Regulatory Alerts2016-04-26
Legume, Inc. No Action Letter
The Pennsylvania Department of Banking and Securities issued a no-action letter regarding Legume, Inc.'s proposal to sell Value/Loyalty Certificates that appreciate in value and are redeemable for restaurant gift certificates. The Department's staff will not recommend enforcement action for the offer and sale of these certificates without registration under the Pennsylvania Securities Act of 1972, as they do not constitute securities. This position is limited to the specific transaction details provided and does not address compliance with federal credit card laws or state gift certificate expiration and escheatment regulations.
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