Practus, LLP
Season & Sell 2.0SM

The Season & Sell 2.0SM FinTech solution is a US tax legal program for non US investors investing in newly-originated or recently-modified US loans.

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ABOUT SEASON & SELL 2.0SM

Season & Sell 2.0SM provides Non-US Investors with an alternative strategy to invest in newly originated loans and recently modified loans. If you consider the traditional Season and Sell program to be unattractive due to cost or another reason, we have the solution.

Season & Sell 2.0SM turns a potentially “tainted loan”  into a “clean loan”. 

    • Tainted loans” are loans that are potentially treated as being newly-originated in the US by a non-US investor either directly, or indirectly (or constructively) by an agent of the non-US investor. 

    • Clean loans” are loans that are acquired in the secondary market rather than through origination.

Learn more about Season & Sell 2.0SM by contacting Todd Anderson

WHO WE SERVE

  • Non-US Investors
  • US direct lending funds
  • US mortgage REITs
  • Non-US CLO issuers
  • Master limited partnerships
  • Publicly traded partnerships
  • US loan originators
  • Investors using historic season
    & sell process
 

THE SOFTWARE SUPPORTS

Forward Flow
Arrangements

In-House
Origination

Workouts

Read the Latest Season & Sell 2.0SM Article

DESIGNING A NON-US INVESTOR'S US LOAN INVESTMENT PROGRAM

 

US TAX OPINION SAFEGUARDS

Season & Sell 2.0SM utilizes a number of US tax opinion safeguards – including a very carefully selected open loan marketplace and a very carefully designed set of proprietary boilerplate US tax representations. As a result, our tax opinion safeguards ensure: 

      • A fully transparent loan sale with equal opportunities to fully diligence, bid, and purchase loans
      • The assurance of zero gamesmanship
      • A reduction between 33% - 77% of the traditional loan seasoning period often required for related-party loan sales
      • An elimination of a number of other restrictions traditionally imposed by historic season & sell processes.

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Simple, Flexible, & Inexpensive

With the ability to generally work with any size loan, it is easy to incorporate Season & Sell 2.0SM into any current or future loan origination program or platform. 

US Tax Legal Comfort

For the benefit of the loan buyer, Practus, LLP® will render a US tax opinion at the highest level at the time of each loan purchase that satisfies the Season & Sell 2.0SM requirements. 

Robust Trading Marketplace

Each loan trades through an open and decentralized secondary loan trading marketplace platform. Plus, there is zero tax gamesmanship by any party in the marketplace.


Disclaimer:

  • This opinion is rendered on a loan-by-loan basis and does not create an attorney-client relationship with the loan buyer. The loan buyer should consult with its own tax advisors to determine the best method of incorporating Season & Sell 2.0SM into its current or future loan origination program or platform.
  • Investors should consult with their own tax advisors to determine the best method of incorporating Season & Sell 2.0SM into their
    current or future loan origination programs or platforms
  • This page, provided by Practus, LLP may be considered Attorney Advertising in some jurisdictions. Attorney advertising - Practus, LLP 61 Massachusetts Ave, Hyannis Port, MA 02647 (646)-942-0311.
  • Prior results do not guarantee a similar outcome. 

LET'S TALK!

For more information,
fill out the form or contact
Stephanie Recupero
(240) 206-6027 Email

Practus, LLP