kaal:claim:5454054-023

LER can be engineered outside the Howey test by keeping reward units consumptive as discounts or credits, non-yielding, unmarketed for appreciation, and by disabling secondary trading.

LER could be engineered to fall outside of the Howey test. This is possible by avoiding a reasonable expectation of profits derived from the efforts of others. LER voucher loyalty reward units remain consumptive as discounts/credits, non-yielding, and not marketed for appreciation.

Wulf A. Kaal, Liquid Equity Rewards (2025), Securities Law (SEC), p. 23
https://ssrn.com/abstract=5454054 · source PDF

Wulf A. Kaal, Liquid Equity Rewards (2025). SSRN: https://ssrn.com/abstract=5454054

• United States securities law
• secondary trading disabled

designsupport: arguedsecurities-laweconomics

• extended_by kaal:claim:5583610-020 Non-transferability is what defeats the expectation of profits prong: because LER vouchers cannot be listed, t...

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