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Friday, May 03, 2013 7:24:10 AM
Section 169 applies to every person who is the beneficial owner of more than 10% of any class of equity security registered under Section 12 of the Exchange Act,10 and each officer and director (collectively, "reporting persons" or "insiders") of the issuer of such security.
We might conclude that ownership of more than 10% of the preferred class would create a reporting obligation for transactions in common. However, I'm not sure that the JBI preferreds were "registered" and if that lack of registration creates a reporting loophole for transactions in common.
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