Self-Regulatory Organizations; Financial Industry Regulatory Authority, Inc.; Order Instituting Proceedings To Determine Whether To Approve or Disapprove a Proposed Rule Change Relating to per Share Estimated Valuations for Unlisted DPP and REIT Securities, 30217-30219 [2014-12072]
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Federal Register / Vol. 79, No. 101 / Tuesday, May 27, 2014 / Notices
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–72193; File No. SR–FINRA–
2014–006]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Order Instituting
Proceedings To Determine Whether To
Approve or Disapprove a Proposed
Rule Change Relating to per Share
Estimated Valuations for Unlisted DPP
and REIT Securities
May 20, 2014.
I. Introduction
On January 31, 2014, the Financial
Industry Regulatory Authority, Inc.
(‘‘FINRA’’) (f/k/a National Association
of Securities Dealers, Inc. (‘‘NASD’’))
filed with the Securities and Exchange
Commission (‘‘SEC’’ or ‘‘Commission’’),
pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2 a
proposed rule change to amend
provisions in the NASD and FINRA
rulebooks addressing per share
estimated valuations for unlisted direct
participation program (‘‘DPP’’) and real
estate investment trust (‘‘REIT’’)
securities. The proposed rule change
was published for comment in the
Federal Register on February 19, 2014.3
The Commission received eighteen (18)
comment letters in response to the
proposed rule change.4 On March 14,
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Release No. 34–71545 (Feb. 12, 2014), 79 FR
9535 (Feb. 19, 2014) (Notice of Filing of Proposed
Rule Change Relating to Per Share Estimated
Valuations for Unlisted DPP and REIT Securities)
(‘‘Notice of Filing’’). The comment period closed on
March 12, 2014.
4 Letters to Elizabeth Murphy, Secretary, SEC,
from Mark Goldberg, Chairman, Investment
Program Association, dated February 5, 2014; David
Bellaire, Executive Vice President and General
Counsel, Financial Services Institute, dated
February 5, 2014; Mark Kosanke, President, Real
Estate Investment Securities Association, dated
February 11, 2014; Steven Wechsler, President and
CEO, National Association of Real Estate
Investment Trusts, dated February 14, 2014; Kirk
Montgomery, Head of Regulatory Affairs, CNL
Financial Group, LLC, dated March 12, 2014;
Dechert LLP, dated March 12, 2014 (‘‘Dechert
Letter’’); Jeff Johnson, CEO, Dividend Capital
Diversified Property Fund Inc., dated February 28,
2014; David Bellaire, Executive Vice President and
General Counsel, Financial Services Institute, dated
March 12, 2014 (‘‘FSI Letter’’); Mark Goldberg,
Chairman, Investment Program Association, dated
March 12, 2014 (‘‘IPA Letter’’); Michael Crimmins,
CEO and Managing Director, KBS Capital Markets
Group, dated February 28, 2014; Steve Morrison,
Senior Vice President and Associate Counsel, LPL
Financial, dated March 12, 2014; Steven Wechsler,
President and CEO, National Association of Real
Estate Investment Trusts, dated March 12, 2014
(‘‘NAREIT Letter’’); Martel Day, Principal, NLR
Advisory Services, LLC, dated March 12, 2014;
Scott Ilgerfritz, Immediate Past-President, Public
sroberts on DSK5SPTVN1PROD with NOTICES
2 17
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2014, FINRA extended the time period
in which the Commission must approve
the proposed rule change, disapprove
the proposed rule change, or institute
proceedings to determine whether to
approve or disapprove the proposed
rule change to May 20, 2014. The
Commission is publishing this order to
institute proceedings pursuant to
Section 19(b)(2)(B) of the Act 5 to
determine whether to approve or
disapprove the proposed rule change.
Institution of proceedings does not
indicate that the Commission has
reached any conclusions with respect to
the proposed rule change, nor does it
mean that the Commission will
ultimately disapprove the proposed rule
change. Rather, as discussed below, the
Commission seeks additional input from
interested parties on the issues
presented by the proposal.
II. Description of the Proposed Rule
Change
NASD Rule 2340 (Customer Account
Statements)
NASD Rule 2340 generally requires
that general securities members 6
provide periodic account statements to
customers, on at least a quarterly basis,
containing a description of any
securities positions, money balances or
account activity since the last statement.
