SEC Division of Corporation Finance no-action letter: Apple REIT Six, Inc.

Apple REIT Six, Inc. proposes modifying its Unit Redemption Program to grant priority redemption to shareholders who own fewer than 100 Units. The company requests that the Division of Corporation Finance determine that these redemptions do not constitute an issuer tender offer under Rule 13e-4 or grant an exemption under Rule 13e-4(h)(9). The request relies on the argument that odd-lot redemptions present minimal potential for fraud and manipulation, consistent with previous no-action relief granted to similar real estate investment trusts.

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McGuireWoods LLP
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Martin 8. Richards rnrichards@mcguirewoods.com Direct: 80.1.775.1 029 ~M~GUIREWOODS Direct Fax: 804.698.2147 VL4 EMAIL and U.S.MAIL

Mr. Brian V. Breheny, Chief

Mr. Daniel F. Duchovny, Special Counsel

Office of Mergers and Acquisitions

Division of Corporation Finance

United States Securities and Exchange Commission

100 F Street,N.E.

Washington, DC 20549

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Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works