Untitled Texas Attorney General Opinion

October8, 1958 Hon. WilliamM. King OpinionNo. WW-504 State SecuritiesCommissioner Austin,Texas Re: Whetherthe proposedoffer of common stock to holdersof sur- plus debenturesunder the facts given is an exempttransaction under the provisionsof either 5(R) or 5(B) of The Securities Dear Sir: Act. You have asked the opinionof this office concerningwhether a certainofferingof the CitizensStandardLife InsuranceCompanyof Corpus Christi,Texas, of common stock to its "advisoryboard investment certificateholders"is exemptedfrom the provisionsof The Securities Act. Your letter is as follows: "In May, 1954, CitizensStandardLife InsuranceCom- pany, CorpusChristi,Texas, authorizedthe issuanceat public sale of 3,000 ADVISORYBOARD INVNSTlMENTCERTIFI- CATES, of the face value of $600.00each. By December31, 1954, subscriptions for 1449 Certificateshad been taken on which $238,590.00in paymentshad been made. A time pay-outplan was offeredsubscribers. "The purposeof this offeringwas to raise surplus funds for expandingthe life insurancebusinessof the company,and all net receiptshave been In the past cred- itedto its unassignedsurplusaccount. The company's obligation:>on the Certificatesis not recognizedor re- ported as a statementliabilityin the annualreportsto the State Board of Insurance. "The originalterms are set forth In the attached copy of a Certificate.The originaloffer of the Cer- tificatesto the publicwas made prior to the effective date of the InsuranceSecuritiesAct; therefore,the of- feringwas not subjectto registrationwith a State agency. "On September17, 1957, over signatureof the com- pany's,secretary,and on September30, 1957, over the signatureof the company'spresident,offersto exchange stock of the companyfor certificatesoutstandingwere Eon. WilliamM. King, page 2 (WW-504) made under terms that were differentfrom the terms pro- vided in the certificates.Copies of these two letters are attached. No applicationfor registrationof securi- ties has been filed. "In your examinationof these lettersit will be noted that an offer is made by the companyto e*chsnge subscriptioncontractsfor the purchaseof stock for subscriptioncontractsfor the purchaseof Advieory Board Certificatesin additionto an offer to exchange stock sharesfor paid-upcertificates. "The SecuritiesAct sets out in Section7.A.that securitiesmust be registeredthereunderif sold or of- fered unless otherwiseregisteredunder Section7.B., or Section7.C., or unless such securitiesare definedby Section5. as exempttransactionsor by Section6. as ex- empt securities. The SecuritiesAct in Section4.A. de- fines a securityand in Section4.E. definesthe term 'sale' or 'offerfor sale'. "Underthe facts as given above, is the exchsnge offer made in the attachedletterssubjectto registra- tion under the SecuritiesAct, unless exemptunder Sec- tion 52-7.1 "Section5.F. of the SecuritiesAct sets out as an exempttransactionthe issuanceof securitiesby a com- pany to its securitiesholders,or creditors,when made in good faith in the processof a bona fide reorgsniza- tlon. In your opinionwould an amendmentto a corpora- tion's charterchangingits capitalstock from par value to non par value, and increasingthe number of shares, joinedwith the stockholders' decisionto exchangecom- mon stock for surplusdebentures,alteringthe terms thereof,constitute.sreadjustmentof capitalstructure or a seriousoverhaulingby legal proceduresto bring such changewithin the meadng of a bona fide reorgani- zation as used in Section5.F.T "Your consideration of these matterswill be greatlyappreciated." The CitizensStan&d Life InsuranceCompanyissuedapproxi- mately 3,000 of its so-called"advisoryboard investmentcertificates," each having a $600 face or maturityvalue. The certificates were issued either for cash or upon a five-yearpaymentplan. Under the terms of the certificate,the companyagreed to pay the certificateholder inter- est at the rate of 4$ on all paymentsmade under the certificate,with Hon. WilliamM. King, page 3 (WW-504) the first year'spaymentof interestto be made out of contributedsur- plus, and thereafterout of earned surplus. It was furtherprovided that at the end of the first full calendaryear after the date of the certificate,8nd the end of each calendaryear thereafteruntil m8turity, the companywould createan "annualbonua fund" for the benefit of the registeredcertificateholdersout of the profitsand/or earned surplus of the company,which it would divide into 3,000 equal parts; 81$ so long a8 a certificatewas in force, one such part would be paid to each owner of the certificate.The amount of the annualbonus fund was to be Z$ of the renewallife insursncepremiumspaid duringthe year to the companyon all life