Notice of Application of the National Association of Realtors for Exemptive Relief Under Sections 15 and 36 of the Exchange Act and Request for Comment, 64688-64694 [E7-22425]
Download as PDF
64688
Federal Register / Vol. 72, No. 221 / Friday, November 16, 2007 / Notices
FOR FURTHER INFORMATION CONTACT:
mstockstill on PROD1PC66 with NOTICES
Elizabeth V. Baltzan, Associate General
Counsel, Office of the United States
Trade Representative, 600 17th Street,
NW., Washington, DC 20508, (202) 395–
3582.
SUPPLEMENTARY INFORMATION: USTR is
providing notice that the DSB has
established, at the request of the EC, a
dispute settlement compliance panel
pursuant to the WTO Understanding on
Rules and Procedures Governing the
Settlement of Disputes (DSU). Such
panel will hold any hearing in Geneva,
Switzerland. It is possible that the
public will be able to observe the
hearing of the panel. If so, then USTR
would intend to provide notice on
USTR’s Web site (under ‘‘Opportunities
to View Dispute Settlement Hearings’’
on the Web page https://www.ustr.gov/
Trade_Agreements/
Monitoring_Enforcement/
Dispute_Settlement/WTO/
Section_Index.html) of the public
hearing and the means by which the
public may observe.
Major Issues Raised by the EC
In the European Communities’ (the
‘‘EC’’) request for the establishment of a
panel in connection with the dispute
United States—Laws, Regulations and
Methodology for Calculating Dumping
Margins (‘‘zeroing’’)—Recourse to
Article 21.5 of the DSU by the European
Communities, the EC challenges the
following:
• The consistency with Articles 17.14
and 21 of the DSU of the dates of entry
into force of the SeCtion 129
determinations issued by the
Department of Commerce to comply
with the recommendations and rulings
of the original proceeding;
• The alleged failure to eliminate
‘‘zeroing’’ in 16 administrative reviews
found, in the original proceeding, to be
inconsistent with U.S. WTO obligations;
the EC alleges that the failure to
eliminate ‘‘zeroing’’ in these reviews is
a breach of Articles 2, 9.3, and 11 of the
Antidumping Agreement and Article
VI:2 of the GATT 1994;
• An alleged miscalculation with
respect to one determination;
• With respect to all measures
identified in the request, the alleged
imposition, collection, or liquidation of
antidumping duties ‘‘inflated’’ by
‘‘zeroing’’ beyond April 9, 2007;
• The increase in the ‘‘all-others’’ rate
in connection with two determinations;
• With respect to original
investigations in which the
recalculation of dumping margins led to
the conclusion that some exporters were
not dumping or had de minimis
margins, the failure to establish whether
VerDate Aug<31>2005
21:48 Nov 15, 2007
Jkt 214001
the remaining amount of dumped
imports was causing injury to the
domestic industry and whether the
volume of dumped imports was not
negligible; and
• The continued use of zeroing in the
reviews related to the measures in
question.
Public Comment: Requirements for
Submissions
Interested persons are invited to
submit written comments concerning
the issues raised in this dispute. Persons
submitting comments may either send
one copy by fax to Sandy McKinzy at
(202) 395–3640, or transmit a copy
electronically to FR0715@ustr.eop.gov,
with ‘‘EC Zeroing (21.5)’’ in the subject
line. For documents sent by fax, USTR
requests that the submitter provide a
confirmation copy to the electronic mail
address listed above.
USTR encourages the submission of
documents in Adobe PDF format, as
attachments to an electronic mail.
Interested persons who make
submissions by electronic mail should
not provide separate cover letters;
information that might appear in a cover
letter should be included in the
submission itself. Similarly, to the
extent possible, any attachments to the
submission should be included in the
same file as the submission itself, and
not as separate files.
A person requesting that information
contained in a comment submitted by
that person be treated as confidential
business information must certify that
such information is business
confidential and would not customarily
be released to the public by the
submitter. Confidential business
information must be clearly designated
as such and the submission must be
marked ‘‘BUSINESS CONFIDENTIAL’’
at the top and bottom of the cover page
and each succeeding page of the
submission.
Information or advice contained in a
comment submitted, other than business
confidential information, may be
determined by USTR to be confidential
in accordance with section 135(g)(2) of
the Trade Act of 1974 (19 U.S.C.
2155(g)(2)). If the submitting person
believes that information or advice may
qualify as such, the submitting person—
(1) Must clearly so designate the
information or advice;
(2) Must clearly mark the material as
‘‘SUBMITTED IN CONFIDENCE’’ at the
top and bottom of each page of the cover
page and each succeeding page; and
(3) Is encouraged to provide a nonconfidential summary of the
information or advice.
PO 00000
Frm 00115
Fmt 4703
Sfmt 4703
Pursuant to section 127(e) of the
URAA (19 U.S.C. 3537(e)), USTR will
maintain a file on this dispute
settlement proceeding, accessible to the
public, in the USTR Reading Room,
which is located at 1724 F Street, NW.,
Washington, DC 20508. The public file
will include non-confidential comments
received by USTR from the public with
respect to the dispute; for the dispute
settlement compliance panel or in the
event of an appeal from such a panel,
the U.S. submissions; the submissions,
or non-confidential summaries of
submissions, received from other
participants in the dispute; the report of
the panel; and, if applicable, the report
of the Appellate Body. An appointment
to review the public file (Docket No.
WT/DS–294) may be made by calling
the USTR Reading Room at (202) 395–
6186. The USTR Reading Room is open
to the public from 9:30 a.m. to noon and
1 p.m. to 4 p.m., Monday through
Friday.
Daniel E. Brinza,
Assistant United States Trade Representative
for Monitoring and Enforcement.
[FR Doc. E7–22451 Filed 11–15–07; 8:45 am]
BILLING CODE 3190–W8–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–56779; File No. S7–26–07]
Notice of Application of the National
Association of Realtors for Exemptive
Relief Under Sections 15 and 36 of the
Exchange Act and Request for
Comment
November 9, 2007
The National Association of Realtors
(‘‘NAR’’) has requested an exemption
pursuant to sections 15(a)(2) and 36(a)
of the Securities Exchange Act of 1934
(‘‘Exchange Act’’) from the broker-dealer
registration requirements of section
15(a)(1) and the reporting and other
requirements of the Exchange Act (other
than sections 15(b)(4) and 15(b)(6)), and
the rules and regulations thereunder,
that apply to a broker or dealer that is
not registered with the Commission.
Subject to the conditions specified in
NAR’s application (‘‘Application’’) and
discussed below, the requested
exemption would permit a licensed real
estate agent or broker who is
predominantly engaged in and has
substantial experience in the
commercial real estate market and the
real estate brokerage firm with which
such agent or broker is licensed to
receive compensation in the form
described below for the sale of a TIC
Security, as defined below.
E:\FR\FM\16NON1.SGM
16NON1
Federal Register / Vol. 72, No. 221 / Friday, November 16, 2007 / Notices
In order to provide an opportunity for
interested persons to comment on the
Application, the Commission is
publishing this notice and request for
comment pursuant to Rule 0–12 under
the Exchange Act. The Commission will
carefully consider all comments
submitted, and, should it determine to
issue an exemption, could eliminate or
add to, or modify, the conditions
discussed below.
Background
Section 15(a)(1) of the Exchange Act
generally requires any broker or dealer
who makes use of the mails or any
instrumentality of interstate commerce
to effect transactions in, or induce the
purchase or sale of, any security to
register with the Commission. Section
3(a)(4)(A) of the Exchange Act generally
defines a ‘‘broker’’ as ‘‘any person
engaged in the business of effecting
transactions in securities for the account
of others.’’ Absent an exemption, a
licensed real estate agent or real estate
broker who receives compensation for
the sale of a TIC Security would be
required to be registered as a broker
with the Commission or to be a
registered associated person of a
registered broker-dealer. Similarly, a
real estate brokerage firm that receives
compensation for the sale of a TIC
Security would be required to register as
a broker-dealer.
Section 15(a)(2) of the Exchange Act
authorizes the Commission to
conditionally or unconditionally
exempt from the broker-dealer
registration requirements of section
15(a)(1) any broker or dealer or class of
brokers or dealers, by rule or order, as
it deems consistent with the public
interest and the protection of investors.1
Similarly, but more broadly, section 36
of the Exchange Act authorizes the
Commission to conditionally or
unconditionally exempt any person,
security, or transaction, or any class or
classes of persons, securities, or
transactions, from any provision or
provisions of the Exchange Act or any
rule or regulation thereunder, by rule,
regulation, or order, to the extent that
such exemption is necessary or
appropriate in the public interest, and is
consistent with the protection of
investors.2
mstockstill on PROD1PC66 with NOTICES
Summary of the Application
NAR requests an exemption to allow
any licensed real estate agent or broker
who is predominantly engaged in and
1 See
2 See
15 U.S.C. 78o(a)(2).
15 U.S.C. 78mm.
VerDate Aug<31>2005
21:48 Nov 15, 2007
Jkt 214001
has substantial experience 3 in the sale
of commercial real estate 4
(‘‘Commercial Real Estate Professional’’)
and the real estate brokerage firm with
which he or she is licensed (‘‘Real Estate
Firm’’) (collectively, a ‘‘RE Participant’’)
to receive a real estate advisory fee
(‘‘Real Estate Advisory Fee’’) from a
purchaser of an undivided tenant-incommon interest in real property (‘‘TIC
Interest’’) 5 that is offered and sold
together with other arrangements that
cause it to be deemed to be a security
under the federal securities laws (‘‘TIC
Security’’).6
Under NAR’s exemptive request, a
Real Estate Advisory Fee could be paid
by the purchaser directly or on behalf of
the purchaser by the sponsor or issuer
of the TIC Security, which could,
thereby, reduce the commission or other
compensation received by a registered
broker-dealer involved in the TIC
Security transaction. The Real Estate
Advisory Fee generally would be paid to
the Real Estate Firm with which the
Commercial Real Estate Professional is
licensed. The Firm would distribute all
3 The Application defines ‘‘substantial
experience’’ to mean a Commercial Real Estate
Professional who (1) has received a Certified
Commercial Investment Member designation from
the Commercial Investment Real Estate Institute, a
designation from the Society of Industrial and
Office REALTORS, or an Accredited Land
Consultant designation from the REALTORS Land
Institute; (2) has education and transaction
experience that is equivalent to those required to
obtain those designations; or (3) has participated in
at least five commercial real estate transactions
having an aggregate value of at least $3 million in
the prior five years or at least 10 commercial real
estate transactions having an aggregate value of at
least $10 million in the prior 10 years, including 3
transactions in the prior 3 years. Alternatively, the
Application provides that a Commercial Real Estate
Professional will satisfy the ‘‘substantial
experience’’ requirement based on a combination of
at least two of the following factors: education in
commercial real estate; the length of time during
which the person has engaged in commercial real
estate transactions; the dollar value of commercial
real estate transactions in which the individual has
participated; and the number of commercial real
estate transactions in which the individual has
participated.
