August 9, 1991
TO: INVESTMENT ADVISERS COMMITTEE NO. 35-91
RE: INSTITUTE COMMENTS ON PROPOSED IDAHO ADVISER RULES
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Attached is a copy of the Institute's comments to the Idaho
Department of Finance regarding their proposed rules for
investment advisers. (See Institute Memorandum to Investment
Advisers Committee No. 26-91, dated June 24, 1991.)
The Institute objected to the proposed requirement that a
designated officer of each adviser pass the Series 65 examination
with a score of 85 percent or better. We also urged the
Department to provide liberal waivers from the Series 65
requirement until the problems associated with the examination
are corrected.
The Institute objected to the proposed rule which would
establish supervisory guidelines and procedures for investment
advisers. The rule appears to be broker-dealer inspired and
should not apply to investment advisers.
Finally, the Institute objected to the broker-dealer
inspired fingerprinting requirement.
We will keep you informed of developments.
W. Richard Mason
Assistant Counsel - Pension
Attachment