On December 22, 2020, the Board of Governors of the Federal Reserve System (the “Board” or the “Federal Reserve”), the Federal Deposit Insurance Corporation (the “FDIC”) and the Office of the Comptroller of the Currency (the “OCC”) (collectively, the “Agencies”) issued a “Revised Statement Regarding Status of Certain Investment Funds and Their Portfolio Investments for Purposes of Regulation O and Reporting Requirements under Part 363 of FDIC Regulations” (the “Revised Statement”). The Revised Statement extends and expands a “no-action” position established initially by the Agencies on December 27, 2019, which was scheduled to expire on January 1, 2021 (the “Original Statement”), for bank extensions of credit to portfolio companies of certain institutional investors that would otherwise violate the limitations and restrictions of Regulation O on bank extensions of credit to the “related interests” of “principal shareholders.” The revised no-action relief will apply until January 1, 2022 unless amended prior to that time.