Opinions

Request for written response stating that Global Cash Access, Inc. does not require licensure under the Arkansas Uniform Money Services Act, Ark. Code Ann. § 23-55-101 – 1005.

Request for no action regarding Education America, Inc. 2008 Stock Option Plan relying on exemption pursuant to Ark. Code Ann. §23-42-503(a)(8).

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.

Request that no enforcement action be taken if Merrill Lynch enters into certain arrangements with departing agents under which it will pay agents a percentage of compensation derived by the firm from payment of fees and commissions from departing agents’ clients.

Request that no enforcement be taken against T.J. Raney & Sons, Inc. (“Raney”) for entering into rental agreements with various Arkansas Banks.  Raney will pay a base rent to those banks plus a percentage of revenue and provide disclosures to clients under 17 CFR Section 275.206(4)-3.

Request for issuance of a no action letter for Brickhouse Group, LLC based on the company issuing additional membership units to certain additional purchasers outlined by Ark. Code Ann. § 23-42-504 and applicable Rule 504.01(A)(12)(i).

Request for the Department to issue a no action letter with respect to transactions involved in a proposed plan to convert from a Texas business corporation to a Delaware corporation operating as a cooperative.