February 6, 2012

The Securities Commissioner has issued an Order of Exemption from licensing as an investment adviser to Kopper Investment Management, Inc., and William Bruce Kopper

Request
Order of Exemption

February 6, 2012

The Securities Commissioner has issued an Order of Exemption from licensing as an investment adviser to Captiva Ventures, LLC

Request
Order of Exemption

February 3, 2012

The staff of the Colorado Division of Securities has reconfirmed the application of an exemption and no-action letter to the Catholic United Investment Trust pursuant to §11-51-307(1)(g), C.R.S.

Request
Response

February 3, 2012

The staff of the Colorado Division of Securities has taken a "no-action" position with regard to the offer and sale of Microcredit Enterprises Global Poverty Alleviation Notes which provide financial credit and other services to facilitate the provision of microfinance globally.

Opinion Request
No-action letter

November 23, 2011

The Securities Commissioner has issued an Order of Exemption from licensing as an investment adviser to Race Street Management, LLC, and Cintra Pollack

Request Letter
Order

August 10, 2011

The staff of the Colorado Division of Securities has issued an opinion letter confirming the prohibition regarding licensing of investment adviser representatives with the Division of Securities as contained in Section 203A(b)(1) of the Investment Advisers Act of 1940.  

Opinion Request
Opinion Letter

July 8, 2011

The Staff of the Division of Securities has declined to issue a No-action letter regarding the licensing requirements for an investment adviser with respect to the publishing and selling of videos that give advice or analysis of oil and gas direct participation investments.

Opinion Request
No-Action Letter

June 30, 2011

The staff of the Colorado Division of Securities has taken a "no-action" position as to the licensing provisions of the Colorado Securities Act with regard to the offer and sale of securities in Colorado by the foreign affiliates of BNP Paribas SA, under the chaperone of BNP Paribas Securities Corp.

Request Letter
No-Action Letter

June 29, 2011

The Securities Commissioner has issued an Order of Exemption from licensing as an investment adviser and investment adviser representative to William E. Kuehn

Rerquest Letter
Order

June 9, 2011

The staff of the Colorado Division of Securities has taken a "no-action" position as to the registration provisions of the Colorado Securities Act with regard to the offer and sale of securities in CBIS Capital Ltd, a fund that limits participation to charitable organizations.

Request Letter
No-Action Letter

May 3, 2011

The staff of the Colorado Division of Securities has taken a "no-action" position with regard to the offer and sale of Capital Sisters Investment Notes, which proceeds will be used to make loans to international microfinance institutions which lend to impoverished women in developing countries.

Request Letter
No-Action Letter

May 3, 2011

The staff of the Colorado Division of Securities has issued an interpretive letter confirming an exemption under §11-51-307(1)(g), C.R.S., to the Presbyterian Church Investment and Loan Program

Request Letter
Exemption Confirmed Letter

April 6, 2011

The staff of the Colorado Division of Securities has taken a "No-Action" position as to whether participating in an internet auction for the sale
of real property involves the offer of a “security.”

Request Letter
No-Action Letter

December 15, 2010

The Securities Commissioner has issued an Order of Exemption from licensing as an investment adviser to Kreiger Asset Management, LLC
Request
Order of Exemption

December 7, 2010

The staff of the Colorado Division of Securities has taken a "No-Action" position with respect to the issuance of “Surplus Notes” by the Segregated Account of Ambac Assurance Corporation.
Request Letter
No Action Letter

The Staff of the Division of Securities has issued an interpretive opinion setting out general principles or guidelines that will be used by the Division in deciding whether the issuance, offer or sale of subscription interests in community solar gardens are securities as that term is defined by the Securities Act.
Request
Interpretive Opinion

July 12, 2010

The staff of the Colorado Division of Securities has taken a "no-action" position with regard to the offer and sale of Finca International Inc., notes which provide financial credit and other services to facilitate the provision of microfinance globally.
Opinion Request and Answer

April 23, 2010

The Securities Commissioner has issued an Order of Exemption from licensing as an investment adviser to Jonathan Murdock and Elemento, LLC
Element o Request
Elemento Order

December 9, 2009

The Securities Comissioner has issued an Order of Exemption from licensing as an investment adviser to Dauntless Financial, LLC
Dauntless Request
Dauntless Order

