Securities

Rule 145

Rule 145 governs securities issued in business combination transactions (mergers, acquisitions, reclassifications), determining when a registration statement is required for shareholders receiving new securities.

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Exam Tip

Rule 145 = M&A transactions requiring shareholder vote = registration required. Affiliates have same restrictions as Rule 144.

What is Rule 145?

Rule 145 addresses securities issued in business combination transactions such as mergers, consolidations, asset acquisitions, and reclassifications. It determines when such securities must be registered with the SEC.

Transactions Covered by Rule 145

Transaction TypeDescription
MergerTwo companies combine into one
ConsolidationTwo companies form new entity
Asset TransferExchange assets for securities
ReclassificationChange in rights/terms of securities

When Registration Required

SituationRegistration Needed?
Shareholder Vote RequiredYes - it's an "offer to sell"
Merger/Acquisition with VoteYes
No Shareholder VoteGenerally no

Rule 145 vs. Rule 144

AspectRule 145Rule 144
FocusBusiness combinationsRestricted/control securities
When AppliesM&A transactionsResale of private placement stock
RegistrationMay require registrationSafe harbor for resale

Affiliate Restrictions Under Rule 145

Securities received by affiliates in Rule 145 transactions:

RequirementDetail
Holding PeriodNone specifically required
Volume LimitsSame as Rule 144
Manner of SaleSame as Rule 144
Current InformationRequired

Non-Affiliate Treatment

Non-affiliates receiving securities in Rule 145 transactions:

  • Can resell freely after 6 months (if issuer is reporting)
  • No volume or manner of sale restrictions
  • No Form 144 filing required

Registration Requirements

DocumentPurpose
Form S-4Standard registration for business combinations
Proxy StatementShareholder disclosure and voting
Joint Proxy/ProspectusCombined disclosure document

Exemptions from Rule 145

ExemptionCondition
Small OfferingsUnder $5 million
No Public TradingNon-public companies
Certain Stock DividendsNo change in proportionate interest

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