AMERICAN REGISTRAR & TRANSFER CO.
342 East 900 South, Salt Lake City, UT 84111
Ph (801) 363-9065 / (801) 363-9066
15 February, 2008
STATEMENT OF POLICY
Regarding Restricted Transfer Requests
Recent amendments to Rule 144 include a disqualification provision (paragraph (i)) that raises questions as to the availability of Rule 144 as a basis for removal of legend(s) from restricted securities of many issuers.
Therefore, American Registrar has elected to require a satisfactory legal opinion in connection with substantially all requests for transfer of restricted securities and hereby gives notice that to be satisfactory, such opinion(s) must address the question of availability of Rule 144 on a complete and specific and factual basis.
Exceptions will only be if American Registrar’s staff recognizes (without any effort on their part) that an issuer in question is outside the disqualification definition. American Registrar will make this determination only as to requests that are physically pending before it (with all applicable fees prepaid) and not on a hypothetical (advance telephone) basis. |