NASAA Seeks Comment on a Model Rule for Electronic Blue Sky Filings


The North American Securities Administrators Association, Inc. (NASAA) posted a web notice requesting comment on model rules that would provide for electronic filings with the states of Form D and other state securities registration and notice filing materials.

One version of the model rule would provide for Form D, amendments and the related processing fees to be filed with NASAA’s Electronic Filing Depository (EFD).  An alternative version would require all state securities registration and notice filings (including Form D), amendments and exemption filings, and the related fees, to be filed with the EFD.  Both rules would require electronic filings after the EFD is capable of receiving these filings and an appropriate notice has been provided to issuers by the relevant state administrator.  Both proposed rules allow electronic signature.

The EFD system will initially be limited to Form D filings and is expected to be deployed in November 2014.  NASAA expects to expand the EFD’s capabilities to accept all state securities registration and notice filing materials.

Comments on the proposed rules are due on or before July 30, 2014.

The NASAA notice can be found at:



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