Comment from American Investment Council

American Investment CouncilOpposeAdvocacy
Summary: The American Investment Council (AIC) opposes the proposed regulations because they create a presumption that acquiring debt is a commercial activity and introduce a facts and circumstances test that they believe reduces clarity. They argue for reverting to the 2011 proposed framework, expanding safe harbors for various debt offerings, and clarifying that customary minority investor protections do not constitute "effective control."
See attached file

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