RER argues that a clause in the legislation--which was enacted after the September 2001 terror attacks to give the government the right to shut down financial opportunities for potential financers of terrorist organizations--would unduly burden legitimate commercial real estate transactions with overwhelming administrative record-keeping to accommodate the new law. "Roundtable asks that the Treasury Department consider the relatively small risk that commercial real estate transactions pose, as compared to the proposed burdens, when determining the scope of the final regulations, and to recognize that the settlement stage is not when significant investigative requirements should be imposed," RER officials write in the letter. "We believe the proposal could have the unintended consequence of imposing an unfair level of regulatory burden on the commercial and multifamily real estate industry."
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