NASAA Proposals
July 29, 2025
Notice of Request for Public Comment Regarding Proposed Amendments to the Investment Adviser Advertising Rules
July 28, 2025
Notice of Request For Public Comment Regarding a Proposed NASAA Model Franchise Broker Registration Act
March 25, 2025
Notice of Request for Public Comment on Proposed Amendments to the NASAA Statement of Policy Regarding Real Estate Investment Trusts
16 Comment Letters
- Formatted Comment Letter (as of the close of the comment period on May 28, 2025, we received 13 comment letters in this or a substantially similar format)
- Robin M. Traxler, Senior Vice President, Policy & Deputy General Counsel, Financial Services Institute, June 2, 2025
- American Investment Council, American Securities Association, Coalition for Business Development, Defined Contribution Real Estate Council, Financial Services Institute, ICSC, Institute for Portfolio Alternatives, Insured Retirement Institute, Investment Company Institute, Money Management Institute, Nareit, National Association of Insurance and Financial Advisors, SIFMA, SIFMA Asset Management Group, U.S. Chamber of Commerce, May 28, 2025
- Blackstone Real Estate Income Trust, Inc., May 28, 2025
- Gail C. Bernstein, General Counsel and Head of Public Policy, and Monique S. Botkin, Associate General Counsel, Investment Adviser Association, May 28, 2025
- Althea Brown, Group Managing Director and Chief Legal Officer, LPL Financial, LPL Financial Holdings, May 28, 2025
- Anya Coverman, President and CEO, Institute for Portfolio Alternatives, May 28, 2025
- Seth A. Miller, General Counsel, President, Advocacy & Administration, Cambridge Investment Research, Inc., May 28, 2025
- Mark Quinn, Director of Regulatory Affairs, Cetera Financial Group, Inc., May 28, 2025
- Securities Industry and Financial Markets Association and the Asset Management Group of the Securities Industry and Financial Markets Association, May 28, 2025
- Simpson Thacher & Bartlett LLP, May 28, 2025
- C. Allan Swaringen, Chair, Nareit Public Non-Listed REIT Council, President & CEO, JLL Income Property Trust, Inc., National Association of Real Estate Investment Trusts, May 28, 2025
- Adam Woodworth, Colorado Financial Service Corporation, May 28, 2025
- John H. Grady, President, The Alternative & Direct Investment Securities Association, May 27, 2025
- Robert A. Stanger & Company, Inc., May 16, 2025
- JLL Income Property Trust, Inc. and LaSalle Investment Management, Inc., May 13, 2025
November 4, 2024
Notice of Request for Public Comment Regarding Proposed Revisions to NASAA’s Dishonest or Unethical Business Practices of Broker-Dealers and Agents Model Rule
21 Comment Letters
- Formatted Comment Letter (As of the close of the comment period on December 19, 2024, we received 636 comment letters in this or a substantially similar format.
- Althea Brown, Chief Legal Officer, LPL Financial, December 19, 2024
- Board of Directors for the Independent Association of Fetch Pet Care, December 19, 2024
- Chad Carlson, December 18, 2024
- Kevin M. Carroll, Deputy General Counsel, SIFMA, December 19, 2024
- Anya Coverman, President & CEO, Institute for Portfolio Alternatives, December 19, 2024
- Lynn Dudley, Senior Vice President, Global Retirement and Compensation Policy, December 19, 2024
- Eversheds Sutherland (US) LLP for the Committee of Annuity Insurers, December 19, 2024
- Adam Gana, President, Public Investors Advocate Bar Association, December 19, 2024
- Jessica R. Giroux, General Counsel, American Securities Association, December 19, 2024
