SEC Issues No-Action Relief for Unregistered Sale of Demand Notes under Section 3(a)(5)(A)
The SEC Division of Corporation Finance issued no-action relief to Staple Cotton Discount Corporation in connection with the unregistered offer and sale of demand notes in reliance on Section 3(a)(5)(A) of the Securities Act. In its request for relief, Staple Cotton Discount Corporation alleged that it was both a "cooperative bank" and "similar institution" within the meaning of Section 3(a)(5)(A), which exempts from registration the securities issued by both kinds of entities.
See: SEC No-Action Letter to Staple Cotton Discount Corporation.