REISA Submits Potential Topics to Add/Revise to NASAA REIT Guidelines

Sep 12, 2014

On Sept, 12, REISA's Legislative & Regulatory Committee submitted potential topics to add/revise to NASAA REIT Guidelines, in response to NASAA's Direct Participation Programs Policy (the "Policy Group") request for comments on the 33 items listed in the "NASAA REIT Guidelines: Potential Topics to Add/Revise" (the "Proposal").

REISA has the following comments and/or observations regarding the Proposal. To the extent that certain provisions were contained in the Proposal but not contained in REISA’s comments below, REISA either believes such changes are noncontroversial and/or are a welcome update. However, REISA still reserves the right to comment once the language of the proposed guidelines has been provided for public comment. 

REISA’s Legislative & Regulatory Committee 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 letter was signed by REISA President Mark Kosanke, Concorde Investment Services.

Read the full letter here.