insurancepolicies,plus l$ of the "excessin- terest earningson all investments"of the company. The companywas requiredto continuethe paymentsinto the annual bonus fund until the maturityof the certificateor until the certificatehad been called in the m8nner providedin the contract. In additionto the annualbonus fund provided,the company also agreedto set up on its books 8 "specialsurplusfund account"and agreedto creditto that accountat the end of each calendaryear after the date of the certificatea sum equal to 33-l/3$ of its net surplus earningsfor each year. It w8s providedth8t the certificateshould mature and the face value thereofpaid to the registeredowner within 60 days after the amount accumulatedin said "specialsurplusfund BC- count" shouldbe equal to the aggregateof the total face value of all outstandingadvisoryboard investmentcertificatesand the accumulated interest,if any. At such maturitythe companyagreedto pay to the registered owner the face value of $600.00'plusinterestand further"withinthe limits of its presentlyexistinglegal contractualpowers,to permit the owner of this certificate,if he so elects,in lieu of acceptance of paymentof the face value in cash, to convertthe face value of this certificateinto the compaay'scommon stock at the stipulatedprice of $100 per.sh8re.w Under the terms in the certificateunder the heading"Guaran- teed SurrenderValue,"the certificateholder could discontinuepayment and could receive8 “modifiedcertificate" which in effectwas a pro rata advisoryboard certificate,less certainliquidatedd8mage charges givingthe certificateholderthe right to participateon a pro rat8 basis in 811 the benefitsexceptthe 8Mual bonus fund. Under the heading "Miecellaneoun," it was ProVidd that any moneys paid for the investmentcertificateshouldbe treated8s paid- in surplusand th8t the companycouldmake use of such funds in any way that surplusfunds of the companymight be lawfullyused. It was fur- ther providedthat all interestwas payableonly 88 therein set forth, and that the investmentcertificate,togetherwith the interestthereon, shouldnot be a liabilityof the companyor a claim againstany of its I. 4 . Eon. WilliamM. King, page 4 (WW-504) assets except8s above specifiedin the paragraph. And in seemingly conflictingterms, it was furtherprovidedthat in the event of liquida- tion of the companythe investmentcertificateshould immediatelymature and become 8 presentliabilityof the companysubjectto the rights of the policyholder. ~...,". These certificateshave not yet matured. It is the purpose of the CitizensStandardLife InsuranceCompanyto offer to each holder of an advisoryboard investmentcertificate60 sharesof its common stock in exchangefor a surrenderof qych certificateplus 8 bonus of 6 shares to each certificateholder c&&l&ing h& paymentsby a date specified which would be in advanceof the &&es specifiedin the certificate. It shouldbe noted that under the terms of the certificatethe company hd agreedthat at maturitythe face value shouldbe payablein cash or stock of the companyat the electionof the certificateholder. Thus, under the terms of the certificateat maturity,each certificateholder of a full $600.00 certificatewould have been entitledto elect to re- ceive six shares of stock. Since the issuanceof these certificates the corporatestructureof the CitizensStandardLife InsuranceCompany has been changedresultingin 8 ten-for-onesplit.. i Prior to the charteramendmentcreatingthe stock here in ques- tion, the companyhad issuedstock to other certificateholderswho had paidyinfull the amount of their certificate.The generalplan of the companyhas been to Obtain charteramendmentsincreasingtheir capital stock periodicallyto accommodatethese certificateholders. The SecuritiesAct statesthat securitiesas definedtherein must be registeredunder Section7 if sold or offeredfor sale unless the sale or offer of sale of such securitiesconstitute"exempttrans- actions"as definedby Section5, or such securitiesare "exemptsecuri- ties" as &fined by Section6. The term "sale"and relatedterms are definedin great detail in Section4(E) and it is only necessaryto re- fer to 8 portionof this definitionto ascertainthat the contemplated exchsngein this case would constitutea sale or offer to sell of securi- ties requiringregistrationunless exempted. Section4(E) is 8s follows: "The terms 'sale'or 'offerfor sale' or 'sell'shall includeevery disposition,or attemptto disposeof a se- curity for 8 value. The term 'sale'means and includes contractsand agreementswhereby securitiesare sold, traded or exchangedfor money, property,or other things of value, or anyJtrensferor agreementto transfer,in trust or other- wise . , . The sale of 8 securityunder conditionswhich en- title the purchaser. . . to