1300 W. Washington Street

Phoenix, AZ 85007-2996

 

 

Main: (602) 542-4242

Email: SecuritiesDiv@azcc.gov

Arizona No Action Letters

Statute

Name of No Action Letter

CCH Blue Sky Law Reporter Paragraph

 Atlas Resources Series 28-2010 L.P., August 2017
 

A.R.S. §44-1801(9)-Definition of dealer

Norwest, December 1990

Independent Commercial Brokerage, October 1992

Regional Operations Group, Inc. November 1992

John Levins, November 1993

Bank Julius Baer, September 1996

Chase Manhattan Bank, March 1998

David Evans and Associate, Inc., March 2000

Zap.com, Inc., June 2000

American Savings Life Insurance Co, April 2003

not printed

9658

9661

not printed

9696

9696O

9696W

9696Y

9703

A.R.S. §44-1801(21)-Definition of sale

Collagen Corporation, December 1990

H.C.B., Inc., October 1991

International Leisure Enterprises, April 1992

Home Shopping Network, Inc., June 1992

Home Shopping Network, Inc., October 1992

Roche Holding AG, April 2008

not printed

not printed

9635

9644

9653

9713

A.R.S. §44-1801(22)-Definition of salesman

M & I Brokerage Services, Inc., May 1991

Smith Barney Inc., August 1995

Firstar Trust Company, August 1996

Prudential Securities Inc., July 1996

Chase Manhattan Bank, March 1998

Gruntal & Co., L.L.C., June 1998

not printed

9695Q

9696A

not printed

9696O

9696Q

A.R.S. §44-1801(26)-Definition of security

Rainbow Retreats, Inc., December 1991

Mobile Home Lot Owners Cooperative Association, September 1991; January 1992

Loma-Sabino Exchange Program, February 1992

California Rental Benefits Corporation, March 1992

Hardware Wholesalers, Inc., August 1992

Collision Automotive Repair Services, Inc., October 1992

Lucky Lotto Advertising, Inc., December 1992

Villa Lafayette Associates, Inc., February 1993

Dean Witter Financial Services Group, Inc. – Capital Accumulation Plan, April 1993

Investors Fiduciary Trust Corporation, November 1993

Atlantic Shores, a Cooperative, December 1993

WW Storage Association, April 1994

Primerica Financial Services Home Mortgages LP of Arizona, March 1995

Ace Hardware Corporation, August 1995

National Turf Cooperative, Inc., June 1996

Far Horizons Mobile Home Park Residents Cooperative Association, July 1996

Forex Investment Services Corporation and Eastern Vanguard Forex, Ltd., October 1997

Professional Veterinary Products, Inc., December 1996

EBCO Resources, Inc./EBCO U.S.A. Incorporated, May 1997

A World of ResidenSea Limited, May 1997

A World of ResidenSea Limited, October 1997

21st Century Pay Communications, Inc., October 1997

Green Bay Packers, Inc., November 1997

Stock Farm Club, Inc., July 1998

American Pharmacy Cooperative, Inc., January 2012

9622

 

9629

 

9625

9632

9651

9656

not printed

9664

 

9667

 

9681

9683

9685

9695K

9695P

not printed

not printed

 

9696I

not printed

9696H

9696F

not printed

9696K

9696M

9696R

A.R.S. §44-1842-Transactions by unregistered dealers and salesmen prohibited

Merrill Lynch Client Transition Program, September 2007

UAM Trust Company, July 1998

General Motors Financial Company, Inc., June 2016

 

9710

9696S

A.R.S. §44-1843(A)(1)-Exemption for securities issued or guaranteed by the U.S., any state or territory, or any political subdivision, agency, or instrumentality

Jasper County Indiana Pollution Control Revenue Refunding Bonds, June 1991

Public Building Commission of Chicago, January 1992

Industrial Development Authority of the City of Glendale Arizona, January 1992

City of Tucson Minibond Sale, May 1992

Louisiana Public Facilities Authority, Hospital Revenue Refunding Bonds (Southern Baptist Hospital Project), June 1992

Maine Health & Higher Education Facilities Authority, June 1992

Prairie Lakes Health Care System Issue, June 1992

AIG Liquidity Corp./American International Group, Inc., July 1992

Independent Commercial Brokerage, October 1992

County of Riverside California, October 1992

Regional Airports Improvement Corporation Facilities Lease Refunding Revenue Bonds Issue of 1992--United Airlines, Inc. (Los Angeles Int’l Airport), October 1992

State of Missouri Health Facilities Revenue Bonds, November 1992

Colorado Health Facilities Authority Hospital Revenue Bonds, March 1993

Triborough Bridge and Tunnel Authority, April 1993

California Statewide Communities Development Authority, July 1993

Industrial Development Authority of Maricopa-Catholic Healthcare West, July 1993

Industrial Development Authority of Maricopa-Catholic Healthcare West, November 1993

