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September 7, 1990
TO: INVESTMENT ADVISERS COMMITTEE NO. 30-90
RE: INSTITUTE STATEMENT AT NASAA FALL CONFERENCE
__________________________________________________________
Attached is a copy of the Institute's testimony presented
to the Financial Planner/Investment Advisers Committee meeting on
August 27, 1990 at the NASAA fall conference in Billings,
Montana.
As you recall, we circulated a copy of a questionnaire
prepared by Joanne Jones regarding investment adviser disclosure.
(See Memorandum to Investment Advisers Committee No. 25-90 dated
August 10, 1990). That questionnaire was not sent to the states.
A revised questionnaire will be circulated to the Institute and
other industry members for comments before it is sent to the
states.
The Institute's written statement nevertheless supports
NASAA's adoption of a rule which exactly mirrors Rule 206(4)-4
regarding adviser disclosure. A copy of the Institute's letter
to Joanne Jones which discusses the industry's position on this
matter in greater detail is attached to our written statement.
In addition, our statement reiterates the Institute's position
regarding the definition of investment adviser representative and
requests NASAA to revise its model definition accordingly.
The NASAA Uniform Examinations Committee also met on
Monday, August 27. The committee appears to have made progress
in resolving some of the problems associated with the Series 65
examination for investment advisers by eliminating double
negatives and multiple choice questions with more than one right
answer, expanding the length of time to take the exam and
abbreviating the text of many questions. These changes will be
implemented in the next few months and comprehensive study
materials should be available this winter. The committee is also
interested in working with industry members regarding its
comments on the study materials for the test and is considering
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establishing an industry review panel who could critique the exam
for the committee. We will discuss this matter at the next
Committee meeting in October.
We will keep you informed of further developments.
W. Richard Mason
Assistant General Counsel
Attachment