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Blog Swap: Our Partners at IMS Share Their Insights

By Shelley Cernel, Director of Marketing, IMS

According to Forrester, we are 7 years into the Age of the Customer, a theory that says consumers are more empowered now than ever before and have elevated expectations for every interaction they have with a company, including their commercial real estate (CRE) firm. Technology has been a powerful driver of this concept, lowering the barriers to switching business providers and simultaneously presenting a challenge for firms to consistently provide high-value experiences for their investors. Indeed, commercial real estate investors are taking a big risk when they place their trust, and their dollars, in a CRE sponsor, and they want to feel confident that they are making the right decision. After all, choosing the right sponsor with the right portfolio opportunities can be the difference between success or failure. The sponsor, on the other hand, needs the skills, knowledge, experience, and tooling to manage the portfolio in an effective and trustworthy manner and to keep investors informed and satisfied.

Need further evidence that the investor experience should be a priority for 2018? A Salesforce study found that 1 in 2 consumers will switch firms if a company cannot anticipate their needs. And today’s clients have expectations for engagements and level of service that they never would have even imagined just five years ago.

Commercial real estate has long been an industry based on relationships where networking and face-to-face interactions are not optional.

Want to enhance client experience and engagement? Read ahead for four steps to understanding and exceeding investor expectations.

Build Meaningful Relationships

Commercial real estate has long been an industry based on relationships where networking and face-to-face interactions are not optional. Investors want to work with somebody who they trust, who has a solid track record and reputation, and who is similarly aligned in terms of values and business priorities.

Traditionally, raising capital would involve mass emailing your closest family members, friends, and peers. To build your web of contacts, you would need to attend networking events or connect with friends of friends. But now technology is making it easier and more efficient for sponsors to connect with and contact potential investors or vice versa. On the flip side, sponsors need to make a point to personalize engagements and continuously work towards building meaningful and ongoing relationships.

Invest in Technology

Investors, particularly those from younger generations, are increasingly less likely to work with people and companies that aren’t investing in their technology infrastructure or tech stack. Investors are looking for sponsors who have upgraded their operation, similar to other investment industries. They see things being done faster, smarter, or more cost effectively in other markets and expect to see the same in the commercial real estate industry. After all, you can manage your bank accounts and play the stock market online 24/7, so why shouldn’t you be able to also access your CRE investments?

Unfortunately, over 1/3 of the CRE industry still uses outdated technology on a daily basis. But many investors have already seen the progression of technology and its ability to monitor and track as key to the success of their portfolio. Further, it helps to streamline processes and drive efficiencies.

Communicate Efficiently

Effective and constant communication benefits both parties. The industry has started to shift from a demand perspective. Investors are starting to ask for more information; they want insights into deal flow, deal interaction, deal progress, and distribution history. That is why communication with investors is so important. An informed investor is obviously a good investor, but a well-communicated investor is a great investor. The more engaged and connected investors and sponsors can be, the more benefit both parties will receive from the relationship.

Today’s sponsors need to consider how they can better interact, engage, and communicate with their investors, ensuring they have the data, insights, and control that they need in real-time. Further, technology enables sponsors to communicate and provide information and data much more quickly than traditional methods, such as snail mail, enabling them to engage more readily with their investor base. Technology will lead to a deeper connection and enable effective engagement between sponsors and their investors.

Investors in today’s on-demand, instant gratification culture expect accessibility and transparency about their CRE investments, with real-time, on-demand availability offering both convenience and control.

Provide Accessibility & Transparency

Related to communication is the idea of transparency, something which 2/3 of investors cite as being an important consideration when making an investment. Investors in today’s on-demand, instant gratification culture expect accessibility and transparency about their CRE investments, with real-time, on-demand availability offering both convenience and control. Reinforcing this point is the fact that CRE is an increasingly global business. Regardless of your firm’s time zone and business hours, investors across the country or even the world need instant access to key information. Similarly, people need access beyond just their office, such as while working remote at home, while on the road for business trips and conferences, or even during their commute. With these requirements, investors expect to have their portfolio readily available online with 24/7, on-demand, real-time access, at any time and from anywhere.

Transparency also enables sponsors to build credibility with their investors. Ultimately, this open exchange of information facilitates a smoother transactional process and strongly factors into having successful long-term relationships.

