August 15, 1991
TO: INVESTMENT ADVISERS COMMITTEE NO. 37-91
PENNSYLVANIA INVESTMENT ADVISER MEMBERS
PENNSYLVANIA INVESTMENT ADVISER ASSOCIATE MEMBERS
RE: PENNSYLVANIA PROPOSED ADVISER RULES
__________________________________________________________
Attached is a copy of proposed rules regarding investment
adviser registration in Pennsylvania. The rules promulgate the
Securities Commission's examination policy, requiring passage of
the Series 65 examination and the Series 2, 7, 8 or 24. The rule
provides a waiver for individuals who have met the examination
and two-year experience requirements prior to the date the rules
are finally adopted.
Also attached is a copy of the Institute's comments
regarding the proposal. In addition to objecting to the
examination requirements, the Institute questioned the
requirement that an investment adviser be required to "verify"
associated person Forms U-4.
We will keep you informed of developments.
W. Richard Mason
Assistant Counsel - Pension
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