Question: Can a principal of a brokerage firm use that firm to effect ordinary “brokers’ transactions” for the principal’s personal account under Rule 144(f)?
Answer: Yes. A principal of a brokerage firm may use that firm to effect ordinary “brokers’ transactions” for the principal’s personal account under Rule 144(f). [Jan. 26, 2009]
Question 134.02
Question: Does the publication of a customer limit order in accordance with Exchange Act Rule 11Ac1-4 constitute the solicitation or arrangement for the solicitation of orders to buy securities within the meaning of Rule 144(f)(2)?
Answer: No. The publication of a customer limit order in accordance with Exchange Act Rule 11Ac1-4 would not constitute the solicitation or arrangement for the solicitation of orders to buy securities within the meaning of Rule 144(f)(2). See the Goldman, Sachs & Co. no-action letter (Dec. 6, 1996) issued by the Division. [Jan. 26, 2009]
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