Skip to main content

IAA Comments on NASAA’s Proposed REIT Guidelines

September 20, 2022

On September 13, the IAA submitted a letter to the North American Securities Administrators Association (NASAA) in response to proposed revisions to their statement of policy on non-traded real estate investment trusts (REITs). Among other things, the revisions would amend the standards of conduct to incorporate Reg BI and impose a new concentration limit on investments in these REITs.

The IAA calls on NASAA to (i) clarify that it is not seeking, directly or indirectly, to impose conduct standards on SEC-registered advisers – which it is preempted from doing under federal law – and (ii) make changes to the proposal to ensure that SEC-registered advisers, as well as registered and private funds, are not directly or indirectly subject to any concentration limit.

You are now leaving Investment Adviser Association

The IAA provides links to web sites of other organizations in order to provide visitors with certain information. A link does not constitute an endorsement of content, viewpoint, policies, products or services of that web site. Once you link to another web site not maintained by the IAA, you are subject to the terms and conditions of that web site, including but not limited to its privacy policy.

You will be redirected to

Click the link above to continue or CANCEL