April 10, 1989
TO: INVESTMENT ADVISERS COMMITTEE NO. 19-89
RE: OKLAHOMA ADOPTS PROPOSED PERMANENT INVESTMENT ADVISER RULES
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The Oklahoma Securities Commission has recently adopted
proposed permanent rules concerning investment advisers and
investment adviser representatives. The proposed permanent rules
are not official until the Oklahoma legislature approves them. A
copy of the relevant proposed permanent rules are attached.
The proposed permanent rules would make changes to the
existing investment adviser rules in Oklahoma. For example, the
rules would coordinate Oklahoma's renewal procedure with the
SEC's procedure by requiring advisers to renew registration by
submitting a copy of Form ADV-S. Another change would require
advisers to submit a completed Form ADV, including Schedules A
through G (previously, only Schedules A through C and E through G
were required).
In the books and records area, advisers would be required
to keep its books and records "in a central location." The
proposed permanent rules would also amend the existing standards
of ethical practices for investment advisers to make them
applicable to investment adviser representatives.
Finally, the proposed permanent rules would include a rule
that sets forth the Oklahoma Securities Commission's position of
the applicability of the investment adviser provisions of the
Oklahoma Securities Act to financial planners and other persons
who provide investment advisory services as an integral component
of other financial related services. This rule would make it
clear that all those individuals or entities who hold themselves
out to the public as financial planners would be required to be
registered as investment advisers.
If you have any comments on the proposed permanent rules in
Oklahoma, please contact the undersigned by April 26, 1989.
Robert L. Bunnen, Jr.
Assistant General Counsel
Attachment