As further described in the Notice of
Filing, FINRA proposes to amend NASD
Rule 2340 to eliminate the requirement
contained in paragraph (c) that a general
securities member disclose in a
customer’s account statement a per
share estimated value of the customer’s
unlisted DPP or REIT securities
holdings, provided that such a value is
reflected in the DPP’s or REIT’s annual
report. Thus, under the proposal, a
general securities member would no
longer be required to include a per share
estimated value for an unlisted DPP or
REIT security in a customer account
statement, but any member may do so
Investors Arbitration Bar Association, dated March
11, 2014; Mark Kosanke, President, Real Estate
Investment Securities Association, dated March 12,
2014 (‘‘REISA Letter’’); Thomas Price, Managing
Director, Securities Industry and Financial Markets
Association, dated March 12, 2014; David
Hirschmann, President and CEO, U.S. Chamber of
Commerce, Center for Capital Markets
Competitiveness, dated March 12, 2014 (‘‘Chamber
of Commerce Letter’’); Jacob Frydman, Chairman
and CEO, United Realty Trust Incorporated, dated
March 12, 2014.
5 15 U.S.C. 78s(b)(2)(B).
6 NASD Rule 2340(d)(2) defines ‘‘general
securities member’’ as any member that conducts a
general securities business and is required to
calculate its net capital pursuant to the provisions
of Rule 15c3–1(a) under the Act. A member that
does not carry customer accounts and does not hold
customer funds or securities is exempt from the
definition.
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30217
if the value has been developed in a
manner reasonably designed to ensure
that it is reliable, the member has no
reason to believe that it is unreliable,
and the account statement includes
certain disclosures. FINRA proposes
two methodologies under which an
estimated value would be presumed to
have been developed in a manner
reasonably designed to ensure that it is
reliable: (1) The net investment
methodology; and (2) the independent
valuation methodology.
The net investment methodology
would reflect the ‘‘net investment’’
disclosed in the issuer’s most recent
periodic or current report. The ‘‘net
investment’’ would be based on the
‘‘amount available for investment’’
percentage in the ‘‘Estimated Use of
Proceeds’’ section of the offering
prospectus or, where ‘‘amount available
for investment’’ is not provided, another
equivalent disclosure.7 The per share
estimated value also must deduct the
portion, if any, of cumulative
distributions per share that exceeded
Generally Accepted Accounting
Principles (‘‘GAAP’’) net income per
share for the corresponding period, after
adding back depreciation and
amortization or depletion expenses.
Moreover, the deduction for each
distribution would be limited to the full
amount of the distribution.
The independent valuation
methodology would consist of the most
recent valuation disclosed in the
issuer’s periodic or current reports. It
would also require that a third-party
valuation expert or experts determine,
or provide material assistance in the
process of determining, the valuation.8
FINRA Rule 2310 (Direct Participation
Programs)
FINRA Rule 2310 generally provides
that no member is permitted to
participate in a public offering of DPP
or REIT securities unless the general
partner or sponsor will disclose in each
annual report distributed to investors
7 FINRA states that this disclosure is typically
included in the prospectus for REIT offerings and
is described in the SEC’s Securities Act Industry
Guide 5 (Preparation of registration statements
relating to interests in real estate limited
partnerships). FINRA states that it would permit the
use of equivalent disclosure in DPP offerings if the
disclosure provides a percentage amount available
for investment by the issuer after deduction of
organizational and offering expenses.
8 According to FINRA, valuation definitions and
methodologies for real estate investments generally
use GAAP (ASC 820) as a standard. Performance
reporting for institutional real estate investments
also relies on GAAP as its foundational basis. See
Investment Program Association Practice
Guidelines 2013–01, entitled ‘‘Valuations of
Publicly Registered Non-Listed REITs’’ (Apr. 29,
2013).
