January 31, 1997
TO: INVESTMENT ADVISERS COMMITTEE No. 6-97
RE: CALIFORNIA PROPOSES CHANGES TO EXAMINATION REQUIREMENTS
______________________________________________________________________________
The California Department of Corporations has published for comment amendments to
its rules governing the examination requirements of investment advisers and their associated
persons. In particular, the Department proposes to require the Series 65 or 66 examination and
either the Series 7, General Securities Representative Examination, or one of the following
designations: Chartered Financial Analyst ("CFA"), Certified Financial Planner ("CFP"),
Chartered Investment Counselor ("CIC"), or Personal Financial Specialist ("PFS"). Under
current law, the Department requires either the Series 63, the Series 7, or a CFA or CIC
designation.
As proposed, any "portfolio manager" or "securities analyst" would continue to be
exempt from these examination requirements. The Departments proposal includes definitions
for the terms "portfolio manager" and "securities analyst", which are not defined under current
law. Finally, persons that prior to July 1, 1997 either were issued a certificate from the
Department or filed an application for registration with the Department would not be required
to comply with the proposed requirements.
A copy of the Departments proposed rule is attached. Comments are due to the
Department by February 28, 1997. Members with comments on the proposal, particularly the
proposed definitions, should contact me by phone (202/326-5825), fax (202/326-5828) or e-mail
(tamara@ici.com) no later than Friday, February 21, 1997. Members filing their own comment
letter should send them to:
Gerardo Partida, Senior Corporations Counsel
California Department of Corporations
980 Ninth Street, Suite 500
Sacramento, California 95814
Please provide me by fax a copy of any comment letter filed with the Department.
Tamara Cain Reed
Associate Counsel
Attachment (in .pdf format)