A Note by Any Other Name, or What Is a “Security”
By Christopher C. Kendall
Business and Securities Law,
February 2025
An analysis of the 3rd District Appellate Court case, Stukel v. Rowe, where the plaintiff alleged that the promissory note was a “security” under the Illinois Securities Law and that the defendant had acted as a salesperson in connection with the sale. Plaintiff’s theory was that the promissory note was indeed a security because repayment of the loan was “contingent upon the completion of” a construction project for which the loan was provided.
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