Definitions

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As used in this chapter, the term:

  1. "Agent" means an individual, other than a broker-dealer, who represents a broker-dealer in effecting or attempting to effect purchases or sales of securities or who represents an issuer in effecting or attempting to effect purchases or sales of the issuer's securities. A partner, officer, or director of a broker-dealer or issuer or an individual having a similar status or performing similar functions may be an agent if the individual performs the duties of an agent. This term does not include an individual excluded by rule adopted or order issued under this chapter.
  2. "Bank" means:
    1. A banking institution organized under the laws of the United States;
    2. A member bank of the Federal Reserve System;
    3. Any other banking institution, whether incorporated or not, doing business under the laws of a state or of the United States, a substantial portion of the business of which consists of receiving deposits or exercising fiduciary powers similar to those permitted to be exercised by national banks under the authority of the Comptroller of the Currency pursuant to Section 1 of P. L. 87-722, 12 U.S.C. Section 92a, and which is supervised and examined by a state or federal agency having supervision over banks and which is not operated for the purpose of evading this chapter; or
    4. A receiver, conservator, or other liquidating agent of any institution or firm included in subparagraph (A), (B), or (C) of this paragraph.
  3. "Broker-dealer" means a person engaged in the business of effecting transactions in securities for the account of others or for the person's own account. The term does not include:
    1. An agent;
    2. An issuer;
    3. A bank, trust company, credit union, or savings institution if its activities as a broker-dealer are limited to those specified in subsections 3(a)(4)(B)(i) through (vi) and (viii) through (x) of the Securities Exchange Act of 1934, 15 U.S.C. Section 78c(a)(4); subsection 3(a)(4)(B)(xi) of the Securities Exchange Act of 1934, 15 U.S.C. Section 78c(a)(4) if limited to unsolicited transactions; or subsections 3(a)(5)(B) and 3(a)(5)(C) of the Securities Exchange Act of 1934, 15 U.S.C. Section 78c(a)(5), or a bank that satisfies the conditions described in subsection 3(a)(4)(E) of the Securities Exchange Act of 1934, 15 U.S.C. Section 78c(a)(4);
    4. An international banking institution; or
    5. A person excluded by rule adopted or order issued under this chapter.
  4. "Central Registration Depository" means a computerized data base that contains information about most brokers, their representatives, and the firms they work for. It can be used to find out if brokers are properly licensed and if they have had previous disputes with regulators or received serious complaints from investors.
  5. "Credit union" means any credit union incorporated under the laws of this state, the United States, or any state or territory of the United States or the District of Columbia.
  6. "Commissioner" means the Secretary of State of Georgia.
    1. "Depository institution" means:
      1. A bank; or
      2. A savings institution, trust company, credit union, or similar institution that is organized or chartered under the laws of a state or of the United States, authorized to receive deposits, and supervised and examined by an official or agency of a state or the United States if its deposits or share accounts are insured to the maximum amount authorized by statute by the Federal Deposit Insurance Corporation or the National Credit Union Share Insurance Fund or a successor authorized by federal law.
    2. The term does not include:
      1. An insurance company or other organization primarily engaged in the business of insurance;
      2. A Morris Plan bank; or
      3. An installment loan company that is not an "insured depository institution" as defined in subsection 3(c)(2) of the Federal Deposit Insurance Act, 12 U.S.C. Section 1813(c)(2), or any successor federal statute.
  7. "Federal covered investment adviser" means a person registered under the Investment Advisers Act of 1940, 15 U.S.C. Section 80b-1, et seq.
  8. "Federal covered security" means a security that is, or upon completion of a transaction will be, a covered security under Section 18(b) of the Securities Act of 1933, 15 U.S.C. Section 77r(b), or rules or regulations adopted pursuant to that provision.
  9. "Filing" means the receipt under this chapter of a record by the Commissioner or a designee of the Commissioner.
  10. "Fraud," "deceit," or "defraud" is not limited to common law deceit.
  11. "Guaranteed" means guaranteed as to payment of all principal and all interest.
  12. "Institutional investor" means any of the following, whether acting for itself or for others in a fiduciary capacity:
    1. A depository institution or international banking institution;
    2. An insurance company;
    3. A separate account of an insurance company;
    4. An investment company as defined in the Investment Company Act of 1940, 15 U.S.C. Section 80a-1, et seq.;
    5. A broker-dealer registered under the Securities Exchange Act of 1934, 15 U.S.C. Section 78a, et seq.;
    6. An employee pension, profit-sharing, or benefit plan if the plan has total assets in excess of $10 million or its investment decisions are made by a named fiduciary, as defined in the Employee Retirement Income Security Act of 1974, 29 U.S.C. Section 1001, et seq., that is a broker-dealer registered under the Securities Exchange Act of 1934, 15 U.S.C. Section 78a, et seq., an investment adviser registered or exempt from registration under the Investment Advisers Act of 1940, 15 U.S.C. Section 80b-1, et seq., an investment adviser registered under this chapter, a depository institution, or an insurance company;
    7. A plan established and maintained by a state, a political subdivision of a state, or an agency or instrumentality of a state or a political subdivision of a state for the benefit of its employees if the plan has total assets in excess of $10 million or its investment decisions are made by a duly designated public official or by a named fiduciary, as defined in the Employee Retirement Income Security Act of 1974, 29 U.S.C. Section 1001, et seq., that is a broker-dealer registered under the Securities Exchange Act of 1934, 15 U.S.C. Section 78a, et seq., an investment adviser registered or exempt from registration under the Investment Advisers Act of 1940, 15 U.S.C. Section 80b-1, et seq., an investment adviser registered under this chapter, a depository institution, or an insurance company;
    8. A trust if it has total assets in excess of $10 million, its trustee is a depository institution, and its participants are exclusively plans of the types identified in subparagraph (F) or (G) of this paragraph, regardless of the size of their assets, except a trust that includes as participants self-directed individual retirement accounts or similar self-directed plans;
    9. An organization that is not formed for the specific purpose of acquiring the securities offered, with total assets in excess of $10 million, including an organization described in subsection 501(c)(3) of the Internal Revenue Code, 26 U.S.C. Section 501(c)(3), a corporation, a Massachusetts trust or similar business trust, a limited liability company, or a partnership;
    10. A small business investment company licensed by the Small Business Administration under Section 301(c) of the Small Business Investment Act of 1958, 15 U.S.C. Section 681(c), with total assets in excess of $10 million;
    11. A private business development company as defined in Section 202(a)(22) of the Investment Advisers Act of 1940, 15 U.S.C. Section 80b-2(a)(22), with total assets in excess of $10 million;
    12. A federal covered investment adviser acting for its own account;
    13. A qualified institutional buyer as defined in Rule 144A(a)(1), other than Rule 144A(a)(1)(H),17 C.F.R. 230.144A, adopted under the Securities Act of 1933,15 U.S.C. Section 77a, et seq.;
    14. A major United States institutional investor as defined in Rule 15a-6(b)(4)(I), 17 C.F.R. 240.15a-6, adopted under the Securities Exchange Act of 1934, 15 U.S.C. Section 78a, et seq.;
    15. Any other person, other than an individual, of institutional character with total assets in excess of $10 million not organized for the specific purpose of evading this chapter; or
    16. Any other person specified by rule adopted or order issued under this chapter.
  13. "Insurance company" means a company organized as an insurance company whose primary business is writing insurance or reinsuring risks underwritten by insurance companies and which is subject to supervision by the insurance commissioner or a similar official or agency of a state.
  14. "Insured" means insured as to payment of all principal and all interest.
  15. "International banking institution" means an international financial institution of which the United States is a member and whose securities are exempt from registration under the Securities Act of 1933, 15 U.S.C. Section 77a, et seq.
  16. "Investment adviser" means a person that, for compensation, engages in the business of advising others, either directly or through publications or writings, as to the value of securities or the advisability of investing in, purchasing, or selling securities or that, for compensation and as a part of a regular business, issues or promulgates analysis or reports concerning securities. The term includes a financial planner or other person that, as an integral component of other financially related services, provides investment advice to others for compensation as part of a business or that holds itself out as providing investment advice to others for compensation. The term does not include:
    1. An investment adviser representative;
    2. A lawyer, accountant, engineer, or teacher whose performance of investment advice is solely incidental to the practice of the person's profession;
