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Date

Jul 12th, 2015

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The so-called Issuer Exemption

Issuer Exemption

Rule 3(a)(4)-1 simply means that an issuer who acts om its own behalf is not effecting transaction "forthe account of others" and therefore doesn´t meet the definition of Broker".The Issuer Exemption is a non-exclusive ´Safe Harbour´from Broker registration but is not exclusive means by which persons associated with the issuer may sell that issuer´s securities w/ out registering as a Broker.

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