September 10, 1990
TO: INVESTMENT ADVISER MEMBERS NO. 44-90
INVESTMENT ADVISER ASSOCIATE MEMBERS NO. 40-90
RE: RHODE ISLAND EMERGENCY INVESTMENT ADVISER REGULATIONS
__________________________________________________________
As we previously advised you, Rhode Island revised its laws
regarding the regulation of investment advisers. The changes
became effective on July 12, 1990. (See Memorandum to Investment
Adviser Members No. 34-90 and Investment Adviser Associate
Members No. 30-90, dated July 23, 1990.) The attached emergency
regulations were recently released clarifying some of the
provisions in the revised law.
The emergency regulations state that investment adviser
representatives must pass the Series 63 and Series 65
examinations. However, in response to Institute recommendations,
the Division of Securities issued a policy statement on September
7, 1990 which provides that, until current problems associated
with the Series 65 examination are resolved, the examination
requirements in Rhode Island will be satisfied by passage of
either the Series 63 and Series 65 examinations or passage of the
Series 7 and Series 63 examinations.
The emergency regulations also provide that certain
investment adviser supervisory personnel must pass the Series 24
examination.
Finally, advisers who are not registered with the SEC who
have custody of client funds must file a surety bond between
$100,000.
We will keep you informed of further developments.
W. Richard Mason
Assistant General Counsel
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