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: 0000905148-05-000172
AI Filing Summary & Sentiment
File numbers found in text: 333-121295
Letter
WRITER'S DIRECT WRITER'S E-MAIL NUMBER ADDRESS 212-839-5531 ckaplan@sidley.com January 12, 2005 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:
We have received the fax transmittal dated January 10, 2005 setting forth comments regarding the above-referenced matter. 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 revise page 38 of the prospectus (under the heading "Swap Agreements") to delete references to "options" generally in that section, including "interest rate option" and "currency option" or to explain supplementally why they are necessary.
We have revised the prospectus to remove such references.
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 January 12, 2005
Page 2
2. You requested that we remove the parenthetical on page 38 "including any option with respect to any of the foregoing transactions".
We have revised the prospectus to remove the parenthetical.
3. You requested that we confirm supplementally that none of the transactions contemplated in this discussion would have an equity based security as its reference obligation.
The Company confirms that none of the transactions contemplated in the above-referenced matter, unless otherwise permitted by the Staff, will include as an asset of a trust a transaction in which the reference obligation is an equity security.
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
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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 WRITER'S E-MAIL
NUMBER ADDRESS
212-839-5531 ckaplan@sidley.com
January 12, 2005
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:
We have received the fax transmittal dated January 10, 2005 setting
forth comments regarding the above-referenced matter. 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 revise page 38 of the prospectus (under the
heading "Swap Agreements") to delete references to "options" generally
in that section, including "interest rate option" and "currency option"
or to explain supplementally why they are necessary.
We have revised the prospectus to remove such references.
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
January 12, 2005
Page 2
2. You requested that we remove the parenthetical on page 38
"including any option with respect to any of the foregoing
transactions".
We have revised the prospectus to remove the parenthetical.
3. You requested that we confirm supplementally that none of the
transactions contemplated in this discussion would have an equity based
security as its reference obligation.
The Company confirms that none of the transactions contemplated in the
above-referenced matter, unless otherwise permitted by the Staff, will
include as an asset of a trust a transaction in which the reference
obligation is an equity security.
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>
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