Investor Fiduciary Trust Corporation, November 1993

City of Henderson Nevada Insured Health Facility Refunding Service Bonds Series 1993-A-Catholic Healthcare West, November 1993

California Health Facilities Financing Authority Insured Health Facility Refunding Revenue Bonds (Catholic Healthcare West), November 1993

Industrial Development Authority of the County of Greenlee-Phelps Dodge, December 1993

Sister of Charity Leavenworth Health Services Corporation, January 1994

City of Willetts-Refunding Certificates of Participation, February 1994

Industrial Development Authority Bonds-Pima and Saddlebrook Utility Companies, January 1995

Gilpin County Certificates of Participation, April 1995

Industrial Development Authority of Mohave County-Health Care Revenue Refunding Bonds, Chris Ridge and Silver Ridge Village, May 1996

Myrtle Creek Building Authority, July 1996

Dormitory Authority of New York, University of Rochester, August 1996

Virginia Higher Education Tuition Trust Fund, November 1996

not printed

9628

9624

9638

 

9646

9645

9640

9649

9658

9657

 

 

 

9654

9662

9663

9669

9671

 

 

9672

 

9677

not printed

 

9678

 

9679

 

9682

not printed

not printed

 

9695E

9695M

 

not printed

not printed

not printed

not printed

A.R.S. §44-1843(A)(2)-Exemption for securities issued by a bank savings, credit, or loan association

Sterling Savings Association, January 1990

State Bank of India, September 1991

Liberty Savings Bank, April 1993

Investor Fiduciary Trust Corporation, November 1993

California Industrial Loan Companies, March 1994

Vintage Bank, May 1994

Sun Country Bank, July 1994

Dean Witter Utah Industrial Loan Companies, August 1994

Lehman Brothers, March 1995

Idaho Banking Company, May 1996

Smith Barney, August 1996

Oppenheimer Capital, September 1996

Imperial Thrift & Loan Association, November 1996

Pacific Crest Investment and Loan, November 1996

Great Banc, Inc., February 1997

not printed

not printed

9668

9678

9686

9688

9691

9692

9695J

9695U

9695Z

not printed

not printed

not printed

9696C

A.R.S. §44-1843(A)(5)-Public utility exemption

Jasper County Indiana Pollution Control Revenue Refunding Bonds, June 1991

not printed

A.R.S. §44-1843(A)(6)-Eleemosynary exemption

Baptist Foundation of Arizona, Royal Palms Baptist Church, June 1990

Kansas City Municipal Assistance Corporation, October 1990

Roman Catholic Diocese, February 1991

Roman Catholic Diocese, February 1992

Church Development Fund, January 1993

Beth Emeth Congregation, April 1993

Friendship Retirement Corporation, November 1993

Assemblies of God Loan Fund, January 1995

Church Extension Plan, March 1996

Church Extension Plan, April 1997

not printed

not printed

not printed

9626

9665

9674

9676

not printed

not printed

9696E

A.R.S. §44-1843(A)(7)-Exchange exemption

Interco, Inc., June 1990

Norwest, December 1990

American Brands, May 1991

Mercury Air Corp., June 1991

The Options Clearing Corporation, February 1992

Quidel Corp., May 1992

TPI Enterprises, June 1992

AIG Liquidity, July 1992

Central Vermont Public Service, November 1992

not printed

not printed

not printed

not printed

9627

9637

9643

9649

9660

 

A.R.S. §44-1843(A)(10)-Exemption for notes or bonds secured by a mortgage deed of trust on real estate or chattels

Clearwater Development, Inc., March 1992

9630

A.R.S. §44-1844(A)(1)-Private placement

American National Petroleum Company, February 1991

Grupo Financiero Banamax Accival, S.A. de C.V., June 1992

Villa Lafayette Associates, February 1993

Dean Witter Financial Services Group – Capital Accumulation Plan, April 1993

not printed

9647

9664

9667

A.R.S. §44-1844(A)(2)-Sale by trustee, executor, bank, or bankruptcy receiver

First Capital Holding Corp., September 1990

Businessland, Inc., August 1991

Quidel Corporation, May 1992

not printed

not printed

9637

A.R.S. §44-1844(A)(3)-Sale in good faith by pledgee

Recorp Partners, Inc., May 1991

Recorp Partners, Inc., January 1992

Recorp Partners, Inc., May 1992

not printed

9623

9636

A.R.S. §44-1844(A)(4)-Sale in good faith by a bona fide owner other than an issuer or underwriter in an isolated transaction

Rolling Hills Golf Course, Inc., May 1990

KV Partners, May 1996

Houston Enterprises, LLC, June 1996

 

not printed

not printed

9695X

A.R.S. §44-1844(A)(5)-Distribution of a corporation of securities out of retained earnings

