November 2, 1990
TO: INVESTMENT ADVISERS COMMITTEE NO. 37-90
RE: INSTITUTE COMMENTS ON RHODE ISLAND ADVISER REGISTRATION
REGULATIONS
__________________________________________________________
As you recall, the Rhode Island Department of Business
Regulation recently proposed rules regarding the registration of
investment advisers. (See Institute Memorandum to Investment
Advisers Committee No. 35-90). Attached in this regard is a copy
of the Institute's comments on the proposed rules.
The proposed regulations would require applicants for
licensing as investment adviser representatives in Rhode Island
to pass the Series 63 and Series 65 examinations. The Institute
recommended that only one examination, the Series 65, be required
for investment adviser licensing. The Institute also recommended
that a permanent exemption be granted for investment advisers who
have previously passed the Series 63 and either the Series 2 or 7
examinations and have at least two years of experience as
investment adviser representatives in Rhode Island or another
state. As we discussed at the Investment Advisers Committee
meeting last month, passage of the Series 63 and either the
Series 2 or 7 should not be a substitute for passage of the
Series 65, however, advisers who have already passed such
examinations should not have to pass yet another examination.
For this reason, the Institute recommended a two year experience
requirement in order to ensure that unexperienced applicants do
not circumvent the Series 65 requirement.
With regard to the Series 65 examination in general, the
Institute understands that as of October 1, 25% of the exam was
rewritten. In addition, the exam was expanded from 90 to 120
minutes. No recognized course outline or study materials are yet
available.
The Institute also requested the Rhode Island Department of
Securities to grant a class exemption for the Series 24
examination requirement for designated investment adviser
supervisors who are chartered financial analysts. A copy of the
request for the exemption is attached.
We will keep you informed of further developments.
W. Richard Mason
Assistant General Mason
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