Which transaction(s) would require registration under the ’33 Act?

a. I and II

b. II and III

c. I only

d. III only

e. I, II, and III

NewCo is planning to expand its global operations and is considering financing the operations as follows:
I. Issuance of $500,000 of securities in a 12-month period to 145 investors
II. Borrowing $1,000,000 from a bank through a secured promissory note
III. Issuance of $2,000,000 securities over three years to 10 investors