State and federal courts have long struggled with the issue of what constitutes a security. Despite the similarities of state and federal statutory language and the Uniform Securities Act’s interpretive policy, state and federal precedents are hardly interchangeable. Yet, from the genesis of the dual regulatory system, first federal and then state courts have looked to the other for precedential assistance. In the landmark United States Supreme Court decision SEC v. W.J. Howey Co., the Court acknowledged the state source for the federal definition of the catchall term “investment contract.” Additionally, state appellate courts recently followed the United States Supreme Court’s decision in Reves v. Ernst & Young in determining whether the promissory notes at issue were statutory “securities” or, alternatively, “non-securities.” The article addresses the Reves concept of a promissory note as a security and the first trilogy of opinions representing Reves’ state level progeny.