Model Rules September 8, 2025

NASAA Amends Non-Traded REIT Guidelines to Add Best-Interest Standard and Concentration Limits

At its Fall 2025 Annual Conference, NASAA members approved amendments to the NASAA Statement of Policy Regarding Real Estate Investment Trusts (the "REIT Guidelines"), announced September 8, 2025.

The amendments incorporate a best-interest conduct standard for broker-dealer recommendations of non-traded REITs.

They also require issuers of non-traded REITs to establish concentration limits for their offerings and update the net-income and net-worth investor-qualification thresholds to reflect inflation since the guidelines were last amended in 2007.

The changes are most relevant to broker-dealers and dual registrants that recommend or sell non-traded REITs. The amendments were released for public comment in March 2025 before membership approval.

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