August 13, 1990
TO: INVESTMENT ADVISERS COMMITTEE NO. 26-90
RE: MARYLAND INVESTMENT ADVISER REGISTRATION REGULATIONS
__________________________________________________________
As we previously informed you, the Maryland Securities
Division recently released proposed regulations regarding
investment adviser registration. (See Institute Memorandum to
Investment Advisers Committee No. 23-90, dated July 24, 1990.)
The Institute filed preliminary comments on a draft of the
proposed regulations, most of which were incorporated into the
proposed regulations. However, the Securities Division did not
adopt our recommendation not to require the Series 65 exam until
the problems with it are satisfactorily resolved. Therefore, the
Institute filed the attached letter today recommending that
passage of the Series 7 and Series 63 examinations be accepted in
lieu of the Series 65 until those problems associated with the
Series 65 examination are resolved. In addition, the Institute
recommended that advisers who have received certifications as
Chartered Financial Analysts and Chartered Investment Counselors
be added to the list of individuals who are exempt from the
examination requirement.
We will keep you informed of further developments.
W. Richard Mason
Assistant General Counsel
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