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REISA Submits Letter in Response to FINRA's Proposed Amendments to NASD Rule 2340

Mar 12, 2014

REISA’s Legislative & Regulatory Drafting Task Force has submitted a letter to the SEC in response to FINRA’s proposed amendments to NASD Rule 2340 – Customer Account Statements – to amend the provisions relating to the inclusion of per share estimated values for publicly registered DPP and REIT securities on customer account statements, as well as modify the requirements applicable to FINRA members’ participation in public offerings of DPP and REIT securities under FINRA Rule 2310 (the Proposed Amendments).
 
REISA believes that while the Proposed Amendments continue to have the right goals in mind, there are some issues with the Proposed Amendments that require some adjustments, as our association remains committed to collectively working to improve the industry from the standpoint of transparency and valuation.
 
REISA’s Legislative & Regulatory Drafting Task Force is comprised of Deborah Froling, Arent Fox; John Grady, National Fund Advisors; Tom Voekler, Kaplan  Voekler Cunningham & Frank; and Darryl Steinhause, DLA Piper. The comment letter was signed by REISA President Mark Kosanke, Concorde Investment Services.
 
Read the full comment letter here.