July 8, 1991
TO: INVESTMENT ADVISER MEMBERS NO. 28-91
INVESTMENT ADVISER ASSOCIATE MEMBERS NO. 28-91
RE: NEBRASKA REVISES REGISTRATION REQUIREMENTS
__________________________________________________________
The Nebraska Bureau of Securities recently revised its
procedures regarding investment adviser registration and
regulation. A copy of revised Interpretive Opinion No. 18 is
attached.
Nebraska previously required investment adviser
"principals" to pass the NASD General Securities Principal
Examination (Series 24). As recommended by the Institute, the
Securities Bureau has eliminated this requirement because it is
not designed for investment advisers. Investment adviser
"principals" and employees who provide investment advice to
clients in Nebraska will be required to pass the Series 65,
Uniform Investment Adviser Law Examination. However, as
suggested by the Institute, individuals who have received the
Chartered Financial Analyst (CFA) certification will be exempt
from the Series 65 examination requirement.
The opinion contains restrictions on individuals who are
dually registered as investment advisers and broker-dealers. It
also contains requirements and duties of investment advisers
regarding conflicts of interest. Finally, the state will
increase its registration and renewal fee from $50 to $200
effective September 6, 1991.
We will keep you informed of related developments.
W. Richard Mason
Assistant Counsel - Pension
Attachment