4 For purposes of the Application, ‘‘commercial
real estate’’ includes all real estate categories other
than single-family and one- to four-unit residential
dwellings, including office, retail, raw land,
multifamily (i.e., greater than four dwellings),
industrial and others. It does not include TIC
Securities.
5 TIC Interests are generally offered as a
replacement property to individuals seeking to
complete tax-deferred exchange transactions
pursuant to Section 1031 of the Internal Revenue
Code of 1986, as amended.
6 TIC Securities are sold by a sponsor through a
registered broker-dealer acting as a placement agent
(‘‘Lead Placement Agent’’). Such Lead Placement
Agent may be the sole distributor of the TIC
Securities or may enter into an agreement with one
or more other registered broker-dealers to sell the
TIC Securities as participating brokers (each, a
‘‘Selling Broker-Dealer’’). A Lead Placement Agent
also may act as a Selling Broker-Dealer.
PO 00000
Frm 00116
Fmt 4703
Sfmt 4703
64689
or a previously agreed upon percentage
of the Real Estate Advisory Fee to the
Commercial Real Estate Professional
that signed a buyer’s agent agreement
with the client and to any other
Commercial Real Estate Professional or
Real Estate Firm that was added to the
agreement with the consent of the
client.
As proposed by NAR, in order for any
Commercial Real Estate Professional or
any Real Estate Firm with which such
person is licensed to receive or share in
a Real Estate Advisory Fee in reliance
on the requested exemption, the
Commercial Real Estate Professional,
the Real Estate Firm, the Selling BrokerDealer and the Lead Placement Agent
for the TIC Security transaction would
comply with the following conditions,
as applicable:
(1) General Conditions
a. A Real Estate Advisory Fee shall
only be paid to or shared with a
Commercial Real Estate Professional
who is predominantly engaged in sales
of real estate other than TIC Securities,
has substantial experience in
commercial real estate,7 is appropriately
licensed in compliance with the
applicable state real estate laws, and is
identified in the buyer’s agent
agreement (as further described below)
with the client.8
b. Each client of the RE Participant
purchasing a TIC Security must receive
at closing a deed representing his or her
undivided fractional interest in the TIC
Security property and the TIC Security
must qualify as a ‘‘replacement
property’’ for purposes of an IRC section
1031 exchange, regardless of whether
the client is purchasing the TIC Security
for that purpose.
c. The TIC Security transaction must
be effected through a registered brokerdealer.
(2) Buyer’s Agent Agreement and
Introduction to Selling Broker-Dealer
a. Prior to the Commercial Real Estate
Professional discussing a specific TIC
Security property with his or her client,
the client must enter into a written
buyer’s agent agreement with the RE
Participant, which shall obligate the RE
Participant to solely represent the client
in connection with the purchase of a
TIC Security.
b. The buyer’s agent agreement must
identify any other RE Participant who is
7 See
note 3.
not proposed as a condition to NAR’s
requested exemption, NAR states in its application
that it ‘‘believes’’ the buyer’s agent agreement
‘‘should include’’ a representation that the
Commercial Real Estate Professional who receives
or shares a Real Estate Advisory Fee has substantial
experience in commercial real estate.
8 Although
E:\FR\FM\16NON1.SGM
16NON1
64690
Federal Register / Vol. 72, No. 221 / Friday, November 16, 2007 / Notices
to receive or share in the Real Estate
Advisory Fee and any such other RE
Participant may only be added to the
buyer’s agent agreement with the
consent of the client.
c. The buyer’s agent agreement must
state the aggregate maximum amount of
the Real Estate Advisory Fee to be paid
by the client to all RE Participants,
including any RE Participant that is
added to the agreement, which shall be
expressed as either a fixed dollar
amount or as a dollar amount that is
determined in accordance with a
predetermined formula (e.g., a fixed
percentage of the property’s full
purchase price or a fixed percentage of
the cash paid for the property).
d. The aggregate maximum amount of
Real Estate Advisory Fee that is actually
paid by the client to all RE Participants,
including any RE Participant that is
added to the buyer’s agent agreement,
will not exceed the amount of the
contracted Real Estate Advisory Fee
even if the client, the sponsor, or
another person is willing to pay a higher
fee.
e. The Commercial Real Estate
Professional may discuss the real estate
characteristics of a TIC Security
property with the client and arrange for
the client to inspect a TIC Security
property and any other non-securities
property before introducing the client to
the Selling Broker-Dealer, but shall
arrange such introduction upon the
client advising the Commercial Real
Estate Professional that he or she is
considering the purchase of a specific
TIC Security property.
mstockstill on PROD1PC66 with NOTICES
(3) Restrictions on Conduct of the RE
Participant
A RE Participant that, directly or
indirectly, receives a portion of a Real
Estate Advisory Fee will not:
a. List or otherwise advertise the
availability of TIC Securities or
advertise that the RE Participant
represents clients in connection with
the purchase of TIC Securities;
b. Share a Real Estate Advisory Fee
with any person not permitted to
receive such Fee under the requested
exemption;
c. Handle customer funds or securities
in a TIC Security transaction;
d. Negotiate the terms and conditions
of the purchase of any TIC Security on
behalf of the client with a broker-dealer
or sponsor selling a TIC Security or have
any power to bind the client in the TIC
Security transaction, but may transmit
documents and information between the
parties and may attend meetings
between the Lead Placement Agent,
Selling Broker-Dealer, and the sponsor
VerDate Aug<31>2005
21:48 Nov 15, 2007
Jkt 214001
and the client (solely in order to assist
the client);
e. Represent the client as a ‘‘purchaser
representative,’’ as defined in Rule
501(h) of the Securities Act of 1933;
f. Participate in the structuring of a
TIC Security investment offered to the
client;
g. Have the authority to close a
purchase of a TIC Security on a client’s
behalf; or
h. Assist a client that purchases a TIC
Security to obtain financing, except to
provide a list of potential lenders.
(4) Other Obligations of the RE
Participant
a. The RE Participant must deliver a
copy of the executed buyer’s agent
agreement to the Lead Placement Agent
at closing.
b. Any Commercial Real Estate
Professional that is to receive, directly
or indirectly, a portion of a Real Estate
Advisory Fee must not be subject to any
‘‘statutory disqualification,’’ as that term
is defined in section 3(a)(39) of the
Exchange Act (other than subparagraph
(E) of that section), and will deliver a
representation in writing to that effect to
the Lead Placement Agent at closing. To
the extent the statutory disqualification
representation is included in the buyer’s
agent agreement, it must be updated at
closing with respect to each Commercial
Real Estate Professional that may,
directly or indirectly, receive any
portion of a Real Estate Advisory Fee.
(5) Obligations of the Selling BrokerDealer and Lead Placement Agent
a. Before the TIC Security transaction
is effected, the Selling Broker-Dealer
must perform a suitability analysis of
the TIC Security transaction in
accordance with the rules of the Selling
Broker-Dealer’s applicable selfregulatory organization (‘‘SRO’’) as if the
Selling Broker-Dealer had recommended
the TIC Security transaction and must
deliver a representation in writing to
that effect to the Lead Placement Agent
at closing or, if the Selling Broker-Dealer
is the Lead Placement Agent, must make
a representation in writing to that effect
at closing.
b. The Selling Broker-Dealer will
inform the customer if the Selling
Broker-Dealer determines that the TIC
Security transaction to be effected for
the customer is not suitable under the
rules of the Selling Broker-Dealer’s
applicable SRO, and will not effect the
TIC Security transaction unless it
obtains the customer’s written
affirmation that the customer wants to
proceed with the TIC Security
transaction notwithstanding the Selling
Broker-Dealer’s determination. The
PO 00000
Frm 00117
Fmt 4703
Sfmt 4703
Selling Broker-Dealer must deliver the
written affirmation to the Lead
Placement Agent at closing or, if the
Selling Broker-Dealer is the Lead
Placement Agent, must maintain the
written affirmation as specified below.
c. The Lead Placement Agent must
maintain a copy of each of the
documents that is to be made and/or
delivered at closing pursuant to the
requested exemption (i.e., the buyer’s
agent agreement, the statutory
disqualification representations, the
suitability representation, and, if
applicable, the customer’s written
affirmation), the relevant part of the real
estate closing documents that evidences
the amount of the Real Estate Advisory
Fee paid to any RE Participant involved
in the TIC Security transaction, and any
other records that are required to be
maintained in accordance with the
recordkeeping requirements of the
federal securities laws for a period of
three (3) years in accordance with
Exchange Act Rule 17a–4(f).
Summary of Reasons for the Exemption
NAR states that the requested
exemption would allow a potential
purchaser of a TIC Security to benefit
from the real estate expertise of a
Commercial Real Estate Professional,
while receiving necessary protections
afforded by federal and state securities
laws and regulations. NAR states that
the proposed conditions would limit the
role of a Commercial Real Estate
Professional and Real Estate Firm with
which such person is licensed that
would receive a Real Estate Advisory
Fee. As a result, NAR states that an
exemption from registration and
regulation of the Commercial Real Estate
Professional and the Real Estate Firm
with which such person is licensed as
a broker-dealer would be appropriate in
the public interest and consistent with
the protection of investors.
NAR has waived its request for
confidential treatment and the
Application is available on the
Commission’s Web site (https://
www.sec.gov/rules/other.shtml) and at
the Commission’s Public Reference
Room, 100 F Street, NE., Washington,
DC 20549, on official business days
between the hours of 10 a.m. and 3 p.m.
Request for Comment
The Commission invites any person to
submit comments or other information
that relates to the exemptions requested
in the Application, including whether
the exemption should be granted,
whether the conditions are appropriate,
and whether conditions should be
added, eliminated, or modified. In
E:\FR\FM\16NON1.SGM
16NON1
mstockstill on PROD1PC66 with NOTICES
Federal Register / Vol. 72, No. 221 / Friday, November 16, 2007 / Notices
particular, the Commission requests
comment as to the following:
• Is the Application’s definition of
‘‘substantial experience in commercial
real estate’’ appropriate? Should
‘‘substantial experience in commercial
real estate’’ be defined differently? If so,
how?
