Date: September 12, 2016

Issue: Capital Formation

To: Vermont Department of Financial Regulation, Ohio Department of Commerce, and North American Securites Administratiors Association (NASAA)

Filing Type: Regulatory

Description: The U.S. Chamber of Commerce writes to express our deep concern relating to North American Securities Administrators Association, Inc.’s (“NASAA”) proposed amendments to its Statement of Policy Regarding Real Estate Investment Trusts (the “Proposed
Amendments”), as we believe that these amendments will significantly impact continued investment in the real estate industry and deprive investors of all types with access to an important asset class: non-traded real estate investment trusts (“nontraded REITs”).

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