ADISA believes that the proposed revisions to Rule 1301:6-309 Registration by Qualification to remove the qualifying language used in the accredited investor exemption and remove the waiver form initially proposed to remove the affiliate restriction from the concentration limit policy will be beneficial to investors looking to invest in these types of products and a positive step for issuers looking to raise capital and a welcome change for ADISA’s members.

ADISA also believes that the ability of an issuer to immediately make such changes to its prospectus while the Division works to have these changes formally codified, if approved by CSI and JCARR, will be helpful for ADISA members.

The letter was drafted by ADISA’s Legislative & Regulatory Committee Co-Chairs Deborah Froling, Kutak Rock, and Catherine Bowman, The Bowman Law Firm, and was signed by ADISA President John Grady, ABR Dynamic Funds.

Read the letter in its entirety here.