    3. A broker-dealer or its agents whose performance of investment advice is solely incidental to the conduct of business as a broker-dealer and that does not receive special compensation for the investment advice;
    4. A publisher of a bona fide newspaper, news magazine, or business or financial publication of general and regular circulation;
    5. A federal covered investment adviser;
    6. A bank or savings institution;
    7. A credit union;
    8. Any other person that is excluded by the Investment Advisers Act of 1940, 15 U.S.C. Section 80b-1, et seq., from the definition of investment adviser; or
    9. Any other person excluded by rule adopted or order issued under this chapter.
  17. "Investment Adviser Registration Depository" means an electronic filing system that facilitates investment adviser registration, regulatory review, and the public disclosure information of investment adviser firms.
  18. "Investment adviser representative" means an individual employed by or associated with an investment adviser or federal covered investment adviser who makes any recommendations or otherwise gives investment advice regarding securities, manages accounts or portfolios of clients, determines which recommendation or advice regarding securities should be given, provides investment advice or holds herself or himself out as providing investment advice, receives compensation to solicit, offer, or negotiate for the sale of or for selling investment advice, or supervises employees who perform any of the foregoing. The term does not include an individual who:
    1. Performs only clerical or ministerial acts;
    2. Is an agent whose performance of investment advice is solely incidental to the individual acting as an agent and who does not receive special compensation for investment advisory services;
    3. Is employed by or associated with a federal covered investment adviser, unless the individual has a place of business in this state as that term is defined by rule adopted under Section 203A of the Investment Advisers Act of 1940, 15 U.S.C. Section 80b-3a, and is:
      1. An investment adviser representative as that term is defined by rule adopted under Section 203A of the Investment Advisers Act of 1940, 15 U.S.C. Section 80b-3a; or
      2. Not a supervised person as that term is defined in Section 202(a)(25) of the Investment Advisers Act of 1940, 15 U.S.C. Section 80b-2(a)(25); or
    4. Is excluded by rule adopted or order issued under this chapter.
  19. "Issuer" means a person that issues or proposes to issue a security, subject to the following:
    1. The issuer of a voting trust certificate, collateral trust certificate, certificate of deposit for a security, or share in an investment company without a board of directors or individuals performing similar functions is the person performing the acts and assuming the duties of depositor or manager pursuant to the trust or other agreement or instrument under which the security is issued;
    2. The issuer of an equipment trust certificate or similar security serving the same purpose is the person by which the property is or will be used or to which the property or equipment is or will be leased or conditionally sold or that is otherwise contractually responsible for assuring payment of the certificate; or
    3. The issuer of a fractional undivided interest in an oil, gas, or other mineral lease or in payments out of production under a lease, right, or royalty is the owner of an interest in the lease or in payments out of production under a lease, right, or royalty, whether whole or fractional, that creates fractional interests for the purpose of sale.
  20. "Nonissuer transaction" or "nonissuer distribution" means a transaction or distribution not directly or indirectly for the benefit of the issuer.
  21. "Offer to purchase" includes an attempt or offer to obtain or solicitation of an offer to sell a security or interest in a security for value. The term does not include a tender offer that is subject to Section 14(d) of the Securities Exchange Act of 1934, 15 U.S.C. Section 78n(d).
  22. "Person" means an individual; corporation; business trust; estate; trust; partnership; limited liability company; association; joint venture; government; governmental subdivision, agency, or instrumentality; public corporation; or any other legal or commercial entity.
  23. "Place of business" of a broker-dealer, an investment adviser, or a federal covered investment adviser means:
    1. An office at which the broker-dealer, investment adviser, or federal covered investment adviser regularly provides brokerage or investment advice or solicits, meets with, or otherwise communicates with customers or clients; or
    2. Any other location that is held out to the general public as a location at which the broker-dealer, investment adviser, or federal covered investment adviser provides brokerage or investment advice or solicits, meets with, or otherwise communicates with customers or clients.
  24. "Predecessor Act" means Chapter 5 of this title, the "Georgia Securities Act of 1973," as it existed immediately prior to July 1, 2009.
  25. "Price amendment" means the amendment to a registration statement filed under the Securities Act of 1933, 15 U.S.C. Section 77a, et seq., or, if an amendment is not filed, the prospectus or prospectus supplement filed under the Securities Act of 1933, 15 U.S.C. Section 77a, et seq., that includes a statement of the offering price, underwriting and selling discounts or commissions, amount of proceeds, conversion rates, call prices, and other matters dependent upon the offering price.
  26. "Principal place of business" of a broker-dealer or an investment adviser means the executive office of the broker-dealer or investment adviser from which the officers, partners, or managers of the broker-dealer or investment adviser direct, control, and coordinate the activities of the broker-dealer or investment adviser.
  27. "Record," except in the phrases "of record," "official record," and "public record," means information that is inscribed on a tangible medium or that is stored in an electronic or other medium and is retrievable in perceivable form.
  28. "Sale" includes every contract of sale, contract to sell, or disposition of a security or interest in a security for value. Offer to sell includes every attempt or offer to dispose of or solicitation of an offer to purchase a security or interest in a security for value. Both terms include:
    1. A security given or delivered with or as a bonus on account of a purchase of securities or any other thing constituting part of the subject of the purchase and having been offered and sold for value;
    2. A gift of assessable stock involving an offer and sale; and
    3. A sale or offer of a warrant or right to purchase or subscribe to another security of the same or another issuer and a sale or offer of a security that gives the holder a present or future right or privilege to convert the security into another security of the same or another issuer, including an offer of the other security.
  29. "Securities and Exchange Commission" means the United States Securities and Exchange Commission.
  30. "Security" means a note; stock; treasury stock; security future; bond; debenture; evidence of indebtedness; certificate of interest or participation in a profit-sharing agreement; collateral trust certificate; preorganization certificate or subscription; transferable share; investment contract; voting trust certificate; certificate of deposit for a security; fractional undivided interest in oil, gas, or other mineral rights; put, call, straddle, option, or privilege on a security, certificate of deposit, or group or index of securities, including an interest therein or based on the value thereof; put, call, straddle, option, or privilege entered into on a national securities exchange relating to foreign currency; or, in general, an interest or instrument commonly known as a "security"; or a certificate of interest or participation in, temporary or interim certificate for, receipt for, guarantee of, or warrant or right to subscribe to or purchase any of the foregoing. The term:
    1. Includes both a certificated and an uncertificated security;
    2. Does not include an insurance or endowment policy or annuity contract under which an insurance company promises to pay a fixed or variable sum of money either in a lump sum or periodically for life or other specified period;
    3. Does not include an interest in a contributory or noncontributory pension or welfare plan subject to the Employee Retirement Income Security Act of 1974, 29 U.S.C. Section 1001, et seq.;
    4. Includes as an investment contract an investment in a common enterprise with the expectation of profits to be derived primarily from the efforts of a person other than the investor where common enterprise means an enterprise in which the fortunes of the investor are interwoven with those of either the person offering the investment, a third party, or other investors; and
    5. Includes as an investment contract, among other contracts, an interest in a limited partnership or a limited liability company and an investment in a viatical settlement or similar agreement.
  31. "Self-regulatory organization" means a national securities exchange registered under the Securities Exchange Act of 1934, 15 U.S.C. Section 78a, et seq., a national securities association of broker-dealers registered under the Securities Exchange Act of 1934, 15 U.S.C. Section 78a, et seq., a clearing agency registered under the Securities Exchange Act of 1934, 15 U.S.C. Section 78a, et seq., or the Municipal Securities Rulemaking Board established under the Securities Exchange Act of 1934, 15 U.S.C. Section 78a, et seq.
  32. "Sign" means, with present intent to authenticate or adopt a record:
    1. To execute or adopt a tangible symbol; or
    2. To attach or logically associate with the record an electronic symbol, sound, or process.
  33. "State" means a state of the United States, the District of Columbia, Puerto Rico, the United States Virgin Islands, or any territory or insular possession subject to the jurisdiction of the United States.