Information Resources, Inc., October 1990

Deprenyl Research Limited, June 1992

Home Shopping Network, Inc., June 1992

Home Shopping Network, Inc., October 1992

Horace Mann Growth Fund, Inc., December 1992

Aztec Energy Corporation, August 1993

Velocity HSI, Inc., July 2000

TEL Offshore Trust-Magnum Hunter Resources, Inc., March 2005

Brookfield Infrastructure Partners L.P., September 2007

Infrared Systems International, July 2008

not printed

9642

9644

9653

9666

9670

9696Z

9708

9711

not printed

 

A.R.S. §44-1844(A)(6)-Transaction incident to a statutory or judicially approved reorganization and pursuant to shareholder approval

Peoples Financial Corp., January 1990

ECOVA Corporation, June 1990

Home Interstate Bancorp, July 1990

American Savings & Loan Association of Florida, February 1991

Magna Bancorp, Inc., December 1990

Dakota Bancorp, February 1991

Equus Investment I, L.P., February 1991

Santan Arizona Avenue Partners, L.P., February 1991

Utilitech, February 1991

Timberline Community Bank, July 1991

Kirksville Bancshares, Inc., August 1991

Mason-Dixon Bancshares, Inc., August 1991

Shelby County Savings Bank, August 1991

UF Bancorp, Inc., August 1991

BOK Financial Corporation, September 1991

Equus Investment II, L.P., December 1991

DiMark, Inc., March 1992

Abraxas Petroleum Corp., June 1992

American Federal Bank/Am-First Financial Corp., August 1992

CB Bancorp, Inc., October 1992

Fourth Financial Corporation, October 1992

Morgan County Federal Savings & Loan Association, November 1992

Fourth Financial Corporation, November 1993

Healthcare America, Inc., November 1993

Northwestern Financial Corp., November 1993

Northwest Equities Corp., February 1994

Midland Mutual Life Insurance Company, May 1994

Twin City Bancorp, Inc., November 1994

Colonial Funds, January 1995

First Federal Bancorporation, January 1995

Shrewsbury State Bank, February 1995

First State Bank of Fort Collins, April 1995

Mentor Funds, April 1995

N S&L Bancorp, Inc., April 1995

Putnam Intermediate Tax Exempt Fund, April 1995

Sun Capital Bank/Sun Capital Bancorp, April 1995

Gallup Federal Savings and Loan Association, May 1995

HealthPartners of Arizona, May 1995

Putnam Growth & Income Fund II, May 1995

Mentor Capital Growth Portfolio, June 1995

Farm Family Mutual Insurance Company, March 1996

Heartland Bancshares, Inc., March 1996

Westwood Savings Bank/Westwood Financial Corp., March 1996

Cerulean Company, Inc., May 1996

First Lancaster Bancshares, Inc., May 1996

Houston Enterprises, LLC, June 1996

Putnam Intermediate US Government Income Fund II, July 1996

Rocky Ford Financial, Inc., March 1997

High Country Bancorp, Inc., September 1997

The Canada Life Assurance Company, May 1999

Sun Life Assurance Company of Canada, May 1999

Gentry Resources Ltd., February 2001

Anthem Insurance Companies, Inc., July 2001

Farmers Home Holding Company Inc., October 2005

Trelawney Mining and Exploration Inc., August 2011

not printed

not printed

not printed

not printed

not printed

not printed

not printed

not printed

not printed

not printed

not printed

not printed

not printed

not printed

not printed

9621

9633

9639

9650

9652

9655

9659

9675

not printed

not printed

not printed

9687

not printed

9695H

9695A

9695I

not printed

not printed

not printed

9695N

not printed

not printed

9695O

not printed

not printed

9695T

not printed

not printed

9695V

not printed

9695X

not printed

not printed

not printed

9696T

not printed

9700

9698

not printed

A.R.S. §44-1844(A)(7)-Exchange with existing shareholders

Colonial Strategic Income Trust, July 1990

Mason-Dixon Bancshares, Inc., August 1991

Rhodes, Inc., November 1991

Morgan County Federal Savings and Loan Association, November 1992

Quidel Corporation, May 1992

Northwestern Financial Corporation, November 1993

Levitz Furniture, Inc., February 1996

not printed

not printed

not printed

9659

9637

not printed

9695S

 

A.R.S. §44-1844(A)(8)-Sale to a bank, savings institution, insurance company, investment company, pension or profit sharing trust or other financial institution or institutional buyer or a dealer whether acting for itself or in a fiduciary capacity

