April 18, 1989
TO: STATE LIAISON COMMITTEE NO. 5-89
RE: COMMENTS REQUESTED ON OKLAHOMA'S RENEWAL PROCESS
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The Institute has recently been contacted by several
members stating that Oklahoma's renewal process is overly
burdensome. Based on conversations with Institute members and
the staff of the Oklahoma Department of Securities, it is our
understanding that the following documents are required for
renewal in Oklahoma:
. Form U-1,
. Form U-2,
. Form U-2A,
. A copy of the latest post effective amendment,
. A copy of the latest prospectus and statement of
additional information, and
. A speciman certificate and opinion of counsel, if the
Department's files do not contain such documents.
As you know, NASAA adopted a resolution in 1984 that
recommended that the states require only a Form U-1 and current
prospectus for renewal. In a recent conversation, the Director
of Registration for the Department stated that he was willing to
consider reducing the amount of paper filed with the Department
but that he could not reduce the amount of information that must
be contained in his files. He stated that he would consider any
suggestions to reduce the burden as long as he could maintain
complete files.
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I think it would be helpful to discuss this matter at the
upcoming State Liaison Committee meeting on April 27, 1989.
Based on ideas generated at the upcoming meeting, the Institute
will send a comment letter to the Department with suggestions for
reducing the renewal filing burden on funds.
Natalie Shirley
Associate General Counsel