• Should a Commercial Real Estate
Professional be considered to have
‘‘substantial experience in commercial
real estate’’ if he or she meets a
combination of two subjective factors
(such as education and dollar value of
transactions), or should substantial
experience only be demonstrated by the
specific education or transactional
benchmarks enumerated in the
Application?
• Should the quantitative factors
included in the Application’s definition
of ‘‘substantial experience in
commercial real estate’’ be periodically
adjusted for inflation? If so, how often
and which measure of inflation should
be used?
• Are there education and experience
designations from groups other than
those affiliated with NAR that would be
appropriate to name specifically as
evidencing ‘‘substantial experience in
commercial real estate’’?
• Should the exemption include a
quantitative threshold to describe when
a Commercial Real Estate Professional
would be ‘‘predominantly engaged’’ in
the sale of real estate other than TIC
Securities? If so, what should that
threshold be? For example, should 85
percent of the dollar value of a
Commercial Real Estate Professional’s
sales during one or more prior calendar
years be in real estate other than TIC
securities in order to meet the
predominance requirement?
• Should the exemption be
conditioned on the buyer’s agent
agreement including a representation
that the Commercial Real Estate
Professional who receives or shares a
Real Estate Advisory Fee has substantial
experience in commercial real estate?
• Is there a possibility that the
exemption, if granted, could create an
incentive for Commercial Real Estate
Professionals to sell TIC Securities
instead of non-security forms of
commercial real estate investments to
their clients? Are there countervailing
factors that would mitigate or neutralize
any such incentive? Should the
possibility of any such incentive be
addressed by one or more conditions,
for example, by requiring Commercial
Real Estate Professionals to disclose in
the buyer’s agent agreement the various
fees they would receive for selling TIC
Securities and non-security forms of
commercial real estate investments? Are
VerDate Aug<31>2005
21:48 Nov 15, 2007
Jkt 214001
there other conditions that could
address this incentive?
• Are the proposed conditions that
would impose obligations on registered
broker-dealers appropriate? Would they
be sufficient to accomplish the desired
goals, including maintaining investor
protection? Should any be eliminated or
modified, or should additional
conditions be included? Commenters
are invited to suggest conditions and
explain their purpose.
For further information, contact
Catherine McGuire, Chief Counsel;
Brian Bussey, Assistant Chief Counsel;
or Michael Hershaft, Special Counsel, at
(202) 551–5550, Office of Chief Counsel,
Division of Market Regulation,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–6628.
Submission of Comments
Comments may be submitted by any
of the following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/other.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
No. S7–26–07 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Nancy M. Morris, Secretary,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–1090.
All submissions should refer to File No.
S7–26–07. This file number should be
included on the subject line if e-mail is
used. To help the Commission process
and review your comments more
efficiently, please use only one method.
The Commission will post all comments
on the Commission’s Internet Web site
(https://www.sec.gov/rules/other.shtml).
All comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to File No. S7–
26–07 and should be submitted on or
before December 17, 2007. The
Commission will take final action on the
Application no earlier than December
18, 2007.
Paperwork Reduction Act Analysis
Certain provisions of the requested
exemption contain ‘‘collection of
information’’ requirements within the
meaning of the Paperwork Reduction
PO 00000
Frm 00118
Fmt 4703
Sfmt 4703
64691
Act of 1995.9 The Commission has
submitted these information collections
to the Office of Management and Budget
(‘‘OMB’’) for review in accordance with
44 U.S.C. 3507(c) and 5 CFR 1320.10.
These collections of information under
the requested exemption are new, and
OMB has not yet assigned a control
number for them. An agency may not
conduct or sponsor, and a person is not
required to respond to, a collection of
information unless it displays a
currently valid control number.10
A. Delivery of the Buyer’s Agent
Agreement to the Lead Placement Agent
at Closing
1. Collection of Information
The requested exemption would be
conditioned on the RE Participant
delivering a copy of the executed
buyer’s agent agreement to the Lead
Placement Agent at closing.
2. Proposed Use of the Information
The proposed buyer’s agent agreement
is designed to assist in implementing
the requested exemption and
monitoring for compliance. The
proposed delivery requirement is
designed to ensure that the Lead
Placement Agent has a copy of the
buyer’s agent agreement in order to
comply with its recordkeeping
obligations discussed below, which
would facilitate monitoring compliance
with the requested exemption.
3. Respondents
The proposed collection of
information would apply to RE
Participants who rely on the requested
exemption.
4. Reporting and Recordkeeping Burden
The Commission estimates that
approximately 800 RE Participants 11
would rely on the requested exemption
and each RE Participant would, on
average, deliver to the Lead Placement
Agent a copy of an executed buyer’s
agent agreement 6.63 times 12 a year.
9 44
U.S.C. 3501, et seq.
U.S.C. 3512.
11 Based on discussions with industry
participants on the number of registered
representatives currently involved in TIC Security
transactions, the Commission estimates that
approximately 800 Commercial Real Estate
Professionals would rely on the requested
exemption. Although this collection of information
covers RE Participants, which includes Commercial
Real Estate Professionals and the real estate
brokerage firms with which they are licensed, the
Commission expects that the Commercial Real
Estate Professionals, and not the firms, would
actually fulfill the delivery requirement.
12 Based on discussions with industry
representatives, we understand that there were
approximately 312 TIC Security offerings in 2006
10 44
E:\FR\FM\16NON1.SGM
Continued
16NON1
64692
Federal Register / Vol. 72, No. 221 / Friday, November 16, 2007 / Notices
Based on these estimates, the
Commission estimates that this
requirement would result in
approximately 5,304 disclosures 13 per
year. The Commission also estimates
that a RE Participant would spend
approximately five minutes per
disclosure to the Lead Placement Agent.
Thus, the estimated total annual
reporting and recordkeeping burden for
this requirement is 442 hours 14 for the
RE Participants.
Advisory Fee to not be subject to any
‘‘statutory disqualification,’’ as defined
in section 3(a)(39) of the Exchange Act
(other than subparagraph (E) of that
section), and to deliver a representation
in writing to that effect to the Lead
Placement Agent at closing.16
2. Proposed Use of the Information
5. Collection of Information is
Mandatory
This proposed collection of
information would be mandatory for RE
Participants who rely on the requested
exemption.
6. Confidentiality
The proposed collection of
information would be provided by the
RE Participant to the Lead Placement
Agent and would be available for
inspection by the Commission and the
applicable SRO.
The proposed ‘‘statutory
disqualification’’ representation would
be used in implementing the requested
exemption and monitoring its use. The
proposed delivery requirement is
designed to ensure that the Lead
Placement Agent has a copy of the
statutory disqualification representation
in order to comply with its
recordkeeping obligations discussed
below, which would facilitate
monitoring compliance with the
exemption.
3. Respondents
7. Record Retention Period
The requested exemption does not
contain a separate record retention
period.15
4. Reporting and Recordkeeping Burden
B. Delivery of the Statutory
Disqualification Representation at
Closing
mstockstill on PROD1PC66 with NOTICES
1. Collection of Information
The requested exemption would
require any Commercial Real Estate
Professional that is to receive, directly
or indirectly, a portion of a Real Estate
and approximately 17 participants per offering for
a total of 5,304 TIC Security transactions. For
purposes of calculating the reporting and
recordkeeping burden, the Commission estimates
that all TIC Security transactions would be
conducted pursuant to the requested exemption.
The Commission recognizes that it is highly
unlikely that all TIC Security transactions would
involve a RE Participant pursuant to the requested
exemption in light of the existing broker-dealer
sales channel for TIC Securities. However, the
Commission does not have sufficient information to
estimate participation rates of less than 100 percent,
and thus has chosen the most conservative estimate
for calculating the reporting and recordkeeping
burden. Accordingly, 5,304 TIC Security
transactions/800 RE Participants = 6.63. The
Commission has rounded its calculation to two
decimal places. Assuming a relatively even
distribution of transactions among potential
respondents, some respondents would deliver to
the Lead Placement Agent a copy of an executed
buyer’s agent agreement six times a year, and others
would do so seven times a year.
13 6.63 × 800 = 5,304.
14 5,304 TIC Security transactions × five minutes
per transaction = 26,520/60 = 442.
15 The Lead Placement Agent, as a registered
broker-dealer, would be subject to the record
retention provisions of Exchange Act Rule 17a–4.
OMB has approved the collection of information
related to these record retention provisions. See
OMB control number 3235–0279.
VerDate Aug<31>2005
21:48 Nov 15, 2007
Jkt 214001
The proposed collection of
information would apply to Commercial
Real Estate Professionals who would
receive, directly or indirectly, a portion
of a Real Estate Advisory Fee pursuant
to the requested exemption.
The Commission estimates that
approximately 800 Commercial Real
Estate Professionals 17 would rely on the
requested exemption and each
Commercial Real Estate Professional
would on average deliver the written
statutory disqualification representation
6.63 times 18 a year. Based on these
estimates, the Commission anticipates
that this requirement would result in
5,304 disclosures 19 per year. The
Commission estimates that
approximately 95 percent of
Commercial Real Estate Professionals
would spend approximately five
minutes for each representation to the
Lead Placement Agent. The Commission
also estimates that approximately five
percent of Commercial Real Estate
16 Although the requested exemption would
require a Commercial Real Estate Professional to
update the ‘‘statutory disqualification’’
representation at closing, if the ‘‘statutory
disqualification’’ notice were already included in
the buyer’s agent agreement, there would be no
requirement to include the representation in the
buyer’s agent agreement. Commercial Real Estate
Professionals would have only one ‘‘statutory
disqualification’’ representation disclosure
requirement per transaction.
17 See note 11.
18 See note 12. The Commission has rounded its
calculation to two decimal places. Assuming a
relatively even distribution of transactions among
potential respondents, some respondents would
deliver to the Lead Placement Agent a written
statutory disqualification representation six times a
year, and others would do so seven times a year.
19 See note 13.
PO 00000
Frm 00119
Fmt 4703
Sfmt 4703
Professionals 20 would spend
approximately 30 minutes for their first
representation to the Lead Placement
Agent,21 and five minutes for each of the
5.63 subsequent representations. Thus,
the estimated total annual reporting and
recordkeeping burden for these
requirements is 458.67 hours 22 for
Commercial Real Estate Professionals.
5. Collection of Information Is
Mandatory
This proposed collection of
information would be mandatory for
Commercial Real Estate Professionals
who rely on the requested exemption.
6. Confidentiality
The collection of information would
be provided by the Commercial Real
Estate Professional to the Lead
Placement Agent and to the customer
and would be available for inspection
by the Commission and the applicable
SRO.
