Simpson Thacher Authors Comment Letter on Proposed Revisions to NASAA Statement on Policy Regarding Real Estate Investment Trusts
09.15.22
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Simpson Thacher recently submitted a comment letter detailing proposed revisions (the “Proposal”) to the North American Securities Administrators Association (“NASAA”) Statement on Policy Regarding Real Estate Investment Trusts. The letter encourages NASAA to consider potential modifications to the Proposal, in particular with regard to concentration limits on individual investor portfolios in non-traded REITs. The firm argued that the Proposal would impose arbitrary limits on retail investors, interfere with private contractual relationships between investors and their financial professionals and violate federal law in certain respects, and further that the Proposal could create unintended consequences resulting in diminished investor protections. The letter was primarily drafted by Partners Rajib Chanda and Benjamin Wells, Counsel Daniel Honeycutt, and Associates Meredith Abrams and Alexa Shockley.
To read the full letter, please click here.