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One mutual fund respondent noted the elimination of merit review (Mentor Funds) and another reported that the majority of states accept uniform Form NF (Nationwide).
One company noted that there appears to be an easing of secondary market trading restrictions (Obie Media).
Thirteen respondents indicated that there have been no changes since NSMIA. Another three indicated that they did not have sufficient knowledge and experience to respond to this question.
f. Question 6. Exigent asserted that interests in employee benefit plans should be exempted from state registration and review by self-executing exemptions, i.e., exemptions not requiring notice filings or fees. BellSouth, whose securities are quoted on the NYSE and are therefore "covered securities" and exempt from state registration requirements, recommended that interests in employee benefit plans should be "covered securities" and exempt from state registration and review if the employer's securities are "covered securities."
Simulations asserted that state blue-sky costs decrease the assets of securities issuers to the detriment of investors. Strayer noted that some states appear to be motivated economically by requiring fees and filings. This respondent suggested that all states should follow the same laws with respect to registration of securities.
With respect to investment companies, Nationwide recommended that all registration periods terminate two months following the end of the fiscal year and that fees should be paid on sales from the previous year. Mentor Funds questioned whether New York could fail to recognize the date of receipt of Form NF as the effective date.
Regarding asset-backed securities, Norwest Asset suggested that the states should be encouraged not to require closing reports at the end of each reporting period.
Thirteen companies gave no response to this question.
The BSE noted the application of coordinated review procedures by the states after NSMIA.
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