Arkansas Securities Department

Request for an interpretation of the word "person" as that term is used in Rule 504.01(A)(12)(a) of the Rules of the Arkansas Securities Commissioner.

Request for the Department's position regarding the propriety of payment by a registered investment adviser to individuals who are not registered as investment adviser representatives for the solicitation of customers.

Request for no action that no notice filing is required for covered securities, which are securities exempt under (3)(a)(2) of the Securities Act of 1933.

Request for a no action regarding the organization of a limited partnership under Rule 504.01(A)(12)(a) of the Rules of the Arkansas Securities Commissioner and subsequent transfer of securities by gift is not a sale pursusant to Ark. Code Ann. § 23-42-102(13).

Request for no action position regarding exemption of registation for University Alumni Funds, LLC as a broker-dealer. The request for no action postion is declined.

Request that no enforcement action be taken involving sale of a business pursuant to Rule 504.01(A)(12)(1) of the Rules of the Arkansas Securities Commissioner.

Request for no action position not to require registration of the retired agents who participate in this plan pursuant to Ark. Code Ann. § 23-42-301.

Request that no enforcement action be taken involving 100% sale of business, seller will amintain position on Board and receive a 5 year promissory note.

Requesting no action that registration as an investment adviser is not needed when advice is given over the internet, but not based on the individual client's needs. James Moore is a registered agent and will receive compensation.

Integration issues regarding Ark. Code Ann. § 23-42-503(b) public offering exemption and Rule 503.01(B) of the Rules of the Arkansas Securities Commissioner.

Requesting no-action that guaranty of revenue bonds by Continental Airlines are not treated as a separate security.  Bonds are a covered security Section 18(b)(4)(C) of the Securities Act of 1933.

Requesting no action that notes in this transaction are not considered securities, but a commercial transaction with a bank.

Requesting no action position that allows typed signatures instead of manual and notarized signatures.

Request that no enforcement action be taken involving two companies with foreign subsidiaries and affiliates that would not normally generate audited finanicals on time. The Department will allow them to file at a later date, but require them to file interims on time.

Request for interpretative opinion of "manual exemption" pursuant to Ark. Code Ann. § 23-42-504(a)(2).