The SEC Division of Corporation Finance (the "Division") granted no-action relief to Griffin Capital Essential Asset REIT II, Inc. ("Griffin"), a Maryland-based real estate investment trust, from tender offer requirements under Exchange Act Rule 13e-4. The no-action relief allows Griffin to adopt a New Redemption Program (the "Program") that gives stockholders the option of redeeming shares of common stock on a quarterly basis.

According to Griffin, the Program was developed in order to provide liquidity for stockholders in connection with a revised public offering plan and is similar to the redemption plans of other perpetual-life, non-listed REITs that recently have been granted no-action relief by the Division. While several classes of stockholders will be eligible for the Program, stockholders who have held stocks for less than one year, or stockholders who have held Griffin shares from its initial public offering for less than four years, will not be eligible.

The Division determined that the Program would not constitute an issuer tender offer, subject to Exchange Act Rule 13e-4.

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