E:\FR\FM\27MYN1.SGM
27MYN1
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Federal Register / Vol. 79, No. 101 / Tuesday, May 27, 2014 / Notices
pursuant to Section 13(a) of the Act: (1)
A per share estimated value of the
securities; (2) the method by which the
estimated value was developed; and (3)
the date of the data used to develop the
estimated value.9
As further described in the Notice of
Filing, FINRA proposes to amend
FINRA Rule 2310 to provide that a
member may not participate in a public
offering of a DPP or REIT security
unless: (A) A per share estimated value
is calculated on a periodic basis in
accordance with a methodology
disclosed in the prospectus, or (B) the
general partner or sponsor has agreed to
disclose in the first periodic report filed
pursuant to Section 13(a) or 15(d) of the
Act after the second anniversary of
breaking escrow: (1) A per share
estimated value of the DPP or REIT
calculated by, or with the material
assistance of, a third-party valuation
expert; (2) an explanation of the method
by which the per share estimated value
was developed; (3) the date of the
valuation; and (4) the identity of the
third-party valuation expert used. In
addition, the general partner or sponsor
of the DPP or REIT must have agreed to
ensure that the valuation is conducted
at least once every two years; is derived
from a methodology that conforms to
standard industry practice; and is
accompanied by a written opinion to the
general partner or sponsor of the DPP or
REIT that explains the scope of the
review, the methodology used to
develop the valuation, and the basis for
the per share estimated value.
sroberts on DSK5SPTVN1PROD with NOTICES
III. Summary of Comments
While the commenters to the Notice
of Filing generally expressed support for
the goals of the proposed rule change,
they raised a number of concerns
regarding various aspects of the
proposal. For instance, several
commenters opposed the deduction of
offering and organizational costs from
the share price under the net investment
methodology, citing difficulties in
accurately determining those
expenses.10 A number of commenters
also opposed the net investment
methodology’s deduction of ‘‘overdistributions’’ from the share value,
arguing, among other things, that such
a requirement was unprecedented and
would have severe implementation
challenges, as well as unintended
negative consequences, such as actually
reducing the level of investor
9 FINRA Rule 2310(b)(5) (Valuation for Customer
Account Statements).
10 See, e.g., REISA Letter.
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19:12 May 23, 2014
Jkt 232001
understanding regarding the sources of
distributions.11
Many commenters opposed the
elimination of any requirement to
include a per share valuation of unlisted
DPP or REIT securities in customer
account statements. Commenters stated
that FINRA, in its proposal, put forth
two valuation methodologies that it
deems presumptively reliable, and
allowing an unlisted DPP or REIT
security to nevertheless be shown as
‘‘not priced’’ in customer account
statements would deprive investors of
useful information and be viewed as a
retreat from a policy of transparency.12
In addition, some commenters raised
concerns about the proposed rule
change’s anticipated implementation
period.13 These commenters favored a
longer period in order to minimize
investor confusion and avoid market
disruption as the industry develops the
appropriate controls and procedures to
comply with the rule.
Commenters further questioned,
among other things, the timing of the
initiation of valuations for unlisted DPP
and REIT securities under FINRA Rule
2310; 14 the frequency with which
valuations are estimated under FINRA
Rule 2310; 15 the effect of the proposed
rule change on business development
companies and daily NAV REITs; 16 and
the lack of an economic analysis.17
On May 16, 2014, FINRA noted that
it is still considering the points raised
by commenters and anticipates filing an
official response in the near future.18
IV. Proceedings To Determine Whether
To Approve or Disapprove SR–FINRA–
2014–006 and Grounds for Disapproval
Under Consideration
The Commission is instituting
proceedings pursuant to Section
19(b)(2)(B) of the Act to determine
whether the proposed rule change
should be approved or disapproved.19
11 See,
e.g., IPA Letter.
12 Id.
13 See,
e.g., NAREIT Letter.
e.g., IPA Letter.
15 See, e.g., FSI Letter.
16 See, e.g., Dechert Letter.
17 See, e.g., Chamber of Commerce Letter.
18 See Letter from Matthew Vitek, Assistant
General Counsel, FINRA, to Kevin O’Neill, Deputy
Secretary, SEC, dated May 16, 2014. Any FINRA
response will be included in the comment file for
this rule filing.
19 15 U.S.C. 78s(b)(2). Section 19(b)(2)(B) of the
Act provides that proceedings to determine whether
to disapprove a proposed rule change must be
concluded within 180 days of the date of
publication of notice of the filing of the proposed
rule change. The time for conclusion of the
proceedings may be extended for up to an
additional 60 days if the Commission finds good
cause for such extension and publishes its reasons
for so finding or if the self-regulatory organization
consents to the extension.