exchangethe same for, or to purchasesome other security,shsll not be deemed8 sale or offer fbr sale of such other security;but no exchangefor or sale:of such other securityshall ever be msde unless and ." until the sale thereof shall have been first authorizedin Texas under this act, if not exempt hereunder,or by other provisjonsof law. . .' Hon. WilliamM. King, page 5 (WW-504) Clearly,the consummationof the prospectiveplan would fall within this definition. You have requestedin your letter the opinionof this office whether or not the transactionin questionis exempt from registration under the provisionsof The SecuritiesAct. It has been suggestedthat the transactionmay be exempt eitherunder the provisionsof 5(D)(E)(G) exemptingcertaindistributions by a corporationof securitiesdirectly to its stockholders, or the provisionsof 5(F) relatingto transfers in the courseof reorganization.We shall take up the exemptionunder 5(D)(E)(G)first. Section5 of The SecuritiesAct is, in part, 88 follows: "Section5. ExemptTransactions. "Exceptas hereinafterin this Act specificallypro- vided, the provisionsof this act shallnot apply to the sale of any securitywhen made in any of the following transactionsand under any of the followingconditions, and the companyor person engagedthereinshall not be deemeds dealerwithin the meaning of this act; that is to say, the provisionsof this act shall not apply to any sale, offer for sale, solicitation,subscription, dealingin or deliveryof any securityunder any of the followingtransactionsor conditions: ‘1.. . "I). The distributionby a corporationof securities directto its stockholdersas a stock dividendor other distributionpaid out of earningsor surplus. '73. The sale of sn increaseof capitalstock of a corporationonly to its stockholdersand withoutpayment of any commissionor expenseto any officer,employee, broker or agent; ‘1.. . “CL The transferor exchangeby, or on accountof, one corporationto anotheror to its stockholdersof their or its own securitiesin connectionwith a pro- posed consolidationor merger of such corporationor in connectionwith the change of par value stock to non par value stock or vice versa, or the exchangeof outstsnd- ing shares for a greateror smallernumber of shares, providedthat in such case such stockholdersdo not pay or give or promiseand are not obligatedto pay or give Eon. WilliamM. King, Page 6 (WW-504) any considerationfor the eecu'ritlee So transferredor exchangedother than the securitieri of said corporation then held by them; . . ." These exemptionsapply only to "stockholders" of the corpora- tion. The contentionhas been advancedthat becauseunder the terms of the so-calledadvisoryboard investmentcertificates, the holders of the certificates, after completingthe terms of their agreementand sfter maturity,8re given the right to requirethe companyto redeem the certificate,iacommon stock ratherthan in cash, they shouldbe clae- sifled 88 stockholders.However,under the facts recited,the certifi- cates in questionhave not maturedand there is not at this time under the terms of the contractany existingright on the part of the certifi- cate holdersto requirethe redemptionof these certificates,either in C8Sh or in stock. While it may be true that in some circumstancesand under certainconditionsperSonSholdingby right of contractor other- wise 8 right to become 8 Stockholdermay exerciseunder~certaincondi- tions Some of the right8and prerogativesof 8 Stockholder,the certifi- cate holdersdo not fall withih the normal definitionof the term "stock- holdere." We hold that the transactionis not exemptunder Sections 5(D), 5(E) or 5(G). We next considerwhetherthe tr8neactionin questionqualifies as an exemptionas the issue of Securitiesin the course of a reorgani- zationunder the provisionsof Section5(E) which is as follows: "F. The issue in good faith of Securitiesby a com- pany to its securityholders,or creditors,in the process of 8 bona fide reorg8nlzation of the companymade in good faith, . . . providedthat . . . Such Securitiesare issued in exchangefor securitiesof such holdersor claimsof such creditors,or both, and . . . securityholdersor cred- itors do not p8y or give or promiseand 8re not obligatedto pay or give any consideration for Securitiesso issuedother than the SecuritiesOf or CtiiQIS 8g8inSt Said company . . . then held or owned by them." The term "reorganization"is not definedin the statute. Nor do we find any cases in Texss Interpretingthe meaningof this exemption though it has been in effect in substantiallythe same languagein the SecuritiesActs since 1935. Nor have we been able to find any Texas caSes dealingwith the meaningof this term which would have a Signifi- cance to its presentapplication.The term "reorganization" has been definedby Texas Jurisprudencein,Volume10-B, page 676, as follows: "A 'reorg8niS8tlon' has been termed 8 plan under which the financialstructureof the corporationwas rearranged, as by 811Increaseor decreaseof capital." n Hon. WilliamM. King, page 7 (WW-504) This definitionof the term "reorganization"is so broad that it would includeevery transactionwherebythe capitalstock of a cor- porationwas increasedor decreased. While it is true that almost every "reorganization" will effecta change in the financialstructureof the . zne corporation,it is not true tnat every cnange *n I. rlnancial ^. structure is 8 "reorganization." We find thst the above quoted. from Texas Jurisprudenceis not supportedby the cases cited therein. At 15 Fletcher'sCyclopediaCorporations,Section201, page 318 (1938revisedvolume),it is demonstratedthat the term "reorgani- zation"has many meanings. "The term 'reorganization' signifiesthe act or proc- ess of organieinganew. As anpliedto corporations,it denotesvariousproceedingsand transactionsby which a successionof corporationsis broughtabout. Ordinarily it involvesthe creationof a new corporationto take over the assetsand propertyand continuethe businessof the old. This, however,is not necessarilythe effect of a reorganization.The terms of the statuteand the inten- tion of the Legislatureand of the partiesmay be merely to continuethe existingcorporation,without dissolution, under the same or differentname and with the same or dif- ferentpowers,and under the 881116)or a differentmanage- ment. Accordingto Mr. Morawetz, the term 'reorganization' is 'commonlyappliedto the formationof a new corporation by the creditorsand shareholdersof a corporationwhich is in financialdifficulties, for the purposeof purchasing the company'sworks and other propertyafter the foreclo- sure of a mortgageor judicialsale'. . "It is proper to classifyreorganizations as (1) re- organizationsin connectionwith the foreclosureof corpo- rate mortgages,or in connectionwith other judicialor executionsales of the corporatepropertyby the purchasers at the sale, and (2) other reorganizationsor reincorpora- tions. The latter class is divisibleinto (a) reincorpora- tions where the purpose is merely to correctillegalities or defectsin the originalincorporation, or to broadenthe scope of the powers of the corporation,including,in one sense of the word, the amendmentas well as the extension or revivalof charters;(b) the scalingof securitiesby voluntaryagreementsand (c) the organization, primarily by or on behslf of the stockholdersas distinguishedfrom the creditors,of 8 new corporation,without8ny forced sale, to take over the propertyof the existingcorporation. The term is used most often in connectionwith the foreclosure Hon. WilliamM. King, page 8 (UW-504) of corporatemortg8geSwhere 8 new corporationis formed by the foreclosurepurchases,and most of the law, as laid down in the decision,in connectionwith reorganizations, relatesto the first class of reorg8nization,and much of such law is not applicableto other reorganizations. "The reasons inducing8 reorganization are not in every case the same,but for the most part they are to be found in the weak financialor insolventconditionof the p8rticul8rcorporation.And so the aim of a corporatere- organizstionis generallyto put the companyupon a sound finsncialbasis,and to enable it to take care of it8 ob- ligations,therebyavoidingllquld8tlonor bsnkruptcy. But in Some cases 8 reorganization IS effected,notwith- standingthe corpor8tiOnIS SolVent. Very often 8 'sound enterprise,earningan adequatereturn,will be hampered by 8n unsound finsnclalStructureinvolvingexcessivefixed charges,such 8s bond Interest;or again the difficultyof refunding8 materialbonded indebtednessduring8 time of financialstringency,or the urgent need of additionalcapi- tal for improvements, or the weight of an unfundeddebt will make 8 reorganization necessary. "The reorganization of an Insolventbusinessinvolves considerationsnot presentin the reorganization of a sol- vent one. Almost alxaysthe 18tter is 8 matter of purely businesspolicy not intendedto nor resultingin dieturb- ante of existinglegal rights of creditorsor Stockholders. It Is carriedthrough in strictconformitywith Such rights, the purposebeing to better an existingcondition. The former is compelledby the ineXOr8blelogic of 8 bad situa- tion, is designedto save 8s much 8s possiblefrom impending wreckage,8IId8lw8yS inYOlYeSchange8in the existinglegal rights of some, if not all',of those having rights in con- nectionwith the propertyinvolved." Cur attentionla calledto the case of Utility InvestingCorpo- rationv. Stewart,11 Fed. Supp. 391 by the FederalDistrictCourt in Pennsylvania,which opinionw8e affirmedIn