7. Record Retention Period
The requested exemption does not
contain a separate record retention
period.23
C. Suitability Determination by the
Selling Broker-Dealer
1. Collection of Information
The requested exemption would
require a Selling Broker-Dealer to
deliver a representation in writing that
the Selling Broker-Dealer performed a
suitability analysis to the Lead
Placement Agent at closing, or, if the
Selling Broker-Dealer is the Lead
Placement Agent, to make such a
representation in writing at closing.
2. Proposed Use of the Information
The proposed suitability
representation would be used in
20 Based on the Commission’s experience with
disciplinary disclosures by registered
representatives on Forms U–4, the Commission
estimates that five percent of Commercial Real
Estate Professionals could be subject to a statutory
disqualification and would require more time to
make such a determination.
21 The Commission estimates that these
Commercial Real Estate Professionals would spend
25 minutes to determine whether they would be
subject to a statutory disqualification and to
generate the representation, and five minutes to
disclose the representation.
22 800 × .95 × 6.63 × 5 = 25,194/60 = 419.90 total
burden hours for 95 percent of the Commercial Real
Estate Professionals. 800 × .05 × 1 × 30 = 1,200/60
= 20 hours for the first representation by five
percent of the Commercial Real Estate
Professionals. 800 × .05 × 5.63 × 5 = 1,126/60 =
18.77 hours for the second and third
representations by five percent of the Commercial
Real Estate Professionals. Thus total burden hours
would be 419.90 + 20 + 18.77 = 458.67. The
Commission has rounded its calculations to two
decimal places.
23 See note 15.
E:\FR\FM\16NON1.SGM
16NON1
Federal Register / Vol. 72, No. 221 / Friday, November 16, 2007 / Notices
implementing the requested exemption
and monitoring its use. The proposed
delivery requirement is designed to
ensure that the Lead Placement Agent
has a copy of the suitability analysis in
order to comply with its recordkeeping
obligations discussed below, which
would facilitate monitoring compliance
with the exemption.
3. Respondents
The proposed collection of
information would apply to Selling
Broker-Dealers, who deliver or make a
suitability determination pursuant to
the requested exemption.
mstockstill on PROD1PC66 with NOTICES
6. Confidentiality
The proposed collection of
information would be provided by the
Selling Broker-Dealer to the Lead
Placement Agent, or if the Selling
24 The approximate number of Selling BrokerDealers is based on discussions with industry
participants.
25 The Commission estimates that there would be
approximately 5,304 TIC Security transactions a
year. See note 12. The Commission estimates that
approximately five percent of all proposed TIC
Security transactions would be determined to be
not suitable for a customer under the requested
exemption. This estimate is based on discussions
with industry, which indicated that currently
approximately five percent of proposed TIC
Security transactions are determined to be not
suitable for a potential purchaser. Accordingly, the
Commission estimates that Selling Broker-Dealers
would make or deliver a suitability determination
in approximately 95 percent of all transactions.
Thus, a Selling Broker-Dealer would make or
deliver approximately ((5,304 × .95)/150) = 33.59
determinations. The Commission has rounded its
calculation to two decimal places. Assuming a
relatively even distribution of transactions among
potential respondents, some respondents would
make or deliver a suitability representation 33 times
a year, and others would do so 34 times a year.
26 (5,304 × .95) × five minutes per transaction =
25,194/60 = 419.90.
Jkt 214001
The requested exemption does not
contain a separate record retention
period.27
1. Collection of Information
5. Collection of Information Is
Mandatory
This proposed collection of
information would be mandatory for
Selling Broker-Dealers who rely on the
requested exemption.
21:48 Nov 15, 2007
7. Record Retention Period
D. Customer Affirmation by the Selling
Broker-Dealer
4. Reporting and Recordkeeping Burden
The Commission estimates that
approximately 150 Selling BrokerDealers 24 would either deliver or make
a representation at closing and each
Selling Broker-Dealer would on average
deliver or make such a representation
33.59 times 25 a year. Based on the
simplicity of the record to be created,
the Commission also estimates that a
Selling Broker-Dealer would spend
approximately five minutes on each
disclosure. Thus, the estimated total
annual reporting and recordkeeping
burden for this requirement is 419.90
hours 26 for Selling Broker-Dealers.
VerDate Aug<31>2005
Broker-Dealer is the Lead Placement
Agent, to create the collection of
information and would be available for
inspection by the Commission and the
applicable SRO.
The requested exemption would
require a Selling Broker-Dealer that
determines that a TIC Security
transaction is not suitable to obtain a
written affirmation that the customer
wants to proceed with the TIC Security
transaction notwithstanding the Selling
Broker-Dealer’s determination. It also
would require the Selling Broker-Dealer
to deliver the written affirmation to the
Lead Placement Agent at closing or, if
the Selling Broker-Dealer is the Lead
Placement Agent, to maintain the
written affirmation consistent with the
record retention provisions of Exchange
Act Rule 17a–4.
2. Proposed Use of the Information
This proposed information is
designed to ensure that the customer is
informed if a Selling Broker-Dealer
determines a transaction is not suitable,
and, if the customer wants to proceed
with the transaction, that the customer
has made such a decision in light of the
broker-dealer’s determination. In
addition, the proposed delivery
requirement is designed to ensure that
the Lead Placement Agent has a copy of
the customer affirmation in order to
comply with its recordkeeping
obligations discussed below, which
would facilitate monitoring compliance
with the exemption.
3. Respondents
The proposed collection of
information would apply to Selling
Broker-Dealers who deliver or maintain
a customer affirmation determination
pursuant to the requested exemption.
4. Reporting and Recordkeeping Burden
The Commission estimates that there
are approximately 150 Selling BrokerDealers that are potential respondents,
those Selling Broker-Dealers would
obtain and then deliver or maintain a
written affirmation from 265.20
customers who are clients 28 of
27 See
note 15.
discussed in note 25, the Commission
estimates that approximately five percent of all
proposed TIC Security transactions would be
28 As
PO 00000
Frm 00120
Fmt 4703
Sfmt 4703
64693
Commercial Real Estate Participants a
year, and each Selling Broker-Dealer
would on average obtain and then
deliver or maintain such an affirmation
1.77 29 times a year. The Commission
also estimates that a customer would
spend approximately 30 minutes on
each disclosure and the Selling BrokerDealer would spend approximately 35
minutes on each disclosure.30 Thus, the
estimated total annual reporting and
recordkeeping burden for this proposed
requirement is an aggregate of 132.60
hours for customers 31 and 154.70 hours
for the Selling Broker-Dealers.32
5. Collection of Information Is
Mandatory
This collection of information would
be mandatory for Selling Broker-Dealers
who rely on the requested exemption.
6. Confidentiality
The proposed collection of
information would be provided by the
Selling Broker-Dealer to the Lead
Placement Agent, or retained as a
determined to be not suitable. 5,304 × .05 = 265.20.
The Commission has rounded its calculation to two
decimal places. In other words, in any given year
the Commission estimates there would be either
265 or 266 customers whose Selling Broker-Dealer
determines that a TIC Security transaction is not
suitable.
29 The Commission estimates that there would be
approximately 5,304 TIC Security transactions
under the requested exemption. See note 12. The
Commission estimates that Selling Broker-Dealers
would obtain and then deliver or maintain the
customer affirmation in five percent of all
transactions under the requested exemption. This
estimate is based on discussions with industry,
which indicated that currently approximately five
percent of proposed TIC Security transactions are
determined to be not suitable for a potential
purchaser. For purposes of calculating the reporting
and recordkeeping burden, the Commission
estimates that all customers whose Selling BrokerDealer determines that a TIC Security transaction is
not suitable would provide a written affirmation
pursuant to the requested exemption. The
Commission recognizes that it is highly unlikely
that all customers would provide a written
affirmation in the face of a Selling Broker-Dealer’s
determination that a TIC Security transaction is not
suitable. However, the Commission does not have
sufficient information to estimate affirmation rates
of less than 100 percent, and thus has chosen the
most conservative estimate for calculating the
reporting and recordkeeping burden. Thus, a
Selling Broker-Dealer would obtain approximately
((5,304 × .05)/150) = 1.77 affirmations a year. The
Commission has rounded its calculation to two
decimal places. Assuming a relatively even
distribution of transactions among potential
respondents, some respondents would obtain an
affirmation one time a year, and others would do
so two times a year.
30 We estimate that it would take the Selling
Broker-Dealer 30 minutes to explain to its customer
that the transaction is not suitable, and to discuss
with and obtain the subsequent affirmation from the
customer, and five minutes to deliver or maintain
the affirmation.
31 265.20 TIC Security transactions (5,304 × .05)
× 30 minutes per transaction = 7,956/60 = 132.60.
32 265.20 TIC Security transactions (5,304 × .05)
× 35 minutes per transaction = 9,282/60 = 154.70.
E:\FR\FM\16NON1.SGM
16NON1
64694
Federal Register / Vol. 72, No. 221 / Friday, November 16, 2007 / Notices
record, if the Selling Broker-Dealer is
the Lead Placement Agent, and would
be available for inspection by the
Commission and the applicable SRO.
Agent would spend 10 minutes per
closing to maintain a copy of these
documents. Thus, the estimated total
annual reporting and recordkeeping
burden for this requirement is 884
hours.37
7. Record Retention Period
The requested exemption does not
contain a separate record retention
period.33
5. Collection of Information Is
Mandatory
E. Recordkeeping by the Lead Placement
Agent
1. Collection of Information
The requested exemption would
require the Lead Placement Agent to
maintain a copy of each of the
documents that is to be made and/or
delivered at closing, as discussed above
(i.e., the buyer’s agent agreement, the
statutory disqualification
representations, the suitability
representation, and, if applicable, the
customer’s written affirmation), and the
relevant part of the real estate closing
documents that evidences the amount of
the Real Estate Advisory Fee paid to any
RE Participant involved in the TIC
Security transaction.34
2. Proposed Use of the Information
The proposed use of this information
is to facilitate monitoring compliance
with the exemption by compelling the
Lead Placement Agent to maintain
records of all documents that are
required to be delivered at closing.
3. Respondents
The proposed collection of
information would apply to Lead
Placement Agents that act pursuant to
the requested exemption.
4. Reporting and Recordkeeping Burden
The Commission estimates that
approximately 45 Lead Placement
Agents 35 would act pursuant to the
requested exemption. On average, a
Lead Placement Agent would maintain
copies of the relevant documents for
approximately 117.87 TIC Security
transactions 36 a year. The Commission
also estimates that a Lead Placement
33 See
note 15.
requested exemption also would require
the Lead Placement Agent to maintain a copy of any
other records that are required to be maintained in
accordance with the recordkeeping requirements of
the federal securities laws. See note 15.
