February 1, 1991
TO: INVESTMENT ADVISERS COMMITTEE NO. 4-91
MARYLAND INVESTMENT ADVISER MEMBERS
MARYLAND INVESTMENT ADVISER ASSOCIATE MEMBERS
RE: INSTITUTE COMMENTS ON MARYLAND REPROPOSAL
__________________________________________________________
As we previously informed you, the Maryland Securities
Division recently reproposed regulations regarding investment
advisers. (See Institute Memorandum to Investment Advisers
Committee No. 2-19, dated January 16, 1991).
In response to the reproposal, the Institute recommended
that the Securities Division liberally grant exemptions from the
Series 65 examination requirement under its discretionary
authority. The Institute also recommended that the Securities
Division accept a photocopy of Form ADV-S rather than a manually
signed copy for advisers whose fiscal years would require filing
an ADV-S with a date different from that filed with the
Securities and Exchange Commission.
We understand that it is not within the regulatory
authority of the Securities Commission to grant waivers or
credits for investment adviser and investment adviser
representative registration fees paid in 1990 other than
investment adviser representative fees paid by registrants who
are dually registered with an affiliated broker-dealer. However,
the Securities Commission has indicated that it will attempt to
secure legislative relief in this regard. We will keep you
informed of developments.
W. Richard Mason
Assistant General Counsel
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