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IPA Responds to NASAA Concentration Limits Proposal

By August 11, 2016No Comments

August 11, 2016

Members and Friends –

The North American Securities Administrators Association (“NASAA”) recently announced that it is requesting public comment regarding a proposed amendment to its statement of policy regarding Real Estate Investment Trusts (“REIT Guidelines”).

Key provisions of NASAA’s REIT Guideline proposal include:

  • A uniform concentration limit of 10 percent of an individual’s liquid net worth, applicable to their aggregate investment in a REIT, its affiliates, and other non-traded REITs. Liquid net worth consists of cash, cash equivalents, and readily marketable securities.
  • The proposal also includes a carve-out for Accredited Investors under the income and net worth standards set forth in Regulation D, Rule 501.

Final comments are due to NASAA on or before September 12, 2016.  An IPA task force has been actively engaged on this issue, and expects to finalize our comment letter in the days ahead.  We will be communicating our position to Membership in the event that member firms wish to supplement their own comments and/or support the IPA position.

The IPA will continue to keep our members informed as we move forward on this critical initiative.

Thank you,
Anthony Chereso
President and Chief Executive Officer
Investment Program Association