October 28, 1994
TO: INVESTMENT ADVISERS COMMITTEE NO. 54-94
NEVADA ASSOCIATE MEMBERS
RE: NEVADA ADOPTS AMENDMENTS TO INVESTMENT ADVISER REGULATIONS
__________________________________________________________
As we previously advised you, in June the Nevada Secretary
of State published for comment proposed amendments to regulations
under the Nevada Uniform Securities Act (the "Act") relating to
investment advisers. (See Memorandum to Investment Adviser
Committee No. 41-94 and Nevada Associate Members, dated June 28,
1994.) On August 15, 1994, these regulations were adopted
substantially as proposed. Two of the regulations incorporate by
reference Rule 204-2, relating to books and records requirements,
and Rule 204-3, the "brochure rule", under the Investment
Advisers Act of 1940.
Additionally, the adopted amendments exempt registered
representatives of broker-dealers from having to register as
investment adviser representatives if the only investment advice
rendered by such person is as part of a wrap fee program.
A copy of the adopted regulations is attached.
Tamara K. Cain
Assistant Counsel
Attachment