Tender Offer - TRANSCONTINENTAL REALTY INVESTORS INC

Form Type: CORRESP

Filing Date: 2025-01-16

Corporate Action: Tender-offer

Type: Update

Accession Number: 000183988225002525

Filing Summary: Transcontinental Realty Investors, Inc. (TCI) filed a response to comments from the Securities and Exchange Commission (SEC) regarding their previous filings, including Schedule TO-T and Schedule 13E-3. The correspondence addresses six key comments from the SEC, revising critical sections of the filings. Notably, the Amendment No. 2 to Schedule TO corrects the outstanding shares information, confirming 4,066,178 shares as of November 8, 2024. The response asserts that there have been no recent transactions by TCI concerning IOR shares and clarifies the transaction value, stating it is not calculable until shares are tendered. The filing also confirms an extension of the tender offer to January 29, 2025, allowing shareholders sufficient time to review amendments. The document discusses the limited nature of the offer and clarifies potential inconsistencies regarding future acquisitions and transaction values, emphasizing that the offer is voluntary for unaffiliated IOR shareholders and detailing the basis of the offer value. Also, it addresses various comments on the need for clarity in specific terms, financial disclosures, and compliance with regulatory requirements.

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