It’s more important now than ever before to meet and exceed investor expectations, leveraging technology to create a value-add investor experience. As Deloitte says, “The real estate industry is on an accelerating disruption curve that will challenge industry leaders to look differently at the ways they do business and interact with their investors.” If you don’t take steps to make changes now, there’s a good chance your competitors will.

IMS Webinar Series Welcomes VENTURE.co’s Greg Brown to Panel

Sign up for the Webinar on Tuesday, June 19th at 2pm.

Recent regulations have enabled technology to streamline the capital raising process. Commercial real estate sponsors can now host their offerings on online portals, and online deals range from crowdfunding to traditional structures. This opportunity helps sponsors increase their outreach, increase fidelity, and decrease their workload. Now that so many real estate offerings are online, investors must wade through wide variety of deals. How can issuers cut through that noise to reach more investors while remaining compliant?

In this upcoming Investor Management Services (IMS) webinar, VENTURE.co’s Head of Real Estate and Registered Representative Greg Brown will join host and IMS VP of Business Development Ron Rossi and finLawyer.com attorney and former FINRA regulator Scott Anderson. This panel will explore and discuss issues surrounding:

  • Commercial real estate offerings using the issuer exemption versus a broker-dealer
  • Pitfalls of the issuer exemption 
  • Cost and benefit of using a FINRA-registered broker-dealer

Greg Brown will bring his perspective as a commercial real estate issuer and early adopter of software solutions. Greg often writes about the archaic, inefficient “sausage-making” process of raising capital before the JOBS Act (2012).  During this webinar, he will further outline what that process used to entail, and how that process has changed now that technology has enabled online distribution of offerings under Exemption 506(c) to the Securities Act. Major benefits include:

  • Smaller issuers (under $25mm) have greater access to broker-dealers and investment banks
  • Broker-dealers can reach out, on behalf of issuers, to investors with whom they have no prior relationship
  • Now that offerings are online and more widely distributed, compliance issues in some cases are easier for regulators to flag.  Importantly, under the 506(c) exemption, the accredited status of investors now must be verified.

Join us and IMS on June 19th at 2 pm, as this experienced panel discusses various trends, successes, failures, and red flags with technology-enabled commercial real estate offerings. This webinar is appropriate for issuers, sponsors, investors, or those interested in learning more about alternative investments.

Sign up for the Webinar on Tuesday, June 19th at 2pm.

VENTURE.co Brokerage Services, LLC Attracts Seasoned Broker to Management Team

New York, NY.

Joe Ventresca Headshot

VENTURE.co Brokerage Services, LLC, a FINRA-member broker-dealer, is proud to announce that Joseph (Joe) Ventresca will join the leadership team in a newly created role, Managing Director of Investment Banking.  Joe brings decades of investment banking experience advising middle market companies seeking capital, and placing investments on behalf of institutional and high net-worth clients at Merrill Lynch Private Client, Investec, and Asgard Partners.

As Managing Director of Investment Banking, Joe will lead the VENTURE.co investment banking team from the company’s Midtown Manhattan location.  He will work with companies seeking capital and increase the distribution of alternative investment products across our growing independent broker-dealer platform.  He will also help expand the market share of our proprietary software as a service solution for private securities offering compliance management, syndication/distribution, and subscription execution.

“The capital raising process is archaic whether you are raising money from institutions, family offices, or accredited investors. VENTURE.co’s brokerage and technology platform offer solutions for compliance and enhanced distribution of appropriately vetted alternative investment offerings to institutional investors, family offices, and accredited investors. Also, I see a complementary opportunity for investment advisors — enhancing access to appropriately vetted alternative investments to diversify client portfolios,” Joe said.

Aaron Pollak, CEO of VENTURE.co, said, “After working with Joe on a number of private offerings, we are delighted to announce that he will be joining the VENTURE.co team full time. Joe’s experience in the investment banking industry, combined with his entrepreneurial drive to reset inefficient processes, make him the right fit for our growing firm.”

