TAILIEUCHUNG - STATEMENT OF POLICY REGARDING REAL ESTATE INVESTMENT TRUSTS

Citing the Fair Debt Collection Practices Act (FDCPA), attorneys allegedly representing credit card holders submitted letters to financial institutions demanding that the institutions cease communication with the accountholders, including phone calls to accountholders and communications that involved the transmittal of monthly statements, annual privacy notices, change in terms notices, and collection letters. The attorneys falsely told the customers that once the financial institutions received the demand letters the financial institutions could not pursue further collection efforts. Other purported attorneys signed up thousands of credit card debtors for debt management services by claiming they would provide legal services to. | STATEMENT OF POLICY REGARDING REAL ESTATE INVESTMENT TRUSTS As revised and adopted by the NASAA membership on May 7 2007 I. INTRODUCTION A. Application 1. This Statement of Policy applies .to qualifications and registrations of Real Estate Investment Trusts REITs 2. While applications not conforming to the standards contained herein shall be looked upon with disfavor where good cause is shown certain guidelines may be modified or waived by the Administrator. B. Definitions 1. ADMINISTRATOR The official or agency administering the Securities laws of a jurisdiction. 2. ACQUISITION EXPENSES Expenses including but not limited to legal fees and expenses travel and communications expenses cost of appraisals nonrefundable option payments on property not acquired accounting fees and expenses title insurance and miscellaneous expenses related to selection and acquisition of properties whether or not acquired. 3. ACQUISITION FEE The total of all fees and commissions paid by any party to any party in connection with making or investing in mortgage loans or the purchase development or construction of property by a REIT. Included in the computation of such fees or commissions shall be any real estate commission selection fee DEVELOPMENT FEE CONSTRUCTION FEE nonrecurring management fee loan fees or points or any fee of a similar nature however designated. Excluded shall be development fees and CONSTRUCTION FEES paid to PERSONS not affiliated with the SPONSOR in connection with the actual development and construction of a project. 4. ADVISOR The PERSON responsible for directing or performing the day-to-day business affairs of a REIT including a PERSON to which an Advisor subcontracts substantially all such functions. To the extent the provisions of this Statement of Policy are germane they shall apply to self-administered REITS. 5. AFFILIATE An AFFILIATE of another PERSON includes any of the following a. any PERSON directly or indirectly owning controlling or holding with power .

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