14 See,
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Institution of such proceedings appears
appropriate at this time in view of the
legal and policy issues raised by the
proposal. As noted above, institution of
proceedings does not indicate that the
Commission has reached any
conclusions with respect to any of the
issues involved. Rather, the Commission
seeks and encourages interested persons
to comment on the issues presented by
the proposed rule change and provide
the Commission with arguments to
support the Commission’s analysis as to
whether to approve or disapprove the
proposal.
Pursuant to Section 19(b)(2)(B) of the
Act,20 the Commission is providing
notice of the grounds for disapproval
under consideration. In particular,
Section 15A(b)(6) of the Act 21 requires,
among other things, that FINRA rules
must be designed to prevent fraudulent
and manipulative acts and practices, to
promote just and equitable principles of
trade, and, in general, to protect
investors and the public interest. In
addition, Section 15A(b)(9) of the Act 22
requires that FINRA rules not impose
any unnecessary or inappropriate
burden on competition.
The Commission believes FINRA’s
proposed rule change raises questions as
to whether it is consistent with the
requirements of Section 15A(b)(6) and
15A(b)(9) of the Act.
V. Request for Written Comments
The Commission requests that
interested persons provide written
submissions of their views, data, and
arguments with respect to the issues
raised by the proposed rule change. In
particular, the Commission invites the
written views of interested persons
concerning whether the proposed rule
change is inconsistent with Sections
15A(b)(6) and 15A(b)(9), or any other
provision, of the Act, or the rules and
regulations thereunder.
Although there do not appear to be
any issues relevant to approval or
disapproval which would be facilitated
by an oral presentation of views, data,
and arguments, the Commission will
consider, pursuant to Rule 19b–4, any
request for an opportunity to make an
oral presentation.23 Interested persons
20 15
U.S.C. 78s(b)(2)(B).
U.S.C. 78o–3(b)(6).
22 15 U.S.C. 78o–3(b)(9).
23 Section 19(b)(2) of the Act, as amended by the
Securities Acts Amendments of 1975, Public Law
94–29, 89 Stat. 97 (1975), grants the Commission
flexibility to determine what type of proceeding—
either oral or notice and opportunity for written
comments—is appropriate for consideration of a
particular proposal by a self-regulatory
organization. See Securities Acts Amendments of
1975, Report of the Senate Committee on Banking,
21 15
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Federal Register / Vol. 79, No. 101 / Tuesday, May 27, 2014 / Notices
are invited to submit written data,
views, and arguments by June 26, 2014
concerning whether the proposed rule
change should be approved or
disapproved. Any person who wishes to
file a rebuttal to any other person’s
submission must file that rebuttal by
July 11, 2014. Comments may be
submitted by any of the following
methods:
rebuttal comments should be submitted
by July 11, 2014.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.24
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–12072 Filed 5–23–14; 8:45 am]
BILLING CODE 8011–01–P
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rulecomments@sec.gov. Please include File
Number SR–FINRA–2014–006 on the
subject line.
sroberts on DSK5SPTVN1PROD with NOTICES
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–FINRA–2014–006. This file
number should be included on the
subject line if email 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/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of such
filing also will be available for
inspection and copying at the principle
office of FINRA. 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
publicly available.
All submissions should refer to File
Number SR–FINRA–2014–006 and
should be submitted on or before July
11, 2014. If comments are received, any
Housing and Urban Affairs to Accompany S. 249,
S. Rep. No. 75, 94th Cong., 1st Sess. 30 (1975).
VerDate Mar<15>2010
19:12 May 23, 2014
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–72191; File No. SR–FINRA–
2014–024]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing and
Immediate Effectiveness of a Proposed
Rule Change Relating to the Definition
of ‘‘Reporting Member’’ in the Order
Audit Trail System Rules
May 20, 2014.
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 May 12,
2014, Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’) filed with the
Securities and Exchange Commission
(‘‘SEC’’ or ‘‘Commission’’) the proposed
rule change as described in Items I and
II below, which Items have been
prepared by FINRA. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
FINRA is proposing to amend FINRA
Rule 7410 to permit members to route
orders to two Reporting Members for a
defined period of time provided certain
conditions are met without losing the
exception from the definition of
‘‘Reporting Member’’ in the Order Audit
Trail System (‘‘OATS’’) rules.
Below is the text of the proposed rule
change. Proposed new language is in
italics; proposed deletions are in
brackets.