(Code 1981, §10-5-2, enacted by Ga. L. 2008, p. 381, § 1/SB 358; Ga. L. 2017, p. 774, § 10/HB 323; Ga. L. 2020, p. 156, § 8/SB 462.)

The 2017 amendment, effective May 9, 2017, part of an Act to revise, modernize, and correct the Code, substituted "the 'Georgia Securities Act of 1973,"' for "the 'Georgia Securities Act of 1973'," in the middle of paragraph (25).

The 2020 amendment, effective June 30, 2020, substituted "installment loan" for "industrial loan" preceding "company" in division (7)(B)(iii). See the Editor's notes for applicability.

Cross references.

- Designation of Secretary of State as commissioner of securities, § 10-5-10.

Code Commission notes.

- Pursuant to Code Section 28-9-5, in 2008, "July 1, 2009" was substituted for "the effective date of this chapter" in paragraph (25).

Editor's notes.

- Ga. L. 2020, p. 156, § 10/SB 462, not codified by the General Assembly, provides that: "This Act shall apply to all installment loan agreements entered into on and after July 1, 2020."

Law reviews.

- For article on the definition of a security in light of the "Georgia Securities Act of 1973" and the need for maximizing investor protection, see 30 Emory L.J. 73 (1981). For article, "Uniformity under the Securities Laws: Regulation D and the New Georgia Uniform Limited Offering Exemption," see 19 Ga. St. B. J. 74 (1982). For annual survey of law of business associations, see 56 Mercer L. Rev. 77 (2004). For survey of 11th Circuit securities regulation cases, see 56 Mercer L. Rev. 1341 (2005). For article, "The Georgia Uniform Securities Act of 2008: An Analysis of Significant Changes to Georgia's Blue Sky Law," see 14 (No. 6) Ga. St. B. J. 18 (2009). For note, "Regulation of the Franchise as a Security," see 19 J. of Pub. L. 105 (1970). For note discussing the classification of pyramid marketing scheme contracts as securities prior to enactment of Georgia Securities Act of 1973, see 21 J. of Pub. L. 445 (1972). For note discussing standards used by Georgia courts to define securities, and their application, see 31 Mercer L. Rev. 333 (1979). For note, "The Economic Realities of Condominium Registration Under the Securities Act of 1933," see 19 Ga. L. Rev. 747 (1984). For comment, the purchase of all the shares of stock of a business is not the purchase of a "security" within the meaning of the Federal Securities Act of 1933 or the Georgia Securities Act of 1973, see 30 Emory L.J. 1212 (1981).

JUDICIAL DECISIONS

ANALYSIS

  • General Consideration
  • "Sale" or "Sell"
  • "Salesman"
  • "Security"

General Consideration

Editor's notes.

