Ace Hardware Corporation; §7; §12; No Action Recommended, 9/25/1995

No action recommended to require registration of shares to be issued by hardware wholesaler to its network of retail hardware dealers where shares sold exclusively to hardware dealers participating in the network. Each participant must purchase one Class A share and 40 or 50 Class C shares, each priced at par value. The shares were not entitled to any dividends and transfer of the shares was highly restricted. No action recommended to require registration of the company or its officers or employees as dealers.