Rule 137 Non Participants

Firms that are not participating in a distribution of securities may issue recommendations, information, or opinions relating to the securities that are in registration, if the issuer is a reporting company as required by The Securities and Exchange Act of 1934. So long as the broker dealer did not receive compensation from the issuer, a selling shareholder, or a participant in the distribution for issuing the report it will not constitute an offer of the securities. 

RULE 138 NONEQUIVALENT SECURITIES

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