June 7, 1989
TO: INVESTMENT ADVISER MEMBERS NO. 32-89
INVESTMENT ADVISER ASSOCIATE MEMBERS NO. 32-89
RE: INDIANA PASSES INVESTMENT ADVISER LAW
__________________________________________________________
Effective July 1, 1989, investment advisers and investment
adviser representatives will be subject to an amended securities
law in Indiana. A copy of the Act as amended is attached.
The amended Act includes a number of provisions affecting
investment advisers and investment adviser representatives
including a definition of investment adviser representative (see
Section 1(q)), a de minimus and institutional investor exemption
from registration (see Section 7(c)), a requirement that an
investment adviser post a surety bond in an amount up to $25,000
(see Section 8(b)), a minimum financial requirement for
investment advisers (see Section 8(f)), and a $100 and $50 fee
requirement for initial and renewal registration for investment
advisers and a fee of $25 for both initial and renewal
registration for investment adviser representatives (see Section
8(d)). The registration exemptions and other important
provisions were included as a result of comments by the Institute
and Institute members.
In conversations with the Securities Commissioner in
Indiana, the Institute learned that he does not intend to propose
rules under the law for at least the next year. Thus, provisions
which require rulemaking in order to become effective will not be
required until rules are adopted.
We will inform you of any developments.
Robert L. Bunnen, Jr.
Assistant General Counsel
Attachment