JAN 24, 1979

Concerning of a transaction exempt from 16(b) of the Act [15 U.S.C. § 78 p(b)] by SEC Rules X–16b–1 through X–16b–11 (17 C.F.R. § 240.16b–1 through 240.16b–11) also exempt from the operation of § 35–9–40 S.C. Code (1976), even where no exemptions therefrom have been promulgated by the State.

Requested by: John W. Lindsay, Chief Insurance Commissioner

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