CIM Real Estate Finance Trust Tender Offer, Investigation and Loss Recovery Options

Investors of CIM Real Estate Finance Trust, formerly known as Cole Credit Property Trust IV, should know that Haselkorn & Thibaut ( have started an investigation into alleged improper sales of the investment to investors. This non-traded REIT is allegedly planning to reposition its portfolio into commercial mortgage loans and intends to sell off its portfolio of shopping center and real estate assets, to do so.

CIM Real Estate Finance Trust, Inc. (CMFT), a company formerly known as Cole Credit Property Trust IV, is a non-traded real estate investment trust (REIT) that originally sold shares of stock for $10 each.

Several law firms are currently investigating legal claims on behalf of CMFT investors, including our firm, Haselkorn & Thibaut, The allegations involve improper sales of the investment to investors and possible securities fraud.

CIM REIT investors can 1-800-856-3352 for a free consultation with one of our experienced securities fraud lawyers on recovery losses. There is limited time to file claims.

CIM Real Estate Tend Offers

Mackenzie Realty Capital Offer 2019

In a recent letter to investors, Mackenzie Realty Capital, Inc. offered $4.79/share to investors up until 12/30/19.  The REIT estimates share value at a stated value of $8.65/share (as of December 2018).  Notwithstanding those estimates, the most recent trading range a secondary market data source reported was in the $6.35/share to $6.53/share range.  See Central Trade and Transfer data.

Comrit Investments 1 LP Tender Offer 2023

Comrit Investments 1 LP, a Tel Aviv-based investment fund company, has reportedly extended an unsolicited tender offer to purchase up to 22.4 million shares of CMFT stock for $4.61 per share. Comrit’s potential proposal involves acquiring as many as 22 million shares in CIM Real Estate Finance Trust Inc. at a price of $4.57 per share. As of November 8, 2022, Comrit held around 3.1 million shares of CIM REIT’s common stock, accounting for 0.7% of the total common stock. The net asset value (NAV) per share for CIM REIT was estimated at $6.57 on September 30, 2022, and it was recently traded on LODAS Markets at $5.42 per share. This may indicate significant losses for investors who originally purchased shares at $10 each.

Cole Credit Property Trust IV - CIM GROUP
Cole Credit Property Trust IV – CIM GROUP

CIM Real Estate Finance Trust Suitability and Supervision Issues

These investments are generally offered by financial advisors working at independent broker-dealer firms.  They represent one type of transaction: Direct Participation Programs (DPPs).  Non-Traded REITs are typically risky illiquid alternative investments that the United States Securities and Exchange Commission (SEC) defines as a “Reg D” offering, also known as “private placement.” The reference to Regulation D provides exemptions from the typical registration requirements of Section 5 of the Securities Act of 1933.

A brokerage firm selling a private placement still has a duty to conduct a reasonable investigation of any securities it recommends. FINRA found problems in the past concerning some private placements were significant and included alledged fraud and sales practice abuse in Regulation D offerings.  With private placements, the firm recommending the investment to a customer must also conduct a reasonable investigation into the issuer and its management, the future business prospects of the issuer, the assets held by or to be, total assets acquired by the issuer, the claims being made by the issuer, and the intended use of the offering.

Failure of a firm to adequately investigate a given private placement transaction can violate federal securities law antifraud provisions, FINRA Rule 2010 (adherence to just and equitable principles of trade), and Rule 2020 (prohibiting manipulative and fraudulent devices).  In addition to various cases and enforcement actions cited in Regulatory Notice 10-22 (and its endnotes), another sweep by FINRA resulted in more crackdowns on firms and affiliates (and individuals) that did not conduct a reasonable investigation before selling private placements to customers.

Also, concerning private placement investments, broker-dealer firms still must supervise their brokers in the investigation and recommendations being made to invest with the customer.  In addition to the typical supervision duties that the board of a broker-dealer firm has over its registered representatives, as required by FINRA Rule 3010, private placements necessitate additional supervisory procedures.

As reminded by FINRA Regulatory Notice 10-22, those additional supervisory procedures must be reasonably designed to ensure that a broker-dealer firm’s registered representatives: (1) engage in an inquiry due diligence that is sufficiently rigorous to comply with their legal and regulatory requirements; (2) perform the analysis required by FINRA Rule 2111 (formerly, NASD Rule 2310); (3) qualify their customers as eligible to purchase securities offered pursuant to Regulation D; and (4) do not violate the antifraud provisions of the federal securities laws or FINRA rules in connection with their preparation or distribution of offering documents or sales literature. Importantly, each Reg. D offering must be properly supervised “before it is marketed to other firms or sold directly to customers.”

CIM Group Investors Seeking to Recover Losses

For some investors, a private FINRA arbitration customer dispute enables them to bring a claim and potentially recoup their investment losses.  These customer disputes typically involve only paper discovery and no depositions. They are a faster and more efficient alternative to traditional court litigation, as they provide a private forum to resolve disputes between shareholders more quickly and efficiently.

About Haselkorn & Thibaut, P.A.

Haselkorn and Thibaut, P.A. is a nationwide law firm specializing in handling investment fraud and securities arbitration cases. The law firm has offices in Palm Beach, Florida, on Park Avenue in New York, as well as in Phoenix, Arizona, and in Cary, North Carolina.  The two founding partners have nearly 45 years of legal experience.

Haselkorn & Thibaut, P.A. has filed numerous (private arbitration) customer disputes with the Financial Industry Regulatory Association (FINRA) for customers who suffered investment losses relating to issues similar to those abovementioned matters. No depositions are typically involved; those cases are typically handled on contingency with no cash recovery and no fee fees.

Experienced attorneys at Haselkorn & Thibaut, P.A. are available for a free consultation as a public service. Call today for more information at 1-800-856-3352 or visit our website and email us from there at

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