June 18, 1992
TO: INVESTMENT ADVISERS COMMITTEE NO. 25-92
VIRGINIA INVESTMENT ADVISER ASSOCIATE MEMBERS
RE: VIRGINIA PROPOSES AMENDMENTS TO INVESTMENT ADVISER RULES
__________________________________________________________
The Virginia Division of Securities and Retail Franchising
has proposed amendments to several investment adviser rules. A
copy of the proposed amendment is attached.
The Division has, among other things, proposed a waiver
from the requirement that applicants for registration pass the
Series 65 Examination (Rule 1106). Under the proposal, an
applicant would have to file an executed Affidavit for Waiver of
Series 65 Examination (Form S.A.3) (a copy of the Form is
included in the proposed amendments).
In addition, the Division has proposed new Rule 1401
relating to the registration requirements of investment adviser
representatives who solicit clients on behalf of investment
advisers participating in "wrap fee" or similar investment
advisory programs. Specifically, the proposal clarifies that an
individual may solicit clients on behalf of more than one
investment adviser without having to register as a representative
of more than one adviser, so long as (1) the individual is
registered under the Virginia Securities Act as an investment
adviser representative of an investment adviser so registered
under the Act and (2) the other investment adviser is registered
under the Act as an investment adviser.
Comments are due on the proposed amendments to the Virginia
Securities Division by July 10, 1992. Please provide me with
your comments on the proposed amendments by July 1. My direct
number is 202/955-3523.
Amy B.R. Lancellotta
Associate Counsel
Attachment