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ADISA Submits Comments to the Ohio Division of Securities regarding Rule 1301:6-3-09 Registration by Qualification

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Earlier this week, ADISA submitted comments to the Ohio Division of Securities regarding its proposal on registration by qualification. ADISA appreciates the Division’s continuing openness to hearing from industry members impacted by the proposal and submits the following thoughts on the proposal for the Division’s consideration.

  1. The proposed limitation on illiquid or restricted securities; and
  2. Proposed advertising guidelines.

ADISA supports efforts to ensure that investment programs of all kinds, and especially those pertaining to non-exchange listed REITs and BDCs, employ sales materials that are clear, comprehensive, and helpful to investors. Toward that end, the principles that the Division is proposing to put into its regulations aim to achieve similar if not the same goals. ADISA can say on behalf of its members that it is important to provide as much guidance and color around these requirements as is possible. ADISA recommends that the Division publish FAQs that reflects its views on the issues presented by these guidelines, and to get and incorporate feedback from the industry.

The letter, drafted by ADISA’s Legislative & Regulatory Committee Co-Chairs John Grady, ABR Dynamic Funds, and Catherine Bowman, The Bowman Law Firm, was signed by ADISA President Michael Underhill.

Read the letter in its entirety here.