We advised SUA 2025-1 on its inaugural securitization notes offering

Davis Polk advised SUA 2025-1 LLC in connection with a Rule 144A and Regulation S offering of $133.3 million aggregate principal amount of its tax lien securitization notes. The notes are collateralized by certain tax liens secured by properties located in the states of Alabama, Colorado, Illinois, Iowa, Louisiana, Montana, Nebraska and Ohio. The net proceeds were used, among other things, to pay the purchase price for the tax lien assets.

The issuer is a Delaware limited liability company formed for the purpose of issuing the notes and the acquisition, owning, holding, administering, financing, management, selling and pledging of the tax lien assets securing the notes. The issuer’s membership interests are initially solely owned by the seller.

The seller is a Delaware limited liability company jointly managed by the originators as a joint venture, with SIP Tax Lien Fund 1, LLC acting as the administrator with respect to certain day-to-day operations of the seller. Each originator is a limited liability company primarily engaged in the business of purchasing tax liens.

The Davis Polk finance team included partner Ryan D. McNaughton, counsel Yuko Sin and associates Mario Babic, Aaron Kirchner-Loeser, Zachariah C. Taylor and Nazli Ungan. Partners John B. Meade and Stephen A. Byeff and counsel John H. Runne provided capital markets advice. Partner Gregory S. Rowland provided 1940 Act advice. All members of the Davis Polk team are based in the New York office.