Quote Originally Posted by Dubdee View Post
I assume in the absence of an offer document Alan will be relying on his personal aquaintance with the investors. That is an exemption under the Act
Dubdee, are you referring to the close business association exemption. If so perhaps you're right. Except can AH get over this threshold? " sufficiently closely connected on a personal basis with the issuer that the assumption could be made that they would each have sufficient relevant knowledge of their relative's affairs or the means of readily obtaining that knowledge"

I don't think he'll make it. There are over 400 individual investors. The accountants here will know if 400 clients is a lot or not many to have a close association. But lets say 400 is quite manageable for an accountant - what about an accountant who is single handedly manging one of the countries largest investment companies which even someone with Sandy Maiers background is taking a while to get the hang of - let alone the new auditors who also took ages coming to grips with the accounts. Not something I'd expect some widowed grannie with no alternative means to cash would be able to do.