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January 16, 1991
TO: INVESTMENT ADVISERS COMMITTEE NO. 2-91
MARYLAND INVESTMENT ADVISER ASSOCIATE MEMBERS
MARYLAND INVESTMENT ADVISER MEMBERS
RE: MARYLAND REPROPOSES REGULATIONS WITH FEE WAIVER
__________________________________________________________
As we previously informed you, the Maryland Securities
Division proposed regulations regarding investment advisers last
July (see Institute Memorandum to Investment Adviser Committee
No. 23-90, dated July 24, 1990) and orally informed the Institute
that 1991 registration fees for investment advisers and their
representatives who are dually-registered as broker/dealers and
agents, respectively, and who paid investment adviser and
investment adviser representative registration fees for 1990
would be waived (see Institute Memorandum to Investment Adviser
Members No. 51-90 and Investment Adviser Associate Members No.
46-90, dated October 29, 1990).
The Securities Division recently reproposed its adviser
regulations with significant changes affecting examination
requirements and registration fees. With regard to the
examination requirements, the individuals who are exempt from the
Series 65 examination is expanded to include Chartered Financial
Analysts (CFAs) and Chartered Investment Counselors (CICs) as
well as those who are in the registry of financial planning
practitioners of the IAFP. Also, the period for qualifying for
the examination "grandfather" for practicing advisers is extended
to October 1, 1991.
With regard to registration fees, the reproposed regulation
provides that if an investment adviser representative became
registered between October 1, 1990 and December 31, 1990 and is
also registered as an agent and submits notice of the dual
registration in his or her application for renewal registration
as an investment adviser representative, then the fee for such
renewal registration for the period January 1, 1991 through
December 31, 1991 is waived. The reproposed regulations do not
appear to waive the registration fee for the investment adviser.
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Comments on the attached reproposed regulation must be
received by the Securities Division by February 1, 1991.
Therefore, please call me with regard to any comments you have on
the reproposals by January 28, 1991.
We will keep you informed of further developments.
W. Richard Mason
Assistant General Counsel
Attachment