Rule 138 Non Equivalent Securities

If a registration statement has been filed for a non-convertible bond or a non-convertible preferred stock, a broker dealer, who is a participant in a distribution of the securities, may in the normal course of business issue recommendations, information, or opinions relating to the issuer’s common stock or convertible securities. If the registration statement covers common stock or a convertible security of the issuer a broker dealer may only issue recommendations, information, or opinions relating to the issuer’s non-convertible debt or preferred stock.

RULE 139 ISSUING RESEARCH REPORTS

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