October 19, 1990
TO: INVESTMENT ADVISERS COMMITTEE NO. 35-90
RHODE ISLAND INVESTMENT ADVISER ASSOCIATE MEMBERS
RE: PROPOSED RHODE ISLAND ADVISER REGISTRATION REGULATIONS
__________________________________________________________
Attached are the proposed rules regarding the registration
of investment advisers in the State of Rhode Island.
Pursuant to Institute recommendations, the proposed rules
contain four types of exemptions from investment adviser
representative registration under Proposed Rule 204(3)-1. These
exemptions in effect narrow the statutorily broad definition of
investment adviser representative under the Rhode Island Code.
The proposed rules contain the same examination
requirements set forth in the emergency rules issued earlier this
year. (See Institute Memorandum to Investment Adviser Members
No. 44-90 and Investment Adviser Associate Members No. 40-90,
dated September 10, 1990.) Thus, each representative must pass
the Series 63 and Series 65 examinations and one supervisor must
pass the Series 24 examination. As we discussed at the
Investment Advisers Committee meeting on October 10, 1990, the
Institute will request a class exemption in Rhode Island from the
Series 24 examination for supervisors who have attained a CFA
certification.
Since written comments on the proposed rules must be
received by the Rhode Island Department of Business Regulation by
October 30, 1990, please provide me any comments you may have on
the proposed by October 26, 1990.
We will keep you informed of further developments.
W. Richard Mason
Assistant General Counsel
Attachment