22. The following shall constitute trading in securities:
(a) any alienation or disposal, for a valuable consideration, of a security or of an interest in or option on a security, any solicitation for or obtaining of a subscription to a security for such a consideration and any attempt to do any of the aforesaid acts;
(b) any underwriting of all or part of an issue of securities;
(c) any act, transaction, advertisement, conduct or negotiation other than a preliminary negotiation for the purpose or having the effect of carrying out, directly or indirectly, any operation contemplated in subparagraphs a and b or defined by the regulations as constituting a trade in securities.