*
*
*
*
*
7000. CLEARING, TRANSACTION
AND ORDER DATA REQUIREMENTS,
AND FACILITY CHARGES
*
*
*
*
*
24 17 CFR 200.30–3(a)(12); 17 CFR 200.30–
3(a)(57).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
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30219
7400. ORDER AUDIT TRAIL SYSTEM
7410. Definitions
(a) through (n) No Change.
(o) ‘‘Reporting Member’’ shall mean a
member that receives or originates an
order and has an obligation to record
and report information under Rules
7440 and 7450.
(1) A member shall not be considered
a Reporting Member in connection with
an order, if the following conditions are
met:
(A) the member engages in a nondiscretionary order routing process,
pursuant to which it immediately
routes, by electronic or other means, all
of its orders to:
(i) a single receiving Reporting
Member; or
(ii) two receiving Reporting Members,
provided:
(a) orders are routed by the member
to each receiving Reporting Member on
a pre-determined schedule approved by
FINRA; and
(b) orders are routed to two receiving
Reporting Members pursuant to the
schedule for a time period not to exceed
one year; and
(B) the member does not direct and
does not maintain control over
subsequent routing or execution by the
receiving Reporting Member(s);
(C) the receiving Reporting Member(s)
record(s) and report(s) all information
required under Rules 7440 and 7450
with respect to the order; and
(D) the member has a written
agreement with the receiving Reporting
Member(s) specifying the respective
functions and responsibilities of each
party to effect full compliance with the
requirements of Rules 7440 and 7450.
(2) No Change.
*
*
*
*
*
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
FINRA included statements concerning
the purpose of and basis for the
proposed rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item IV below. FINRA has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of such statements.
E:\FR\FM\27MYN1.SGM
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Agencies
[Federal Register Volume 79, Number 101 (Tuesday, May 27, 2014)]
[Notices]
[Pages 30217-30219]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-12072]
[[Page 30217]]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-72193; File No. SR-FINRA-2014-006]
Self-Regulatory Organizations; Financial Industry Regulatory
Authority, Inc.; Order Instituting Proceedings To Determine Whether To
Approve or Disapprove a Proposed Rule Change Relating to per Share
Estimated Valuations for Unlisted DPP and REIT Securities
May 20, 2014.
I. Introduction
On January 31, 2014, the Financial Industry Regulatory Authority,
Inc. (``FINRA'') (f/k/a National Association of Securities Dealers,
Inc. (``NASD'')) filed with the Securities and Exchange Commission
(``SEC'' or ``Commission''), pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4
thereunder,\2\ a proposed rule change to amend provisions in the NASD
and FINRA rulebooks addressing per share estimated valuations for
unlisted direct participation program (``DPP'') and real estate
investment trust (``REIT'') securities. The proposed rule change was
published for comment in the Federal Register on February 19, 2014.\3\
The Commission received eighteen (18) comment letters in response to
the proposed rule change.\4\ On March 14, 2014, FINRA extended the time
period in which the Commission must approve the proposed rule change,
disapprove the proposed rule change, or institute proceedings to
determine whether to approve or disapprove the proposed rule change to
May 20, 2014. The Commission is publishing this order to institute
proceedings pursuant to Section 19(b)(2)(B) of the Act \5\ to determine
whether to approve or disapprove the proposed rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Release No. 34-71545 (Feb. 12, 2014), 79 FR 9535 (Feb.
19, 2014) (Notice of Filing of Proposed Rule Change Relating to Per
Share Estimated Valuations for Unlisted DPP and REIT Securities)
(``Notice of Filing''). The comment period closed on March 12, 2014.