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About VENTURE.co: headquartered in Burlington, Vermont and with offices in Midtown Manhattan, VENTURE.co Holdings, Inc. is a financial services company focused on providing alternative investment solutions.  VENTURE.co Holdings, Inc. includes subsidiaries that specialize in facilitating private placements and providing technology solutions. VENTURE.co Holdings, Inc. is the parent company of VENTURE.co Brokerage Services, LLC, a registered broker-dealer with FINRA and member of SIPC, and VENTURE.co Technologies, LLC, a technology services provider. For more information, please visit https://www.VENTURE.co.

Forward-Looking Statements
This release may contain certain forward-looking statements regarding our prospective performance and strategies within the meaning of Section 27A of the Securities Act of 1933, as amended, and Section 21E of the Securities Exchange Act of 1934, as amended. We intend such forward-looking statements to be covered by the safe harbor provisions for forward-looking statements contained in the Private Securities Litigation Reform Act of 1995, and are including this statement for purposes of said safe harbor provisions. Forward-looking statements, which are based on certain assumptions and describe future plans, strategies, and expectations of the Company, are generally identified by use of words “anticipate,” “believe,” “estimate,” “expect,” “intend,” “plan,” “project,” “seek,” “strive,” “try,” or future or conditional verbs such as “could,” “may,” “should,” “will,” “would,” or similar expressions. Our ability to predict results or the actual effects of our plans or strategies is inherently uncertain. Accordingly, actual results may differ materially from anticipated results. Readers are cautioned not to place undue reliance on these forward-looking statements, which speak only as of the date of this release. Except as required by applicable law or regulation, VENTURE.co undertakes no obligation to update these forward-looking statements to reflect events or circumstances that occur after the date on which such statements were made.

What Should I Look For In A Sponsor?

BY GREG BROWN, REGISTERED REPRESENTATIVE AT VENTURE.CO BROKERAGE SERVICES, LLC.

The views and opinions expressed in this article are those of the authors and do not necessarily reflect the official policy or position of VENTURE.co.

Private, online real estate investments are risky. Just. Like. Every. Private. Real. Estate. Investment. Ever.

There are more conservative products if you don’t like risk.

But if you are intrigued by online real estate investing, and I think you should be, read on. (Online real estate investing is not going away.)

You will rarely hear me use the word “crowdfunding”. You’ve probably heard the word bandied about in association with real estate investing. And you may also hear that crowdfunding is “disrupting” and “democratizing” real estate investing right before our very eyes.

With all due respect, “crowdfunding” is not what is happening with investment real estate. The investment process is simply moving online and away from cigar smoke-filled rooms in the back of the country club clubhouse. Sidebar: that’s not really where this happens. I’ve been in commercial real estate over 20 years and never made a deal there. I just like the visual.

All that said, crowdfunding is one of the reasons we’ve all seen a market flooded with deals that should otherwise not see the light of day. Putting together an offering package is not hard; if a deal sponsor can put together a website and manage the legal work in under $10K, they can technically create an offering. Putting together a good deal is a different story. But it can be hard to tell what’s what when you’re looking at an overwhelming number of deals.

I would be especially thorough in considering deals using the Issuer Exemption that have not been fully vetted and underwritten by a FINRA-licensed broker-dealer.

Sponsors need to know the market comparables, the new development pipeline, and the economic drivers, not just be able to cut and paste them from a market survey into an offering memorandum.

Real estate is not a commodity: it requires active, and preferably experienced, management.  When looking at a deal, I go straight to:

  • Who exactly is responsible for the deal being curated in the first place?
  • Who is going to mind it going forward?

A credible deal sponsor should have:

  1. Connectivity to the asset type. It is riskier to back a sponsor with a track record in office buildings who has suddenly pivoted to self-storage facilities. Or, a homebuilder who now wants to raise money to build a grocery-anchored shopping center.

This isn’t to say that a sponsor can’t exit an area of expertise to create a new one. There are plenty of successful real estate owners who own different types of assets. I’m just flagging it as risk-IER. Anything you do for the first time has risk. If you can handle that risk as an investor, proceed with caution. If not, stay in the right lane and find the next warehouse deal from a sponsor that has already done five warehouse deals.

  1. And/or connectivity to the submarket. There are real estate investing challenges that technology is still years away from solving. One of these is having local market knowledge. This is why high-level economic and demographic data is about as useful to a specific real estate investment as a Facebook political rant.

