Cottonwood Residential O.P. D/A Indefinite amount in equity, sold $49.2M, 289 investors

The Securities and Exchange Commission has not necessarily reviewed the information in this filing and has not determined if it is accurate and complete.
The reader should not assume that the information is accurate and complete.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM D

Notice of Exempt Offering of Securities

OMB APPROVAL

OMB Number:	3235-0076
Estimated average burden
hours per response:	4.00

1. Issuer's Identity

CIK (Filer ID Number)

Previous Names

X None

Entity Type

0001480126

	Corporation
X	Limited Partnership
	Limited Liability Company
	General Partnership
	Business Trust
	Other (Specify)

Name of Issuer

Cottonwood Residential O.P., LP

Jurisdiction of Incorporation/Organization

DELAWARE

Year of Incorporation/Organization

	Over Five Years Ago
X	Within Last Five Years (Specify Year)	2009
	Yet to Be Formed

2. Principal Place of Business and Contact Information

Name of Issuer
Cottonwood Residential O.P., LP
Street Address 1		Street Address 2
6350 SOUTH 3000 EAST, SUITE 510
City	State/Province/Country	ZIP/PostalCode	Phone Number of Issuer
SALT LAKE CITY	UTAH	84121	801-278-0700

3. Related Persons

Last Name	First Name	Middle Name
Christensen	Chad
Street Address 1	Street Address 2
6350 South 3000 East, Suite 510
City	State/Province/Country	ZIP/PostalCode
Salt Lake City	UTAH	84121

Relationship: X Executive Officer X Director Promoter

Clarification of Response (if Necessary):

President and Chairman of the General Partner of the Issuer

Last Name	First Name	Middle Name
Shaeffer	Daniel
Street Address 1	Street Address 2
6350 South 3000 East, Suite 510
City	State/Province/Country	ZIP/PostalCode
Salt Lake City	UTAH	84121

Relationship: X Executive Officer X Director Promoter

Clarification of Response (if Necessary):

CEO of the General Partner of the Issuer

Last Name	First Name	Middle Name
Christensen	Gregg
Street Address 1	Street Address 2
6350 South 3000 East, Suite 510
City	State/Province/Country	ZIP/PostalCode
Salt Lake City	UTAH	84121

Relationship: X Executive Officer X Director Promoter

Clarification of Response (if Necessary):

Executive Vice President and General Counsel of the General Partner of the Issuer

Last Name	First Name	Middle Name
Spohn	Debra
Street Address 1	Street Address 2
6350 South 3000 East, Suite 510
City	State/Province/Country	ZIP/PostalCode
Salt Lake City	UTAH	84121

Relationship: X Executive Officer Director Promoter

Clarification of Response (if Necessary):

Senior Vice President, Head of Operations of the General Partner of the Issuer

Last Name	First Name	Middle Name
Hallenberg	Susan
Street Address 1	Street Address 2
6350 South 3000 East, Suite 510
City	State/Province/Country	ZIP/PostalCode
Salt Lake City	UTAH	84121

Relationship: X Executive Officer Director Promoter

Clarification of Response (if Necessary):

Chief Financial Officer of the General Partner of the Issuer

Last Name	First Name	Middle Name
Marlin	Eric
Street Address 1	Street Address 2
6350 South 3000 East, Suite 510
City	State/Province/Country	ZIP/PostalCode
Salt Lake City	UTAH	84121

Relationship: X Executive Officer Director Promoter

Clarification of Response (if Necessary):

Senior Vice President, Marketing of the General Partner of the Issuer

Last Name	First Name	Middle Name
Fredenberg	Paul
Street Address 1	Street Address 2
6350 South 3000 East, Suite 510
City	State/Province/Country	ZIP/PostalCode
Salt Lake City	UTAH	84121

Relationship: X Executive Officer Director Promoter

Clarification of Response (if Necessary):

Vice President of Acquisitions of the General Partner of the Issuer

Last Name	First Name	Middle Name
Robertson	David
Street Address 1	Street Address 2
6350 South 3000 East, Suite 510
City	State/Province/Country	ZIP/PostalCode
Salt Lake City	UTAH	84121

Relationship: Executive Officer X Director Promoter

Clarification of Response (if Necessary):

Last Name	First Name	Middle Name
Graber	Lance
Street Address 1	Street Address 2
6350 South 3000 East, Suite 510
City	State/Province/Country	ZIP/PostalCode
Salt Lake City	UTAH	84121

Relationship: Executive Officer X Director Promoter

Clarification of Response (if Necessary):

4. Industry Group

Agriculture Banking & Financial Services Commercial Banking Insurance Investing Investment Banking Pooled Investment Fund Is the issuer registered as an investment company under the Investment Company Act of 1940? Yes No Other Banking & Financial Services Business Services Energy Coal Mining Electric Utilities Energy Conservation Environmental Services Oil & Gas Other Energy

