In response to request for comment: Current, licensing requirements for real estate capital transactions (e.g., private debt and equity placements, M&A, and Sales) are too numerous (e.g., SIE, S63, S22, S79, and S82), overlapping, time consuming, and do very little to protect investors (Accredited Investors and Institutions). This is further compounded by additional licensing requirements from each state (e.g., real estate broker license).