Securities Act of 1933
Section 2(a)(1)

August 29, 2011

Response of the Office of Chief Counsel
Division of Corporation Finance

Based on the facts presented, the Division will not recommend enforcement action to the Commission if, in reliance upon your opinion of counsel that SolarCondos are not securities, CommunitySun offers and sells the SolarCondos without registration under the Securities Act of 1933 and the Securities Exchange Act of 1934.

This position is based on the representations made to the Division in your letter. Any different facts or conditions might require the Division to reach a different conclusion. Further, this response expresses the Division’s position on enforcement action only and does not express any legal conclusion on the question presented.

Incoming Letter:

The Incoming Letter is in Acrobat format.

http://www.sec.gov/divisions/corpfin/cf-noaction/2011/communitysun082911-2a1.htm