Arkansas Securities Department

A request in which the Department confirms either that the distribution is exempt from registration requirements of the Securities Act § 23-42-101 et al, or that the distribution does not constitute a sale of securities under § 23-42-102(13)(B)(ii).

Arkansas Mutual Insurance Company (the "Company") requests that no enforcement be taken with regard to the issuance of "Surplus Notes" to Arkansans.  Alternatively, the Company requests the Department find that registration is not necessary under Ark. Code Ann. § 23-42-503(a)(9).

Request for advice regarding exemption from registration of an SEC Rule 701 Stock Compensation Plan.