Compliance and Disclosure Interpretations ('C&DIs') of the SEC Staff Chapter Two

摘要

In our view, the Rule 144 interpretations set forth in the January 26, 2009 Update to the C&DIs are an indispensible resource for Rule 144 practitioners in ascertaining the position of the SEC staff on many of the questions such practitioners are called upon to answer. It seems to us that the comments of Tom Kim, the Chief Counsel of the Division of Corporation Finance, quoted in footnote 2, herein supports this view.