July 8, 2009

The staff of the Colorado Division of Securities has taken a "No-Action" position as to the licensing requirements for broker-dealers and securities sales representatives under §11-51-401 with respect to the sale of commercial paper to sophisticated, institutional investors by employees of companies who do not receive transaction based compensation, but whose primary function is the offer and sale of the paper.
Opinion Request and Answer

July 8, 2009

The staff of the Colorado Division of Securities has taken a "No-Action" position as to the licensing requirements for broker-dealers and securities sales representatives under §11-51-401 with respect to the distribution by a parent corporation to its shareholders a dividend of the shares of a wholly owned subsidiary of the parent corporation.
Opinion Request and Answer

March 25, 2009

The staff of the Colorado Division of Securities has taken a "no-action" position with regard to the offer and sale of Microcredit Enterprises Global Alleviation Notes which provide financial credit and other services to facilitate the provision of microfinance globally.
Opinion Request and Answer

January 26, 2009

September 19, 2008

August 15, 2008

The staff of the Colorado Division of Securities has taken a "No-Action" position with respect to the distribution by a parent corporation to its shareholders a dividend of the shares of a wholly owned subsidiary.
Request
No-Action Letter

April 24, 2008

The Securities Comissioner has issued an Order of Exemption from licensing as an investment adviser to Consolidated Investment Group, LLC
Request
Order

April 23, 2008

The Securities Comissioner has issued an Order of Exemption from licensing as an investment adviser to Mantucket Capital Management
Request
Order

The staff of the Colorado Division of Securities has issued a "No-Action" position with respect to the offering of notes by Green Gables Country Club to its members.
Request and Answer

September 12, 2007

The staff of the Colorado Division of Securities has issued an opinion letter stating that the staff will not take a formal position on Merrill Lynch's Client Transition Program.
Request and Answer

August 28, 2007

The staff of the Colorado Division of Securities has issued a "No-Action" position with respect to the distribution of limited partnership interests of Brookfield Infrastructure Partners L.P to the shareholders of Brookfield Asset Management Inc.
Request and Answer

July 11, 2007

The staff of the Colorado Division of Securities has issued a "No-Action" position to the Royal Bank of Scotland, Banco Santander Central Hispano, S.A.and Fortis SA/NV regarding their reorganization.

April 13, 2007

The staff of the Colorado Division of Securities has issued an opinion letter declining to confirm that an Internet newsletter comes within the publisher's exclusion of the definition of "Investment Adviser" under the Act.
Order
Request

April 9, 2007

The Securities Commissioner has issued an Order of Exemption under the Municipal Bond Supervision Act for capital appreciation bonds for Fallbrook Metropolitan District.
Order
Request

January 18, 2007

The staff of the Colorado Division of Securities has issued an interpretive opinion confirming an exemption under section 11-51-307(1)(g) to Catholic United Investment trust.

December 18, 2006

The staff of the Colorado Division of Securities has issued a "No-Action" position to EIG Holding Company regarding their reorganization.

November 7, 2006

The staff of the Colorado Division of Securities has issued a "No-Action" position as to Handy Hardware Wholesale, Inc.'s conversion of its stock.

August 29, 2006

The staff of the Colorado Division of Securities has issued an interpretive opinion to the Heartland Voluntary Advertisiing Group Cooperative Exchange declining to confirm that the interests are not "securities" under the Act but takes a "No-Action" position as to the offering of the interests.

July 27, 2006

The staff of the Colorado Division of Securities has issued an interpretive opinion declining to confirm that the sale of partnership interests in 10 Smith St. Development Partners does not constitute a "security" under the Act.

December 6, 2005

The staff of the Colorado Division of Securities has issued an interpretive opinion regarding the offer and sale of rights involved in the sale of a casino property.

October 7, 2005

The staff of the Colorado Division of Securities has issued an interpretive opinion regarding the offer and sale of securities to one unsecured creditor residing in Colorado by a Canadian company. (Stelco, Inc.)

August 24, 2005

The staff of the Colorado Division of Securities has issued a "No-Action" position regarding the licensing of an issuer planning to distribute its subsidiary's shares to its own shareholders. (Clear Channel Communications)

July 27, 2005

The staff of the Colorado Division of Securities has issued a "No-Action" position regarding the licensing of an issuer planning to distribute its subsidiary's shares to its own shareholders. (ACCO World Corporation)

The staff of the Colorado Division of Securities has taken a "No-Action" position with regard to the availability of an exemption under § 11-51-308 for Magnum Hunter Resources, a company subject to the reporting requirements under Section 13 or 15(d) of the Securities Exchange  Act of 1934.

