July 24, 1991
TO: INVESTMENT ADVISERS COMMITTEE NO. 33-91
UTAH INVESTMENT ADVISER ASSOCIATE MEMBERS
RE: UTAH PROPOSES ADVISER LICENSING RULES
__________________________________________________________
Attached is a copy of rules proposed by the Utah Securities
Division regarding licensing of investment advisers. We
understand the rules will become effective August 1, 1991. Also
attached is a copy of the Institute's comments regarding the
proposed rules.
The rules require investment adviser personnel to pass both
the Series 63 and Series 65 examination as a condition of
licensing. Utah currently requires the Series 63 examination. A
grandfather provision exists for individuals who have been
licensed within the last two years.
The Institute objected to the double examination
requirement and recommended that the Securities Division grant
liberal waivers from the Series 65 examination until the problems
associated with the test are resolved.
We will keep you informed of developments.
W. Richard Mason
Assistant Counsel - Pension
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