August 9, 1991
TO: INVESTMENT ADVISERS COMMITTEE NO. 36-91
RE: WISCONSIN PROPOSES BRANCH OFFICE RULE
__________________________________________________________
Attached is a copy of proposed revisions to the
Administrative Rules of the Wisconsin Commissioner of Securities.
Section 2 of the proposal defines the term "branch office"
for purposes of investment adviser provisions as any office of
the adviser where investment advice is normally provided to
clients or any place of business that is held out to the public
as a business location of the investment adviser.
Section 23 of the proposal would require every branch
office of an adviser to prepare and keep all current records now
required to be kept by the adviser. These records must be
preserved for three years, and in an easily accessible place for
the first two years. The records may be retained by computer if
a printed copy of the record can be prepared immediately upon
request. The Securities Commission noted that these record
keeping rules are designed to parallel broker-dealer branch
office procedures.
A hearing on the proposals will be held on September 25,
1991 in Madison. Written comments will be accepted until the
date of the hearing. Therefore, please call me at 202/955-3516
by September 11, 1991 with regard to any comments you would like
the Institute to include in its written submission.
We will keep you informed of developments.
W. Richard Mason
Assistant Counsel - Pension
Attachment