September 23, 2016
I am an attorney in private practice in Irvine, California. I am writing in my individual capacity and not on behalf of my law firm or any of my law firm's clients.
I previously served as California's Commissioner of Corporations and in that capacity administered and enforced California's securities laws. I have taught as an adjunct professor at the University of California, Irvine and Chapman School of Law. I have also served as Co-Chairman of the Corporations Committee of the Business Law Section of the California State Bar and Chairman of the Business and Corporate Law Section of the Orange County (California) Bar Association. I am also the co-author of Nevada Corporations and Limited Liability Companies. As indicated above, this letter is written in my individual capacity and not on behalf of either of these groups.
Although the release includes a discussion of state regulation of transfer agents, it makes no mention of the fact that at least one state, Nevada, imposes a licensing requirement on persons that transact business as a transfer agent in Nevada. NRS 90.310.