1
It should be noted that provisions in the attached regulations which
are labeled "(NEW)" may actually be existing regulations that merely have been
renumbered.
November 8, 1993
TO: INVESTMENT ADVISERS COMMITTEE NO. 34-93
RE: PROPOSED AMENDMENTS TO CONNECTICUT INVESTMENT ADVISER RULE
__________________________________________________________
The Connecticut Department of Banking has issued for comment proposed
amendments to the regulations under the Connecticut Uniform Securities Act
dealing with investment advisers. The proposed amendments are designed to update
existing regulations to make them easier to read and understand. A copy of the
proposed amendments is attached.1
Several of the significant amendments include: (1) a new rule which
requires delivery of a disclosure document similar to that required by Rule 204-3
under the federal Investment Advisers Act (the "Brochure Rule") to advisory
clients; (2) a provision imposing supervisory requirements on investment
advisers; (3) a special filing requirement for persons who use a trade name other
than that of the registrant; (4) expanded authority for the Commissioner to
conduct inspections; (5) a new provision, which tracks Rule 102(a)(4)-1 of the
NASAA Model Amendments to the Uniform Securities Act, defining unethical business
practices by investment advisers and investment adviser agents; and, (6) a
requirement that investment adviser agents pass the Series 65 exam. Exempted
from this examination requirement are persons who have not been the subject of
any disciplinary proceedings and who are associated with an adviser as of October
1, 1994.
Additionally, the proposed amendments add several additional records to the
list of records which must be maintained by the adviser at its principal place
of business and in each of it branch offices. (See Sec. 36-500-482b).
Comments on these proposed regulations must be submitted by December 3,
1993. If you have any comments on the proposed regulations, please provide them
to me by Friday November 19, 1993. My direct dial number is 202/955-8432.
Tamara K. Cain
Assistant Counsel
Attachment