September 2, 1994
TO: INVESTMENT ADVISERS COMMITTEE NO. 47-94
RE: NORTH CAROLINA PROPOSES AMENDMENTS TO RULES RELATING TO
INVESTMENT ADVISERS
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The North Carolina Securities Division (the "Division") has
issued for comment proposed revisions to rules of the Division
relating to investment advisers. The Division's proposed revisions
would, among other things: (1) increase the registration/renewal
fee for investment adviser representatives from $45 to $55; (2)
repeal a provision that currently requires partners, executive
officers, and directors to be separately registered as investment
adviser representatives. Such repeal would mean that only those
persons involved in the rendering of investment advice would need
to be registered with the Division; (3) require a renewal
application filed by an adviser to include a current fee schedule;
(4) require notification to the Division of any change of address
or the opening or closing of any office within thirty (30) days of
such change; (5) exclude subordinated loans from the types of
assets deemed appropriate for purposes of complying with the
minimum financial requirements; and, (6) charge an adviser a
registration fee for each representative whose registration is
transferred in a mass transfer.
A copy of the Division's proposed rules is attached. Comments
on the proposal should be submitted to the Securities Division no
later than Monday October 3, 1994. If these are issues you would
like the Institute to consider submitting to the Division, please
contact me by phone at 202/326-5825 or by fax at 202/326-5828 no
later than Friday, September 23, 1994.
Tamara K. Cain
Assistant Counsel
Attachment