April 30, 1991
TO: INVESTMENT ADVISERS COMMITTEE NO. 19-91
FLORIDA INVESTMENT ADVISER MEMBERS
FLORIDA INVESTMENT ADVISER ASSOCIATE MEMBERS
RE: INSTITUTE URGES FLORIDA TO REVISE BRANCH OFFICE PROPOSAL
__________________________________________________________
As we previously informed you, the Florida Securities
Division proposed amending its regulations regarding the
definition of "branch office" and its books and recordkeeping
requirements for investment advisers. (See Instititute
Memorandum to Investment Advisers Committee No. 13-91, dated
April 5, 1991.)
The Institute objected to the recordkeeping requirements in
the proposed regulations. We urged the Division to exempt
investment advisers from the scope of the expanded requirements.
Alternatively, we suggested a method whereby advisers could
comply with the requirements by undertaking to provide documents
upon request within 14 days. We also provided a proposal whereby
investment advisers would be deemed to satisfy the new
requirements if documentation could be accessed by branch offices
within 24 hours by electronic or other means, including
facsimile.
We will keep you informed of developments.
W. Richard Mason
Assistant Counsel
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