Form of Request
A no-action request should be in the form required in A.R.S. § 44-1826. In addition to other requirements, the request must identify the requesting entity, set forth the details of the transaction, cite the exemption or statutory basis for the conclusion that the transaction does not violate the Arizona Securities Act or the Arizona Investment Management Act, and contain the analysis supporting such conclusion.
Due to the fact-specific nature of no-action letters, the name of the entity for which a no-action letter is being requested must be included in the letter of request. Until the name is provided, the Division will not begin its review. Blind-pool offerings will not be considered for no-action letters.