September 24, 1991
TO: INVESTMENT ADVISERS COMMITTEE NO. 48-91
RE: INSTITUTE COMMENTS ON PROPOSED BRANCH OFFICE RULE
__________________________________________________________
Attached is a copy of the Institute's testimony regarding
the Wisconsin Securities Commissioner's proposed rule on
investment adviser branch offices. (See Institute Memorandum to
Investment Advisers Committee No. 36-91, dated August 9, 1991.)
The proposed rule would require complete recordkeeping in
each adviser "branch office." The Institute objected to the
proposed rule because of the cost of the unnecessary paperwork.
Such records can easily be accessed electronically or by
facsimile. The Institute also objected to the regulation of
investment advisers like broker-dealers.
We will keep you informed of developments.
W. Richard Mason
Assistant Counsel - Pension
Attachment