Stewartv. Utility IIwesting Corporation(C.C.A. 3rd) 78 Fed.2d 279. Thin case Is apparentlythe only one interpretingthe meaningof the term "reorganization"in the contextof the State SecuritiesAct. The PennSylvaniaSecuritiesAct providedthat: "The issue of securitiesto the Securityholderaor other creditorsof 8 corporation,in the processof 8 bon8 fide reorganization of such corporation,made In good faith . . . In exchangefor the securities. . . of such creditors. . . [Shouldnot constitutethe perSon or com- pany engagedtherein8 dealerwithin itS meaning].” Hon. WilliamM. King, page 9 (WW-504) Under the facts involvedin the case, the corporationin ques- tion was offeringto debentureholdersof that companycertainnew or differentsecuritiesin exchangefor their debentures. It was the pur- pose of the companyto relieveitselfof the burden of having to meet fixed interestchargesat definiteperiodsby invitingthe holdersof fixed interestdebenturesto exchangethem for new obligationsat a high rate of interest,cumulative,but payableonly as earnedand coupled with a sinkingfund provision. The holderswere also offeredtwo options, the exerciseof either of which was describedby the court as havingthe effectof naturallylighteningthe fixed interestburden upon the equi- ties of the holdingcompany. The court stated: "I entertainno doubt that this rearrangementof its capitalstructureis a reorganization of the companywith- in the meaning of the act. While corporatereorganizations are frequently,in fact usually,effectivethroughthe me- dium of receivershipand judicialsale, the ordinarymean- ing of the word is quite broad enoughto includevoluntary capitalreadjustments.Nor is it necessarythat there be a new corporationor changeof managementor ownershipof physicalassets. Nor need the equitiesbe affected(though in this case they are). That the act contemplates,among others,reorganizations entirelyconfinedto the credit structureappearsfrom the fact that the provisionin ques- tion may be read as applicableto 'issueof securitiesto the . . . creditors. . . in exchangefor the . . . claims of such creditors.' 70 P.S. Pa. Sec. 2(c) and (11). "The underlyingpurposeof this and similarstatutes is to protectthe investingpublic. The method by which the PennsylvaniaAct does it is the licensingof dealers. Exceptionsfrom the operationof the law are createdby ex- cludingfrom the class of dealerspersonsengagedin cer- tain specifiedtranssctions,one of which is the offer of securitiesin the course of corporatereorganizations.The only conditionis that the reorganizationbe bona fide and the offer of securitiesmade in good faith." This decisionrecognizesthat whethera given transactionis a reorganization dependsupon the particularfacts involved. Though recognizingcertainsimilarities, we believethe fact situationinvolved in your requestdiffersfrom those in this decisionso that it would not controleven though it be the law in Texas. In connectionwith this transactionthe CitizensStandardLife InsuranceCompanyhas made applicationto the Commissionerof Insurance for approvalto amend their charterto permit the increaseof their capl- tal in order to transferthe stockto their so-calledcertificateholders. We call attentionto certaintestimonytaken by the Commissionon February Hon. WilliamM. King, page 10 (WW-504) 25, 1958,in connectionwith said application. On page 13 of this trans- criptMr. PrestonDoughty,Presidentof the CitizensStandardLife In- suranceCompany,explainedthe purposeof the amendmentin the following language: "In fact, the programof gettingthese ~ . . this charteramendmentwas motivatedby constantrequestsfrom the advisoryboard, of certificateholdersthat they be permittedto surrendertheir certificateand be issued stock. The stock of the company,on a local market,has a very good, high demand." On this same subjectmatterMr. Doughty statedon page 14: "Many of these certificateowners,having completed their payments,continuouslyrequestedof us that they be Issued stock." Again, on page 15 Mr. Doughty stated: II. . . We felt, and the holdersof the certificates felt, too, that their positionwould be improvedif they could be permittedto become stockholders." The nature of the transactionis furtherdiscussedby Mr. Doughty on page 15 when he was asked whetherthe certificateholderswere sur- renderingtheir certificatesand taking out stockunder the option called for in the certificate,and Mr. Doughtyrepliedthat they were not obtain- ing their certificatesunder the optionbut in additionto the option, and furtherstated in responseto a questionas to whether or not the exchangewas made on the same basis of the option,as follows: "Alteredonly by the fact that the stock--theten sharesof no par stock had been authorizedand issuedfor each share