RegAlert2003-04-30
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SEC Division of Corporation Finance no-action letter: Hechinger Liquidation Trust
The Division of Corporation Finance will not recommend enforcement action to the Commission if the Hechinger Liquidation Trust complies with the certification requirements of Rules 13a-14 and 15d-14 by providing a modified certification in the exact form submitted in the April 30, 2003 letter. This position accounts for the Trust's lack of executive officers and a board of directors, as well as its provision of financial statements on a liquidation basis. The response applies only to enforcement action and does not constitute a legal conclusion on the matter.
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Securities Act of 1934 - Rules 13a-14 and 15d-14
May 15, 2003 DIVISION OF CORPORATION FINANCE
Re: Hechinger Liquidation Trust
Incoming letter dated April 30, 2003
Based on the facts presented in your letter, this Division will not recommend enforcement action to the Commission if Hechinger Liquidation Trust complies with the certification requirements of Rules 13a-14 and 15d-14 of the Exchange Act of 1934, as applicable, by providing a certification in the exact form of the certification provided in your letter. In reaching this position, we considered in particular Hechinger Liquidation Trust's lack of executive officers and board of directors and that its financial statements are provided on a liquidation basis in accordance with generally accepted accounting principles.
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