TIC Monthly

TICM: How will the SEC's newly approved Form D andmandated electronic filing affect TIC sponsors, and what do theyneed to know?

Froling: I was involved in the American BarAssociation's comment letter to the SEC on this, and there was alot of back and forth on Reg D stuff, and some discussion anddissension within various groups as to good things and bad things.I don't think they've published the final rule yet. I've only seenthe press release. The phase-in is going to be in September of '08,so we've got another nine months before it even starts, and it'snot mandatory until March of '09. That gives some period of timefor the states to figure out how they're going to deal with it.Trying to get 50 states to agree on how fees and those kinds ofthings are going to be facilitated is an implementation issue thatneeds to be resolved. What's the purpose of having one-stop filingif you still have to send the fees to the states? I'm interested tosee how the states are going to deal with it, and we're not goingto know that for a period of time.