January 15, 1991
TO: INVESTMENT ADVISER MEMBERS NO. 4-91
INVESTMENT ADVISER ASSOCIATE MEMBERS NO. 4-91
RE: RHODE ISLAND ISSUES REMAINING REGULATIONS
__________________________________________________________
As we previously informed you, the Rhode Island Division of
Securities issued final regulations regarding investment adviser
and investment adviser representative licensing effective
December 6, 1990. (See Institute Memorandum to Investment
Adviser Members No. 55-90 and Investment Adviser Associate
Members No. 51-90, dated November 28, 1990.) At that time, the
Division had withheld certain regulations pending reproposal at a
later date.
Attached are the remaining adviser regulations effective
Monday, January 28, 1991. The regulations state that applicants
for initial licensing must pass the Series 65 examination.
However, until November 30, 1991, passage of (i) the Series 63
and (ii) the Series 2 or 7 or CFA Level I examinations may be
substituted for the Series 65. As recommended by the Institute,
these examination requirements are waived for any advisers who
were previously licensed in Rhode Island within the last two
years. In addition, certain adviser representatives who were
registered with the NASD and licensed in another state which
required passage of the Series 63 are exempt from the Series 65
requirement.
The regulations provide that designated investment adviser
supervisors will be required to pass either the Series 24
examination or have a CFA or CFP designation. The final rules
also contain provisions regarding post-licensing filings and
unethical or dishonest practices.
We will keep you informed of further developments.
W. Richard Mason
Assistant General Counsel
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