# kaal:claim:5454054-023

**Claim.** 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.

**Type.** design  **Support.** argued

**Holds when.**

- United States securities law
- secondary trading disabled

**Source quote.**

> 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.

**From.** Wulf A. Kaal, *Liquid Equity Rewards* (2025), Securities Law (SEC), page 23

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

**Verify.** sha256 of source PDF `9f53a865e6f0e5424640779df8f9b50923cd7d05649301dd4cc727144749b6e6` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kaal%20-%202025%20-%20Liquid%20Equity%20Rewards.pdf

**Topics.** securities-law, economics

**Keywords.** howey-test, design, non-transferability, secondary-market, sec

**Related claims.**

- extended_by: https://wulfkaal.github.io/claims/5583610-020

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