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SEC Company Response from CREDIT SUISSE ASSET REPACKAGING DEPOSITOR LLC (CIK 0001310793) — Jan 12, 2005

CREDIT SUISSE ASSET REPACKAGING DEPOSITOR LLC (CIK 0001310793)
Date: Jan. 12, 2005 · CIK: 0001310793 · Accession: 0000905148-05-000170

AI Filing Summary & Sentiment

File numbers found in text: 333-121295

Date
December 22, 2004
Author
/s/ Cathy M. Kaplan
Form
CORRESP
Company
CREDIT SUISSE ASSET REPACKAGING DEPOSITOR LLC (CIK 0001310793)

Letter

WRITER'S DIRECT NUMBER WRITER'S E-MAIL ADDRESS 212-839-5531 ckaplan@sidley.com December 22, 2004 Ms. Hanna Teshome Attorney-Adviser Securities and Exchange Commission Division of Corporation Finance 430 Fifth Street, N.W., Mail Stop 0305 Washington, D.C. 20549-0305

Re: CSFB Asset Repackaging Depositor LLC (the "Company") Registration Statement on Form S-3, File No. 333-121295, Filed on December 7, 2004 -------------------------------------------------------

Dear Ms. Teshome:

Thank you for your phone call today regarding the above-referenced matter. Set forth below are responses to the points you raised during the call. All factual statements and information set forth below are based on information furnished to us by representatives of the Company.

Form S-3 --------

Prospectus ----------

1. You requested that we delete references to "indexed certificates" on page 23 of the prospectus.

We have revised the prospectus to remove such references.

2. You requested that we delete references to "index swap" and "index option" in the first

SIDLEY AUSTIN BROwN & WOOD LLP IS A DELAWARE LIMITED LIABILITY PARTNERSHIP PRACTICING IN AFFILIATION WITH OTHER SIDLEY AUSTIN BROWN & WOOD PARTNERSHIPS

<PAGE>

SIDLEY AUSTIN BROWN & WOOD LLP NEW YORK

Ms. Hanna Teshome December 22, 2004 Page 2

bullet point under the heading "Swap Agreements" on page 38.

We have revised the prospectus to remove such references.

3. You requested further clarification of the terms "bond option" and "interest rate option" in the first 3. bullet point under the heading "Swap Agreements" on page 38.

We have revised the prospectus to remove the reference to "bond option".

An "interest rate option" is a contract which gives one party (the buyer) the right, but not the obligation, to receive from or pay to another party (the seller) a specific interest rate on a predetermined principal for a predetermined period of time. The discharge of payments may not be in one period, but over several repetitive periods. Payments from the buyer's side are limited to the premium payment while the seller's payments are subject to the situation or actions of the buyer in accordance with the option contract purchased by the buyer. The seller of an interest rate option receives premium in the form of an upfront payment or annuity/increased interest rate payment in return for allowing the buyer to benefit under certain possible future movements in interest rates.

4. You requested that we delete the following language under the heading "Swap Agreements" on page 38: "any 4. other transaction identified in the swap agreement or the relevant confirmation and described in the prospectus supplement".

We have revised the prospectus to remove the language.

We attach marked pages to the prospectus showing the requested revisions. Should you require any further information, please feel free to call the undersigned at (212) 839-5531.

Thank you for your continued attention to this matter.

Sincerely,
/s/ Cathy M. Kaplan

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                        SIDLEY AUSTIN BROWN & WOOD LLP

      BEIJING                787 SEVENTH AVENUE              LOS ANGELES
       ----               NEW YORK, NEW YORK 10019               ----
     BRUSSELS             TELEPHONE 212 839 5300               NEW YORK
       ----                FACSIMILE 212 839 5599                ----
      CHICAGO                  www.sidley.com               SAN FRANCISCO
       ----                                                      ----
      DALLAS                   FOUNDED 1866                    SHANGHAI
       ----                                                      ----
      GENEVA                                                  SINGAPORE
       ----                                                      ----
     HONG KONG                                                   TOKYO
       ----                                                      ----
       LONDON                                               WASHINGTON, D.C.

WRITER'S DIRECT NUMBER                                 WRITER'S E-MAIL ADDRESS
    212-839-5531                                           ckaplan@sidley.com

                                December 22, 2004

Ms. Hanna Teshome
Attorney-Adviser
Securities and Exchange Commission
Division of Corporation Finance
430 Fifth Street, N.W., Mail Stop 0305
Washington, D.C.  20549-0305

            Re:  CSFB Asset Repackaging Depositor LLC (the "Company")
                 Registration Statement on Form S-3, File No. 333-121295,
                 Filed on December 7, 2004
                 -------------------------------------------------------

Dear Ms. Teshome:

         Thank you for your phone call today regarding the above-referenced
matter. Set forth below are responses to the points you raised during the call.
All factual statements and information set forth below are based on information
furnished to us by representatives of the Company.

Form S-3
--------

Prospectus
----------

1.     You requested that we delete references to "indexed certificates" on
       page 23 of the prospectus.

       We have revised the prospectus to remove such references.

2.     You requested that we delete references to "index swap" and "index
       option" in the first

SIDLEY AUSTIN BROwN & WOOD LLP IS A DELAWARE LIMITED LIABILITY PARTNERSHIP
PRACTICING IN AFFILIATION WITH OTHER SIDLEY AUSTIN BROWN & WOOD PARTNERSHIPS

<PAGE>

SIDLEY AUSTIN BROWN & WOOD LLP                                       NEW YORK

Ms. Hanna Teshome
December 22, 2004
Page 2

       bullet point under the heading "Swap Agreements" on page 38.

       We have revised the prospectus to remove such references.

3.     You requested further clarification of the terms "bond option" and
       "interest rate option" in the first 3. bullet point under the heading
       "Swap Agreements" on page 38.

       We have revised the prospectus to remove the reference to "bond option".

       An "interest rate option" is a contract which gives one party (the
       buyer) the right, but not the obligation, to receive from or pay to
       another party (the seller) a specific interest rate on a
       predetermined principal for a predetermined period of time. The
       discharge of payments may not be in one period, but over several
       repetitive periods. Payments from the buyer's side are limited to the
       premium payment while the seller's payments are subject to the
       situation or actions of the buyer in accordance with the option
       contract purchased by the buyer. The seller of an interest rate
       option receives premium in the form of an upfront payment or
       annuity/increased interest rate payment in return for allowing the
       buyer to benefit under certain possible future movements in interest
       rates.

4.     You requested that we delete the following language under the heading
       "Swap Agreements" on page 38: "any 4. other transaction identified in
       the swap agreement or the relevant confirmation and described in the
       prospectus supplement".

       We have revised the prospectus to remove the language.

       We attach marked pages to the prospectus showing the requested
revisions. Should you require any further information, please feel free to call
the undersigned at (212) 839-5531.

       Thank you for your continued attention to this matter.

                                               Sincerely,

                                               /s/ Cathy M. Kaplan

                                               Cathy M. Kaplan

cc:   Helena Willner, Esq.

</TEXT>
</DOCUMENT>