Top line data does not cover the political and economic power dynamics of a specific submarket. For example: is there a plan afoot to widen a road? Is there risk of a development moratorium because of a shortage of infrastructure capacity? Could there be a flood of competing products developed to devalue your investment property? You need the sponsor to have boots in-country to tap into the undercurrent of activity.  They need to know the market comparables, the new development pipeline, and the economic drivers, not just be able to cut and paste them from a market survey into an offering memorandum.

I will qualify the above by saying that the size of a deal sponsor could blow your normal considerations out of the water. Clearly, large companies have the scale and ability to draw upon assets that smaller deal sponsors do not, so keep that in mind. Sponsors can also partner with local experts, but make sure those local experts remain part of the deal going forward.

Just stay away from the deal sponsors channeling their inner Lewis & Clark.

This publication is a service to our clients and friends. It is designed only to give general information on the developments actually covered. It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion.

Investor Management Services and VENTURE.co Team Up to Offer Clients Best-In-Class Technology Along With Broker-Dealer Services

Charlotte, NC and Burlington, VT:

Investor Management Services (IMS), the leader in software for commercial real estate firms to manage their investors and assets and the only complete solution for investor management, and VENTURE.co, a registered broker-dealer with technology solutions tailored for how securities professionals, advisors, issuers, and sponsors attract and retain investors, announced today that they have entered into a strategic partnership.  This alliance will deliver best-in-class technology to VENTURE.co’s clients, along with capital raising through a registered broker-dealer for IMS’ clients.

Real estate accounts for over $100B in the private investing marketplace, yet only a small fraction of this activity has moved online.  At the same time, long-standing federal rules have changed, now allowing General Solicitation (under certain conditions, via the 506(c) exemption to the Securities Act). The combination of technology and business services offered by IMS and VENTURE.co address challenges faced by real estate deal sponsors and issuers seeking to realize the opportunity of General Solicitation, while remaining compliant with federal and states securities law.

“We set a goal for 2018 to form partnerships with firms that add value and streamline processes for our respective clients. In partnering with VENTURE.co, CRE sponsors will be able to market investment opportunities to a very sophisticated investor base through their private capital markets platform, resulting in an efficient and seamless transaction,” said Ron Rossi, Vice President of Business Development at IMS.

“We see significant opportunities for our technology to enhance how investments in real estate are acquired and managed. While we have focused on developing best-in-class transaction solutions alongside our FINRA-registered broker-dealer, IMS has focused on simplifying complex investor distribution and reporting needs in real estate transactions.  This potent integration yields the leading marketing, transaction processing, and investment management suite,” said Aaron Pollak, CEO and Co-Founder of VENTURE.co.

About Investor Management Services (IMS)

IMS Logo

Serving real estate investment firms, Investor Management Services (IMS) is the leader in the investment management software space providing the only all-in-one platform.  We enable our customers to better serve their investors while improving the efficiency of their firm.  The IMS Platform includes an Investor Dashboard, Document Management and Sharing, Customer Relationship Management (CRM), Waterfall Distribution Processing, and Analytics.  For more information, please visit https://www.imscre.com/.

About VENTURE.co

venture-logo-color-notext-squareHeadquartered in Burlington, Vermont and with offices in Midtown Manhattan, VENTURE.co Holdings, Inc. is a financial services company focused on providing alternative investment solutions.  VENTURE.co Holdings, Inc. includes subsidiaries that specialize in facilitating private placements and providing technology solutions.  VENTURE.co Holdings, Inc. is the parent company of VENTURE.co Brokerage Services, LLC, a registered broker-dealer (Member, FINRA/SIPC) and VENTURE.co Technologies, LLC, a technology services provider.  For more information, please visit https://www.venture.co/.

Issuer Exemption Pitfalls

by Andrew Szabó CFA, Chief Compliance Officer at VENTURE.co Brokerage Services, LLC.

The views and opinions expressed in this article are those of the authors and do not necessarily reflect the official policy or position of VENTURE.co.

To raise capital in the market, the 1933 Act requires that a company issuing non-exempt securities must:

  •  qualify for an issuer exemption, or
  • employ a licensed broker-dealer, or
  • register itself in each state as a securities dealer.

Frankly, however, many issuers blunder, thinking they can employ the issuer exemption, while falling outside of it and leaving themselves at profound risk. This is especially common in the real estate field but is not limited to it. Let’s look more deeply at this problem.

