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#482628 - 01/12/06 09:26 PM Phase I to Phase II exemption
#12 Offline
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Joined: Jun 2005
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We have a business customer that we had on our Phase I exempt list because they were a listed company. In December, they were bought out, and are no longer publicly listed. So, we want to change them to a Phase II exemption. They qualify in all other aspects. So, how do I go about doing this? Do I just file a Designation of Exempt Person form, check amended exemption, then check eligible non-listed business? If so, what do I list as the effective date of the exemption? Thanks in advance for the advice.
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#482629 - 01/13/06 04:24 PM Re: Phase I to Phase II exemption
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
I suggest you file a revocation of the phase I exemption effective on the date they were delisted.

Then, do the paperwork necessary to qualify them as a phase II exemption and file the DOEP form with the current date. It is effectively retroactive for 30 days and, since you are acting promptly, there are probably not going to be any reportable transactions.
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#482630 - 01/13/06 05:01 PM Re: Phase I to Phase II exemption
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That makes more sense. Thank you Ken!
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