Earlier this week, the SEC's Division of Corporation Finance posted new interpretations of Rule 144, specifically addressing "Persons Deemed Not to be Engaged in a Distribution and Therefore Not Underwriters." The interpretations are available here.
The new interpretations of Rule 144 replace those from the July 1997 Manual, the March 1999 Supplement and the November 2000 Current Issues and Rulemaking Project Outline. Some of the new interpretations were originally in the Manual of Publicly Available Telephone Interpretations, but even some of these have been revised by the SEC in its latest release.
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