\4\ Letters to Elizabeth Murphy, Secretary, SEC, from Mark
Goldberg, Chairman, Investment Program Association, dated February
5, 2014; David Bellaire, Executive Vice President and General
Counsel, Financial Services Institute, dated February 5, 2014; Mark
Kosanke, President, Real Estate Investment Securities Association,
dated February 11, 2014; Steven Wechsler, President and CEO,
National Association of Real Estate Investment Trusts, dated
February 14, 2014; Kirk Montgomery, Head of Regulatory Affairs, CNL
Financial Group, LLC, dated March 12, 2014; Dechert LLP, dated March
12, 2014 (``Dechert Letter''); Jeff Johnson, CEO, Dividend Capital
Diversified Property Fund Inc., dated February 28, 2014; David
Bellaire, Executive Vice President and General Counsel, Financial
Services Institute, dated March 12, 2014 (``FSI Letter''); Mark
Goldberg, Chairman, Investment Program Association, dated March 12,
2014 (``IPA Letter''); Michael Crimmins, CEO and Managing Director,
KBS Capital Markets Group, dated February 28, 2014; Steve Morrison,
Senior Vice President and Associate Counsel, LPL Financial, dated
March 12, 2014; Steven Wechsler, President and CEO, National
Association of Real Estate Investment Trusts, dated March 12, 2014
(``NAREIT Letter''); Martel Day, Principal, NLR Advisory Services,
LLC, dated March 12, 2014; Scott Ilgerfritz, Immediate Past-
President, Public Investors Arbitration Bar Association, dated March
11, 2014; Mark Kosanke, President, Real Estate Investment Securities
Association, dated March 12, 2014 (``REISA Letter''); Thomas Price,
Managing Director, Securities Industry and Financial Markets
Association, dated March 12, 2014; David Hirschmann, President and
CEO, U.S. Chamber of Commerce, Center for Capital Markets
Competitiveness, dated March 12, 2014 (``Chamber of Commerce
Letter''); Jacob Frydman, Chairman and CEO, United Realty Trust
Incorporated, dated March 12, 2014.
\5\ 15 U.S.C. 78s(b)(2)(B).
---------------------------------------------------------------------------
Institution of proceedings does not indicate that the Commission
has reached any conclusions with respect to the proposed rule change,
nor does it mean that the Commission will ultimately disapprove the
proposed rule change. Rather, as discussed below, the Commission seeks
additional input from interested parties on the issues presented by the
proposal.
II. Description of the Proposed Rule Change
NASD Rule 2340 (Customer Account Statements)
NASD Rule 2340 generally requires that general securities members
\6\ provide periodic account statements to customers, on at least a
quarterly basis, containing a description of any securities positions,
money balances or account activity since the last statement. As further
described in the Notice of Filing, FINRA proposes to amend NASD Rule
2340 to eliminate the requirement contained in paragraph (c) that a
general securities member disclose in a customer's account statement a
per share estimated value of the customer's unlisted DPP or REIT
securities holdings, provided that such a value is reflected in the
DPP's or REIT's annual report. Thus, under the proposal, a general
securities member would no longer be required to include a per share
estimated value for an unlisted DPP or REIT security in a customer
account statement, but any member may do so if the value has been
developed in a manner reasonably designed to ensure that it is
reliable, the member has no reason to believe that it is unreliable,
and the account statement includes certain disclosures. FINRA proposes
two methodologies under which an estimated value would be presumed to
have been developed in a manner reasonably designed to ensure that it
is reliable: (1) The net investment methodology; and (2) the
independent valuation methodology.
---------------------------------------------------------------------------
\6\ NASD Rule 2340(d)(2) defines ``general securities member''
as any member that conducts a general securities business and is
required to calculate its net capital pursuant to the provisions of
Rule 15c3-1(a) under the Act. A member that does not carry customer
accounts and does not hold customer funds or securities is exempt
from the definition.
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The net investment methodology would reflect the ``net investment''
disclosed in the issuer's most recent periodic or current report. The
``net investment'' would be based on the ``amount available for
investment'' percentage in the ``Estimated Use of Proceeds'' section of
the offering prospectus or, where ``amount available for investment''
is not provided, another equivalent disclosure.\7\ The per share
estimated value also must deduct the portion, if any, of cumulative
distributions per share that exceeded Generally Accepted Accounting
Principles (``GAAP'') net income per share for the corresponding
period, after adding back depreciation and amortization or depletion
expenses. Moreover, the deduction for each distribution would be
limited to the full amount of the distribution.
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\7\ FINRA states that this disclosure is typically included in
the prospectus for REIT offerings and is described in the SEC's
Securities Act Industry Guide 5 (Preparation of registration
statements relating to interests in real estate limited
partnerships). FINRA states that it would permit the use of
equivalent disclosure in DPP offerings if the disclosure provides a
percentage amount available for investment by the issuer after
deduction of organizational and offering expenses.
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The independent valuation methodology would consist of the most
recent valuation disclosed in the issuer's periodic or current reports.
