March 26, 1992
TO: INVESTMENT ADVISERS COMMITTEE NO. 14-92
FLORIDA INVESTMENT ADVISER MEMBERS
FLORIDA INVESTMENT ADVISER ASSOCIATE MEMBERS
RE: INSTITUTE COMMENTS ON FLORIDA BRANCH OFFICE PROPOSAL
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As you may recall, the Florida Securities Division last
year proposed amendments to the definition of the term "branch
office" contained in Florida Rule 3E-200.001, as well as related
amendments to certain books and records requirements applicable
to broker-dealers and investment advisers. The Institute filed a
comment letter in response to those proposals requesting an
exemption from the proposed recordkeeping requirements for
investment advisers, and suggesting alternative methods for
advisers to comply if the Division were unwilling to grant an
exemption. See Memorandum to Investment Advisers Committee No.
19-91 and to Florida Investment Adviser Members and Florida
Investment Adviser Associate Members, dated April 30, 1991. The
proposals were not adopted.
Recently, the Division again proposed certain amendments to
the definition of "branch office." A copy of those proposed
amendments is attached. The Institute submitted a comment letter
(a copy of which also is attached) stating that the Institute is
pleased that the recordkeeping requirements proposed last year,
which would have imposed substantial burdens on investment
advisers without enhancing investor protection, have been deleted
from the proposed amendments.
We will keep you informed of developments.
Frances M. Stadler
Assistant General Counsel
Attachments