September 21, 1992
TO: INVESTMENT ADVISERS COMMITTEE NO. 34-92
BROKER/DEALER ASSOCIATE MEMBERS NO. 14-92
RE: ADOPTION OF AMENDMENTS TO FORM BD THAT ARE ANTICIPATED
FOR FORM ADV
__________________________________________________________
The SEC recently adopted amendments to Form BD, which
become effective on November 16, 1992. As we previously
mentioned, the SEC anticipates proposing amendments to Form ADV
similar to the Form BD amendments. (See Memorandum to Investment
Advisers Committee No. 43-91, dated September 11, 1991.) In the
attached release, the SEC indicates that it continues to be
interested in providing more uniformity between Forms BD and ADV.
The Institute had submitted a comment letter to the SEC on
the Form BD amendments, in anticipation of the amendments to Form
ADV. (See Memorandum to Investment Advisers Committee No. 51-91,
dated October 11, 1991.) The amendments incorporate the
Institute’s recommendation that, in disclosing its investment-
related business, the applicant generally not be required to
disclose a business activity that constitutes only a nominal
percentage (in this case, less than 1%) of the applicant’s
securities-related revenue. However, the amendments require
disclosure of all violations of investment-related statutes and
regulations, rather than only those that occurred during the
previous ten years as the Institute had suggested.
We will keep you informed of any developments.
Thomas Selman
Assistant Counsel
Attachment