While the New York Investor Protection Bureau (IPB) has indicated that Form 99 “Notification Filings” for new offerings will no longer be accepted after February 1, 2021, it is unclear at this time whether the New York Real Estate Finance Bureau will also phase out Form 99 “Notification Filings” for offerings of real estate interests. This aligns the form and timing of New York’s filing requirements with those of the federal Securities and Exchange Commission and most other states. As of December 2, 2020, issuers in private placements of securities (aside from real estate interests) are now required to file a Form D through the Electronic Filing Depository (EFD) of the North American Securities Administrators Association (NASAA) within 15 days of the first sale to a New York resident. Prior to adoption of these changes, issuers of “covered securities” were required to complete a Form 99 “Notification Filing,” a cumbersome and expensive document that was unique to New York and had to be submitted before any securities could be sold to residents of that state.
In a press release, the Attorney General described these changes as the latest in ongoing efforts to “streamline and enhance the oversight of the securities industry in New York.”
SCOTT SCHWARTZ MANATT REGISTRATION
On December 1, 2020, the New York Attorney General announced the adoption of regulatory amendments governing registration of securities sold to residents in the state. New rules will simplify the notice filing process for private placements by requiring filings be made on a Form D via the North American Securities Administrators Association multistate Electronic Filing Depository, consistent with how such filings have long been made in most other states.
0 kommentar(er)
