US CLO Risk Retention

IMG_2290With the CLO risk retention deadline of 12/24/16 in the rear view mirror  most were expecting to see CLO refi activity drop to near zero however in the first two weeks of 2017 we have already seen at least 2 deals initiate refinancing.  Has there been a clarification from the government that refinanced notes won’t be considered an offer of new securities?  I’ll update this post as I learn more.  Let’s discuss in the comments if you have thoughts on this.