AL Sarroff, October 1991

Painewebber, July 1992

Corporate Network Brokerage Services, Inc., November 1993

ERP Operating L.P., May 1994

AmeriData Delaware LLC, April 1995

Collins Bay Island Securities, June 2001

CUSO Partners, L.L.C., August 2005

not printed

9648

9680

9689

9695L

9699

9709

A.R.S. §44-1844(A)(10)-Incorporators’ exemption

SedonaLoan, L.L.C., March 2005

not printed

A.R.S. §44-1844(A)(11)-Manual exemption

Painewebber, July 1992

Trans Canada Options Inc., August 1994

9648

9694

A.R.S. §44-1844(A)(14)-Sales in connection with a qualified employee benefit plan

Bromar, Inc., December 1990

INVESCO Retirement Trust, December 1990

CIGNA Corporation, June 1991

JIB Group Ltd., October 1991

Acceptance Insurance Company Inc., February 1994

National Health Enhancement Systems, August 1994

Cookson Group US Stock Purchase Plan, August 1994

AG Edwards Trust Company, July 1996

Emeriti Consortium for Retirement Health Solutions, December 2004

not printed

not printed

not printed

not printed

not printed

9693

9695B

9695Y

9705

A.R.S. §44-1844(A)(18)-Non-issuer transaction in an outstanding security

Aztec Energy Corporation, August 1993

9670

A.R.S. §44-1844(A)(19)-Secondary transactions to non-residents

Stuart-James Company Inc., August 1990

 

not printed

A.R.S. §44-1893-Contents of application for registration of securities by qualification

Clear Sky, May 1997

9696G

A.R.S. §44-3101(5)-Definition of investment adviser

Stock Search International, August 1994

TML Investment Advisers, Inc., October 1994

Baptist Foundation of Arizona, October 1994

Bank Julius Baer, September 1996

Koch Industries, Inc., July 2004

9695

9695D

9695F

9696

9706

A.R.S. §44-3101(6)-Definition of investment adviser representative

Henry & Horne, PLC, January 2005

9707

A.R.S. § 44-3151-Licensure of investment advisers and investment adviser representatives

Merrill Lynch Client Transition Program, September 2007

9710

A.R.S. §44-3152-Exemption of certain investment advisers

Genes Capital Management Co., November 1994

 

9695G

 

A.R.S. § 44-3159 – Reporting Requirements

Trendstat Capital Management, Inc., August, 2002

9702

A.R.S. §44-3321-Notice filings by open-end companies and unit investment trusts

Automated Business Development Corporation, April 1998

9696N

A.A.C. R14-4-101-Exempt transaction to existing shareholders and employees

Aztec Energy Corporation, August 1993

 

 

 

9670

A.A.C. R14-4-104-Salesman and dealer registration required for certain exempt offerings and transactions

Greycliff Group, Inc., April 1992

City of Tucson Minibond Sales, May 1992

Dewey Ballentine, July 1993

Virginia Higher Education Tuition Trust Fund, May 1997

First Industrial L.P., October 1997

Alcatel Alsthom Compagnie Generale d’Electricite, November 1997

Alcatel 2000 Group Savings Plan, July 2000

Statesman Realty, LLC, February 2008

9634

9638

9673

9696D

9696J

9696L

not printed

9712

A.A.C. R14-4-132-Books and records of dealers

Financial Network Investment Corporation, November 1995

9695R

 

A.A.C. R14-4-136-Exemption for certain compensatory benefit plans

General Instrument Corporation, June 1992

World Internet Holdings, Inc., December 2000

9641

9697

A.A.C. R14-4-137-Exemption for securities issued pursuant to court or governmental order

National Realty, L.P., March 1992

Quidel Corporation, May 1992

York Research Corporation, January 1994

Lida, Inc., October 1994

Cerulean Companies, Inc., May 1996

Harvey Universal, May 1996

Wired Ventures, Inc., May 1996

Washington Construction Group, Inc., September 1996

NTN Communications, Inc., November 1996

Data Systems Network Corp., June 1999

MMI Holdings, Inc., January 2000

CBOE Holdings, Inc., July 2009

9631

9637

9684

9695C

9695V

not printed

9695W

9696B

not printed

9697U

9696X

A.A.C. R14-4-308-Recission and restitution rule

David Evans & Associates, Inc., November 1991

Not printed

A.A.C. R14-6-206 – Custody of client funds or securities by investment adviser

Trendstat Capital Management, Inc., August 2002

9702

A.A.C. R14-6-212 – Application, Notice Filing, and Renewal Requirements

Trendstat Capital Management, Inc., August 2002

9702

Policy Statement – distribution of indentifying statements and preliminary prospectuses

BC Ziegler and Co. – Northridge Church, July 2002

9701

 

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Arizona Corporation Commission

1200 W. Washington Street

Phoenix, AZ 85007

 

Corporations Division

1300 W. Washington Street

Phoenix, AZ 85007

 

Tucson Office (Walk-ins only)

400 W. Congress Street

Tucson, AZ 85701