SEC Expands Favorable Rule 144 Interpretive Guidance to UP-PTP Structures
On November 16, 2016, the staff of the Division of Corporation Finance of the Securities and Exchange Commission orally confirmed to Simpson Thacher & Bartlett LLP that its recent interpretive guidance relating to the Rule 144(d) holding period for corporation shares or REIT shares acquired upon an exchange of operating partnership units in UP-C and UPREIT structures also applies to similar Umbrella Partnership – Publicly Traded Partnership (UP-PTP) structures.