Written by: Phil Feigin
My life and career changed dramatically and forever in July 1982. I have been encouraged to do some reflecting on times past every once in a while. I couldn’t help but think back to 30 years ago this summer. It was one of those pivotal periods in my life—which is not particularly important to anyone but me, my family and friends—but also in securities regulation and the maturation of the North American Securities Administrators Association (“NASAA”).
Let me set the stage, first on NASAA. Until the late 1970s, NASAA was an organization where the “blue sky” administrators, the bosses, met twice a year, in Washington, D.C. in the spring and a host state venue in the fall. The administrators were usually outnumbered by a large multiple by industry professionals from brokerage firms, investment companies, law firms and the like. It was a good opportunity to discuss events, issues and projects blue sky staffs had been working on back home. NASAA was funded by the dues paid by the blue sky agencies and their jurisdictions. Therefore, it was usually the bosses alone who got to attend the meetings, and only those administrators able to obtain state funding for the trips.
Investing was becoming a middle class/consumer fact of life to an ever increasing degree, inflation was rampant, and brokers across the country were reaching out to investors everywhere, not just where the brokers had their offices. That meant that both firms and agents had to fill out forms, take qualification examinations and meet other requirements of each state jurisdiction where they sought investors, on top of what they had to do for the SEC and the NASD. That was becoming an unholy mess.
The late 1970s and early 80s saw an unusual spasm of uniformity and cooperation that must be marveled at and commended. The SEC, the states and NASAA, and the NASD worked together to come up with uniform forms, entry requirements and tests, and a computerized system for administering all of it. The most recognizable feature of the new system was the Central Registration Depository, or CRD. There were bumps in the road to be sure, and it wasn’t perfect, but the CRD and coordinated registration/licensing process for firms and reps remains a model and paragon for every multistate/federal regulatory registration/licensing structure.