December 17, 1990
TO: INVESTMENT ADVISERS COMMITTEE NO. 42-90
RE: INSTITUTE REQUESTS RELIEF IN ALABAMA
__________________________________________________________
As we previously informed you, investment advisers and
investment adviser representatives must be registered in Alabama
by January 1, 1991. (See Institute Memorandum to Investment
Adviser Members No. 51-90 and Investment Adviser Associate
Members No.46-90, dated October 29, 1990)
The Institute understands that the Alabama Securities
Commission is requiring registration as investment adviser
representatives of all individuals who supervise, whether
directly or indirectly, investment adviser representatives in
Alabama. This would include not only supervisors specified by
the Alabama Securities Act but individuals throughout the
hierarchy of a multi-jurisdictional investment adviser.
In response to this administrative practice, the Institute
recommended that the Securities Commission require registration
only of the immediate supervisors of investment adviser
representatives. The Commission has jurisdiction over other
supervisory personnel because it has jurisdiction over the
investment adviser.
The Institute also requested the Securities Commission to
provide a grace period to any investment adviser or investment
adviser representative who fails to register by January 1, 1991.
The grace period would equal three months beginning on the date
the Commission releases copies of its final regulations regarding
investment advisers.
We will keep you informed of further developments.
W. Richard Mason
Assistant General Counsel
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