Arkansas Securities Department

A. Heath Abshure, Commissioner

Heritage West Building, Suite 300

201 East Markham Street

Little Rock, Arkansas 72201-1692

Main Telephone: (501) 324-9260 Facsimile: (501) 324-9268 Hotline: (800) 981-4429

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1999 Legal Opinions and No Action Letters

99-016 12/15/99	Gaudin & Associates, Inc. Brooke Inzerella Request waiver of Series 7 for Investment Adviser rep registration.
99-015 12/8/99	Arkansas Mortgage Loan Broker Licensing Requirements Legal opinion regarding the requirement of a maintainer of a website\bulletin board, where mortgage loan brokers list property for free and lenders pay to access the website, to register as a loan broker.
99-014 11/8/99	State Street Securities(8) Request no-action if they file all mutual fund forms with a typed signature.
99-013 10/29/99	Arkansas Mortgage Loan Company and Loan Broker Act Attorney presents six scenarios requesting advice on whether mortgage loan company registration is necessary or appropriate.
99-012 10/6/99	IBT. Inc. Securities Request no-action position that Key Employee Stock Investment Program quailifies as employee stock purchase program even though plan does not qualify for federal income tax purposes as employee benefit plan.
99-010 9/14/99	American Rivers Oil Company Securities Request no-action positions that exchange offer conforms to class vote exemption.
99-009 9/7/99	Section 18(b)(4)(A) of the Securities Act of 1933 Securities Interpretation of "Covered Security".
99-008 8/31/99	Financial Network Investment Corporation Securities Request for clarification of Arkansas' position regarding percentage lease networking arrangements between financial institutions and third party broker dealers.
99-007 7/30/99	John Hancock Mutual Life Insurance Company Securities Demutualization of mutual life insurance company. No action letter.
99-006 7/29/99	Metropolitan Life Insurance Company Securities Demutualization of mutual life insurance company and conversion to stock life insurance company.
99-005 6/07/99	Data Systems Network Corporation Securities No action taken on judicially approved issuance of stock and money to previous and existing stockholders.
99-004-S 4/29/99	Securities No action letter regarging demutualization of a mutual life insurance company to be achieved by a reaorganization incident to a class vote of all interest holders. (Request for confidential treatment granted)
99-003 4/16/99	Robert L. Stiles Securities Denial of a No Action letter regarding registration as a broker dealer and agent.
99-002 3/4/99	Purina Mills, Inc. Securities No Action letter concerning the offering of a cattle management program.
99-001 2/25/99	Conway Regional Surgery Center, LLC A.C.A. § 23-42-504(a)(9), Rule 504.01(a)(9)(A) and 206.01(A) No Action letter concerning the sales of units purchased solely for investment purposes.