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Thursday, December 17, 2020
New York recently adopted new regulations that redefine the categories of “dealer” that would require mandatory notice and fee filings.  The new regulations outline that the following issuers selling securities will be “dealers” (Dealers) under the New York Martin Act, and will be subject to new filing requirements, with mandatory compliance effective Feb. 1, 2021:
Federal Covered Regulation D Dealers
Federal Tier 2 Dealers
Federal Covered Investment Company Dealers
All other dealers that are issuers not falling under Section 359-e(1)(a) definition1 of dealer that issue real estate securities, and/or are not defined as any of the Dealers listed above, will be required to file the Form M-11, unless an available exemption from filing the Form M-11 is available and written application for the exemption is submitted. ....

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