It would also require that a third-party valuation expert or experts
determine, or provide material assistance in the process of
determining, the valuation.\8\
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\8\ According to FINRA, valuation definitions and methodologies
for real estate investments generally use GAAP (ASC 820) as a
standard. Performance reporting for institutional real estate
investments also relies on GAAP as its foundational basis. See
Investment Program Association Practice Guidelines 2013-01, entitled
``Valuations of Publicly Registered Non-Listed REITs'' (Apr. 29,
2013).
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FINRA Rule 2310 (Direct Participation Programs)
FINRA Rule 2310 generally provides that no member is permitted to
participate in a public offering of DPP or REIT securities unless the
general partner or sponsor will disclose in each annual report
distributed to investors
[[Page 30218]]
pursuant to Section 13(a) of the Act: (1) A per share estimated value
of the securities; (2) the method by which the estimated value was
developed; and (3) the date of the data used to develop the estimated
value.\9\
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\9\ FINRA Rule 2310(b)(5) (Valuation for Customer Account
Statements).
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As further described in the Notice of Filing, FINRA proposes to
amend FINRA Rule 2310 to provide that a member may not participate in a
public offering of a DPP or REIT security unless: (A) A per share
estimated value is calculated on a periodic basis in accordance with a
methodology disclosed in the prospectus, or (B) the general partner or
sponsor has agreed to disclose in the first periodic report filed
pursuant to Section 13(a) or 15(d) of the Act after the second
anniversary of breaking escrow: (1) A per share estimated value of the
DPP or REIT calculated by, or with the material assistance of, a third-
party valuation expert; (2) an explanation of the method by which the
per share estimated value was developed; (3) the date of the valuation;
and (4) the identity of the third-party valuation expert used. In
addition, the general partner or sponsor of the DPP or REIT must have
agreed to ensure that the valuation is conducted at least once every
two years; is derived from a methodology that conforms to standard
industry practice; and is accompanied by a written opinion to the
general partner or sponsor of the DPP or REIT that explains the scope
of the review, the methodology used to develop the valuation, and the
basis for the per share estimated value.
III. Summary of Comments
While the commenters to the Notice of Filing generally expressed
support for the goals of the proposed rule change, they raised a number
of concerns regarding various aspects of the proposal. For instance,
several commenters opposed the deduction of offering and organizational
costs from the share price under the net investment methodology, citing
difficulties in accurately determining those expenses.\10\ A number of
commenters also opposed the net investment methodology's deduction of
``over-distributions'' from the share value, arguing, among other
things, that such a requirement was unprecedented and would have severe
implementation challenges, as well as unintended negative consequences,
such as actually reducing the level of investor understanding regarding
the sources of distributions.\11\
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\10\ See, e.g., REISA Letter.
\11\ See, e.g., IPA Letter.
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Many commenters opposed the elimination of any requirement to
include a per share valuation of unlisted DPP or REIT securities in
customer account statements. Commenters stated that FINRA, in its
proposal, put forth two valuation methodologies that it deems
presumptively reliable, and allowing an unlisted DPP or REIT security
to nevertheless be shown as ``not priced'' in customer account
statements would deprive investors of useful information and be viewed
as a retreat from a policy of transparency.\12\
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\12\ Id.
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In addition, some commenters raised concerns about the proposed
rule change's anticipated implementation period.\13\ These commenters
favored a longer period in order to minimize investor confusion and
avoid market disruption as the industry develops the appropriate
controls and procedures to comply with the rule.
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\13\ See, e.g., NAREIT Letter.
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Commenters further questioned, among other things, the timing of
the initiation of valuations for unlisted DPP and REIT securities under
FINRA Rule 2310; \14\ the frequency with which valuations are estimated
under FINRA Rule 2310; \15\ the effect of the proposed rule change on
business development companies and daily NAV REITs; \16\ and the lack
of an economic analysis.\17\
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\14\ See, e.g., IPA Letter.
\15\ See, e.g., FSI Letter.
\16\ See, e.g., Dechert Letter.
\17\ See, e.g., Chamber of Commerce Letter.
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On May 16, 2014, FINRA noted that it is still considering the
points raised by commenters and anticipates filing an official response
in the near future.\18\
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\18\ See Letter from Matthew Vitek, Assistant General Counsel,
FINRA, to Kevin O'Neill, Deputy Secretary, SEC, dated May 16, 2014.
Any FINRA response will be included in the comment file for this
rule filing.
