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ent 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。s Corner: An Interesting Time For Real Estate Has there ever been a more interesting time in real estate finance? Happier times, yes, more profitable times, definitely yes .But more interesting? The year leading up to September 2020 saw the creation of real estate finance structures of breathtaking plexity .since than time in the real estate finance industry have been involved mainly in trying to understand what went wrong, and to determine whether the collapse, was in any material way the result of flaws in these plex real estate finance structures .or was it just a function of external economic pressures and the cyclical nature of real estate .while the jury is still out. The answer seems to be that the structures did not cause the real estate recession, but through their opaque nature they may have made the recession worse, both by delaying the recognition of the underling fragility of the market and by making the problems, once recognized, even more difficult to resolve. One thing is sure: many people, whether legislators, regulators, lawyers, accountants, bankers or those who raise and consume real estate capital are now working very hard to address(1) how to resolve distressed real estate capital structures, and (2)how to improve the structures and form of delivery of real estate capital to the market in the future. Change being considered now will affect the real estate markets through the next generation. Following are a few examples. RESTORING AMERICAN F