Thanks Sunny for putting this together As part of
Post# of 8054
As part of a process to remove restrictions, DTC requires an opinion letter
from an INDEPENDENT securities counsel -who is acceptable to the DTC
[on a DTC approved list-which is a subset of qualified independent securities counsel- something many co's dont understand when they get an opinion letter from other counsel re conformity w the sec's rules re exempted securities- securities lawyers are a rare specialty as it is-
for all docs re such an unregistered securities transaction
including prior opinion letters from attorneys at the time who said such sales were complicit with SEC/DTC etc requirements [DTC etc then reportedly often goes after such lawyers- a real hard case]
and these violations are widespread, which allows DTC to SELECT which cases to go after, often based on political considerations-
As author of Predator Nation said on the Charlie Rose show, at the time, the agencies had not gone after any of the big boys responsible for the manipulations which contributed to the great recession etc- though BAC and JP have since been fined heavily for mortgage fraud etc]
and accredited investors certification etc
a copy of any form D's
and must show either were not rule 144 restricted [exempt from registration requirements if held the requisite 6 month or 12 month periods before sale] or the physical stock certificates showed proper restrictive legends, and DTC mentions rule 504- which I previously summarized -there are also other exemptions from registration requirements other than rule 504 and 505