We begin with a presumption that every note is a security.

We nonetheless recognize that

this presumption cannot be irrebutable.
The following relevant factors must be considered:
1. Whether the borrowers motivation is to raise money for general business use, and
whether the lenders motivation is to make a profit, including interest.
2. Whether the borrowers plan of distribution of the note resembles the plan of distribution
of a security.
3. Whether the investing public reasonably expects that the note is a security.
4. Whether there is a regulatory scheme that protects the investor other than the securities
laws.
Moreover, it was further stated in the case the types of notes that are not "securities",
which includes:
the note delivered in consumer financing;
the note secured by a mortgage on a home;
the short-term note secured by a lien on a small business or some of its assets;
the note evidencing a `character' loan to a bank customer;
short-term notes secured by an assignment of accounts receivable;
a note which simply formalizes an open-account debt incurred in the ordinary course
of business; or
notes evidencing loans by commercial banks for current operations.
A note is presumed to be a "security," and that presumption may be rebutted only by a
showing that the note bears a strong resemblance (in terms of the four factors we have
identified) to one of the enumerated categories of instrument.

Source Case:
Reves et al. v. Ernst & Young, 494 U.S. 56 (1990)