The Securities Division holds the position that when a guarantee/letter of credit is an integral part of an underlying security and is not separable from the underlying security and has no value apart from the underlying security, the guarantee/letter of credit and the underlying security will be considered as a single unit.  When the underlying security is exempt from registration, separate registration o the guarantee/letter of credit is not required.  When registration is required, a single registration of both the underlying security and the guarantee/letter of credit is sufficient.

Policy Statement, Arizona Corporation Commission, Securities Division, 1-21-91.