Whisky Certificates

Bard, Attorney General,

— You have asked to be advised on the following two questions:

1. Whether whisky certificates, also known as warehouse receipts for distilled spirits in bond, come within the definition of securities in the Pennsylvania Securities Act, and whether the Pennsylvania Securities Commission has control over the offering for sale of such whisky certificates within the Commonwealth of Pennsylvania?

2. Whether the activities of vendors of whisky certificates, who solicit security owners to induce and effect a switching of their securities for whisky certificates, also known as…