April 26, 1989
TO: INVESTMENT ADVISERS COMMITTEE NO. 20-89
RE: VIRGINIA PROPOSES INVESTMENT ADVISER RULES
__________________________________________________________
On April 19, 1989, the State Corporation Commission of
Virginia proposed rules concerning investment advisers and
investment adviser representatives. A copy of the relevant
proposed Virginia rules is attached for your review.
The proposed rules cover several subject matters including
(1) a requirement that investment advisers file a balance sheet
as presribed by Part II, item 14 of Form ADV, unless excluded
from such requirement, (2) a requirement that an investment
adviser representative applying for registration on or after July
1, 1989 be required to pass the Series 65 Uniform Investment
Adviser Law Examination with a minimum grade of 70%, (3) a
requirement that an investment adviser maintain as part of his
books and records all advertisements and worksheets and
calculations necessary to form the basis for performance data in
his advertisements, and (4) a laundry list of dishonest or
unethical practices applicable to investment advisers and a
separate list of dishonest or unethical practices for investment
adviser representatives.
Because comments must be received by the Virginia
Securities Commission by May 19, 1989, please submit any comments
you may have to the undersigned by Friday, May 12, 1989.
Robert L. Bunnen, Jr.
Assistant General Counsel
Attachment