- In light of the similarity of the statutory provisions, decisions under former Ga. L. 1920, p. 250, Ga. L. 1957, p. 134, as amended, former Code 1933, § 97-102, former O.C.G.A. § 10-5-2, and under 15 U.S.C. § 77(b), which were subsequently repealed but were succeeded by provisions in this Code section, are included in the annotations for this Code section.

Commodity futures dealer not a "dealer".

- One who deals in commodity futures is not a "dealer" in securities. Monarch Co. v. Weis, 86 Ga. App. 7, 70 S.E.2d 600 (1952) (decided under former Ga. L. 1920, p. 250, as amended).

"Issuers".

- Persons who procure contracts of subscription to the stock of a proposed corporation not in esse but which may be organized in the future are not "issuers" of such stock within the intent and meaning of that term as defined in the securities law. Felton v. Highlands Hotel Co., 165 Ga. 598, 141 S.E. 793, 57 A.L.R. 987 (1928) (decided under former Ga. L. 1920, p. 250).

Cited in Hamilton Bank & Trust Co. v. Holliday, 469 F. Supp. 1229 (N.D. Ga. 1979); Hirsch v. Equilateral Assocs., 245 Ga. 373, 264 S.E.2d 885 (1980); Novatex Sales, Inc. v. Prince, 159 Ga. App. 559, 284 S.E.2d 65 (1981); Jorges v. Griffin, 161 Ga. App. 439, 288 S.E.2d 356 (1982); Nicholson v. Harris, 179 Ga. App. 35, 345 S.E.2d 63 (1986); Turem v. Sinowski & Jones, 195 Ga. App. 829, 395 S.E.2d 60 (1990); Haupt v. State, 290 Ga. App. 616, 660 S.E.2d 383 (2008); Golden Atlanta Site Dev., Inc. v. Tilson, 299 Ga. App. 646, 683 S.E.2d 166 (2009).

"Sale" or "Sell"

Term "sale" or "sell" is not limited to technical common-law sales or transactions ordinarily governed by the commercial law of sales. Peoples Bank v. North Carolina Nat'l Bank, 139 Ga. App. 405, 228 S.E.2d 334 (1976) (construing similar federal provision, 15 U.S.C. § 77b(3)).

Promissory note was a security.

- Borrowers did not commit fraud upon a lender; the borrowers advised the lender that the lender's $150,000 would fund the corporation until the borrowers secured $1.5 million to build the necessary greenhouses, and the borrowers payment of salaries to themselves of $600 per week each was not inconsistent with the borrowers stated purpose. Because there was no intent to defraud, the borrowers were not liable for securities fraud under O.C.G.A. § 10-5-50, although the promissory note was a security under O.C.G.A. § 10-5-2. Sims v. Natural Prods. of Ga., LLC, 337 Ga. App. 20, 785 S.E.2d 659 (2016).

Payment may be made in any medium which the payor and the payee regard as equivalent to money, such as goods, chattels, securities, lands, services, credits, or bank notes. Utzman v. Caribbean & S.E. Dev. Corp., 107 Ga. App. 56, 129 S.E.2d 62 (1962) (decided under former Ga. L. 1957, p. 134, as amended).

Cancelling or assuming debt as payment.

- Payment may be made by cancelling an existing debt owed one by the creditor of another, whether by request or compulsion, or by rendering an account which makes the person rendering it liable for another's debt. Utzman v. Caribbean & S.E. Dev. Corp., 107 Ga. App. 56, 129 S.E.2d 62 (1962) (decided under former Ga. L. 1957, p. 134, as amended).

Determining whether "sale" occurred in Georgia.

- Former Code 1933, § 102-108 did not limit the application of the statutory security provisions; thus, whether a "sale" within the meaning of the statutory security provisions occurred in Georgia must be decided on basic principles. Allen v. Smith & Medford, Inc., 129 Ga. App. 538, 199 S.E.2d 876 (1973) (decided under former Ga. L. 1957, p. 134, as amended).

Although one defendant testified that the plaintiff agreed to lend $50,000.00 in Florida, the agreement which concerned the debenture or security sets forth that the agreement was entered into in Atlanta, Georgia, and that the plaintiff, who resided in Georgia, executed the contract in Georgia and received the stock in Georgia; thus, there was a "sale" in Georgia. Allen v. Smith & Medford, Inc., 129 Ga. App. 538, 199 S.E.2d 876 (1973) (decided under former Ga. L. 1957, p. 134, as amended).

After Texas residents sent a Georgia resident letters, brochures and other materials regarding a cattle feeding and sales investment program and, during a telephone conversation, solicited a cash downpayment from the Georgia resident, who then transferred the payment from the Georgia resident's bank account, these contacts were sufficient to establish a "sale" within the state. Seale v. Miller, 698 F. Supp. 883 (N.D. Ga. 1988);(decided under former O.C.G.A. § 10-5-2).

"Salesman"

Sufficiency of evidence.

- Whether defendant was a "dealer" under former O.C.G.A. § 10-5-3 was immaterial since the evidence at trial was sufficient for a jury to find that the defendant was a "salesman" pursuant to paragraph (a)(25) of former O.C.G.A. § 10-5-2. Greenhill v. State, 199 Ga. App. 218, 404 S.E.2d 577, cert. denied, 199 Ga. App. 906, 404 S.E.2d 557 (1991);(decided under former O.C.G.A. § 10-5-2).

"Security"

Treatment similar to federal Acts.

- Treatment extended to notes and securities, while not precisely the same under Georgia law and the federal Acts, is virtually identical. Blau v. Redmond, 143 Ga. App. 897, 240 S.E.2d 273 (1977);(decided under former Code 1933, § 97-102).

Test for determining whether an investment is a security is the same under both the former Georgia Securities Act and the federal securities laws. Eberhardt v. Waters, 901 F.2d 1578 (11th Cir. 1990);(decided under former O.C.G.A. § 10-5-2).

"Any note" and "evidence of indebtedness".

- Ordinary terms of "any note" or "evidence of indebtedness" in paragraph (a)(19) of this section are self-defining and require no further definition. Peoples Bank v. North Carolina Nat'l Bank, 139 Ga. App. 405, 228 S.E.2d 334 (1976) (holding note a "security") (construing similar provisions of 15 U.S.C. § 77b(1)); Blau v. Redmond, 143 Ga. App. 897, 240 S.E.2d 273 (1977);(decided under former Code 1933, § 97-102).

