January 2, 1991
TO: INVESTMENT ADVISER MEMBERS NO. 1-91
INVESTMENT ADVISER ASSOCIATE MEMBERS NO. 1-91
RE: EXTENSION OF TIME TO REGISTER IN ALABAMA
__________________________________________________________
As we previously informed you, the State of Alabama
required registration of investment advisers and investment
adviser representatives by January 1, 1991 (unless the
institutional or 5 client de minimus exemption in Section 8-6-3-
(b) of the Alabama Securities Act was available). (See Institute
Memorandum to Investment Adviser Members No. 51-90 and Investment
Adviser Associate Members No. 46-90, dated October 29, 1990).
In response to the Institute’s request, the Alabama
Securities Commission has granted investment advisers who have
not complied with Alabama registration requirements prior to
January 1, 1991 an extension of time to register until March 31,
1991. However, the adviser must provide reasonable and
sufficient cause for its failure to register prior to January 1,
1991 in order to qualify for this grace period. The Institute
requested the extension in light of the Securities Commission’s
failure to release copies of the rules applicable to investment
adviser registration on a timely basis. (See Institute
Memorandum to Investment Adviser Members No. 57-90 and Investment
Adviser Associate Members No. 53-90, dated December 18, 1990.)
A copy of the Securities Commission’s release is attached.
We will keep you informed of further developments.
W. Richard Mason
Assistant General Counsel
Attachment