Comment on File No. S7-2026-17, Registered Offering Reform
TOBIN backed the SEC’s push to strip away state-by-state merit review for registered offerings. Her data point: non-traded REIT fundraising collapsed from $33.2 billion to $5.7 billion as issuers fled into private placements to escape the burden. Justine argued that removing duplicative state oversight keeps investor protections intact while bringing capital raises back into the registered, transparent market.