To determine whether stock constitutes a "security" under either the Georgia Securities Act of 1973, former O.C.G.A. § 10-5-1 et seq., or the federal securities acts, it is necessary to apply the test in Landreth Timber Co. v. Landreth, 471 U.S. 681, 105 S. Ct. 2297, 85 L. Ed. 692 (1985), which is whether the stock "bears such characteristics usually associated with common stock that a purchaser justifiably may assume that appropriate securit[ies] laws apply." Cohen v. William Goldberg & Co., 202 Ga. App. 172, 413 S.E.2d 759 (1991), cert. denied, 202 Ga. App. 905, 413 S.E.2d 759, modified on other grounds, 262 Ga. 606, 423 S.E.2d 231 (1992), vacated on other grounds, 207 Ga. App. 174, 428 S.E.2d 117 (1993);(decided under former O.C.G.A. § 10-5-2).

Appropriate test to be employed in resolving issues of whether particular stock is a security is whether the stock bears such characteristics usually associated with common stock that a purchaser justifiably may assume that appropriate security laws apply. Cohen v. William Goldberg & Co., 262 Ga. 606, 423 S.E.2d 231 (1992);(decided under former O.C.G.A. § 10-5-2).

In determining whether stock is a security, if, and only if, the stock does not meet the statutory definition under either the Georgia or federal securities acts, the next inquiry should be whether the stock meets the Howey economic reality test as tailored by Tech Resources to resolve issues concerning "investment contracts" and any "instrument commonly known as a 'security.'" Cohen v. William Goldberg & Co., 262 Ga. 606, 423 S.E.2d 231 (1992) (decided under former O.C.G.A. § 10-5-2).

Four tests are applicable in determining whether a transaction falls within the definition of "security": the "Howey" test (Securities & Exch. Comm'n v. W.J. Howey Co., 328 U.S. 293, 66 S. Ct. 1100, 90 L. Ed. 1244 (1946)); the "Joiner" test (Securities & Exch. Comm'n v. C.M. Joiner Leasing Corp., 320 U.S. 344, 64 S. Ct. 120, 88 L. Ed. 88 (1943)); the "Risk Capital" test (Silver Hills Country Club v. Sobieski, 55 Cal. 2d 811, 13 Cal. Rptr. 186, 361 P.2d 906 (1961)); and the "Managerial Efforts" test (Securities & Exch. Comm'n v. Glenn W. Turner Enters., Inc., 474 F.2d 476 (9th Cir. 1973)). Jaciewicki v. Gordarl Assocs., 132 Ga. App. 888, 209 S.E.2d 693 (1974) (decided under former Ga. L. 1957, p. 134, as amended); D.K. Properties, Inc. v. Osborne, 143 Ga. App. 832, 240 S.E.2d 293 (1977) (decided under former Code 1933, § 97-102).

A factual situation which falls within the framework of either the "Howey," "Joiner," "Risk Capital," or "Managerial Efforts" test, or any combination thereof, will afford a sufficient basis for a finding that a "security" is involved. Jaciewicki v. Gordarl Assocs., 132 Ga. App. 888, 209 S.E.2d 693 (1974) (decided under former Ga. L. 1957, p. 134, as amended).

Applying the stock characterization test, shares of stock were securities when stockholders were entitled to receive dividends, the stock was negotiable, the shares could be pledged or hypothecated, the by-laws provided that stockholders were entitled to one vote per share, and the stock apparently had the capacity to increase in value. Bell v. Sasser, 238 Ga. App. 843, 520 S.E.2d 287 (1999) (decided under former O.C.G.A. § 10-5-2).

Neither restrictions on the negotiability of stock in a closely held corporation nor its unregistered status negated the stock's character as a security. Cox v. Edelson, 243 Ga. App. 5, 530 S.E.2d 250 (2000) (decided under former O.C.G.A. § 10-5-2).

Policy to protect investor when success depends on promoter's efforts.

- Basic policy behind all the tests for a "security" is to protect the investor with the shield of the securities laws when the promoter or syndicator puts forth the essential managerial efforts which affect the failure or success of the enterprise. D.K. Properties, Inc. v. Osborne, 143 Ga. App. 832, 240 S.E.2d 293 (1977) (decided under former Code 1933, § 97-102).

Form should be disregarded for substance and emphasis should be on economic reality when making a determination as to whether or not an instrument is a security. Tech Resources, Inc. v. Estate of Hubbard, 246 Ga. 583, 272 S.E.2d 314 (1980); Cocklereece v. Moran, 532 F. Supp. 519 (N.D. Ga. 1982) (decided under former Code 1933, § 97-102).

Label used on instrument not determinative.

- Label placed on the instrument by the parties or by the courts does not determine whether the instrument is a "security." Instead, the characteristics of the instrument and the underlying economic reality are the significant factors for a court to consider in classifying an instrument as a "security." Dunwoody Country Club of Atlanta, Inc. v. Fortson, 243 Ga. 236, 253 S.E.2d 700 (1979); Redmond v. Blau, 153 Ga. App. 395, 265 S.E.2d 329 (1980) (decided under former Code 1933, § 97-102).

As there was no dispute that agreements and notes defendant provided the defendant's victims in exchange for money were investments and that the victims relied on the defendant to manage the investments and to provide a return on the investments, the instruments were "securities" within the meaning of Georgia's blue sky law; that the amount of expected return was fixed was immaterial. Rasch v. State, 260 Ga. App. 379, 579 S.E.2d 817 (2003) (decided under former O.C.G.A. § 10-5-2).

Expectation of profits from efforts of others.

- Touchstone of a "security" is the presence of an investment in a common venture premised on a reasonable expectation of profits to be derived from the entrepreneurial or managerial efforts of others. Dunwoody Country Club of Atlanta, Inc. v. Fortson, 243 Ga. 236, 253 S.E.2d 700 (1979) (decided under former Code 1933, § 97-102).

In order for a transaction to constitute a securities transaction under the law, there must be an investment, a reasonable expectation of profits, and a reliance on the management of another party to bring about the profits. Tech Resources, Inc. v. Estate of Hubbard, 246 Ga. 583, 272 S.E.2d 314 (1980) (decided under former Code 1933, § 97-102).

In determining whether a transaction constitutes a "security," the courts focus primarily upon one issue: do persons other than the investors provide the essential managerial efforts from which the investors expect profits? If the answer to that question is in the affirmative, then, for the protection of the investor, who is thereby seen to lack control over the investor's investment, the courts have found the transaction to be a "security." D.K. Properties, Inc. v. Osborne, 143 Ga. App. 832, 240 S.E.2d 293 (1977) (decided under former Code 1933, § 97-102).

