LYNCH, PIERCE, FENNER &
SMITH INCORPORATED
One Bryant Park
New York, New York 10036
April 28, 2014
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549-3628
Attention: Suzanne Hayes
Re: Ares Management, L.P.
Registration Statement on Form S-1
File No. 333-194919
Acceleration Request
Ladies and Gentlemen:
As representatives of the several underwriters of the proposed public offering of 18,196,436 shares of common stock of Ares Management, L.P. (the “Company”), we hereby join the Company’s request to accelerate the date of the above-referenced Registration Statement, as then amended, effective as of 4:00 p.m. (New York time) on April 30, 2014, or as soon thereafter as is practicable.
Pursuant to Rule 460 under the Securities Act of 1933, as amended, we wish to advise you that we have distributed approximately 10,165 copies of the Company’s preliminary prospectus, dated April 22, 2014, through the date hereof, to underwriters, dealers, institutions and others.
The undersigned have been informed by the participating underwriters that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
(Signature Page Follows)
Very truly yours,
J.P. MORGAN SECURITIES LLC
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J.P. MORGAN SECURITIES LLC
383 Madison Avenue
New York, New York 10079
MERRILL LYNCH, PIERCE, FENNER &
SMITH INCORPORATED
One Bryant Park
New York, New York 10036
April 28, 2014
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
100 F. Street, N.E.
Washington, D.C. 20549-3628
Attention: Suzanne Hayes
Re: Ares Management, L.P.
Registration Statement on Form S-1
File No. 333-194919
Acceleration Request
Ladies and Gentlemen:
As representatives of the several underwriters of the proposed public offering of 18,196,436 shares of common stock of Ares Management, L.P. (the “Company”), we hereby join the Company’s request to accelerate the date of the above-referenced Registration Statement, as then amended, effective as of 4:00 p.m. (New York time) on April 30, 2014, or as soon thereafter as is practicable.
Pursuant to Rule 460 under the Securities Act of 1933, as amended, we wish to advise you that we have distributed approximately 10,165 copies of the Company’s preliminary prospectus, dated April 22, 2014, through the date hereof, to underwriters, dealers, institutions and others.
The undersigned have been informed by the participating underwriters that they have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
(Signature Page Follows)
Very truly yours,
J.P. MORGAN SECURITIES LLC
MERRILL LYNCH, PIERCE, FENNER & SMITH
INCORPORATED
As representatives of the several underwriters
By J.P. MORGAN SECURITIES LLC
By:
/s/ Hank Wilson
Authorized Representative
By MERRILL LYNCH, PIERCE, FENNER & SMITH
INCORPORATED
By:
/s/ Michele A.H. Allong
Authorized Representative