Response to Proposed New York State Reporting and Registration Requirements

On June 12, MFA submitted comments to the New York Attorney General’s office on the proposed rules regarding reporting and registration requirements for investment advisers and finders. In the letter, we expressed support for the proposed amendments to the filing requirements for issuers making private offerings in the state, which will provide a more harmonized and simplified approach compared to federal law. Regarding the proposed categories of “investment adviser representatives” and “finders,” we recommended changes to ensure that they do not create unnecessary confusion with respect to federal law. Finally, we suggested that the Department provide additional guidance as to the newly explicit authority of the Attorney General to deny, suspend or revoke registration statements of investment advisers to ensure appropriate compliance with any new requirements.