The following is known:

**Theorem.** Suppose $V[G]$ is a generic extension of $V$ by a set forcing, and let $N$ be a model of $ZFC$ with $V\subseteq N\subseteq V[G].$ Then $N$ is a generic extension of $V$ by a set forcing, in particular $N=V[A],$ for some set of ordinals.

It seems that the above theorem is not true if $N$ does not satisfy $AC$. In fact the following abstract is given in a talk by James Cummings (see http://settheory.mathtalks.org/cmu-math-logic-seminar-tues-11-september/):

**If $c$ is Cohen-generic over $L$, then there is a transitive class model $M$ of $ZF$ intermediate between $L$ and $L[c]$ which is not of the form $L(A)$ for any $A.$**

Does anyone know a proof of this fact?