35 Based on discussions with industry
representatives, the Commission estimates that
there are 45 sponsors of TIC Security transactions
and that each would have a Lead Placement Agent.
36 5,304 TIC Security transactions/45 Lead
Placement Agents = 117.87. The Commission has
rounded its calculation to two decimal places.
Assuming a relatively even distribution of
transactions among potential respondents, some
Lead Placement Agents would maintain copies of
the relevant documents for 117 transactions a year,
and others would do so for 118 transactions a year.
mstockstill on PROD1PC66 with NOTICES
34 The
VerDate Aug<31>2005
21:48 Nov 15, 2007
Jkt 214001
This proposed collection of
information would be mandatory for
Lead Placement Agents that act
pursuant to the requested exemption.
6. Confidentiality
decision concerning the collection of
information between 30 and 60 days
after publication of this notice in the
Federal Register. Therefore, comments
to OMB are best assured of having full
effect if OMB receives them within 30
days of this publication. Requests for
materials submitted to OMB by the
Commission with regard to this
collection of information should be in
writing, refer to File No. S7–26–07, and
be submitted to the Securities and
Exchange Commission, Branch of
Records Management, 100 F Street, NE.,
Washington, DC 20549–1110.
The proposed collection of
information does not address the
confidentiality of information prepared
under this rule; however, the collection
of information would be available for
inspection by the Commission and the
applicable SRO.
By the Commission.
Nancy M. Morris,
Secretary.
[FR Doc. E7–22425 Filed 11–15–07; 8:45 am]
7. Record Retention Period
SECURITIES AND EXCHANGE
COMMISSION
As specified, the Lead Placement
Agent would be required to maintain
copies of these documents for a period
of three years in accordance with its
existing obligations under Exchange Act
Rule 17a–4(f).
F. Request for Comment
Pursuant to 44 U.S.C. 3506(c)(2)(A),
the Commission solicits comments to:
(1) Evaluate whether the proposed
collections of information are necessary
for the proper performance of the
functions of the Commission, including
whether the information would have
practical utility;
(2) Evaluate the accuracy of the
Commission’s estimate of the burden of
the proposed collections of information;
(3) Enhance the quality, utility, and
clarity of the information to be
collected; and
(4) Minimize the burden of the
collections of information on those
required to respond, including through
the use of automated collection
techniques or other forms of information
technology.
Persons desiring to submit comments
on the proposed collection of
information requirements should direct
them to the Office of Management and
Budget, Attention: Desk Officer for the
Securities and Exchange Commission,
Office of Information and Regulatory
Affairs, Washington, DC 20503, and
should send a copy of their comments
to Nancy M. Morris, Secretary,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–1090, and refer to File No. S7–
26–07. OMB is required to make a
BILLING CODE 8011–01–P
[Release No. 34–56774; File No. SR–CBOE–
2007–114]
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Notice of Filing and
Order Granting Accelerated Approval
of a Proposed Rule Change and
Amendment No. 1 Thereto To List and
Trade Options Already Listed on
Another National Securities Exchange
November 8, 2007.
Pursuant to section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on
September 21, 2007, Chicago Board
Options Exchange, Incorporated
(‘‘CBOE’’ or ‘‘Exchange’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I and II
below, which Items have been
substantially prepared by the Exchange.
On October 26, 2007, CBOE filed
Amendment No. 1 to the proposed rule
change.3 This order provides notice of
the proposal, as amended, and approves
the proposal on an accelerated basis.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to add new
Interpretation .01(c) to CBOE Rule 5.3
(Criteria for Underlying Securities) for
the purpose of permitting the Exchange
to list and trade individual equity
options on the Exchange that are
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 Amendment No. 1 supercedes the original filing
and replaces it in its entirety.
2 17
37 5,304 TIC Security transactions × 10 minutes =
53,040/60 = 884.
PO 00000
Frm 00121
Fmt 4703
Sfmt 4703
E:\FR\FM\16NON1.SGM
16NON1
Agencies
[Federal Register Volume 72, Number 221 (Friday, November 16, 2007)]
[Notices]
[Pages 64688-64694]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E7-22425]
=======================================================================
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-56779; File No. S7-26-07]
Notice of Application of the National Association of Realtors for
Exemptive Relief Under Sections 15 and 36 of the Exchange Act and
Request for Comment
November 9, 2007
The National Association of Realtors[supreg] (``NAR'') has
requested an exemption pursuant to sections 15(a)(2) and 36(a) of the
Securities Exchange Act of 1934 (``Exchange Act'') from the broker-
dealer registration requirements of section 15(a)(1) and the reporting
and other requirements of the Exchange Act (other than sections
15(b)(4) and 15(b)(6)), and the rules and regulations thereunder, that
apply to a broker or dealer that is not registered with the Commission.
Subject to the conditions specified in NAR's application
(``Application'') and discussed below, the requested exemption would
permit a licensed real estate agent or broker who is predominantly
engaged in and has substantial experience in the commercial real estate
market and the real estate brokerage firm with which such agent or
broker is licensed to receive compensation in the form described below
for the sale of a TIC Security, as defined below.
[[Page 64689]]
In order to provide an opportunity for interested persons to
comment on the Application, the Commission is publishing this notice
and request for comment pursuant to Rule 0-12 under the Exchange Act.
The Commission will carefully consider all comments submitted, and,
should it determine to issue an exemption, could eliminate or add to,
or modify, the conditions discussed below.
Background
Section 15(a)(1) of the Exchange Act generally requires any broker
or dealer who makes use of the mails or any instrumentality of
interstate commerce to effect transactions in, or induce the purchase
or sale of, any security to register with the Commission. Section
3(a)(4)(A) of the Exchange Act generally defines a ``broker'' as ``any
person engaged in the business of effecting transactions in securities
for the account of others.'' Absent an exemption, a licensed real
estate agent or real estate broker who receives compensation for the
sale of a TIC Security would be required to be registered as a broker
with the Commission or to be a registered associated person of a
registered broker-dealer. Similarly, a real estate brokerage firm that
receives compensation for the sale of a TIC Security would be required
to register as a broker-dealer.
Section 15(a)(2) of the Exchange Act authorizes the Commission to
conditionally or unconditionally exempt from the broker-dealer
registration requirements of section 15(a)(1) any broker or dealer or
class of brokers or dealers, by rule or order, as it deems consistent
with the public interest and the protection of investors.\1\ Similarly,
but more broadly, section 36 of the Exchange Act authorizes the
Commission to conditionally or unconditionally exempt any person,
security, or transaction, or any class or classes of persons,
securities, or transactions, from any provision or provisions of the
Exchange Act or any rule or regulation thereunder, by rule, regulation,
or order, to the extent that such exemption is necessary or appropriate
in the public interest, and is consistent with the protection of
investors.\2\
---------------------------------------------------------------------------
\1\ See 15 U.S.C. 78o(a)(2).
\2\ See 15 U.S.C. 78mm.
---------------------------------------------------------------------------
Summary of the Application
NAR requests an exemption to allow any licensed real estate agent
or broker who is predominantly engaged in and has substantial
experience \3\ in the sale of commercial real estate \4\ (``Commercial
Real Estate Professional'') and the real estate brokerage firm with
which he or she is licensed (``Real Estate Firm'') (collectively, a
``RE Participant'') to receive a real estate advisory fee (``Real
Estate Advisory Fee'') from a purchaser of an undivided tenant-in-
common interest in real property (``TIC Interest'') \5\ that is offered
and sold together with other arrangements that cause it to be deemed to
be a security under the federal securities laws (``TIC Security'').\6\
---------------------------------------------------------------------------
\3\ The Application defines ``substantial experience'' to mean a
Commercial Real Estate Professional who (1) has received a Certified
Commercial Investment Member designation from the Commercial
Investment Real Estate Institute, a designation from the Society of
Industrial and Office REALTORS[supreg], or an Accredited Land
Consultant designation from the REALTORS[supreg] Land Institute; (2)
has education and transaction experience that is equivalent to those
required to obtain those designations; or (3) has participated in at
least five commercial real estate transactions having an aggregate
value of at least $3 million in the prior five years or at least 10
commercial real estate transactions having an aggregate value of at
least $10 million in the prior 10 years, including 3 transactions in
the prior 3 years. Alternatively, the Application provides that a
Commercial Real Estate Professional will satisfy the ``substantial
experience'' requirement based on a combination of at least two of
the following factors: education in commercial real estate; the
length of time during which the person has engaged in commercial
real estate transactions; the dollar value of commercial real estate
transactions in which the individual has participated; and the
number of commercial real estate transactions in which the
individual has participated.
\4\ For purposes of the Application, ``commercial real estate''
includes all real estate categories other than single-family and
one- to four-unit residential dwellings, including office, retail,
raw land, multifamily (i.e., greater than four dwellings),
industrial and others. It does not include TIC Securities.
\5\ TIC Interests are generally offered as a replacement
property to individuals seeking to complete tax-deferred exchange
transactions pursuant to Section 1031 of the Internal Revenue Code
of 1986, as amended.
\6\ TIC Securities are sold by a sponsor through a registered
broker-dealer acting as a placement agent (``Lead Placement
Agent''). Such Lead Placement Agent may be the sole distributor of
the TIC Securities or may enter into an agreement with one or more
other registered broker-dealers to sell the TIC Securities as
participating brokers (each, a ``Selling Broker-Dealer''). A Lead
Placement Agent also may act as a Selling Broker-Dealer.
---------------------------------------------------------------------------
Under NAR's exemptive request, a Real Estate Advisory Fee could be
paid by the purchaser directly or on behalf of the purchaser by the
sponsor or issuer of the TIC Security, which could, thereby, reduce the
commission or other compensation received by a registered broker-dealer
involved in the TIC Security transaction. The Real Estate Advisory Fee
generally would be paid to the Real Estate Firm with which the
Commercial Real Estate Professional is licensed. The Firm would
distribute all or a previously agreed upon percentage of the Real
Estate Advisory Fee to the Commercial Real Estate Professional that
signed a buyer's agent agreement with the client and to any other
Commercial Real Estate Professional or Real Estate Firm that was added
to the agreement with the consent of the client.
