January 27, 1990
TO: INVESTMENT ADVISERS COMMITTEE NO. 3-90
RE: MARYLAND PROPOSES INVESTMENT ADVISER REGULATIONS
__________________________________________________________
As we have previously informed you, the Maryland Division
of Securities proposed emergency investment adviser regulations
concerning numerous measures affecting investment advisers. (See
Institute Memorandum to Investment Advisers Committee No. 28-89,
dated July 19, 1989). The Division has now reproposed the
investment adviser regulations. A copy of those reproposed
regulations is attached for your review.
These reproposed Maryland investment adviser regulations
include provisions concerning dishonest or unethical practices,
custody of client funds or securities, the brochure rule, agency
cross-transactions, an exemption for certain broker-dealers, a
performance-based compensation rule, and others.
Comments are due to the Maryland Division of Securities by
February 28, 1990. Therefore, if you have any comments you
believe the Institute should make concerning these reproposed
regulations, please submit them to the undersigned no later than
Wednesday, February 21, 1990.
Robert L. Bunnen, Jr.
Assistant General Counsel
Attachment