Stock of closely-held corporation.

- Since restrictions on negotiability of stock were usual and customary for closely-held corporations, the restrictions did not negate the stock's character as a security. Cohen v. William Goldberg & Co., 262 Ga. 606, 423 S.E.2d 231 (1992) (decided under former O.C.G.A. § 10-5-2).

Unregistered stock.

- Unregistered status of stock in a closely-held corporation did not negate the stock's character as a security since the Georgia and federal securities acts contemplate that stock may be a "security" and yet be unregistered. Cohen v. William Goldberg & Co., 262 Ga. 606, 423 S.E.2d 231 (1992) (decided under former O.C.G.A. § 10-5-2).

Limited partnership interests are explicitly included in the definitions of "security." Kleiner v. Silver, 137 Ga. App. 560, 224 S.E.2d 508 (1976) (decided under former Code 1933, § 97-102).

"Unusual instruments".

- Stock not meeting the definition of a security under the test in Landreth Timber Co. v. Landreth, 471 U.S. 681, 105 S. Ct. 2297, 85 L. Ed. 2d 692 (1985), may otherwise come within the Georgia or federal securities acts if the stock qualifies as one of the "unusual instruments" not easily characterized as "securities." Cohen v. William Goldberg & Co., 202 Ga. App. 172, 413 S.E.2d 759 (1991), cert. denied, 202 Ga. App. 905, 413 S.E.2d 759, modified on other grounds, 262 Ga. 606, 423 S.E.2d 231 (1992), vacated on other grounds, 207 Ga. App. 174, 428 S.E.2d 117 (1993) (decided under former O.C.G.A. § 10-5-2).

If investors control decision essential for profit, no sale of securities.

- When the investors have control over the essential decision from which the investors expect profits to flow, the scheme does not involve the sale of securities. D.K. Properties, Inc. v. Osborne, 143 Ga. App. 832, 240 S.E.2d 293 (1977) (decided under former Code 1933, § 97-102).

Restrictive covenants and pledge of shares did not vest control in another.

- When buyer proposed to purchase business of coal mining companies and to operate and control it as its own and to assume certain financial obligations of the companies, existence of restrictive financial covenants in the agreement and pledge of shares as security for performance of covenants did not vest significant managerial control in anyone other than the purchaser and the sale was not a security transaction. Tech Resources, Inc. v. Estate of Hubbard, 246 Ga. 583, 272 S.E.2d 314 (1980) (decided under former Code 1933, § 97-102).

Test applies to "investment contract".

- Test of whether there is an "investment contract" is whether the scheme involves an investment of money in a common enterprise with profits to come solely from the efforts of others. Georgia Mkt. Ctrs., Inc. v. Fortson, 225 Ga. 854, 171 S.E.2d 620 (1969), commented on in 21 Mercer L. Rev. 715 (1970) (decided under former Ga. L. 1957, p. 134, as amended).

An "investment contract" is a security if the scheme involves an investment of money in a common enterprise in which profits are to come solely from the efforts of others. Goldsmith v. American Food Servs., Inc., 123 Ga. App. 353, 181 S.E.2d 95 (1971) (decided under former Ga. L. 1957, p. 134, as amended); Brown v. Computer Credit Sys., 128 Ga. App. 429, 197 S.E.2d 165 (1973) (decided under former Ga. L. 1957, p. 134, as amended).

Elements of an "investment contract" are: (a) the investment of money (b) in a common enterprise (c) with profits to come solely from the efforts of others. The Georgia courts accept this test for an investment contract for purposes of the security law. Plunkett v. Francisco, 430 F. Supp. 235 (N.D. Ga. 1977) (decided under former Ga. L. 1957, p. 134, as amended).

Three elements of an investment contract are: (1) an investment of money; (2) in a common enterprise; and (3) an expectation of profit solely from the efforts of others. Eberhardt v. Waters, 901 F.2d 1578 (11th Cir. 1990) (decided under former O.C.G.A. § 10-5-2).

Sale and lease-back contracts for payphones were found to be investment contracts within the definition of securities pursuant to O.C.G.A. § 10-5-2(a)(26) as the buyer invested money for the purchase, the concept was packaged as an investment venture by the seller, and the purchaser expected to receive a fixed monthly income as a return on each payphone, which represented a fixed return on the purchaser's investment. Garvin v. Sec'y of State, 266 Ga. App. 66, 596 S.E.2d 166 (2004) (decided under former O.C.G.A. § 10-5-2).

Defendant was properly convicted of violating the Georgia Securities Act of 1973 because the evidence authorized the jury to find that all three prongs of the test used to determine whether a particular scheme was an investment contract under the Securities Act, O.C.G.A. § 10-5-2(a)(26), were satisfied; the victims parted with the victims' money in anticipation of investment gains, there was a common enterprise because the victims' funds were pooled to reach the minimum amounts for participation set by the defendant, and the expectation of profits rested solely on the efforts of others. Hicks v. State, 315 Ga. App. 779, 728 S.E.2d 294 (2012).

Investment met Howey "economic reality" test.

- Plaintiff's payment for a 10% interest in a closely held corporation was an "investment contract" under the Howey "economic reality" test. Huggins v. Chapin, 227 Ga. App. 340, 489 S.E.2d 109 (1997) (decided under former O.C.G.A. § 10-5-2).

Investment arrangement involving the sale of cattle embryos, based on the process of artificially inseminating superovulated "donor cows" for reproduction, constituted the sale of a security under Georgia law. Eberhardt v. Waters, 901 F.2d 1578 (11th Cir. 1990) (decided under former O.C.G.A. § 10-5-2).

"Security" may include transaction purporting to be real estate sale.

- Transaction which purports only to be a sale of real estate can, when the economic realities of the transaction are examined, be determined to be a security. The rule which has developed is that any investment will be deemed an "investment contract" and a "security" if the investor's return is essentially dependent upon the efforts of the syndicator or an affiliate. Fortier v. Ramsey, 136 Ga. App. 203, 220 S.E.2d 753 (1975) (decided under former Ga. L. 1957, p. 134, as amended).

Franchise agreement is not a "security" within the meaning of the securities law if the investor is entitled to no return under the agreement except through the investor's own efforts. Brown v. Computer Credit Sys., 128 Ga. App. 429, 197 S.E.2d 165 (1973) (decided under former Ga. L. 1957, p. 134, before it was amended by Ga. L. 1970, p. 450).

