All: Issues & Advocacy

The Federal Arbitration Act and Access to Justice: Will Recent Supreme Court Decisions Undermine the Rights of Consumers, Workers, and Small Businesses?

December 17, 2013–Written statement of Mike Rothman, Commissioner of the Minnesota Department of Commerce on behalf of the North American Securities Administrators Assocation (NASAA) before the Senate Judiciary Committee issued as part of a hearing on the Federal Arbitration Act.

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The JOBS Act at a Year and a Half: Assessing Progress and Unmet Opportunities

October 30, 2013–Written testimony of NASAA Deputy General Counsel Rick Fleming, delivered to the Senate Banking Subcommittee on Securities, Insurance and Investment providing an overview of the current status of NASAA’s work in designing a new multi-state review process for offerings conducted under Title IV of the JOBS Act, including a one-stop, filing process for “Regulation A+” and to offer NASAA’s views on Title II of the JOBS Act, which lifted the long-standing ban on general solicitation, Title III’s crowdfunding provisions and NASAA’s views of the SEC’s proposed rules and other JOBS Act-related issues.

Issues & Advocacy, Legislative Activity, Testimony Read more

Legislation to Further Reduce Impediments to Capital Formation

October 23, 2013 – Written testimony of NASAA Past President and Arkansas Securities Commissioner A. Heath Abshure Arkansas, delivered to the House Committee on Financial Services Subcommittee on Capital Markets and Government Sponsored Enterprises, providing NASAA’s views on various capital formation proposals informally referred to “JOBS Act 2.0”.

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Notice of Request for Public and Internal Comment: Proposed Changes to Model Custody and Recordkeeping Rules Under the Uniform Securities Acts of 1956 and 2002 To Clarify Requirements Relating to Inadvertent Custody of Client Funds

The Board of Directors of the North American Securities Administrators Association, Inc. (“NASAA”) has authorized release for internal and public comment the following proposed changes to Model Rules 102(e)(1)-1 and 203(a)-2 under the Uniform Securities Act of 1956 and Model Rules USA 2002 411(c)-1 and USA 2002 411(f)-(1) under the Uniform Securities Act of 2002 […]

All Comment Letters, Issues & Advocacy, Legal Activity, NASAA Proposals, Regulatory Activity, Regulatory Comment Letters, Request for Comment Read more

Notice of Request for Public Comment: Proposed Changes to Performance Fee Model Rules Under the Uniform Securities Acts of 1956 and 2002

The Board of Directors of the North American Securities Administrators Association, Inc. (“NASAA”) has authorized release for public comment the following proposed changes to Model Rule 102(f)-3 under the Uniform Securities Act of 1956 and Model Rule  502(c) under the Uniform Securities Act of 2002 (“the performance fee model rules” or “the Model Rules”). Public […]

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The JOBS Act: The Importance of Prompt Implementation for Entrepreneurs, Capital Formation, and Job Creation

September 13, 2012 – Written statement of NASAA President Heath Abshure, provided to the House Financial Services Subcommittee on Capital Markets and the House Oversight Subcommittee on TARP, Financial Services, and Bailouts, outlining NASAA’s views on the current status of rulemakings under JOBS Act Titles II (General Solicitation and Advertising in Rules 506/144A), III (Crowdfunding) and IV (Regulation A+) of the Act issued as part of a hearing on JOBS Act implementation.

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H.R. 4624, the Investment Adviser Oversight Act of 2012

June 6, 2012 – Written testimony of Texas Securities Commission John Morgan, delivered before the House Financial Services Committee, outlining NASAA’s opposition to H.R. 4624, the Investment Advisor Oversight Act of 2012.

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Notice of Request for Public Comment: Proposed Model Franchise Exemptions

NASAA’s Franchise and Business Opportunity Project Group (the “Franchise Project Group” or “Project Group”) is rereleasing for comment from interested persons proposed changes to NASAA’s Model Franchise Exemptions (the “Model Exemptions”).  In response to a previous solicitation for comment, NASAA received a total of six (6) public comments regarding various provisions in the Model Exemptions.  […]

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Letter of Support for S. 1907, the PCAOB Enforcement Transparency Act of 2011

December 21, 2011 The Honorable Tim Johnson Chairman Senate Committee on Banking, Housing, & Urban Affairs 534 Dirksen Senate Office Building Washington, DC 20510  The Honorable Richard ShelbyRanking MemberSenate Committee on Banking,Housing, & Urban Affairs534 Dirksen Senate Office BuildingWashington, DC 20510 Dear Chairman Johnson and Ranking Member Shelby: On behalf of the North American Securities Administrators Association (NASAA) I amwriting […]

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Spurring Job Growth Through Capital Formation While Protecting Investors

December 1, 2011 – Written testimony of NASAA President Jack Herstein, delivered to the Senate Committee on Banking, Housing, and Urban Affairs, outlining NASAA’s position that the states are best positioned to oversee small business capital formation, including crowdfunded offerings.

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