- Donna H. Green, December 19, 2024
- The GSFOA Interim Board of Directors, December 18, 2024
- Micah Hauptman, Director of Investor Protection, Consumer Federation of America, December 6, 2024
- Michael Kitces, MSFS, MTAX, CFP, CLU, ChFC, Co-Founder, Executive Chairman, XY Planning Network michael@xyplanningnetwork.com, and Lauren Loney, Esq., Public Policy Counsel, Financial Planning Association, December 18, 2024
- Erin Koeppel, Esq., Managing Director, Government Relations and Public Policy Counsel, CFP Board; Lauren Loney, Esq., Public Policy Counsel, Financial Planning Association; Kathryn Dattomo, MNA, CAE, CFRE, Chief Executive Officer, National Association of Personal Financial Advisors, December 20, 2024
- Kent A. Mason, Davis & Harman LLP, December 18, 2024
- Jade Miller, President, Alternative and Direct Investment Securities Association, December 5, 2024
- Mark Quinn, Director of Regulatory Affairs, Cetera Financial Group, December 19, 2024
- St. Vincent De Paul Legal Program, Inc., Securities Arbitration Clinic, St. John’s University School of Law, December 19, 2024
- Robin Traxler, Senior Vice President, Policy & Deputy General Counsel, Financial Services Institute, December 19, 2024
- Sarah Wood Director, State Policy & Regulatory Affairs, Insured Retirement Institute, December 19, 2024
September 3, 2024
Notice of Request for Public Comment on Proposed Clarifications to the NASAA Broker-Dealer EVEP Rules
May 13, 2024
Notice of Request for Public Comment on Proposed NASAA Model Franchise Broker Registration Act
135 Comment Letters
- Formatted Comment Letter (As of the close of the comment period on June 13, 2024, we received 100 comment letters in this or a substantially similar format.)
- Scott Abbott, CEO, Five Star Franchising, June 11, 2024
- John Anderson, President, Lakeport Franchise Group, June 13, 2024
- Wayne Angel, Founder and Owner, Franchise Angels, LLC, June 13, 2024
- Josh Arnold, President, Card My Yard, June 12, 2024
- Andrew D. Aronson, CFB, FSC, Franchise Logistics, LLC, June 14, 2024
- Jania Bailey, President, FranNet LLC, June 13, 2024
- Kathryn Baker, June 13, 2024
- Katie A. Baker, June 13, 2024
- Charista Baye and Kevin Kohler, Co-owners, Thoughtful Franchise Brokers
- Cale Bearden, June 14, 2024
- Gino Beccherini, Franchise Broker, June 13, 2024
- Anita Best, President, Find Your Franchise, Inc.
- David and Emma Blackwell, June 13, 2024
- Lara Breuche, Premier Martial Arts (PMA) franchisee, June 9, 2024
- Lara Breuche, June 9, 2024
- Rob Cambruzzi and Nick Sheehan, Rep’m Group, June 13, 2024
- Craig Campbell, Senior Franchise Consultant, The You Network, June 12, 2024
- Marc Camras, President, MVision Consulting, LLC, June 13, 2024
- Janice Charles, Franchise Succeed
- Mike Chiodo, June 13, 2024
- Brandon Clifford, CEO, Business Alliance Inc., June 12, 2024
- Brian H. Cole, Certified Specialist, Franchise and Distribution Law, The State Bar of California Board of Legal Specialization, June 13, 2024
- Brenan Compretta, President, Beacon Franchise Brokers, June 13, 2024
- David Costello, RockWater Group | KW Commercial | Franchise Broker Inc., June 13, 2024
- Don Daszkowski, Founder and CEO IFPG, International Franchise Professionals Group
- Sarah Davies, General Counsel, International Franchise Association, June 13, 2024
- Dan Durney, CFE, Director of Franchise Development, Assisting Hands Home Care, June 13, 2024
- Vin DuVerger, 434 Franchise Consulting, June 13, 2024
- Bill Eastin, Franchise Broker, June 13, 2024
