Further clarification on the new 144K rule. There was a lot of confusion as to what determined the starting point for the new six month holding period. Did it start from (1) the date you purchase the securities or (2) the date the company filed to become fully reporting or (3) the date the company started trading as a fully reporting company (4) some other date as determined by the SEC?

We finally have a clear and decisive answer to the question. The new six month holding period starts on the date you purchased the securities and the hold period is retroactive. The date a company becomes fully reporting does not effect or apply to the six month waiting period of when the securities were acquired by the investor. Additionally, the effective date of the new SEC rule 144 changes will not effect the date the investor purchased the securities. So, if you own some 144 paper and its over six months old it will qualify under the six month rule as soon as the rule goes effective which we have been lead to believe will be sometime in February, 2008.

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