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
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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
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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
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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
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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.
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