Sunday, October 02, 2011

NASAA Proposes to Add Cross-Reference Sheets to Four Registration Guidelines

The North American Securities Administrators Association (NASAA) has released for public comment a proposal to add cross reference sheets in the NASAA Guidelines for the Registration of Asset-Backed Securities, the Registration of Equipment Programs, the Registration of Commodity Pool Programs, and the Registration of Oil and Gas Programs. The stated purpose of the proposal is to aid state securities examiners and issuers filing for registration in complying with the NASAA Guidelines.

Although most sets of NASAA Guidelines define the term “Cross Reference Sheet,” require it to be filed and offer the format of a cross reference, the Guidelines affected by the proposal currently do not. A first time applicant for registration of these securities may be unaware, therefore, of the need to prepare and file a cross reference sheet, which may delay an offering from an initial review.

As stated in the Requests for Public Comment, the proposals will define the term cross reference sheet, require it to be filed upon the request of the Administrator and provide instructions. The proposed cross reference sheets do not add or detract from existing Guideline provisions. Paraphrased terms for the cross reference sheets are not intended to interpret Guideline provisions or offer less compliance to the applicant.

The public comment period will remain open until October 21, 2011. Comments should be to each member of the NASAA Direct Participation Programs Policy Project Group and to the NASAA Legal Department.

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