“The World of ResidenSea” Luxury Passenger Vessel and Marketing of Residence Apartments, §7; §12; no action recommended, 5/14/1997

No action recommended to require registration of the offer and sale of residential contracts or agreements and memberships by ResidenSea Limited, where a contract will afford the exclusive right to use and occupy an apartment on a luxury ship and the membership will afford certain non-equity club benefits (like access to common facilities) to residents. The staff noted, among other things, that the arrangements were consistent with the offering of a home rather than a vacation time-share, that the residences would not be marketed as investment opportunities, that the arrangements will not involve any ownership interest in the ship or the ship owner or any corresponding right (such as general voting rights, dividend rights, or rights to profits), that each resident will have responsibility for its own apartment (as a condominium or cooperative owner would), and that the residences and corresponding memberships will be subject to certain transfer restrictions. The staff also recommended no action to require the ship owner or its agents to register as a dealer.