Who gets to use the issuer exemption?

The issuer exemption was meant to provide a safe harbor for employees or directors of the issuer, so that small businesses could raise money more easily and inexpensively. This safe harbor would allow the issuer to avoid registering as a broker-dealer, as they are acting on behalf of their company, not buying and remarketing the securities of a third party.

Does state law create any perils in relying on the issuer exemption?

Yes, there are perils in part stemming from the patchwork of state regulations. In Maryland, New York, and Texas, for example, if you use any form of General Solicitation, then you lose the issuer exemption.

Must issuers follow the same state and federal regulations as a licensed broker-deal in relying upon the Issuer Exemption?

Absolutely. Such rules apply to such matters as accreditation, investor communications, document retention, escrow accounts, risk disclosure, conflicts of interest, related party transactions, Rule 10b-5, “forward-looking statements” and state registration, among others.

What about the use of finders–that’s not a problem, is it?

It can be a big problem. If any part of a finder’s compensation is geared to success in raising capital, or to a formula (such as one related to transaction size), that finder must be licensed in the securities business and affiliated with, and compensated through, a broker-dealer. If not, the issuer, the issue itself, and the finder are all at legal peril. The use of such finders is not always detected by regulators upon issuance, but this delict may well be discovered and pursued by plaintiffs or prosecutors if problems develop later with a deal.

Under the Issuer Exemption, is the Issuer subject to examination by the SEC and by state securities authorities?

Yes. And because many issuers lack sophisticated tools to preserve information about investment material distribution, including content, versions, who read the materials and exact timing, it may be difficult or impossible for such issuers to evidence important aspects of the capital-raising process.

Are there other dangers in relying upon the Issuer Exemption?

Yes, the SEC has ruled that if certain employees or officers of the issuer are paid chiefly to sell securities and have few other duties, they may be deemed “brokers” under law. Further, for issuers who bring more than one issue in any single year, there are strict regulations under the Issuer Exemption.

Is the VENTURE.co platform a marketing and compliance panacea?

No, of course not. What we at VENTURE.co do claim is a broad-ranging set of solutions that can be customized (with the help of our skilled staff) to meet a wide range of marketing and compliance needs. We also claim that our solutions dovetail well with, and greatly facilitate, the work of financial operations, compliance, legal and accounting professionals, whose services remain essential. However, with our tools, issuers may find that that they are spending less on routine compliance tasks, relying instead on these professionals for more complex judgments.

This publication is a service to our clients and friends. It is designed only to give general information on the developments actually covered. It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion.

VENTURE.co Presents at CBC: How To Raise Capital Online

By Greg Brown, Registered Representative at VENTURE.co Brokerage Services, LLC.

The views and opinions expressed in this article are those of the authors and do not necessarily reflect the official policy or position of VENTURE.co.

I was in Orlando, Florida this week to present to attendees of Coldwell Banker Commercial’s (CBC) Annual Conference on “How To Raise Capital Online.”  We walked through changes to regulatory policies, as well as the nuts and bolts of how to set up an online machine to raise equity for deals. We talked about how the JOBS Act (2012), specifically the possibility of “General Solicitation” under the 506(c) exemption, is a big deal for real estate capital.

The questions from the group were great, as many in the room really understood the power of increased access to capital through the use of technology.  It was exciting to watch the wheels turning in the heads of those in the room about how they could use the tools of VENTURE.co for their own assets and those of clients.

One great discussion had to do with asset recapitalization.  Many current owners of investment real estate would be interested in “taking some chips off the table,” but they don’t want to pay the associated taxes, or they don’t want to go through the struggle of trying to find something to exchange into.  We discussed using the VENTURE.co platform to help their clients source new slugs of Limited Partner equity, allowing owners to improve their cash positions as we get closer to the end of this real estate cycle (get back to me on the exact end-date).

Thanks for the time, CBC!

This publication is a service to our clients and friends. It is designed only to give general information on the developments actually covered. It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion.

Why do Deal Sponsors Charge Fees?

By Greg Brown, Registered Representative at VENTURE.co Brokerage Services, LLC.

The views and opinions expressed in this article are those of the authors and do not necessarily reflect the official policy or position of VENTURE.co.

