• NorthStar - ASSET MANAGEMENT GROUP 

Mr. Fred Wong 

Office of Regulations and Interpretations 

Employee Benefits Security Administration 

Attn: Conflict of Interest Rule, Room N-5655 

U.S. Department of Labor 

200 Constitution A venue, NW 

Washington, DC 20210 

Dear Mr. Wong and Ms. Lloyd: 

399 Park Avenue. 18" Roor I New York, NY 10022 

p 21 2.547.2600 I f 212.547.2700 I www.nsamgroup.com I NYSE: NSAM 

Ms. Karen E. Lloyd 

Office of Exemptions Determinations 

Employee Benefits Security Administration 

Attn: D-11712 

U.S. Department of Labor 

122 C St. NW, Suite 400 

Washington, DC 20210 

I am writing on behalf of NorthStar Asset Management Group Inc. ("NorthStar") to request a 45-day 

extension of the comment periods for (1) the proposed rule entitled "Definition of the Term 'Fiduciary'; 

Conflict of Interest Rule -Retirement Investment Advice" (RIN: 121 0-AB32), (2) the proposed class 

exemption entitled "Proposed Best Interest Contract Exemption" (ZRIN: 121 O-ZA25), and (3) the related 

proposed and amended prohibited transactions exemptions that were issued by the U.S. Department of Labor 

(the "DOL") and published in the Federal Register on April 20, 2015 (together the "Proposal"). NorthStar is a 

traded public global asset management firm (NYSE: NSAM) focused on strategically managing public real 

estate companies and other investment platforms in the United States and internationally with approximately 

$22 billion of assets under management. The market capitalization of NorthStar's traded public companies 

exceeds $10 billion. 

NorthStar is also a leading sponsor of alternative investment programs that are sold by financial 

advisors to individual investors, often through their individual retirement accounts, currently managing five 

programs (four non-traded real estate investment trusts and one non-traded business development company) 

that are either active or in registration with a total targeted capital raise of over $7.5 billion. 

The regulations defining a fiduciary have not been updated since they were originally issued in 1975. 

However, these regulations have been the subject of much debate. On October 22, 2010, the DOL published a 

proposed rule regarding the definition of the term "fiduciaty, " and this proposal, along with a subsequent 

hearing, generated in excess of 3 50 comment letters. The comment period for the rule proposed in 201 0 was 

extended from its initial duration and ultimately did not terminate until February 3, 2011, 104 days after its 

publication. 

As a long-time manager of both traded and non-traded public companies with a successful track record 

of building and sustaining shareholder value, we have always been supportive of shareholder transparency and 

accurate and clear reporting. As such and given our status as a large institutional participant in the markets 

impacted by the Proposal, we have a vested interest in insuring that any regulations impacting our current or 

future shareholders be as well understood and vetted as possible and that all potential impacts are analyzed and 
discussed. As the DOL accurately stated in the executive summary of the rule proposed on April20, 2015, the 

changes contemplated by the DOL represent a "broad regulatory package" and we strongly believe that an 

extension ofthe comment periods is necessary for all impacted parties to fully analyze the scope of this broad 

package and to make comments based on a comprehensive view of the current marketplace and regulatory 

regime. Thank you for your consideration of this request. 

Sincerely, 

Daniel R. Gilbert 

Chief Investment and Operating Officer 

cc: Rosemarie A. Thurston, Alston & Bird LLP