September 27, 1991
TO: INVESTMENT ADVISER MEMBERS NO. 42-91
MARYLAND INVESTMENT ADVISER ASSOCIATE MEMBERS
RE: MARYLAND ISSUES EMERGENCY AND PROPOSED INVESTMENT ADVISER
REGULATIONS
__________________________________________________________
The Maryland Securities Division has published for comment
the attached proposed amendments to certain of its investment
adviser regulations. The proposed amendments are intended to
continue the effectiveness of several provisions of the current
regulations pending possible action by the Maryland General
Assembly this year.
The proposed amendment to regulation .10 would require the
filing of Maryland Investment Adviser Certification Form in order
to renew the registration of an investment adviser rather than
federal Form ADV-S. The proposed amendment to regulation .11
clarifies that the 1992 renewal fee for investment adviser
representatives who are also registered as securities agents and
registered between October 1, 1990 and December 31, 1990 will be
waived. The proposed amendment to regulation .13 expands the
existing grandfathering provisions of the examination
requirements to expire on July 1, 1992 rather than October 1,
1991.
The Maryland Securities Commissioner has requested
emergency status for the proposed regulations in order that such
may take effect before the renewal registration season which
begins on October 1, 1991. However, written comments may be
submitted to Ellyn L. Brown, Securities Commissioner, Maryland
Division of Securities, Office of the Attorney General, 200 Saint
Paul Place, 20th Floor, Baltimore, Mayland 21202 through November
5, 1991. A public hearing is scheduled for October 31, 1991 at
10:00 a.m. at the offices of the Attorney General.
Please call me at (202) 955-3523 with any comments you have
on the proposed amendments by October 20, 1991 .
Amy B.R. Lancellotta
Assistant General Counsel
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