Redeemable membership certificate is a certificate of indebtedness, but the certificate of indebtedness does not represent an "investment" within the meaning of the securities law when the certificate creates no expectation of profit because the certificate bears no interest, cannot appreciate, and cannot be pledged or assigned. Dunwoody Country Club of Atlanta, Inc. v. Fortson, 243 Ga. 236, 253 S.E.2d 700 (1979) (decided under former Code 1933, § 97-102).

Defendant properly convicted for violating Securities Act.

- Defendant was properly convicted of violating the Georgia Securities Act of 1973 because the evidence authorized the jury to find that all three prongs of the test used to determine whether a particular scheme was an investment contract under the Securities Act, O.C.G.A. § 10-5-2(a)(26), were satisfied; the victims parted with the victims' money in anticipation of investment gains, there was a common enterprise because the victims' funds were pooled to reach the minimum amounts for participation set by the defendant, and the expectation of profits rested solely on the efforts of others. Hicks v. State, 315 Ga. App. 779, 728 S.E.2d 294 (2012).

Pooled money was security.

- Trial court did not err in holding that the three notes at issue were securities under Georgia law because the funds pooled from the investors in the three commercial ventures had to reach minimum amounts for participation, which indicated an investment in a common enterprise, and the evidence showed that the investors expected their profit from the financial transactions to be obtained through defendants' managerial efforts. Cushing v. Cohen, 323 Ga. App. 497, 746 S.E.2d 898 (2013).

OPINIONS OF THE ATTORNEY GENERAL

ANALYSIS

  • General Consideration
  • "Dealer" and "Salesperson"
  • "Sale" or "Sell"
  • "Security"

General Consideration

Editor's notes.

-.

In light of the similarity of the statutory provisions, opinions under former Ga. L. 1957, p. 134, as amended, former Code 1933, § 97-102, and former O.C.G.A. § 10-5-2, which were subsequently repealed but were succeeded by provisions in this Code section, are included in the annotations for this section.

New York license to sell securities is not valid in Georgia. 1969 Op. Att'y Gen. No. 69-102 (decided under former Ga. L. 1957, p. 134, as amended).

"Dealer" and "Salesperson"

"Commission" construed broadly.

- Term "commission," particularly when further expanded to include any remuneration paid related to the sale of securities, should be given an expansive reading. 1974 Op. Att'y Gen. No. 74-75 (decided under former Code 1933, § 97-102).

"Dealer" or "salesperson" not limited to one receiving explicit commission.

- General partner or executive officer of a real estate syndication should not be excluded from the definition of "salesperson" or "dealer" merely because the partner or officer receives compensation or profit in the form of a profit on sales to the syndication, a real estate brokerage commission, a management fee, or some other form which is not an explicit commission for the sale of securities. 1974 Op. Att'y Gen. No. 74-75 (decided under former Code 1933, § 97-102).

"Sale" or "Sell"

Guarantee of corporate indebtedness.

- Transaction under which a person undertakes to guarantee corporate indebtedness in consideration for the right to receive future corporate profits is a "sale" of a security governed by the statutory provisions on securities. 1973 Op. Att'y Gen. No. 73-177 (decided under former Ga. L. 1957, p. 134, as amended).

"Security"

Exact classification of instrument not necessary.

- It is not necessary that an instrument be susceptible to exact classification coextensive with one or more of the incremental clauses of paragraph (a)(19) of this section and, in addition, since securities regulation is a function of substance, one should hesitate to hand down any conclusive, all-purpose formulae. 1973 Op. Att'y Gen. No. 73-25 (decided under former Ga. L. 1957, p. 134, as amended).

"Investment contract" involves efforts of another.

- If the success of the investment is essentially dependent upon the efforts of the seller or some third person, the security being sold is an "investment contract." 1974 Op. Att'y Gen. No. 75-153 (decided under former Code 1933, § 97-102).

"Investment contract" may involve management of land.

- "Investment contract" includes many situations when investors are offered land in such a way that its value is dependent on management by others. 1973 Op. Att'y Gen. No. 73-25 (decided under former Ga. L. 1957, p. 134, as amended).

Agreement to buy land as tenants in common.

- An agreement to purchase specifically identified parcels of land which purchasers are to hold as tenants in common with the hope of increase in price is not per se a "security." 1971 Op. Att'y Gen. No. U71-118 (decided under former Ga. L. 1957, p. 134, as amended).

If the purchasers of land are passive in the operation, and depend primarily upon the efforts of promoters of the enterprise for their profits, the transaction may well constitute the sale of a "security." 1971 Op. Att'y Gen. No. U71-118 (decided under former Ga. L. 1957, p. 134, as amended).

Real estate syndication anticipating profits from syndicator's efforts.

- Any real estate syndication that is structured or marketed in such a way that the investor anticipates that the investor will realize returns based on the efforts or expertise of the syndicator or some affiliate is a "security". 1974 Op. Att'y Gen. No. 74-75 (decided under former Code 1933, § 97-102).

Limited partnership interest.

- Offering for sale of limited partnerships constitutes the offering for sale of a "security." 1969 Op. Att'y Gen. No. 69-328 (decided under former Ga. L. 1957, p. 134, as amended).

Limited partnership interest is explicitly defined to be a "security" by the securities law. 1974 Op. Att'y Gen. No. 74-75 (decided under former Code 1933, § 97-102).

Investment club interest.

- If the formation of an investment club were essentially the same as that for a limited partnership, such an interest would be a security. 1969 Op. Att'y Gen. No. 69-328 (decided under former Ga. L. 1957, p. 134, as amended).

Travelers checks and money orders deemed "securities".

- "Travelers check," "money order," or "draft," or any similar instrument by whatever name called, sold, or offered for sale to the public through retail outlets for a consideration or fee over and above its face value, which instrument may be later endorsed and cashed by the purchaser at another retail outlet or endorsed by the purchaser to another person for the payment of bills or other purposes are "securities" within the meaning of the securities law and are subject to regulation and control by the commissioner of securities. 1957 Op. Att'y Gen. p. 233 (decided under former Ga. L. 1957, p. 134).

Franchise agreements.

