RegAlert2004-03-29
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SEC Division of Corporation Finance no-action letter: Liberty National Golf Club
The Division of Corporation Finance will not recommend enforcement action if Liberty National Golf Club offers and sells Club Memberships without registration under the Securities Act of 1933. This position applies to the specific non-equity memberships described in the request, which provide recreational use rights without investment characteristics, profit participation, or voting privileges. The Division notes that this stance relies on the representations made and may require different conclusions if facts or conditions differ.
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Securities Act of 1933 - Section 2(a)(1)
March 29, 2004
Response of the Office of Chief Counsel Division of Corporation Finance
Re: WA Golf Company, L.L.C. Liberty National Golf Club ("Liberty") Incoming Letter dated March 29, 2004
Based upon the facts presented, the Division will not recommend enforcement action to the Commission if Liberty, in reliance upon your opinion of counsel that registration is not required, offers and sells the Club Memberships, as such term is defined in your letter, without registration under the Securities Act of 1933.
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Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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