Relying upon legislative history and the particular characteristics of the accounts, the Seventh Circuit in Tcherepnin v. Knight held that withdrawable capital accounts in a savings and loan association are not "securities" within the ambit of the antifraud provisions of the Securities Exchange Act. This note explores the bases of the court's decision and suggests an alternative resolution which both furthers the purposes of the Act and preserves traditional state regulatory power in the savings and loan area.

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