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The IAA files comments on NASAA proposal on non-traded REITs and objects to applying the concentration limit to federal covered advisers; re-proposal follows NASAA’s 2022 proposal that was not adopted.
The IAA recommended that NASAA streamline the continuing education process and decrease the amount of required continuing education. The IAA also requested that final requirements be principles-based, flexible and reasonable, and should permit investment adviser representatives to tailor their training to their specific needs.
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