The U.S. Court of Appeals for the Second Circuit has asked the U.S. Securities and Exchange Commission (SEC) to share its views on the issue of whether syndicated term loans are securities for purposes of the Securities Act of 1933, as amended (the “Securities Act”), under the four-prong “family resemblance” test enumerated in Reves v. Ernst & Young, 494 U.S. 56 (1990).