Todd Yancey

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NASAA Concentration Limits

October 26, 2016 By Todd Yancey

In my career, and especially in my current position as CSO of Investor Services, I have had the great and somewhat unusual experience of getting to know stakeholders who work across all sub-sectors of the alternative asset industry. It is always a highlight for me to get to see my friends and business associates a the ADISA conference every year, and to interact with the organization and its many accomplished and interesting members at other community events. I am hoping to increase my level of involvement with the organization and its members even further in 2017 by being elected to serve on the board.

One of the motivating factors for my decision to run for a position on the ADISA board is that this year, as I have invested considerable time and effort into turning the IRA Services Trust Company brand into one that meets the needs of a bigger (and up til now, radically underserved community), I have come to an even more meaningful appreciation of the different ways that ADISA advocates on behalf of its community members, and looks out for all of our interests.

One hot topic for those of us involved in the alternative asset community is issue of the recent proposal that NASAA’s Policy Project Group recently submitted, a proposal that would amend the existing REIT guidelines to include a uniform cap on an investor’s exposure to non-traded REITs that is equal to 10% of that investor’s “liquid net worth”

While the members of NASAA’s Policy Project Group no doubt had excellent intentions when drafting the proposed amendment–intentions that have the best interest of all investors at heart– I am glad to see ADISA activating its member community against it for several reasons.
As we have built the Investor Services Cloud Platform, I’ve come to a new appreciation of how different customers need and respond to different things. They have different preferences for how they use technology, interpretations of what diversification looks like, preferences for how often and through what media they are contacted…it’s difficult to come up with a logo that reaches everyone, so how is it realistic to think that it’s possible to pass a regulatory amendment that looks out for the best interest of everyone it impacts?

Certainly, there are investors that are best served by limiting their non-asset REIT exposure, but there are others for whom the 10% cap is actually harmful. Moreover, any legislation like this fundamentally undermines the relationships that investors have with their financial advisors. Like the relationship between a patient and his or her doctor, it is one that depends on mutual trust and a comprehensive knowledge of the investor’s immediate and long-term goals. Further regulations impose limits on an advisor’s ability to offer his or her best possible advice, the type of advice that is customized and personal, and that takes into account so many factors that regulations simply can’t accommodate. So many ADISA members are investors, or advisor–or both– and I appreciate their efforts to mobilize this incredible community to make their voices heard on the issue. If you would like to add your voice to those of us who oppose a uniform limit on REIT investing I encourage you to do so here:

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Filed Under: Investor Services, Investor Services Cloud Platform, IRA Services

Chief Revenue Officer @iTrust. Previously @SAP, @IBM, and @Oracle. Focused on culture, technology, and innovation. Devoted to family, friends, and a better world.

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About Todd Yancey

Todd Yancey is the Founder and Chief Revenue Officer for Investor Services, providing Digital Asset Custody for Financial Institutions, and the former Chief Strategy Officer and Executive Board Member of Forge Trust, a financial services firm offering transaction and custody solutions.

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