The document discusses the potential risks and legal implications for an Underlying Fund involved in the sale of securities, particularly those purchased under Regulation D or other exemptions from registration. It highlights the risks of being deemed a 'statutory underwriter' and the potential liabilities associated with misstatements or omissions in prospectuses. The document also covers the holding period requirements for restricted securities under Rule 144 and the implications of being considered part of a 'group' with other investors under the Exchange Act.
doj/DataSet10/EFTA01384664.pdf
{"document_type":"correspondence","key_organizations":["Alpha Group Capital"]}