As proposed by NAR, in order for any Commercial Real Estate
Professional or any Real Estate Firm with which such person is licensed
to receive or share in a Real Estate Advisory Fee in reliance on the
requested exemption, the Commercial Real Estate Professional, the Real
Estate Firm, the Selling Broker-Dealer and the Lead Placement Agent for
the TIC Security transaction would comply with the following
conditions, as applicable:
(1) General Conditions
a. A Real Estate Advisory Fee shall only be paid to or shared with
a Commercial Real Estate Professional who is predominantly engaged in
sales of real estate other than TIC Securities, has substantial
experience in commercial real estate,\7\ is appropriately licensed in
compliance with the applicable state real estate laws, and is
identified in the buyer's agent agreement (as further described below)
with the client.\8\
---------------------------------------------------------------------------
\7\ See note 3.
\8\ Although not proposed as a condition to NAR's requested
exemption, NAR states in its application that it ``believes'' the
buyer's agent agreement ``should include'' a representation that the
Commercial Real Estate Professional who receives or shares a Real
Estate Advisory Fee has substantial experience in commercial real
estate.
---------------------------------------------------------------------------
b. Each client of the RE Participant purchasing a TIC Security must
receive at closing a deed representing his or her undivided fractional
interest in the TIC Security property and the TIC Security must qualify
as a ``replacement property'' for purposes of an IRC section 1031
exchange, regardless of whether the client is purchasing the TIC
Security for that purpose.
c. The TIC Security transaction must be effected through a
registered broker-dealer.
(2) Buyer's Agent Agreement and Introduction to Selling Broker-Dealer
a. Prior to the Commercial Real Estate Professional discussing a
specific TIC Security property with his or her client, the client must
enter into a written buyer's agent agreement with the RE Participant,
which shall obligate the RE Participant to solely represent the client
in connection with the purchase of a TIC Security.
b. The buyer's agent agreement must identify any other RE
Participant who is
[[Page 64690]]
to receive or share in the Real Estate Advisory Fee and any such other
RE Participant may only be added to the buyer's agent agreement with
the consent of the client.
c. The buyer's agent agreement must state the aggregate maximum
amount of the Real Estate Advisory Fee to be paid by the client to all
RE Participants, including any RE Participant that is added to the
agreement, which shall be expressed as either a fixed dollar amount or
as a dollar amount that is determined in accordance with a
predetermined formula (e.g., a fixed percentage of the property's full
purchase price or a fixed percentage of the cash paid for the
property).
d. The aggregate maximum amount of Real Estate Advisory Fee that is
actually paid by the client to all RE Participants, including any RE
Participant that is added to the buyer's agent agreement, will not
exceed the amount of the contracted Real Estate Advisory Fee even if
the client, the sponsor, or another person is willing to pay a higher
fee.
e. The Commercial Real Estate Professional may discuss the real
estate characteristics of a TIC Security property with the client and
arrange for the client to inspect a TIC Security property and any other
non-securities property before introducing the client to the Selling
Broker-Dealer, but shall arrange such introduction upon the client
advising the Commercial Real Estate Professional that he or she is
considering the purchase of a specific TIC Security property.
(3) Restrictions on Conduct of the RE Participant
A RE Participant that, directly or indirectly, receives a portion
of a Real Estate Advisory Fee will not:
a. List or otherwise advertise the availability of TIC Securities
or advertise that the RE Participant represents clients in connection
with the purchase of TIC Securities;
b. Share a Real Estate Advisory Fee with any person not permitted
to receive such Fee under the requested exemption;
c. Handle customer funds or securities in a TIC Security
transaction;
d. Negotiate the terms and conditions of the purchase of any TIC
Security on behalf of the client with a broker-dealer or sponsor
selling a TIC Security or have any power to bind the client in the TIC
Security transaction, but may transmit documents and information
between the parties and may attend meetings between the Lead Placement
Agent, Selling Broker-Dealer, and the sponsor and the client (solely in
order to assist the client);
e. Represent the client as a ``purchaser representative,'' as
defined in Rule 501(h) of the Securities Act of 1933;
f. Participate in the structuring of a TIC Security investment
offered to the client;
g. Have the authority to close a purchase of a TIC Security on a
client's behalf; or
h. Assist a client that purchases a TIC Security to obtain
financing, except to provide a list of potential lenders.
(4) Other Obligations of the RE Participant
a. The RE Participant must deliver a copy of the executed buyer's
agent agreement to the Lead Placement Agent at closing.
b. Any Commercial Real Estate Professional that is to receive,
directly or indirectly, a portion of a Real Estate Advisory Fee must
not be subject to any ``statutory disqualification,'' as that term is
defined in section 3(a)(39) of the Exchange Act (other than
subparagraph (E) of that section), and will deliver a representation in
writing to that effect to the Lead Placement Agent at closing. To the
extent the statutory disqualification representation is included in the
buyer's agent agreement, it must be updated at closing with respect to
each Commercial Real Estate Professional that may, directly or
indirectly, receive any portion of a Real Estate Advisory Fee.
(5) Obligations of the Selling Broker-Dealer and Lead Placement Agent
a. Before the TIC Security transaction is effected, the Selling
Broker-Dealer must perform a suitability analysis of the TIC Security
transaction in accordance with the rules of the Selling Broker-Dealer's
applicable self-regulatory organization (``SRO'') as if the Selling
Broker-Dealer had recommended the TIC Security transaction and must
deliver a representation in writing to that effect to the Lead
Placement Agent at closing or, if the Selling Broker-Dealer is the Lead
Placement Agent, must make a representation in writing to that effect
at closing.
b. The Selling Broker-Dealer will inform the customer if the
Selling Broker-Dealer determines that the TIC Security transaction to
be effected for the customer is not suitable under the rules of the
Selling Broker-Dealer's applicable SRO, and will not effect the TIC
Security transaction unless it obtains the customer's written
affirmation that the customer wants to proceed with the TIC Security
transaction notwithstanding the Selling Broker-Dealer's determination.
The Selling Broker-Dealer must deliver the written affirmation to the
Lead Placement Agent at closing or, if the Selling Broker-Dealer is the
Lead Placement Agent, must maintain the written affirmation as
specified below.
c. The Lead Placement Agent must maintain a copy of each of the
documents that is to be made and/or delivered at closing pursuant to
the requested exemption (i.e., the buyer's agent agreement, the
statutory disqualification representations, the suitability
representation, and, if applicable, the customer's written
affirmation), the relevant part of the real estate closing documents
that evidences the amount of the Real Estate Advisory Fee paid to any
RE Participant involved in the TIC Security transaction, and any other
records that are required to be maintained in accordance with the
recordkeeping requirements of the federal securities laws for a period
of three (3) years in accordance with Exchange Act Rule 17a-4(f).
Summary of Reasons for the Exemption
NAR states that the requested exemption would allow a potential
purchaser of a TIC Security to benefit from the real estate expertise
of a Commercial Real Estate Professional, while receiving necessary
protections afforded by federal and state securities laws and
regulations. NAR states that the proposed conditions would limit the
role of a Commercial Real Estate Professional and Real Estate Firm with
which such person is licensed that would receive a Real Estate Advisory
Fee. As a result, NAR states that an exemption from registration and
regulation of the Commercial Real Estate Professional and the Real
Estate Firm with which such person is licensed as a broker-dealer would
be appropriate in the public interest and consistent with the
protection of investors.
NAR has waived its request for confidential treatment and the
Application is available on the Commission's Web site (https://
www.sec.gov/rules/other.shtml) and at the Commission's Public Reference
Room, 100 F Street, NE., Washington, DC 20549, on official business
days between the hours of 10 a.m. and 3 p.m.
Request for Comment
The Commission invites any person to submit comments or other
information that relates to the exemptions requested in the
Application, including whether the exemption should be granted, whether
the conditions are appropriate, and whether conditions should be added,
eliminated, or modified. In
[[Page 64691]]
particular, the Commission requests comment as to the following:
Is the Application's definition of ``substantial
experience in commercial real estate'' appropriate? Should
``substantial experience in commercial real estate'' be defined
differently? If so, how?
Should a Commercial Real Estate Professional be considered
to have ``substantial experience in commercial real estate'' if he or
she meets a combination of two subjective factors (such as education
and dollar value of transactions), or should substantial experience
only be demonstrated by the specific education or transactional
benchmarks enumerated in the Application?
Should the quantitative factors included in the
Application's definition of ``substantial experience in commercial real
estate'' be periodically adjusted for inflation? If so, how often and
which measure of inflation should be used?
Are there education and experience designations from
groups other than those affiliated with NAR that would be appropriate
to name specifically as evidencing ``substantial experience in
commercial real estate''?
Should the exemption include a quantitative threshold to
describe when a Commercial Real Estate Professional would be
``predominantly engaged'' in the sale of real estate other than TIC
Securities? If so, what should that threshold be? For example, should
85 percent of the dollar value of a Commercial Real Estate
Professional's sales during one or more prior calendar years be in real
estate other than TIC securities in order to meet the predominance
requirement?
Should the exemption be conditioned on the buyer's agent
agreement including a representation that the Commercial Real Estate
Professional who receives or shares a Real Estate Advisory Fee has
substantial experience in commercial real estate?
Is there a possibility that the exemption, if granted,
could create an incentive for Commercial Real Estate Professionals to
sell TIC Securities instead of non-security forms of commercial real
estate investments to their clients? Are there countervailing factors
that would mitigate or neutralize any such incentive? Should the
possibility of any such incentive be addressed by one or more
conditions, for example, by requiring Commercial Real Estate
Professionals to disclose in the buyer's agent agreement the various
fees they would receive for selling TIC Securities and non-security
forms of commercial real estate investments? Are there other conditions
that could address this incentive?
Are the proposed conditions that would impose obligations
on registered broker-dealers appropriate? Would they be sufficient to
accomplish the desired goals, including maintaining investor
protection? Should any be eliminated or modified, or should additional
conditions be included? Commenters are invited to suggest conditions
and explain their purpose.
For further information, contact Catherine McGuire, Chief Counsel;
Brian Bussey, Assistant Chief Counsel; or Michael Hershaft, Special
Counsel, at (202) 551-5550, Office of Chief Counsel, Division of Market
Regulation, Securities and Exchange Commission, 100 F Street, NE.,
Washington, DC 20549-6628.
Submission of Comments
Comments may be submitted by any of the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://
www.sec.gov/rules/other.shtml); or
Send an e-mail to rule-comments@sec.gov. Please include
File No. S7-26-07 on the subject line.
Paper Comments
Send paper comments in triplicate to Nancy M. Morris,
Secretary, Securities and Exchange Commission, 100 F Street, NE.,
Washington, DC 20549-1090.