The staff of the Colorado Division of Securities has taken a “No-Action” position with regard to a tender offer in accordance with Brazilian law which states that such an offer must be made to remaining shareholders after the successful merger of two companies.

The staff of the Colorado Division of Securities has issued an opinion letter stating that a proposed business of pension consulting with members of the Colorado Public Employee Retirement Association falls within the definition of an investment adviser and thus, those involved in the business would be required to comply with the licensing requirements found in § 11-51-401, C.R.S.

The Securities Commissioner has issued an Order of Exemption from Broker-Dealer and Sales Representative Licensing in the matter of CTEK, a non-profit Colorado Corporation.

The staff of the Colorado Division of Securities has taken a “No-Action” position with regard to whether a proposal to distribute all of the outstanding common units of Rio Vista to its shareholders which represent limited partnership interests in the company would qualify for an exemption.

The staff of the Colorado Division of Securities has taken a “No-Action” position with regard to a proposed issuance of Starboard Media Foundation, Inc. debentures in the aggregate principal amount of $5.2 million and pursuant to their reliance on the exemption from securities registration found in rule 51-3.14 relative to the offer and sale of bonds in Colorado.

The staff of the Colorado Division of Securities has taken a “No-Action” position regarding to United Hardware Distributing Company issuing shares to members without registering them with the Division.

The staff of the Colorado Division of Securities issued an Order of Exemption from Registration of Issuance of Bonds for sisters of the Presentation of the Blessed Virgin Mary, Inc., a New York Not-for-Profit Corporation.

The staff of the Colorado Division of Securities confirmed the availability of the exemption from registration under the Colorado Securities Act found in § 11-51-307(1)(g), C.R.S., in connection with the offer and sale of Trust Units in the Market Neutral Fund.

The staff of the Colorado Division of Securities has taken a “No-Action” position with regard to the offer and sale of unsecured debt instruments for which Brethren in Christ Foundation, Inc. requested a discretionary exemption.

The staff of the Colorado Division of Securities has taken a “No-Action” position with regard to a deferred compensation plan to be established by an insurance company for the benefit of its independent sales agents in Colorado provided the plan qualifies for the federal exemption under Rule 701.

The staff of the Colorado Division of Securities has taken a “No-Action” position with regard to registration of aa Cañon Bank Corporation exchange offering issued for the purposes of reorganization of ownership of the Bank into a bank holding company structure.

The staff of the Colorado Division of Securities has taken a “No-Action” position with regard to the offer and sale of general obligation bonds by Starboard Media Foundation, Inc which requested a discretionary exemption from securities registration under Rule 51-3.14.

July 1, 2003

The staff of the Colorado Division of Securities issued an opinion that they could not confirm an exemption for the online auction and transactions related thereto as proposed by EnergyNet and issued the opinion that the described properties and related interests to be auctioned according to the official opinion request appeared to fall within the statutory definition of a “security” under the Act.

The staff for the Colorado Division of Securities has confirmed an exemption under §11-51-307(1)(g), C.R.S., and Rule 51-3.15 relative to the offer and sale of Church Development Fund, Inc. unsecured debt instruments and has taken a “No-Action” position with regard to violations of the broker-dealer and sales representative licensing provisions of the Act.

The staff for the Colorado Division of Securities has taken a “No-Action” position with regard to whether a proposed Facilities Construction and Service Agreement are subject to the registration provisions of the Colorado Municipal Bond Supervision Act.

The staff for the Colorado Division of Securities has taken a “No-Action” position with regard to whether a proposed distribution of all the outstanding shares of common stock for Hudson Highland Group, Inc. by TMP Worldwide Search, Inc. was subject to an exemption from the broker-dealer and sales representative licensing provisions of the Colorado Securities Act.

The staff for the Colorado Division of Securities has taken a “No-Action” position with regard to whether “Tuition Certificates,” issued by Tuition Plan Consortium, LLC, would constitute an offer and sale of “securities,” as the term is defined under the Colorado Securities Act.

The staff for the Colorado Division of Securities has taken a “No-Action” position with regard to the Individual Deductible Service Plan offered by IDA Management Services, Inc.

The staff for the Colorado Division of Securities has taken a “No-Action” position with regard to a proposed distribution of all the outstanding shares of common stock for Mindspeed by Conexant Systems, Inc and whether such distribution would be subject to an exemption.