Guarantees/letters of credit 

 The Securities Division holds the position that when a guarantee/letter of credit is an integral part of an underlying security and is not separable from the underlying security and has no value apart from the underlying security, the guarantee/letter of credit and the underlying security will be considered as a single unit. When the underlying security is exempt from registration, separate registration of the guarantee/letter of credit is not required. When registration is required, a single registration of both the underlying security and the guarantee/letter of credit is sufficient.

[Policy Statement, Arizona Corporation Commission, Securities Division, 1-21-91.]

 

 

 
This substantive policy statement is advisory only.  A substantive policy statement does not include internal procedural documents that only affect the internal procedures of the agency and does not impose additional requirements or penalties on regulated parties or include confidential information or rules made in accordance with the Arizona administrative procedure act.  If you believe that this substantive policy statement does impose additional requirements or penalties on regulated parties you may petition the agency under section 41-1033, Arizona Revised Statutes, for a review of the statement.