- In every instance when the franchisor is thinly capitalized or so under-capitalized as to require franchisee fees in order to be able to fulfill its obligations to its franchisees, the franchise agreements constitute "securities" within the purview of the securities law. 1969 Op. Att'y Gen. No. 69-471 (decided under former Ga. L. 1957, p. 134, as amended).

Securities coverage is not avoided by simply providing franchisor with adequate capital. 1969 Op. Att'y Gen. No. 69-471 (decided under former Ga. L. 1957, p. 134, as amended).

When, because of its newness, a franchising system is necessarily preorganizational as a matter of fact, then its franchising agreements constitute preorganization certificates and are "securities" within the meaning of the securities law. 1969 Op. Att'y Gen. No. 69-471 (decided under former Ga. L. 1957, p. 134, as amended).

All franchise systems however capitalized are susceptible to securities regulation until such time as the franchise is so well established as a system that the success or failure of an individual franchise is not disproportionately keyed to the success or failure of other franchisees; either the franchisor will have to provide a sufficient number of franchisor-owned and operated outlets to establish the system as a going enterprise without dependence upon the individual activities of the franchisee's cofranchisors or the franchisor will have to comply with the registration requirements of the securities law. 1969 Op. Att'y Gen. No. 69-471 (decided under former Ga. L. 1957, p. 134, as amended).

Club memberships deemed securities when promoter seeks profit.

- When club property will be the chief capital asset of a recreational program conducted by the developer for profit, and the members are asked to allow a business to use their capital without allowing the members a return on the business, and they are required to supply operating capital, because they are obligated to pay dues assessments, the proposed memberships are securities; they are not exempt as securities of a nonprofit corporation because a substantial purpose of the enterprise is profit for the promoter. 1973 Op. Att'y Gen. No. 73-25 (decided under former Ga. L. 1957, p. 134, as amended).

Use of proceeds to develop common property.

- If the transaction otherwise constitutes a security, it does not matter that proceeds were not used to develop the common facility. 1973 Op. Att'y Gen. No. 73-25 (decided under former Ga. L. 1957, p. 134, as amended).

Condominium with rental pool feature.

- Condominium, when combined with rental pool feature, constitutes "security" as defined by this section. 1973 Op. Att'y Gen. No. 73-100 (decided under former Ga. L. 1957, p. 134, as amended).

Sale of time-sharing units in a condominium when coupled with a rental pool or other profit-sharing arrangement constitutes a "security", unless exempt, must be registered pursuant to the statutory provisions on securities; any person offering for sale or selling such securities that are subject to registration must register as a dealer, limited dealer, salesperson, or limited salesperson unless such a person is a real estate broker or salesperson licensed to sell real estate in Georgia. 1976 Op. Att'y Gen. No. 76-75 (decided under former Code 1933, § 97-102).

Guaranteeing corporate indebtedness.

- Transaction under which a person undertakes to guarantee corporate indebtedness in consideration for the right to receive future corporate profits may be a sale of "security" governed by the statutory provisions on securities. 1973 Op. Att'y Gen. No. 73-177 (decided under former Ga. L. 1957, p. 134, as amended).

Transaction under which a corporation would obtain the guarantees of strangers on the corporation's loans in exchange for a percentage of profits in a development for which they guarantee the loan would constitute a sale of a "security". 1973 Op. Att'y Gen. No. 73-177 (decided under former Ga. L. 1957, p. 134, as amended).

Guaranty of a corporate loan by a stockholder if the guarantor expected no direct return from the guaranty, but only the indirect benefit of the increase in value of the corporation should the project be successful and the loan repaid would not constitute the sale of a security. 1973 Op. Att'y Gen. No. 73-177 (decided under former Ga. L. 1957, p. 134, as amended).

Typical scotch whiskey investment is "security." 1973 Op. Att'y Gen. No. 73-187 (decided under former Ga. L. 1957, p. 134, as amended).

Notes given in commercial transaction.

- Notes given in an essentially commercial transaction between a payor and a payee are not subject to the securities law. 1974 Op. Att'y Gen. No. 74-153 (decided under former Code 1933, § 97-102).

Sales of notes or mortgages will be subject to the securities law if the transaction, as a matter of economic reality, is an investment. 1974 Op. Att'y Gen. No. 74-153 (decided under former Code 1933, § 97-102).

Variable annuity contract is subject to regulation as "security." 1962 Op. Att'y Gen. p. 448 (decided under former Ga. L. 1957, p. 134, prior to its amendment by Ga. L. 1969, p. 722).

"Security" does not include variable annuity contracts provided for and regulated under the insurance law. 1970 Op. Att'y Gen. No. 70-22 (decided under former Ga. L. 1957, p. 134, as amended).

Group variable annuity contracts are subject to the control and direction of the Insurance Commissioner; the words "regulated under" do not necessarily require the formal adoption of regulations under Ga. L. 1964, p. 338, § 1 et seq. so long as the contracts are in fact being regulated under the insurance law. 1970 Op. Att'y Gen. No. 70-22 (decided under former Ga. L. 1957, p. 134, as amended).

RESEARCH REFERENCES

Am. Jur. 2d.

- 69 Am. Jur. 2d, Securities Regulation - State, §§ 16, 26 et seq.

C.J.S.

- 79A C.J.S., Securities Regulation and Commodity Futures Trading Regulation, § 2.

ALR.

- Sale of memberships in club or similar organization as sale of securities within provisions of securities Acts, 87 A.L.R.2d 1140.

Who is "dealer" under state securities Acts exempting sales by owners other than issuers not made in course of successive transactions, and the like, 6 A.L.R.3d 1425.

What passes under term "securities" in will, 27 A.L.R.3d 1386.

What constitutes an "investment contract" within the meaning of state Blue Sky Laws, 47 A.L.R.3d 1375.

Validity of pyramid distribution plan, 54 A.L.R.3d 217.

State regulation of viatical life insurance programs, viatical settlements, and viatical investments, 28 A.L.R.6th 281.

"Common enterprise" element of Howey test to determine existence of investment contract regulable as "security" within meaning of federal Securities Act of 1933 (15 USCS § 77a et seq.) and Securities Exchange Act of 1934 (15 USCS § 78a et seq.), 90 A.L.R. Fed. 825.

What is "investment contract" within meaning of § 2(1) of Securities Act of 1933 (15 USCS § 77b(1)) and § 3(a)(10) of Securities Exchange Act of 1934 (15 USCS § 78c(a)(10)), both defining term "security" as including investment contract, 134 A.L.R. Fed 289.


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