- Jeff Elgin, CEO, FranChoice, Inc., June 6, 2024
- Tim Ellisor, Premier Martial Arts franchisee, June 13, 2024
- Joseph Feicht, June 13, 2024
- Stefan Figley, President, 1-800-Packouts
- Sylvester Ford, President, Black Label Franchise, June 13, 2024
- Tamika Franklyn, FBA Broker, Precision Franchise LLC, June 13, 2024
- Tamika Franklyn
- Edward Freeman, July 26, 2024
- Rob Friend, Managing Partner and Owner, FranchisEdge LLC, June 13, 2024
- Dion Garnett President Gnet Holdings LLC DBA Franchise Sells
- Chris George, Senior Broker, Franchise Maverick, LLC, June 13, 2024
- Carey Gille, CEO, and Don Tarinelli, Executive VP of Development, Franchise Fast Lane
- Natalie Gillquist – Franchise Broker, Aspect Collaborative LLC, June 14, 2024
- Doug Grant, CEO and Co-founder, Franchise Options LLC, June 13, 2024
- Dan Guth, Agent, Quantum Franchise Group, June 13, 2024
- Daniel Guth, Quantum Franchise Group, June 13, 2024
- Robert Haar, President, Best Franchise Options, LLC, June 13, 2024
- R Lance Hood, Managing Member, ARC Franchising LLC, June 13, 2024
- William Huffhine, President, Quantum Franchise Group, June 13, 2024
- Patrick Hyland, Franchise Owner – Scenthound, June 12, 2024
- Danessa Itaya, President, Bio-One, June 12, 2024
- Leslie Johnson, Tailored Business Consulting
- Mark Johnson, Tailored Business Consulting
- William Johnson, June 12, 2024
- Michael Judkins, Chief Operating Officer, Franchise Sidekick, June 12, 2024
- Debra Kattler, Franchise Broker, Fearless Franchising, June 13, 2024
- Bill Keely, Certified Franchise Consultant, Honor Franchising, June 13, 2024
- Cindy Kennedy, President, Flawless Franchising, LLC, June 13, 2024
- Ralph Keyslay
- Farha Khaja, President, FranByte Business Consulting, LLC, June 13, 2024
- Bill King, June 13, 2024
- Bill King, Axxiom Franchise Advisors, LLC, June 13, 2024
- Scott Kubec, COO, System4
- Eris Lasku, June 13, 2024
- Rich LeBrun, CEO, CFB, CCIM, LeBrun Advisory Group, May 21, 2024
- Rich LeBrun CEO, CFB, CCIM, LeBrun Advisory Group, May 21, 2024
- Warren Lee Lewis, Ackerman LLP, June 13, 2024
- Morris Lifschutz, June 13, 2024
- Ken Lineberger, President, Waters Edge Wineries, June 13, 2024
- Paul Linenberg, President, Gotcha Covered
- Shawn Livingston, Franchise Broker, Wolfhound Franchise Solutions
- Shawn Livingston, Franchise Broker and Consultant, Wolfhound Franchise Solutions, June 13, 2024
- Keith P. Liscio, President, Excelsior Franchise Center, June 13, 2024
- Kirk Loard, Founder / Broker, Franchise Sense, June 13, 2024
- Jennifer Lucas, Co-Founder, The Franchising Company
- Matt Lucas, Co-Founder, The Franchising Company
- Sumit Madan, Vishnu Franchise Brokers, June 13, 2024
- Curt M. Maier, Owner & President, Maier & Associates, LLC, June 13, 2024
- Victor Marshall, June 12, 2024
- Andrew McNall, PhD, Chief Operating Officer, NexGenEsis Healthcare, LLC, June 13, 2024
- Sean McNally, Boston Black Belt Corporation, June 13, 2024
- Calvin McNeely, Owner/Advisor, ReWired Franchise Advisors, LLC, June 13, 2024
- Karol Mercurio, Franchise Consultant, June 12, 2024
- Nathan Millhouse, MBA, Chief Sales & Development Officer, NexGenEsis Healthcare, LLC, June 13, 2024
- Rick Morgin, Consultant, The Franchise Consulting Company, June 13, 2024
- Jim Nail, June 13, 2024
- Tyler Nay, June 13, 2024
- Nicholas Neonakis, CEO, The Franchise Consulting Company, Inc., June 12, 2024
- Jeff Nichols, President and Owner, Franchise4U, June 13, 2024
- Colleen O’Brien, Owner, Franchise for You Consulting, Inc.
