SEC Grants Exemption to Insurance Company from Exchange Act Registration

The SEC Division of Corporation Finance granted an exemption from the registration of membership interests in a Wisconsin mutual insurance company undergoing reorganization to become a stock insurance company.

The American Family Mutual Insurance Company's ("AFMIC") request for relief stemmed from the AFMIC's conversion from a mutual insurance company to a stock insurance company, which included the restructuring of mutual insurance companies to stock insurance companies, with a mutual insurance holding company as the ultimate parent.

The SEC granted the no-action relief in reliance on AFMIC's opinion of counsel that membership interests are not securities within the meaning of the Securities Act or the Exchange Act.