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NASAA announced the publication of its quarterly newsletter, NASAA Insight . The contents of the current newsletter, designed to keep readers informed of recent NASAA activities, are as follows: A. Heath Abshure of Arkansas Takes NASAA Helm NASAA Urges Caution as SEC Mulls over Solicitation Rule [i.e., the JOBS ACT] Broker-Dealer Compliance Native American Outreach Top Investor Traps Protecting Senior Investors NASAA on JOBS Act Implementation Abshure: NASAA to Add Offense to Defense [about preemption and the role of state regulation] Photo Gallery: NASAA Conference Focuses on Innovation

North American Securities Administrators Association (NASAA) President and Arkansas Securities Commissioner Heath Abshure participated in a news teleconference to discuss the proposed rule with representatives from the AARP, AFL-CIO, Consumer Federation of America, and Americans for Financial Reform. Discussed in the teleconference was the role of NASAA members and the JOBS Act provision, which requires the SEC to amend its Rule 506 to eliminate a ban on the general advertising of private securities offerings. Commissioner Abshure criticized the SEC for abdicating its responsibilities in

NASAA has issued a request for comment on proposed changes to Model Rule 102(f)-3 under the Uniform Securities Act of 1956, and Model Rule 502(c) under the Uniform Securities Act of 2002 (the “performance fee model rules” or the “Model Rules”). These changes will conform these rules to the current exemption under SEC Advisers Act Rule 205-3 for performance fees charged to certain “qualified clients.#8221; Comments Due : December 10, 2012. Cross Reference(s) : 1956 Model Rule with Proposed Revisions;2002 Model Rule with Proposed Revisions Parness Comment : These changes will be extremely

NASAA reported a significant increase in enforcement actions against investment adviser firms last year, with the number of IA enforcement actions nearly doubling to 399 in 2011. Notably, actions against investment adviser firms accounted for 15 percent of all enforcement actions handled by state securities regulators, and Regulation D-Rule 506 private offerings and real estate investment schemes were the most reported products at the basis of enforcement actions for the second consecutive year. Parness Comment: NASAA's latest Enforcement Report reflects an admirable job by the state

The North American Securities Administrators Association ("NASAA") announced an "aggressive advocacy agenda" calling for affirmative Congressional action to promote investor confidence. During a news conference at the National Press Club, NASAA President and Arkansas Securities Commissioner Heath Abshure, and Steve Irwin, NASAA President-elect and Pennsylvania Banking and Securities Commissioner, outlined the following five specific areas in which they will seek Congressional action in the 113th Congress: 1. Promote Sustained Investor Confidence by Ensuring Market Transparency, Enhancing