June 7, 1989
TO: INVESTMENT ADVISER MEMBERS NO. 31-89
INVESTMENT ADVISER ASSOCIATE MEMBERS NO. 31-89
RE: ILLINOIS AMENDS INVESTMENT ADVISER LAW
__________________________________________________________
Effective July 1, 1989, investment advisers and investment
adviser representatives will be subject to an amended investment
adviser law in Illinois. This new law is based on Illinois
Senate Bill 2321. A copy of the amended investment adviser law
is attached.
The amended investment adviser law includes several new
provisions including definitions of investment adviser,
investment adviser representative and principal of an investment
adviser. It also includes a requirement that an investment
adviser list the names of all investment adviser representatives
employed by the investment adviser at the time of the adviser's
initial registration or renewal registration (investment adviser
representatives do not have to register at this time), a
requirement that an investment adviser provide a copy of Part II
of its Form ADV in accord with the federal requirement concerning
the brochure rule, and a requirement that advisers which file
required records (e.g. financial statements) late be assessed an
additional fee (the additional fee, unlike a penalty, does not
trigger the disclosure provisions under certain state and federal
disciplinary disclosure rules such as Investment Advisers Act
Rule 206(4)-4).
We will inform you of further developments.
Robert L. Bunnen, Jr.
Assistant General Counsel
Attachment