When a Shareholder receives new securities in exchange for old securities of the same Issuer under Section 3(a)(9), the new securities received in the exchange assume the same character as the exchanged securities.
Tacking of the Holding Period is Allowed Under Section 3(a)(9) Securities Exchanges
This means that when restricted securities are exchanged, the new securities received under Section (a)(9) are also restricted, but the SEC allows tacking onto the holding period of the former securities.
Rule 144 Legal Opinion Letters by Experienced Securities Counsel
Shareholders receiving shares in 3(a)(9) exchanges can contact OTC Markets and OTC Bulletin Board securities lawyer Matt Stout for a no cost review of their exchange documents, and for the issuance of Rule 144 or Section 4(a)(1) legal opinions at (410) 429-7076 or firstname.lastname@example.org.