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Cooley client alert on CA DFPI pause announced on March 17, 2026, that it is suspending implementation and enforcement of the state’s Fair Investment Practices by Venture Capital Companies Law (FIPVCC), commonly referred to as Senate Bill 54, as amended by SB 164.
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 submitted a letter to Nevada expressing appreciation that its revised proposed regulations regarding fiduciary duty includes language clearly stating that the provisions of the regulation would only apply to an SEC Adviser as permitted by the National Securities Markets Improvement Act of 1996 (NSMIA).
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