【正文】 es in the asset value。 (5) A dramatic increase in the number of manager relationships and mingled investment vehicles provided less control, poorer governance and hindered staff39。 experience during the past 28 years suggests that a real estate strategy focused primarily on direct investment in corerisk type properties has provided a more attractive risk adjusted return than the more aggressive opportunistic strategy. PCA finds significant merit in the overall context of the CalPERS investment program in pursuing a less aggressive strategy. With more controls, than was in place between 2020and 2020. 4 Will this mean that public pension funds increasingly will focus on the same core, stable assets that are being pursued by global investment fund? Perhaps, but in the real estate program review the staff notes that at current values the CalPERS actual real estate investment portfolio is at percent of total asses versus the target allocation of 10 percent and the dislocation in the real estate market will present investment opportunities, which is good news for the real estate capital market. FIARA AND PRIVATE PLACEMENT As noted above, congress is considering adding additional structures to the private placement market. while it is un clear how many of those structures will survive the legislative process, the Financial Industry Regulatory Authority (FINRA), acting as the watchdog of the securities brokerdealers and securities registered representatives who sell private placements of, among other assets, real estate and oil and gas, has published new regulatory guidance as to the obligation of brokerdealers to conduct Reasonable Investigations in Regulation D Offering. Private placement, or socalled Regulation D or Regulation 506 offerings sold through the securities brokerdealers channel, have a long and constructive history of raising capital for small and midsized business , including real estate and oil and gas panies .in the background section of RN 1022,FINRA cites an estimate of $609 billion of such securities on the market in 2020. FINRA cites an estimate of $609 billion of such securities on the market in 2020. However, FINRA reminds its member brokerdealer must have made a reasonable investigation before determining that a security is suitable for investor generally and to the specific investors to whom it is being sold.[RN 1022]obviously this is all very general ,leaving fertile ground for interpretation. perhaps more to the point on a practical level, FINRA reminds brokerdealers that they may conduct their own independent investigation of the issuer and the offering, and not simply rely on information provided by an independent counsel or due diligence firm hired by the brokerdealers, or the syndicate manager, the managing brokerdealer, the brokerdealer independent investigation has to include a reasonable investigation at a minimum into the following issuers: 5 (1) The issuer and its management。 and (5) The intended use of proceeds of the offering [RN 1022] FINRA also add adds a cautionary note on two particular areas of concern: (1) when the brokerdealer is an affiliate of the issuer and (2) when the brokerdealer and now the issuer prepare the private placement memorandum. [RN 1022] It also reminds brokerdealers to look for red flags, financial statements that, although purportedly audited by an accountant, contain numerous indications that the financial statements are inaccurate. Beyond these general principles, after a reminder of supervisory and documentation responsibilities, FINRA