
The North American Securities Administrators Association (NASAA) recently proposed revisions to their Statement of Policy Regarding Real Estate Investment Trusts (REIT Guidelines). This proposal will affect not only real estate, but credit and other portfolio diversifying investments. NASAA’s proposal would limit the ability of investors to diversify their portfolios, particularly at a time of market volatility and high inflation. It would impair access to this popular inflation hedge; unduly restrict investment in federally-regulated products; and place a heavy burden and conflicting conduct standards on sponsors, broker-dealers and investment advisers. We must take action and voice our concerns to emphasize the important role of portfolio diversifying investments for investors, business owners, retirement savers and the broader economy.

PROPOSAL
NOTICE OF REQUEST FOR PUBLIC COMMENT ON PROPOSED REVISIONS TO THE UNIFORM APPLICATION TO REGISTER SECURITIES (FORM U-1)
September 22, 2022
Deadline for Public Comment: October 22, 2022
PROPOSAL
PROPOSED REVISIONS TO NASAA STATEMENT OF POLICY REGARDING REAL ESTATE INVESTMENT TRUSTS
July 12, 2022
Deadline for Public Comment: September 12, 2022


IPA Submits Comment Letter on NASAA’s Proposed Revisions to the Form U-1
Governor Douglas A Ducey: NASAA REIT Proposal Comment Letter
IPA Submits Comment Letter to NASAA on Proposed Revisions to REIT Guidelines
Robert H. Bergdolt: NASAA REIT Proposal Comment Letter
Simpson Thatcher & Bartlett: NASAA REIT Proposal Comment Letter
Inland Investments: NASAA REIT Proposal Comment Letter
LaSalle Investment Management: NASAA REIT Proposal Comment Letter
TIAA and Nuveen: NASAA REIT Proposal Comment Letter
U.S. House of Representatives: NASAA REIT PROPOSAL Comment Letter
Ohio Chamber of Commerce: NASAA REIT Proposal Comment Letter
U.S. House of Representatives: NASAA REIT Proposal Comment Letter
Ohio Business Roundtable: NASAA REIT Proposal Comment Letter
Ares Wealth Management Solutions: NASAA REIT Proposal Comment Letter
Blackstone Real Estate Income Trust (BREIT): NASAA REIT Proposal Comment Letter
Robert A. Stanger, Inc: NASAA REIT Proposal Comment Letter
Brookfield Asset Management: NASAA Proposal Comment Letter
California Business Roundtable: NASAA REIT Proposal Comment Letter