All submissions should refer to File No. S7-26-07. This file number
should be included on the subject line if e-mail is used. To help the
Commission process and review your comments more efficiently, please
use only one method. The Commission will post all comments on the
Commission's Internet Web site (https://www.sec.gov/rules/other.shtml).
All comments received will be posted without change; the Commission
does not edit personal identifying information from submissions. You
should submit only information that you wish to make available
publicly. All submissions should refer to File No. S7-26-07 and should
be submitted on or before December 17, 2007. The Commission will take
final action on the Application no earlier than December 18, 2007.
Paperwork Reduction Act Analysis
Certain provisions of the requested exemption contain ``collection
of information'' requirements within the meaning of the Paperwork
Reduction Act of 1995.\9\ The Commission has submitted these
information collections to the Office of Management and Budget
(``OMB'') for review in accordance with 44 U.S.C. 3507(c) and 5 CFR
1320.10. These collections of information under the requested exemption
are new, and OMB has not yet assigned a control number for them. An
agency may not conduct or sponsor, and a person is not required to
respond to, a collection of information unless it displays a currently
valid control number.\10\
---------------------------------------------------------------------------
\9\ 44 U.S.C. 3501, et seq.
\10\ 44 U.S.C. 3512.
---------------------------------------------------------------------------
A. Delivery of the Buyer's Agent Agreement to the Lead Placement Agent
at Closing
1. Collection of Information
The requested exemption would be conditioned on the RE Participant
delivering a copy of the executed buyer's agent agreement to the Lead
Placement Agent at closing.
2. Proposed Use of the Information
The proposed buyer's agent agreement is designed to assist in
implementing the requested exemption and monitoring for compliance. The
proposed delivery requirement is designed to ensure that the Lead
Placement Agent has a copy of the buyer's agent agreement in order to
comply with its recordkeeping obligations discussed below, which would
facilitate monitoring compliance with the requested exemption.
3. Respondents
The proposed collection of information would apply to RE
Participants who rely on the requested exemption.
4. Reporting and Recordkeeping Burden
The Commission estimates that approximately 800 RE Participants
\11\ would rely on the requested exemption and each RE Participant
would, on average, deliver to the Lead Placement Agent a copy of an
executed buyer's agent agreement 6.63 times \12\ a year.
[[Page 64692]]
Based on these estimates, the Commission estimates that this
requirement would result in approximately 5,304 disclosures \13\ per
year. The Commission also estimates that a RE Participant would spend
approximately five minutes per disclosure to the Lead Placement Agent.
Thus, the estimated total annual reporting and recordkeeping burden for
this requirement is 442 hours \14\ for the RE Participants.
---------------------------------------------------------------------------
\11\ Based on discussions with industry participants on the
number of registered representatives currently involved in TIC
Security transactions, the Commission estimates that approximately
800 Commercial Real Estate Professionals would rely on the requested
exemption. Although this collection of information covers RE
Participants, which includes Commercial Real Estate Professionals
and the real estate brokerage firms with which they are licensed,
the Commission expects that the Commercial Real Estate
Professionals, and not the firms, would actually fulfill the
delivery requirement.
\12\ Based on discussions with industry representatives, we
understand that there were approximately 312 TIC Security offerings
in 2006 and approximately 17 participants per offering for a total
of 5,304 TIC Security transactions. For purposes of calculating the
reporting and recordkeeping burden, the Commission estimates that
all TIC Security transactions would be conducted pursuant to the
requested exemption. The Commission recognizes that it is highly
unlikely that all TIC Security transactions would involve a RE
Participant pursuant to the requested exemption in light of the
existing broker-dealer sales channel for TIC Securities. However,
the Commission does not have sufficient information to estimate
participation rates of less than 100 percent, and thus has chosen
the most conservative estimate for calculating the reporting and
recordkeeping burden. Accordingly, 5,304 TIC Security transactions/
800 RE Participants = 6.63. The Commission has rounded its
calculation to two decimal places. Assuming a relatively even
distribution of transactions among potential respondents, some
respondents would deliver to the Lead Placement Agent a copy of an
executed buyer's agent agreement six times a year, and others would
do so seven times a year.
\13\ 6.63 x 800 = 5,304.
\14\ 5,304 TIC Security transactions x five minutes per
transaction = 26,520/60 = 442.
---------------------------------------------------------------------------
5. Collection of Information is Mandatory
This proposed collection of information would be mandatory for RE
Participants who rely on the requested exemption.
6. Confidentiality
The proposed collection of information would be provided by the RE
Participant to the Lead Placement Agent and would be available for
inspection by the Commission and the applicable SRO.
7. Record Retention Period
The requested exemption does not contain a separate record
retention period.\15\
---------------------------------------------------------------------------
\15\ The Lead Placement Agent, as a registered broker-dealer,
would be subject to the record retention provisions of Exchange Act
Rule 17a-4. OMB has approved the collection of information related
to these record retention provisions. See OMB control number 3235-
0279.
---------------------------------------------------------------------------
B. Delivery of the Statutory Disqualification Representation at Closing
1. Collection of Information
The requested exemption would require any Commercial Real Estate
Professional that is to receive, directly or indirectly, a portion of a
Real Estate Advisory Fee to not be subject to any ``statutory
disqualification,'' as defined in section 3(a)(39) of the Exchange Act
(other than subparagraph (E) of that section), and to deliver a
representation in writing to that effect to the Lead Placement Agent at
closing.\16\
---------------------------------------------------------------------------
\16\ Although the requested exemption would require a Commercial
Real Estate Professional to update the ``statutory
disqualification'' representation at closing, if the ``statutory
disqualification'' notice were already included in the buyer's agent
agreement, there would be no requirement to include the
representation in the buyer's agent agreement. Commercial Real
Estate Professionals would have only one ``statutory
disqualification'' representation disclosure requirement per
transaction.
---------------------------------------------------------------------------
2. Proposed Use of the Information
The proposed ``statutory disqualification'' representation would be
used in implementing the requested exemption and monitoring its use.
The proposed delivery requirement is designed to ensure that the Lead
Placement Agent has a copy of the statutory disqualification
representation in order to comply with its recordkeeping obligations
discussed below, which would facilitate monitoring compliance with the
exemption.
3. Respondents
The proposed collection of information would apply to Commercial
Real Estate Professionals who would receive, directly or indirectly, a
portion of a Real Estate Advisory Fee pursuant to the requested
exemption.
4. Reporting and Recordkeeping Burden
The Commission estimates that approximately 800 Commercial Real
Estate Professionals \17\ would rely on the requested exemption and
each Commercial Real Estate Professional would on average deliver the
written statutory disqualification representation 6.63 times \18\ a
year. Based on these estimates, the Commission anticipates that this
requirement would result in 5,304 disclosures \19\ per year. The
Commission estimates that approximately 95 percent of Commercial Real
Estate Professionals would spend approximately five minutes for each
representation to the Lead Placement Agent. The Commission also
estimates that approximately five percent of Commercial Real Estate
Professionals \20\ would spend approximately 30 minutes for their first
representation to the Lead Placement Agent,\21\ and five minutes for
each of the 5.63 subsequent representations. Thus, the estimated total
annual reporting and recordkeeping burden for these requirements is
458.67 hours \22\ for Commercial Real Estate Professionals.
---------------------------------------------------------------------------
\17\ See note 11.
\18\ See note 12. The Commission has rounded its calculation to
two decimal places. Assuming a relatively even distribution of
transactions among potential respondents, some respondents would
deliver to the Lead Placement Agent a written statutory
disqualification representation six times a year, and others would
do so seven times a year.
\19\ See note 13.
\20\ Based on the Commission's experience with disciplinary
disclosures by registered representatives on Forms U-4, the
Commission estimates that five percent of Commercial Real Estate
Professionals could be subject to a statutory disqualification and
would require more time to make such a determination.
\21\ The Commission estimates that these Commercial Real Estate
Professionals would spend 25 minutes to determine whether they would
be subject to a statutory disqualification and to generate the
representation, and five minutes to disclose the representation.
\22\ 800 x .95 x 6.63 x 5 = 25,194/60 = 419.90 total burden
hours for 95 percent of the Commercial Real Estate Professionals.
800 x .05 x 1 x 30 = 1,200/60 = 20 hours for the first
representation by five percent of the Commercial Real Estate
Professionals. 800 x .05 x 5.63 x 5 = 1,126/60 = 18.77 hours for the
second and third representations by five percent of the Commercial
Real Estate Professionals. Thus total burden hours would be 419.90 +
20 + 18.77 = 458.67. The Commission has rounded its calculations to
two decimal places.
---------------------------------------------------------------------------
5. Collection of Information Is Mandatory
This proposed collection of information would be mandatory for
Commercial Real Estate Professionals who rely on the requested
exemption.
6. Confidentiality
The collection of information would be provided by the Commercial
Real Estate Professional to the Lead Placement Agent and to the
customer and would be available for inspection by the Commission and
the applicable SRO.
7. Record Retention Period
The requested exemption does not contain a separate record
retention period.\23\
---------------------------------------------------------------------------
\23\ See note 15.
---------------------------------------------------------------------------
C. Suitability Determination by the Selling Broker-Dealer
1. Collection of Information
The requested exemption would require a Selling Broker-Dealer to
deliver a representation in writing that the Selling Broker-Dealer
performed a suitability analysis to the Lead Placement Agent at
closing, or, if the Selling Broker-Dealer is the Lead Placement Agent,
to make such a representation in writing at closing.
2. Proposed Use of the Information
The proposed suitability representation would be used in
[[Page 64693]]
implementing the requested exemption and monitoring its use. The
proposed delivery requirement is designed to ensure that the Lead
Placement Agent has a copy of the suitability analysis in order to
comply with its recordkeeping obligations discussed below, which would
facilitate monitoring compliance with the exemption.
3. Respondents
The proposed collection of information would apply to Selling
Broker-Dealers, who deliver or make a suitability determination
pursuant to the requested exemption.
4. Reporting and Recordkeeping Burden
The Commission estimates that approximately 150 Selling Broker-
Dealers \24\ would either deliver or make a representation at closing
and each Selling Broker-Dealer would on average deliver or make such a
representation 33.59 times \25\ a year. Based on the simplicity of the
record to be created, the Commission also estimates that a Selling
Broker-Dealer would spend approximately five minutes on each
disclosure. Thus, the estimated total annual reporting and
recordkeeping burden for this requirement is 419.90 hours \26\ for
Selling Broker-Dealers.
---------------------------------------------------------------------------
\24\ The approximate number of Selling Broker-Dealers is based
on discussions with industry participants.
