January 24, 1990
TO: INVESTMENT ADVISERS COMMITTEE NO. 2-90
RE: PROPOSED AMENDMENTS TO MASSACHUSETTS BROKER-DEALER RULES
__________________________________________________________
The Massachusetts Securities Division has recently proposed
for public comment several amendments to its broker-dealer
regulations. The amendments are important for investment
advisers because of the specific proposed amendment to Section
12.201 concerning registration requirements.
Under Section 12.201(C), registration as an agent for a
broker-dealer is required of
"every individual who represents or acts for a
broker-dealer in effecting or attempting to effect
purchases and sales of securities, including
without limitation, any person who solicits
transactions or new accounts on behalf of the
broker-dealer, renders advice concerning the
purchase and sale of securities to particular
customers or executes trades for particular
customers, and every individual who supervises any
of the foregoing (emphasis added)."
Attached is a copy of the proposed amendments. The
securities division will hold a public hearing on the proposed
amendments Wednesday, January 31, 1990. However, written
comments may be submitted through February 10, 1990. Please
contact me with any comments by February 6, 1990 if you would
like them to be included in the Institute's comment letter.
Robert L. Bunnen, Jr.
Assistant General Counsel
Attachment