Health Care Biotechnology Health Insurance Hospitals & Physicians Pharmaceuticals Other Health Care Manufacturing Real Estate Commercial Construction REITS & Finance X Residential Other Real Estate

Retailing Restaurants Technology Computers Telecommunications Other Technology Travel Airlines & Airports Lodging & Conventions Tourism & Travel Services Other Travel Other

5. Issuer Size

Revenue Range		OR	Aggregate Net Asset Value Range
	No Revenues			No Aggregate Net Asset Value
	$1 - $1,000,000			$1 - $5,000,000
	$1,000,001 - $5,000,000			$5,000,001 - $25,000,000
	$5,000,001 - $25,000,000			$25,000,001 - $50,000,000
	$25,000,001 - $100,000,000			$50,000,001 - $100,000,000
	Over $100,000,000			Over $100,000,000
X	Decline to Disclose			Decline to Disclose
	Not Applicable			Not Applicable

6. Federal Exemption(s) and Exclusion(s) Claimed (select all that apply)

Rule 504(b)(1) (not (i), (ii) or (iii))		Rule 505
Rule 504 (b)(1)(i)	X	Rule 506
Rule 504 (b)(1)(ii)		Securities Act Section 4(5)
Rule 504 (b)(1)(iii)		Investment Company Act Section 3(c)
	Section 3(c)(1) Section 3(c)(9)   Section 3(c)(2) Section 3(c)(10) Section 3(c)(3) Section 3(c)(11) Section 3(c)(4) Section 3(c)(12) Section 3(c)(5) Section 3(c)(13) Section 3(c)(6) Section 3(c)(14) Section 3(c)(7)

7. Type of Filing

	New Notice	Date of First Sale	2010-09-27	First Sale Yet to Occur
X	Amendment

8. Duration of Offering

Does the Issuer intend this offering to last more than one year? X Yes No

9. Type(s) of Securities Offered (select all that apply)

X	Equity	Pooled Investment Fund Interests
	Debt	Tenant-in-Common Securities
	Option, Warrant or Other Right to Acquire Another Security	Mineral Property Securities
	Security to be Acquired Upon Exercise of Option, Warrant or Other Right to Acquire Security	Other (describe)

10. Business Combination Transaction

Is this offering being made in connection with a business combination transaction, such as a merger, acquisition or exchange offer? X Yes No

Clarification of Response (if Necessary):

Exchange offer of Limited Partnership Units for tenant in common interests in real property.

11. Minimum Investment

Minimum investment accepted from any outside investor $0 USD

12. Sales Compensation

Recipient	Recipient CRD Number None
Orchard Securities, LLC	133378
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
11650 S. State Street, Suite 225
City	State/Province/Country	ZIP/Postal Code
Draper	UTAH	84020
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
ARKANSAS CALIFORNIA COLORADO CONNECTICUT DISTRICT OF COLUMBIA FLORIDA HAWAII IDAHO KENTUCKY MASSACHUSETTS MINNESOTA MISSISSIPPI MONTANA NEBRASKA NEVADA NEW YORK SOUTH CAROLINA UTAH VIRGINIA WASHINGTON WISCONSIN

Recipient	Recipient CRD Number None
Allied Beacon Partners, Inc.	46227
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
1100 Boulders Park Way, Suite 600
City	State/Province/Country	ZIP/Postal Code
Richmond	VIRGINIA	23225
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA WISCONSIN

Recipient	Recipient CRD Number None
American Investors Company	38
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
2682 Bishop Dr., Suite 123
City	State/Province/Country	ZIP/Postal Code
San Ramon	CALIFORNIA	94583
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA

Recipient	Recipient CRD Number None
Berthel, Fisher & Company Financial Services, Inc.	13609
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
701 Tama Street, Building B
City	State/Province/Country	ZIP/Postal Code
Marion	IOWA	52302
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA FLORIDA IOWA MISSISSIPPI NORTH CAROLINA

Recipient	Recipient CRD Number None
CapWest Securities, Inc.	30002
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
1821 56th Avenue, Suite B
City	State/Province/Country	ZIP/Postal Code
Greeley	COLORADO	80634
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA FLORIDA

Recipient	Recipient CRD Number None
Centaurus Financial, Inc.	30833
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
2300 E. Katella Avenue, Suite 200
City	State/Province/Country	ZIP/Postal Code
Anaheim	CALIFORNIA	92806
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA ILLINOIS

Recipient	Recipient CRD Number None
Concorde Investment Services, LLC	151604
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
1120 East Long Lake Road, Suite 100
City	State/Province/Country	ZIP/Postal Code
Troy	MICHIGAN	48085
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA

Recipient	Recipient CRD Number None
Courtlandt Securities Corporation	137356
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
3991 MacArthur Blvd., Suite 350
City	State/Province/Country	ZIP/Postal Code
Newport Beach	CALIFORNIA	92660
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA

Recipient	Recipient CRD Number None
Girard Securities, Inc.	18697
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
9560 Waples Street, Suite B
City	State/Province/Country	ZIP/Postal Code
San Diego	CALIFORNIA	92121
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA

Recipient	Recipient CRD Number None
Independent Financial Group, LLC	7717
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
12671 High Bluff Drive, Suite 200
City	State/Province/Country	ZIP/Postal Code
San Diego	CALIFORNIA	92130
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA HAWAII IOWA TEXAS WASHINGTON

Recipient	Recipient CRD Number None
Investment Security Corporation	47536
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
24009 Ventura Blvd., Suite 101
City	State/Province/Country	ZIP/Postal Code
Calabasas	CALIFORNIA	91302
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA

Recipient	Recipient CRD Number None
Multi-Financial Securities Corporation	10299
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
4600 South Syracuse, Suite 600
City	State/Province/Country	ZIP/Postal Code
Denver	COLORADO	80237
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
NEW JERSEY NEW YORK UTAH

Recipient	Recipient CRD Number None
NelsonReid, Inc.	45503
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
14420 W. Sylvanfield Dr., Suite 120
City	State/Province/Country	ZIP/Postal Code
Houston	TEXAS	77014
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA

Recipient	Recipient CRD Number None
Omni Brokerage, Inc.	16878
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
406 W. South Jordan Parkway, Suite 200
City	State/Province/Country	ZIP/Postal Code
South Jordan	UTAH	84095
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
ARIZONA ARKANSAS CALIFORNIA FLORIDA GEORGIA MICHIGAN MONTANA NEVADA NEW JERSEY SOUTH DAKOTA UTAH VIRGINIA WASHINGTON WYOMING

Recipient	Recipient CRD Number None
Pacific West Securities, Inc.	6390
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
555 S. Renton Village Pl., Suite 700
City	State/Province/Country	ZIP/Postal Code
Renton	WASHINGTON	98057
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
ALASKA CALIFORNIA OREGON VIRGINIA WASHINGTON

Recipient	Recipient CRD Number None
Phalanx Trading, LLC	146993
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
7 Grove Street
City	State/Province/Country	ZIP/Postal Code
Topsfield	MASSACHUSETTS	01983
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
MASSACHUSETTS

Recipient	Recipient CRD Number None
Primex	29394
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
45 Knollwood Road, 4th Floor
City	State/Province/Country	ZIP/Postal Code
Elmsford	NEW YORK	10523
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA OREGON

Recipient	Recipient CRD Number None
Regent Capital Group, Inc.	126881
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
31255 Cedar Valley Dr., Suite 302
City	State/Province/Country	ZIP/Postal Code
Westlake Village	CALIFORNIA	91362
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
NEW JERSEY

Recipient	Recipient CRD Number None
Resourcive Capital, LLC	145504
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
13955 Stowe Drive, Suite 124
City	State/Province/Country	ZIP/Postal Code
Poway	CALIFORNIA	92064
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA

Recipient	Recipient CRD Number None
Sandlapper Securities, LLC	137906
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
101 N. Main Street, Suite 207
City	State/Province/Country	ZIP/Postal Code
Greenville	SOUTH CAROLINA	29601
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA NORTH CAROLINA TENNESSEE

Recipient	Recipient CRD Number None
Select Capital Corporation	145997
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
31351 Rancho Viejo Rd., Suite 205
City	State/Province/Country	ZIP/Postal Code
San Juan Capistrano	CALIFORNIA	92675
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
NEW YORK

Recipient	Recipient CRD Number None
Steven L. Falk & Associates, Inc.	14297
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
11280 Granite Ridge Drive, Suite 1042
City	State/Province/Country	ZIP/Postal Code
Las Vegas	NEVADA	89135
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA

Recipient	Recipient CRD Number None
Triad Advisors, Inc.	25803
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
5185 Peachtree Parkway, Suite 280
City	State/Province/Country	ZIP/Postal Code
Norcross	GEORGIA	30092
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
NEW YORK

Recipient	Recipient CRD Number None
VFG Securities, Inc.	15121
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
100 Corporate Pointe, Suite 382
City	State/Province/Country	ZIP/Postal Code
Culver City	CALIFORNIA	90230
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA

Recipient	Recipient CRD Number None
Welton Street Investments LLC	132111
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
9780 Mount Pyramid Court, Suite 400
City	State/Province/Country	ZIP/Postal Code
Englewood	COLORADO	80112
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
HAWAII ILLINOIS

