While a Person who makes personal offers of the kind referred to in Rule 5.1.2 does not attract the Prospectus disclosure obligations in these Rules, if that Person frequently sells Units held by him, he would be likely to be 'Dealing in Investments as Principal'. As a result, such a Person would need to be licensed. Similarly, a Person who obtains Units for the purposes of secondary sales would be likely to be regarded as making those sales "by way of business" and would thus trigger the need to be licensed.