- Sabrina Panfilo, CFE, Broker / Consultant, Integrity Franchise Group, June 13, 2024
- Mo Pandoria, Founder and CEO, IDOLIZE Franchising LLC, June 13, 2024
- Daphne Pappas, Registered Consultant, KPO Limits, June 13, 2024
- Mark Pasma CEO & Founder Franchising101.com
- Mike Perez, Trailblazer Franchising, June 13, 2024
- Kim Perrotta, WorldWise Franchise Development
- Stacey & Eric Petrosevich, June 13, 2024
- Mike Pollock, June 14, 2024
- Ann Power, Consultant, The Franchise Consulting Company, June 14, 2024
- Michael Pollock, President, E-Authority Inc., dba FranLift, June 13, 2024
- Joshua and Kimberly Ragland, June 11, 2024
- Maria Rogers, Franchise Broker, FranMent, June 12, 2024
- Scott Rubant, June 13, 2024
- Cecelia J. Runyon, Franchise Consultant, Integrity Franchise Group, June 13, 2024
- Jaime Sanchez, CEO, Interlink FBC, June 13, 2024
- Cary Schneider, Pinnacle Franchise Brokers, June 13, 2024
- Gino Scialdone, CEO, American Recruiters Enterprises, Inc., June 12, 2024
- Stacie Shannon, Fusion Franchising
- Peter and Michelle Silberman, June 12, 2024
- Bryan Smith, Vice President, GradePower Learning, June 21, 2024
- Ewell Smith, Smith Strategies, LLC
- Edna Spearman, Franchise Broker, June 13, 2024
- Max Staplin, Senior Attorney, Fisher Zucker LLC, June 13, 2024
- Steve Sparks, Franchise Broker/Consultant, The Franchise Consulting Company, Inc.
- Scott Steele, June 12, 2024
- Scott Steele, June 13, 2024 (Reference – Video Links)
- John Stopoulos, President, Perfect Choice Franchising, June 13, 2024
- Matt Sullivan, Owner, Express Employment Professionals of Green Bay, June 12, 2024
- Carson Suppé, Director of Franchise Development, Enviro-Master International Franchise
- Alicyn Taft, June 14, 2024
- Shane Taylor, Premier Martial Arts franchisee, June 11, 2024
- Brent and Melissa Thibeaux, June 13, 2024
- Brad Thomas, Franchise Empowerment, LLC, June 13, 2024
- Brad Thomas, Franchise Empowerment, LLC, June 13, 2024
- Chris Tucker, Broker, Quantum Franchise Group, June 13, 2024
- Alesia Visconti, CEO and President, FranServe Inc., June 12, 2024
- Alesia L. Visconti, CFE, CAFC, CFC, CEO & President, FranServe Inc., June 13, 2024
- Sabrina Wall, CEO, Franchise Brokers Association, June 13, 2024
- Graham Waters, Owner, PMA of South Boston, LLC, June 13, 2024
- Michael Wedge, MW Franchises, Inc.
- Lisa Welko, Integrity Franchise Group
- David Whalen, Founder, Visionary Broker, June 13, 2024
- Angela Yi, Franchise Development Agent, Quantum Franchise Group, June 14, 2024
- Colette Young, June 13, 2024
- John A. Zelenika, Capstone Franchise Advisors
January 4, 2024
Notice of Request for Public Comment Regarding Proposed Amendments to NASAA Model Rule Exempting Certain Merger & Acquisition Brokers (“M&A Brokers”) from Registration
1 Comment Letter
September 5, 2023
Notice of Request for Public Comment Regarding Proposed Revisions to NASAA’s Dishonest or Unethical Business Practices of Broker-Dealers and Agents Model Rule
50 Comment Letters
- Formatted Comment Letter (As of the close of the comment period on December 4, 2023, we received seven comment letters submitted in this format.)
