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IAA Comments on NASAA’s Proposed REIT Guidelines

September 20, 2022

On September 13, the IAA submitted a letter to the North American Securities Administrators Association (NASAA) in response to proposed revisions to their statement of policy on non-traded real estate investment trusts (REITs). Among other things, the revisions would amend the standards of conduct to incorporate Reg BI and impose a new concentration limit on investments in these REITs.

The IAA calls on NASAA to (i) clarify that it is not seeking, directly or indirectly, to impose conduct standards on SEC-registered advisers – which it is preempted from doing under federal law – and (ii) make changes to the proposal to ensure that SEC-registered advisers, as well as registered and private funds, are not directly or indirectly subject to any concentration limit.

Tags: NASAA, NSMIA, Preemption, States

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