Putting together a real estate deal is similar to herding cats. But only if those cats are like the ones in the cult classic film Roar, in which a family and its pets, untamed lions (among other animals), are profiled. 70 members of the cast and crew were injured.

And I’m equating this to putting together a real estate deal? I kid. But not by much.

By the time a deal is ready for the investment stage, a sponsor has gone through many hoops to put it together. Saying it’s a lot of work is an understatement.

Now, when I say “deal”, I’m not talking about the creation of marketing slicks and 10-year discounted cash flows. I’m talking about the entrepreneurs who have a vision for a property or project and, at significant risk, attempt to create a vehicle for investment.

You get what you pay for in life. Except in Vegas, where you pay double.

In my view, the long-standing, inefficient sausage-making process that brings a deal to market, by its very nature, requires compensation. If something is easy, anybody can do it. But putting a real estate deal together is, once again, hard work and deserves just compensation.

Because here’s the reality: most opportunities die before they even get close to the stage for raising capital.

I bring this up because too many investors immediately zero in on the fees a sponsor charges in a deal. To me, this is wrongheaded. Here’s why: if a deal sponsor has a solid track record and is offering investors returns commensurate with the risk, “pay that man his money” (-Teddy KGB in the best scene of Rounders).

This doesn’t mean you should brush over a deal’s fee structure. You should focus on it. Just be smart about analyzing it.

  • Make sure the sponsor’s fees aren’t too heavily front-end loaded. The sponsor should have skin in the game down the line, when things could potentially go bad.
  • Is the deal sponsor using fees earned as equity in the deal? If yes, this is not necessarily a bad thing. It shows the sponsor is willing to put their money where their mouth is—and that is a good thing. I would be much more concerned if a sponsor charged a high fee, up front, with little or no reason for the sponsor to ensure the project’s success in the future.
  • When comparing different investments make sure the returns you are comparing are both before fees and after fees. Sponsors are required to disclose all fees. However for return calculation purposes, some sponsors may present the returns not inclusive of all fees associated with a deal. Just make sure you know what the returns are projected to be NET of ALL fees.

If an investment fits your investment goals and has the fundamentals to be successful, don’t be in a hurry to prejudice that deal because it has a significant fee to the sponsor. You get what you pay for in life. Except in Vegas, where you pay double.

This publication is a service to our clients and friends. It is designed only to give general information on the developments actually covered. It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion.

Meet Greg Brown

By Greg Brown, Registered Representative at VENTURE.co Brokerage Services, LLC.

The views and opinions expressed in this article are those of the authors and do not necessarily reflect the official policy or position of VENTURE.co.

Greg Brown HeadshotIf you are looking for windsor knots, french cuffs and real estate perspectives from the top of the ivory tower, this is not the blog for you.

To kick off this blog, let me say something brief about myself. I have a 20+ year career in commercial real estate. Currently, I am Managing Director of NAI DiLeo Bram in Central, NJ, and I’m also a Registered Representative (Series 7/63) with VENTURE.co, a FINRA-registered broker-dealer, where I lead the real estate division.

So why write a blog? Besides every blog on career advice on social media telling me, “You should write a blog”? Because I am passionate about making private real estate capital markets work more efficiently for stakeholders across the board.

For too long it has been nearly impossible for investors to efficiently source quality real estate investments. I aim to be part of the solution. I’m tackling a variety of topics including: how to look at real estate deal sponsor fees, what to look for in a deal sponsor, how to think about assumptions in real estate modeling and reviews on specific deals I find compelling.

So who should read my blog?

  • Current or potential private real estate investors (this likely means you’re accredited) who would like some guidance on cutting through all the noise to sharpen their investment decision-making.
  • Deal sponsors who want to bring transparency and efficiency to the deal-making process—and want to understand what investors these days are struggling with.
  • Anyone who thinks applying fintech to private real estate investment can make the investment process much better.
  • Your mom. I promise she’ll think I’m awesome.

If you are looking for windsor knots, french cuffs and real estate perspectives from the top of the ivory tower, this is not the blog for you. If it is, I hope you stick around. Talk soon.

This publication is a service to our clients and friends. It is designed only to give general information on the developments actually covered. It is not intended to be a comprehensive summary of recent developments in the law, treat exhaustively the subjects covered, provide legal advice, or render a legal opinion.