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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01365535: Holder, Memorandum and Cayman Islands (DS10)

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Offering memorandum for ING IM CLO 2011-1, Ltd., an exempted company incorporated in the Cayman Islands, describing the issuance of Class C, D, and Subordinated Notes totaling approximately $70.72 million, as well as 36,780 Preferred Shares. The document outlines terms for holders of securities and references the company's Memorandum and Articles of Association.

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Excerpt 1
summary does not purport to be complete and is qualified in its entirety by reference to the detailed information appearing elsewhere in this Offering **Memorandum**
Excerpt 2
34,000,000 Class C Notes 20,000,000 Class D Notes 16,500,000 Subordinated Notes 4,220,000 The Issuer will issue 36,780 Preferred Shares pursuant to its **Memorandum**
Excerpt 3
and Articles of Association (as amended from time to time, the "**Memorandum** and Articles") and subject to the terms of the Fiscal Agency Agreement.

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