- Trent Mohn, September 13, 2023
- Kent A. Mason, Davis & Harman LLP, October 13, 2023
- Tom Ripperda, November 14, 2023
- Luke Fuszard, November 15, 2023
- Jason Rae, President & CEO, Wisconsin LGBT Chamber of Commerce, November 20, 2023
- Bob Gibbs, US Congressman, Retired, November 21, 2023
- Sherill Whisenand, November 25, 2023
- Gil Baumgarten, President, Segment Wealth Management, November 27, 2023
- Brett Lindstrom, November 27, 2023
- Allen W. Kerr, President, Allen Kerr Advisors, November 29, 2023
- John Morrow, Wellsville City Councilmember, and Former Wellsville School Board Member, Former, November 29, 2023
- Charles Blasdel, The Blasdel Group, November 30, 2023
- Brandon Rickman and John Sheley, Home Builders Association of Middle Tennessee, November 30, 2023
- State Senator Beau Ballard, Nebraska State Legislature, December 1, 2023
- Matthew Benchener, Managing Director, Personal Investor, Vanguard Group, Inc., December 1, 2023
- Kevin M. Carroll, Deputy General Counsel, Securities Industry and Financial Markets Association, December 1, 2023
- Gregg Connell, Executive Vice President, Shenandoah Chamber & Industry Association, December 1, 2023
- Derwin Jackson, President & CEO, Franklin Housing Authority, December 1, 2023
- Karen Kerrigan, President & CEO, Small Business & Entrepreneurship Council, December 4, 2023
- Shawntell Kroese, December 1, 2023
- Longview Chamber of Commerce (East Texas), December 1, 2023
- Dorsey Ridley, December 1, 2023
- Tyler Riebhoff, December 1, 2023
- Anne Tennant, General Counsel, Morgan Stanley Wealth Management, December 1, 2023
- Sarah Wood, Director, State Policy & Regulatory Affairs, Insured Retirement Institute, December 3, 2023
- Althea Brown, Chief Legal Officer, LPL Financial, December 4, 2023
- American Council of Life Insurers, American Securities Association, Coalition for Business Development, Defined Contribution Alternatives Association, Defined Contribution Real Estate Council, Financial Services Institute, Finseca, Florida Securities Dealers Association, Institute for Portfolio Alternatives, Insured Retirement Institute, National Association of Insurance and Financial Advisors, Nareit, Ohio Chamber of Commerce, Securities Industry & Financial Markets Association, The Real Estate Roundtable, US Chamber of Commerce, December 4, 2023
- Anya Coverman, President and CEO, Institute for Portfolio Alternatives, December 4, 2023
- Scott Curtis, President, Private Client Group, Raymond James Financial, Inc., December 4, 2023
- Lynn Dudley, Senior Vice President, Global Retirement and Compensation Policy, American Benefits Council, December 4, 2023
- Eversheds Sutherland (US) LLP for the Committee of Annuity Insurers, December 4, 2023
- Daniel M. Gallagher, Chief Legal and Corporate Affairs Officer, Robinhood Financial LLC, December 4, 2023
- Casey Galligan, Co-Chief Executive Officer, Ares Wealth Management Solutions, LLC, December 4, 2023
- Andrew Hartnett, Deputy Commissioner for Securities, Iowa Insurance Division, Doug Ommen, Commissioner, Department of Insurance and Financial Services, and Vicki Schmidt, Commissioner, Kansas Insurance Department, December 4, 2023
- State Senator Ricky Hill, Chair of the Arkansas Senate Insurance & Commerce Committee, December 4, 2023
- Christopher A. Iacovella, President & Chief Executive Officer, American Securities Association, December 4, 2023
- Fairbridge Investor Rights Clinic, Elisabeth Haub School of Law at Pace University, December 4, 2023
- Mario H. Lopez, President, Hispanic Leadership Fund, December 4, 2023
- State Representative John Maddox, Chairman of the Arkansas House Insurance & Commerce Committee, December 4, 2023
- Kristen Malinconico, Director, Center for Capital Markets Competitiveness, U.S. Chamber of Commerce, December 4, 2023
- Jennifer McAdam and Madison Ward, American Council of Life Insurers, December 4, 2023
- Montana Business Leadership Council, December 4, 2023
- Todd O’Hair, President & CEO, Montana Chamber of Commerce, December 4, 2023
- Mark Quinn, Director of Regulatory Affairs, Cetera Financial Group, December 4, 2023
- Securities Arbitration Clinic at St. John’s University School of Law, December 4, 2023
- Charles H. Sturdy, Chief Legal Officer, Fidelity Investments LLC, December 4, 2023
- Robin Traxler, Senior Vice President, Policy & Deputy General Counsel, Financial Services Institute, December 4, 2023
- Michael Underhill, President, Alternative and Direct Investment Securities Association, December 4, 2023
- James Beauchamp, President, Midland-Odessa Transportation Alliance, December 5, 2023
April 26, 2023
Notice of Request for Comment Regarding the Uniform Securities Act Manual Exemption
1 Comment Letter
