Arkansas Securities Department

Request for issuance of a no-action letter, determining that the Certificates of Membership and Participation in API are not a security within the meaning of the Arkansas Securities Act. 

Request interpretive opinion regarding integration of two 506 Reg D offerings more than 6 months apart and then an intrastate public offering registered by qualification.

Request for response to letter asking if the company's business activities are now regulated by the Department as the sale of viatical settlement contracts under the Arkansas Securities Act.

Request no action that shareholder is not an issuer even though he is a director based on § 23-42-504(a)(1). Shareholder owns 3% of outstanding stock.

Cooperative hardware company requires ownership in Common Stock to gain membership in coop. Request no action opinion that stock is not a security within the meaning of § 23-42-102(15)(A) of the Act. 

Request for no-action position with respect to the conversion of a mutual insurance company to a stock insurance company based on Rule 504.01(A)(12)(g) promulgated under Ark. Code Ann. § 23-42-504(a)(12). 

Request for opinion on whether a consortium of banks, or Citibank, N.A., as its administrator, must be registered as a mortgage loan company based on Arkansas Code Ann. § 23-39-306(a)(1).

Request for opinion that company is exempt from registration in Arkansas as a broker-dealer as defined and provided for by the Arkansas Securities Act.

Request for the issuance of a no action position regarding the conversion of a mutual life insurance company to a stock life insurance company according to Rule 504.01(A)(12)(g).