[justinjlynn]

Does anyone know if the SEC has any process to formally approach them and say "This is what we're planning on doing and the structure we're planning on using -- this where we're unclear; how would you treat this?" like the IRS has with Private Letter Rulings/Written Determinations?

[azernik]

They do indeed - you can request a "no-action letter" confirming that an activity you have described to the SEC is okay.

https://www.sec.gov/fast-answers/answersnoactionhtm.html