NASAA Proposals
November 1, 2018
Notice of Request for Public Comment Regarding Updates to the SCOR Statement of Policy and the SCOR Form (FORM U-7)
September 23, 2018
Proposed IA Model Rule for Information Security and Privacy Under the Uniform Securities Acts of 1956 and 2002
Comment Letters
- Tamara Salmon, Associate General Counsel, Investment Company Institute, October 2, 2018
- David Bellaire, Executive Vice President and General Counsel, Financial Services Institute, November 26, 2018
- Mark Quinn, Director of Regulatory Affairs, Cetera Financial Group, November 26, 2018
- Max Schatzow, Stark & Stark Attorneys at Law, November 26, 2018
July 19, 2018
Notice of Request for Public Comments Regarding a Proposed Model Rule to Designate Nationally Recognized Securities Manuals for Purposes of the Manual Exemption and a Proposed Model Rule to Exempt Secondary Trading in Securities Issued by Regulation A-Tier 2 Issuers
Comment Letters
- Mary Frances Knight, Chief Operating Officer, StartEngine Crowdfunding, Inc., August 16, 2018
- Douglas S. Ellenoff, Co-founder; James P. Dowd, Co-founder; Sherwood Neiss, Co-founder; GUARRD, Inc., August 20, 2018
- Ryan M. Feit, Chief Operating Officer and Co-founder, SeedInvest, LLC, August 20, 2018
- Andrew Stephenson, Chief Product Officer, CrowdCheck, Inc., August 20, 2018
- Daniel Zinn, General Counsel, OTC Markets Group, Inc OTC-Markets-Group., August 20, 2018
June 12, 2018
Notice of Request for Public Comment: Proposed New State Cover Sheets to Franchise Disclosure Documents
Comment Letters
- Corporon & Katz, LLC, July 14, 2018
- Cheng Cohen LLC, July 13, 2018
- John D. Holland, Dady & Gardner. P.A., July 3, 2018
- Michael J. Katz, Corporon & Katz LLC, July 13, 2018
- Oklahoma Securities Department, July 13, 2018
- Christina Noyes, Gust Rosenfeld PLC, July 13, 2018
- Gray, Plant, Mooty & Bennett, P.A., July 12, 2018
- Brian N. McMahon, Shumaker, Loop & Kendrick, LLP, July 6, 2018
- Larkin, Hoffman, Daly & Lindgren, Ltd., July 5, 2018
December 18, 2017
Notice of Request for Public Comments Regarding Proposed Revisions to NASAA Corporation Finance Statements of Policy
December 7, 2016
Notice of Request for Public Comment Regarding a Proposed Model Statute, a Proposed Model Rule, and a Proposed Solicitation of Interest Form to Permit Testing The Waters in Regulation A Tier 1 Offerings
Comment Letters
October 3, 2016
Notice of Request for Public Comments on a Proposed Statement of Policy Regarding the Use of Electronic Offering Documents and Electronic Signatures
Comment Letters
- Anthony Chereso, President & CEO, Investment Program Association, December 8, 2016
- Mike Bendix, President, Alternative & Direct Investment Securities Association, November 2, 2016
- Pam Guerry, Executive Vice President, Signix, November 2, 2106
- Mary Ann Hanke and Nicole Iannarone, Georgia State University College of Law Investor Advocacy Clinic, November 2, 2016
- Seth Hertlein, Senior Counsel, FS Investments, November 2, 2016
- Thomas Lawson, Vice President, Folio Investing, October 3, 2016
September 14, 2016
Notice of Request for Comments Regarding a Proposed Franchise Commentary on Financial Performance Representations
Comment Letters
- Lane J. Fisher, Fisher Zucker, October 13, 2016
- Gardere Wynne Sewell LLP, October 13, 2016
- Gray, Plant, Mooty, Mooty & Bennett, P.A.’s Franchise Practice Group, October 13, 2016
- Beata Krakus, Greensfelder, Hemker & Gale, P.C., October 13, 2016
- Kristy L. Zastrow Attorney Dady & Gardner, P.A., October 13, 2016
July 27, 2016
Proposed Amendment to the NASAA Statement of Policy Regarding Real Estate Investment Trusts
Comment Letters
- Steven A. Weschler, President & CEO, National Association of Real Estate Investment Trusts
- A. Sidney Browning, Managing Partner, Chief Executive Officer Integras Partners
- Martin A. Hewitt, Chair, Committee on the State Securities Regulation, American Bar Association,
- William F. Galvin, Massachusetts Secretary of the Commonwealth
- Daniel Wildermuth, CEO, Kalos Financial, Inc.
- Rushelle Bailey, Kaela Dahan and Elizabeth Goldman, Cardozo School of Law
- Andres Gil, Director, Center for Capital Markets Competitiveness, U.S. Chamber of Commerce
- Kirk A. Montgomery, Head of Regulatory Affairs, CNL Financial Group, Inc.
- William A. Jacobson, Esq. and Christina M. Kim, Cornell Securities Law Clinic,
- Michael F. Gerber, Executive Vice President; Stephen S. Sypherd, General Counsel; and Seth A. Hertlein, Senior Counsel; FS Investments,
- Robin Traxler, Esq., Vice President, Regulatory Affairs & Associate General Counsel, Financial Services Institute,
- Anthony J. Chereso, President & CEO, Investment Program Association
- Charles J. Schreiber, Jr., Chief Executive Officer, KBS Capital Advisors
- Craig J. McCann, Securities Litigation & Consulting Group
- Brian J. Henderson, Assistant Professor of Finance, The George Washington University
- Marnie C. Lambert, PIABA Executive Vice President/President‐Elect, Chair of NASAA Committee, Public Investors Arbitration Bar Association
- Mike Bendix, President, Alternative & Direct Investment Securities Association
- Michael A. Pagano, Executive Vice President, Compliance, Legal and Risk Assessment, 1st Global
- Keith King, Brendan Lee, Christine Lazaro, Esq.; St. John’s University School of Law Securities Arbitration Clinic