previouslyissuedand authorizedpar stock and givingthem full . . .I' He affirmedthat the certificateholderswere getting60 shares of no-par stock in exchangefor the certificateand that the company was givingthe certificateholdersthe opportunityof obtainingSix ad- ditionalshares if they had previouslypaid in full or would now pay in full the amount of their certificate. Mr. Doughtyfurtherstatedon page 1.6 that a subsequentoffer to the certificateholderswas made purely on the basis of the certifi- cate holders'optionscontainedin the certificate. Again, on page 20 Mr. Doughty,in explainingthe purposeof the charteramendment,stated: Hon. WilliamM. King, page 11 (WW-504) "In order to be of assistanceto them and at the same time the company,to relievethe companyof the burden of payingthem interestand payingthem this participationin the bonus pool, the stockholders,the directors,and the officersof the companyfelt that we shoulddo both these things,go to no-par stock and at the same time offer these people the opportunityto become shareholders." We are of the opinionthat under the facts surroundingthe issuanceof the stock in questionthat the transactiondoes not consti- tute a reorganization as that term is used in Section5(F) for the rea- son that the principalpurposeof the distributionappearsto be the honoringof contractualcommitmentsmade by the companyto Its certifi- cate holdersto allow them the privilegeof becomingstockholders.None of the ordinaryor usual elementsgiving rise to a need for the organi- zation appearsto be predominant. There are no facts to indicatethat the transactionis motivatedby the financialdietressof the corpora- tion, nor does it appear that the primarymotive is the lesseningof the financialburden of the companybecauseof its obligationsto the holdersof the certificates.It shouldheLnotedthat in the ordinary circumstances one of the primarypurposesof reorganization is the pro- tectionof the equity of the present stockholders.That this purpose is not entirelythe purposeof the'presenttransactionis evidencedby the fact that the offer of the companyto certificateholderswho have not paid in full the amount of their certificateis not simplyan offer of stock equal to the presentvalue of their certificatebut ratherunder the plan advancedby the companythe companyhas offeredthese people the opportunityto exchangetheir advisoryboard certificatesfor sub- scriptioncontracts. Clearly,from this point of view the transaction in questiondoes not constitutea reorganization under the terms of Sec- tion 5(F). The holdersof the advisoryboard certificatesthat are not fully paid are only securityholdersor creditor6of the companyto the extentthat they have paid on their certificate.Particularnote must be given of the qualifyingclauseto Section5(F) which providesthat before the exchangein reorganization may be exempt,it must be a trans- action in which the "securityholdersor creditorsdo not pay or give or promiseand are not obligatedto pay or give any consideration for the securitiesso issuedother than the securitiesof or claimsagainst said company . . . then held or owned by them." The certificateholder6who have not fully paid for their cer- tificatesby acceptingsubscriptioncontractswould be bound to pay fur- ther considerationfor the stock of the companyother than the simple surrenderof the certificatethat they held. We are of the opinionalso that the transactionin question does not qualifyas an exempt transactionunder Section5(F) for the additionalreasonthat some of the stock to be issued is in the form of a bonus for early paymentor prior paymentof the face amount of Hon..WilliamM. King, page 12 (WW-504) their certificates.Clearly,such certificateholdershave given con- siderationin the form of early otiprior paymentwhich is in addition to and in excess of the simplesurrenderof the certificatewhich they hold. In the course of this opinionwe have of necessitymade cer- tain factualconclusionsbased on the materialwhich you have furnished this office and from the materialcollectedby the State Board of Insur- ance in connectionwith the charteramendmentapplicationof the company. The fact findingauthorityunder The SecuritiesAct rest6,withyou and you are at libertyto arrive at differentfactualconclusionsfrom those utilizedin this opinion. Issuanceof stockto holdersof advisory board certificatesunder circumstancesin questionis not exempt from registration either under the provisionsof Section 5(D), 5(E), .5(F) or 5(G) of The Securities Act of 1957. Yours very truly, WILL WILSON Attorney-.General of Texas -" Fred B. Werkenthin Aaeistant FBW:llU . APPROVED: ‘OPINION COMMITTEE: Geo. P. Blackburn,Chairman John Reeves Morgan Neebitt REVIEWEDFORTKE ATTORNEYGENERAL BY Riley Eugene FlCtcher