\25\ The Commission estimates that there would be approximately
5,304 TIC Security transactions a year. See note 12. The Commission
estimates that approximately five percent of all proposed TIC
Security transactions would be determined to be not suitable for a
customer under the requested exemption. This estimate is based on
discussions with industry, which indicated that currently
approximately five percent of proposed TIC Security transactions are
determined to be not suitable for a potential purchaser.
Accordingly, the Commission estimates that Selling Broker-Dealers
would make or deliver a suitability determination in approximately
95 percent of all transactions. Thus, a Selling Broker-Dealer would
make or deliver approximately ((5,304 x .95)/150) = 33.59
determinations. The Commission has rounded its calculation to two
decimal places. Assuming a relatively even distribution of
transactions among potential respondents, some respondents would
make or deliver a suitability representation 33 times a year, and
others would do so 34 times a year.
\26\ (5,304 x .95) x five minutes per transaction = 25,194/60 =
419.90.
---------------------------------------------------------------------------
5. Collection of Information Is Mandatory
This proposed collection of information would be mandatory for
Selling Broker-Dealers who rely on the requested exemption.
6. Confidentiality
The proposed collection of information would be provided by the
Selling Broker-Dealer to the Lead Placement Agent, or if the Selling
Broker-Dealer is the Lead Placement Agent, to create the collection of
information and would be available for inspection by the Commission and
the applicable SRO.
7. Record Retention Period
The requested exemption does not contain a separate record
retention period.\27\
---------------------------------------------------------------------------
\27\ See note 15.
---------------------------------------------------------------------------
D. Customer Affirmation by the Selling Broker-Dealer
1. Collection of Information
The requested exemption would require a Selling Broker-Dealer that
determines that a TIC Security transaction is not suitable to obtain a
written affirmation that the customer wants to proceed with the TIC
Security transaction notwithstanding the Selling Broker-Dealer's
determination. It also would require the Selling Broker-Dealer to
deliver the written affirmation to the Lead Placement Agent at closing
or, if the Selling Broker-Dealer is the Lead Placement Agent, to
maintain the written affirmation consistent with the record retention
provisions of Exchange Act Rule 17a-4.
2. Proposed Use of the Information
This proposed information is designed to ensure that the customer
is informed if a Selling Broker-Dealer determines a transaction is not
suitable, and, if the customer wants to proceed with the transaction,
that the customer has made such a decision in light of the broker-
dealer's determination. In addition, the proposed delivery requirement
is designed to ensure that the Lead Placement Agent has a copy of the
customer affirmation in order to comply with its recordkeeping
obligations discussed below, which would facilitate monitoring
compliance with the exemption.
3. Respondents
The proposed collection of information would apply to Selling
Broker-Dealers who deliver or maintain a customer affirmation
determination pursuant to the requested exemption.
4. Reporting and Recordkeeping Burden
The Commission estimates that there are approximately 150 Selling
Broker-Dealers that are potential respondents, those Selling Broker-
Dealers would obtain and then deliver or maintain a written affirmation
from 265.20 customers who are clients \28\ of Commercial Real Estate
Participants a year, and each Selling Broker-Dealer would on average
obtain and then deliver or maintain such an affirmation 1.77 \29\ times
a year. The Commission also estimates that a customer would spend
approximately 30 minutes on each disclosure and the Selling Broker-
Dealer would spend approximately 35 minutes on each disclosure.\30\
Thus, the estimated total annual reporting and recordkeeping burden for
this proposed requirement is an aggregate of 132.60 hours for customers
\31\ and 154.70 hours for the Selling Broker-Dealers.\32\
---------------------------------------------------------------------------
\28\ As discussed in note 25, the Commission estimates that
approximately five percent of all proposed TIC Security transactions
would be determined to be not suitable. 5,304 x .05 = 265.20. The
Commission has rounded its calculation to two decimal places. In
other words, in any given year the Commission estimates there would
be either 265 or 266 customers whose Selling Broker-Dealer
determines that a TIC Security transaction is not suitable.
\29\ The Commission estimates that there would be approximately
5,304 TIC Security transactions under the requested exemption. See
note 12. The Commission estimates that Selling Broker-Dealers would
obtain and then deliver or maintain the customer affirmation in five
percent of all transactions under the requested exemption. This
estimate is based on discussions with industry, which indicated that
currently approximately five percent of proposed TIC Security
transactions are determined to be not suitable for a potential
purchaser. For purposes of calculating the reporting and
recordkeeping burden, the Commission estimates that all customers
whose Selling Broker-Dealer determines that a TIC Security
transaction is not suitable would provide a written affirmation
pursuant to the requested exemption. The Commission recognizes that
it is highly unlikely that all customers would provide a written
affirmation in the face of a Selling Broker-Dealer's determination
that a TIC Security transaction is not suitable. However, the
Commission does not have sufficient information to estimate
affirmation rates of less than 100 percent, and thus has chosen the
most conservative estimate for calculating the reporting and
recordkeeping burden. Thus, a Selling Broker-Dealer would obtain
approximately ((5,304 x .05)/150) = 1.77 affirmations a year. The
Commission has rounded its calculation to two decimal places.
Assuming a relatively even distribution of transactions among
potential respondents, some respondents would obtain an affirmation
one time a year, and others would do so two times a year.
\30\ We estimate that it would take the Selling Broker-Dealer 30
minutes to explain to its customer that the transaction is not
suitable, and to discuss with and obtain the subsequent affirmation
from the customer, and five minutes to deliver or maintain the
affirmation.
\31\ 265.20 TIC Security transactions (5,304 x .05) x 30 minutes
per transaction = 7,956/60 = 132.60.
\32\ 265.20 TIC Security transactions (5,304 x .05) x 35 minutes
per transaction = 9,282/60 = 154.70.
---------------------------------------------------------------------------
5. Collection of Information Is Mandatory
This collection of information would be mandatory for Selling
Broker-Dealers who rely on the requested exemption.
6. Confidentiality
The proposed collection of information would be provided by the
Selling Broker-Dealer to the Lead Placement Agent, or retained as a
[[Page 64694]]
record, if the Selling Broker-Dealer is the Lead Placement Agent, and
would be available for inspection by the Commission and the applicable
SRO.
7. Record Retention Period
The requested exemption does not contain a separate record
retention period.\33\
---------------------------------------------------------------------------
\33\ See note 15.
---------------------------------------------------------------------------
E. Recordkeeping by the Lead Placement Agent
1. Collection of Information
The requested exemption would require the Lead Placement Agent to
maintain a copy of each of the documents that is to be made and/or
delivered at closing, as discussed above (i.e., the buyer's agent
agreement, the statutory disqualification representations, the
suitability representation, and, if applicable, the customer's written
affirmation), and the relevant part of the real estate closing
documents that evidences the amount of the Real Estate Advisory Fee
paid to any RE Participant involved in the TIC Security
transaction.\34\
---------------------------------------------------------------------------
\34\ The requested exemption also would require the Lead
Placement Agent to maintain a copy of any other records that are
required to be maintained in accordance with the recordkeeping
requirements of the federal securities laws. See note 15.
---------------------------------------------------------------------------
2. Proposed Use of the Information
The proposed use of this information is to facilitate monitoring
compliance with the exemption by compelling the Lead Placement Agent to
maintain records of all documents that are required to be delivered at
closing.
3. Respondents
The proposed collection of information would apply to Lead
Placement Agents that act pursuant to the requested exemption.
4. Reporting and Recordkeeping Burden
The Commission estimates that approximately 45 Lead Placement
Agents \35\ would act pursuant to the requested exemption. On average,
a Lead Placement Agent would maintain copies of the relevant documents
for approximately 117.87 TIC Security transactions \36\ a year. The
Commission also estimates that a Lead Placement Agent would spend 10
minutes per closing to maintain a copy of these documents. Thus, the
estimated total annual reporting and recordkeeping burden for this
requirement is 884 hours.\37\
---------------------------------------------------------------------------
\35\ Based on discussions with industry representatives, the
Commission estimates that there are 45 sponsors of TIC Security
transactions and that each would have a Lead Placement Agent.
\36\ 5,304 TIC Security transactions/45 Lead Placement Agents =
117.87. The Commission has rounded its calculation to two decimal
places. Assuming a relatively even distribution of transactions
among potential respondents, some Lead Placement Agents would
maintain copies of the relevant documents for 117 transactions a
year, and others would do so for 118 transactions a year.
\37\ 5,304 TIC Security transactions x 10 minutes = 53,040/60 =
884.
---------------------------------------------------------------------------
5. Collection of Information Is Mandatory
This proposed collection of information would be mandatory for Lead
Placement Agents that act pursuant to the requested exemption.
6. Confidentiality
The proposed collection of information does not address the
confidentiality of information prepared under this rule; however, the
collection of information would be available for inspection by the
Commission and the applicable SRO.
7. Record Retention Period
As specified, the Lead Placement Agent would be required to
maintain copies of these documents for a period of three years in
accordance with its existing obligations under Exchange Act Rule 17a-
4(f).
F. Request for Comment
Pursuant to 44 U.S.C. 3506(c)(2)(A), the Commission solicits
comments to:
(1) Evaluate whether the proposed collections of information are
necessary for the proper performance of the functions of the
Commission, including whether the information would have practical
utility;
(2) Evaluate the accuracy of the Commission's estimate of the
burden of the proposed collections of information;
(3) Enhance the quality, utility, and clarity of the information to
be collected; and
(4) Minimize the burden of the collections of information on those
required to respond, including through the use of automated collection
techniques or other forms of information technology.
Persons desiring to submit comments on the proposed collection of
information requirements should direct them to the Office of Management
and Budget, Attention: Desk Officer for the Securities and Exchange
Commission, Office of Information and Regulatory Affairs, Washington,
DC 20503, and should send a copy of their comments to Nancy M. Morris,
Secretary, Securities and Exchange Commission, 100 F Street, NE.,
Washington, DC 20549-1090, and refer to File No. S7-26-07. OMB is
required to make a decision concerning the collection of information
between 30 and 60 days after publication of this notice in the Federal
Register. Therefore, comments to OMB are best assured of having full
effect if OMB receives them within 30 days of this publication.
Requests for materials submitted to OMB by the Commission with regard
to this collection of information should be in writing, refer to File
No. S7-26-07, and be submitted to the Securities and Exchange
Commission, Branch of Records Management, 100 F Street, NE.,
Washington, DC 20549-1110.
By the Commission.
Nancy M. Morris,
Secretary.
[FR Doc. E7-22425 Filed 11-15-07; 8:45 am]
BILLING CODE 8011-01-P