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IV. Proceedings To Determine Whether To Approve or Disapprove SR-FINRA-
2014-006 and Grounds for Disapproval Under Consideration
The Commission is instituting proceedings pursuant to Section
19(b)(2)(B) of the Act to determine whether the proposed rule change
should be approved or disapproved.\19\ Institution of such proceedings
appears appropriate at this time in view of the legal and policy issues
raised by the proposal. As noted above, institution of proceedings does
not indicate that the Commission has reached any conclusions with
respect to any of the issues involved. Rather, the Commission seeks and
encourages interested persons to comment on the issues presented by the
proposed rule change and provide the Commission with arguments to
support the Commission's analysis as to whether to approve or
disapprove the proposal.
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\19\ 15 U.S.C. 78s(b)(2). Section 19(b)(2)(B) of the Act
provides that proceedings to determine whether to disapprove a
proposed rule change must be concluded within 180 days of the date
of publication of notice of the filing of the proposed rule change.
The time for conclusion of the proceedings may be extended for up to
an additional 60 days if the Commission finds good cause for such
extension and publishes its reasons for so finding or if the self-
regulatory organization consents to the extension.
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Pursuant to Section 19(b)(2)(B) of the Act,\20\ the Commission is
providing notice of the grounds for disapproval under consideration. In
particular, Section 15A(b)(6) of the Act \21\ requires, among other
things, that FINRA rules must be designed to prevent fraudulent and
manipulative acts and practices, to promote just and equitable
principles of trade, and, in general, to protect investors and the
public interest. In addition, Section 15A(b)(9) of the Act \22\
requires that FINRA rules not impose any unnecessary or inappropriate
burden on competition.
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\20\ 15 U.S.C. 78s(b)(2)(B).
\21\ 15 U.S.C. 78o-3(b)(6).
\22\ 15 U.S.C. 78o-3(b)(9).
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The Commission believes FINRA's proposed rule change raises
questions as to whether it is consistent with the requirements of
Section 15A(b)(6) and 15A(b)(9) of the Act.
V. Request for Written Comments
The Commission requests that interested persons provide written
submissions of their views, data, and arguments with respect to the
issues raised by the proposed rule change. In particular, the
Commission invites the written views of interested persons concerning
whether the proposed rule change is inconsistent with Sections
15A(b)(6) and 15A(b)(9), or any other provision, of the Act, or the
rules and regulations thereunder.
Although there do not appear to be any issues relevant to approval
or disapproval which would be facilitated by an oral presentation of
views, data, and arguments, the Commission will consider, pursuant to
Rule 19b-4, any request for an opportunity to make an oral
presentation.\23\ Interested persons
[[Page 30219]]
are invited to submit written data, views, and arguments by June 26,
2014 concerning whether the proposed rule change should be approved or
disapproved. Any person who wishes to file a rebuttal to any other
person's submission must file that rebuttal by July 11, 2014. Comments
may be submitted by any of the following methods:
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\23\ Section 19(b)(2) of the Act, as amended by the Securities
Acts Amendments of 1975, Public Law 94-29, 89 Stat. 97 (1975),
grants the Commission flexibility to determine what type of
proceeding--either oral or notice and opportunity for written
comments--is appropriate for consideration of a particular proposal
by a self-regulatory organization. See Securities Acts Amendments of
1975, Report of the Senate Committee on Banking, Housing and Urban
Affairs to Accompany S. 249, S. Rep. No. 75, 94th Cong., 1st Sess.
30 (1975).
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Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an email to rule-comments@sec.gov. Please include
File Number SR-FINRA-2014-006 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE., Washington, DC 20549-1090.
All submissions should refer to File Number SR-FINRA-2014-006. This
file number should be included on the subject line if email 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/sro.shtml). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for Web site viewing and
printing in the Commission's Public Reference Room, 100 F Street NE.,
Washington, DC 20549, on official business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of such filing also will be available
for inspection and copying at the principle office of FINRA. 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 publicly available.
All submissions should refer to File Number SR-FINRA-2014-006 and
should be submitted on or before July 11, 2014. If comments are
received, any rebuttal comments should be submitted by July 11, 2014.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\24\
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\24\ 17 CFR 200.30-3(a)(12); 17 CFR 200.30-3(a)(57).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-12072 Filed 5-23-14; 8:45 am]
BILLING CODE 8011-01-P