Bell Buckle Holdings (BLLB)

[GoAndCollect]

Attorney Letter with Respect to Current Information - Attorney Opinion Letter with Respect to Year End 12/31/ 2020 Current Information

Posted yesterday

https://backend.otcmarkets.com/otcapi/company/financial-report/269009/content

Constitutes “adequate current public information” concerning the securities and the Company
“is available” within the meaning of Rule 144 (c) (2) under the Securities Act of 1933.
2. Includes all the information that a broker-dealer would be required to obtain from the
Company to publish a quotation for the securities under Rule 15c2-11 under the Securities
Exchange Act of 1934.
3. Complies as to form with the OTC Market Group’s Pink Basic Disclosure Guidelines for
providing adequate Current Information, which are located on the internet at
www.otcmarkets.com.
4. Has been posted through the OTC Disclosure and News Service; and
5. Transfer Online Inc. is registered under the Securities and Exchange Act of 1934.
6. The company currently does not meet the definition of a shell corporation. Rule 405 of the
Securities Act of 1933 and Rule 12b-2 of the Securities Exchange Act of 1934 defines a
shell company as a company with 1) no or nominal operations and either 2) no or nominal
assets, 3) assets consisting solely of cash and cash equivalents or 4) assets consisting of any
amount of cash and cash equivalents and nominal other assets.
7. Kim Halvorson is the CEO, CFO and a director. Her address is 24 Priest Point Drive, NE,
Marysville, WA 98271. Ms. Halvorson owns no shares of BLLB. As Ms. Halvorson owns
no shares of BLLB, the question of whether the shares are restricted is not applicable. The
question regarding consideration received by the company is not applicable.
8. Robert Clegg is a director. His address is 3065, The Alameda, Concord, CA 94519 Mr.
Clegg owns no shares of BLLB. As Mr. Clegg owns no shares of BLLB, the question of
whether the shares are restricted is not applicable. The question regarding consideration
received by the company is not applicable.
9. Don Zeppenfeld is a director. His address is 539 E. Kings College Drive, Saint Johns, FL
32259. Mr. Zeppenfeld owns no shares of BLLB. As Mr. Zeppenfeld owns no shares of
BLLB, the question of whether the shares are restricted is not applicable. The question
regarding consideration received by the company is not applicable.
10. The financial documents were prepared by Rachel Boulds. Ms. Boulds is an independent
CPA. Her address is 6371 S. Glenoaks Street, Murray, UT 84107. As Ms. Boulds owns no
shares of BLLB, the question of whether the shares are restricted is not applicable. The
question regarding consideration received by the company is not applicable.
11. Counsel has made specific inquiry of Ms. Halvorson, Mr. Clegg and Mr. Zeppenfeld, and
Ms. Boulds, persons engaged in promotional activities regarding the Issue (of which there
are none), and persons owning more than five percent (5%) of the Securities-of which there
are none, (collectively, the “Insiders”) and based upon such inquiries and other information
available to counsel, any sales of the Securities by Insiders within the twelve-month period
prior to the opinion have been made in compliance with Rule 144, including, without
limitation, any required filings of Form 144, and nothing has come to the attention of
counsel indicating that any of the Insiders is in possession of any material non-public
information regarding the Issuer or the Securities that would prohibit any of them from
buying or selling the Securities under Rules 10b-5 or 10b5-1 under the Exchange Act.
12. This letter may be relied on by OTC Markets, Inc. but may not be used or relied upon by
any other person for any other purpose whatsoever, without in each instance our prior
written consent. OTC Markets may publish this letter through OTC Disclosure and News
Service for viewing by the public or regulators.