Recipient	Recipient CRD Number None
Western International Securities, Inc.	39262
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
70 South Lake Avenue, Suite 700
City	State/Province/Country	ZIP/Postal Code
Pasadena	CALIFORNIA	91101
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA

Recipient	Recipient CRD Number None
Whitehall-Parker Securities, Inc.	10608
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
477 Pacific Avenue, 2nd Floor
City	State/Province/Country	ZIP/Postal Code
San Francisco	CALIFORNIA	94133
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
CALIFORNIA

Recipient	Recipient CRD Number None
Winslow, Evans & Crocker, Inc.	29686
(Associated) Broker or Dealer X None	(Associated) Broker or Dealer CRD Number X None
None	None
Street Address 1	Street Address 2
175 Federal Street
City	State/Province/Country	ZIP/Postal Code
Boston	MASSACHUSETTS	02110
State(s) of Solicitation (select all that apply) Check “All States” or check individual States All States	Foreign/non-US
MASSACHUSETTS

13. Offering and Sales Amounts

Total Offering Amount		USD	or X Indefinite
Total Amount Sold	$49,196,397	USD
Total Remaining to be Sold		USD	or X Indefinite

Clarification of Response (if Necessary):

14. Investors

Select if securities in the offering have been or may be sold to persons who do not qualify as accredited investors, and enter the number of such non-accredited investors who already have invested in the offering.

Regardless of whether securities in the offering have been or may be sold to persons who do not qualify as accredited investors, enter the total number of investors who already have invested in the offering:

289

15. Sales Commissions & Finder's Fees Expenses

Provide separately the amounts of sales commissions and finders fees expenses, if any. If the amount of an expenditure is not known, provide an estimate and check the box next to the amount.

Sales Commissions	$1,602,289	USD	X Estimate
Finders' Fees	$0	USD	Estimate

Clarification of Response (if Necessary):

16. Use of Proceeds

Provide the amount of the gross proceeds of the offering that has been or is proposed to be used for payments to any of the persons required to be named as executive officers, directors or promoters in response to Item 3 above. If the amount is unknown, provide an estimate and check the box next to the amount.

$299,792 USD X Estimate

Clarification of Response (if Necessary):

Eric Marlin acts as an internal wholesaler for Orchard Securities, LLC and is paid a wholesaling fee of $0.03 for each unit issued under this offering.

Signature and Submission

Please verify the information you have entered and review the Terms of Submission below before signing and clicking SUBMIT below to file this notice.

Terms of Submission

In submitting this notice, each issuer named above is:

• Notifying the SEC and/or each State in which this notice is filed of the offering of securities described and undertaking to furnish them, upon written request, in the accordance with applicable law, the information furnished to offerees.*

• Irrevocably appointing each of the Secretary of the SEC and, the Securities Administrator or other legally designated officer of the State in which the issuer maintains its principal place of business and any State in which this notice is filed, as its agents for service of process, and agreeing that these persons may accept service on its behalf, of any notice, process or pleading, and further agreeing that such service may be made by registered or certified mail, in any Federal or state action, administrative proceeding, or arbitration brought against the issuer in any place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any activity in connection with the offering of securities that is the subject of this notice, and (b) is founded, directly or indirectly, upon the provisions of:  (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these statutes, or (ii) the laws of the State in which the issuer maintains its principal place of business or any State in which this notice is filed.

• Certifying that, if the issuer is claiming a Rule 505 exemption, the issuer is not disqualified from relying on Rule 505 for one of the reasons stated in Rule 505(b)(2)(iii).

Each Issuer identified above has read this notice, knows the contents to be true, and has duly caused this notice to be signed on its behalf by the undersigned duly authorized person.

For signature, type in the signer's name or other letters or characters adopted or authorized as the signer's signature.

Issuer	Signature	Name of Signer	Title	Date
Cottonwood Residential O.P., LP	/s/ Gregg Christensen	Gregg Christensen	Exec VP & Gen. Counsel of the General Partner of the Issuer	2013-01-04

Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB number.

* This undertaking does not affect any limits Section 102(a) of the National Securities Markets Improvement Act of 1996 ("NSMIA") [Pub. L. No. 104-290, 110 Stat. 3416 (Oct. 11, 1996)] imposes on the ability of States to require information. As a result, if the securities that are the subject of this Form D are "covered securities" for purposes of NSMIA, whether in all instances or due to the nature of the offering that is the subject of this Form D, States cannot routinely require offering materials under this undertaking or otherwise and can require offering materials only to the extent NSMIA permits them to do so under NSMIA's preservation of their anti-fraud authority.