Mr. Baldomero C. Falcone
SEC Opinion • Securities and Exchange Commission • Opinions • Aug 5, 1980
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August 5, 1980 Mr. Baldomero C. Falcone City Center Commercial Complex Corporation Suites 211 & 218 PCI Bank Arcade Greenhills, San Juan Metro Manila Dear Mr. Falcone: We refer to your letter of 18 July 1980, requesting opinion relating to your solicitation of reservation fees for commercial spaces in a commercial complex being established in Cebu. It appears that these fees which are equivalent to one month's rental will not be utilized by the developer but will be presented as proof to the syndicating financial institutions of the marketability of the project. The full amount collected is returned should the application be disapproved by your corporation. Considering that the application and reservation forms are merely intended for the occupancy by the prospective tenants/lessees of the spaces in that commercial complex and not reservations to subscribe to the shares of stock of the developer corporation, it is our opinion that such forms do not constitute an offering or sale of securities. This Commission, therefore, does not interpose any objection to your proposed action. Very truly yours, (SGD.) ROSARIO N. LOPEZ Director Corporate and Legal Department
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