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12/19/20 9:33 PM

#654014 RE: kthomp19 #654006

There are many instances in exchange offers that are completed either in a bk through an RSA agreement or outside of bk with exchange offers. The citi example is one where the government was involved but outside that in normal business it is quite common.

https://www.sec.gov/Archives/edgar/data/1232582/000110465920118206/tm2032092d10_ex99-1.htm

https://www.sec.gov/Archives/edgar/data/1232582/000123258220000110/aht-sctoxiamendmentno6_554.htm