In 2009, the State of Michigan adopted several amendments to the Michigan Uniform Securities Act.  One of the major amendments to the Michigan Securities Laws requires all investment adviser representatives to be licensed. 

Under Michigan’s revised definition of “investment adviser representative,” all individuals who make recommendations or give advice, manage accounts, determine recommendations or advice, provide investment advice, solicit for the sale of investment advice or supervise any individual conducting such activities are considered investment adviser representatives and must be licensed. 

To register as an investment adviser representative, an individual must make a Form U4 filing with FINRA’s CRD/IARD System.  As part of this filing, an individual must submit proof that within the previous two years, the individual has passed either the Series 65 or both the Series 7 and the Series 66 examinations.  Individuals may apply for a waiver of the exam requirements, which waiver request must be submitted by August 2, 2010.

The final date to comply with Michigan’s new investment adviser representative registration requirements is November 1, 2010.  However, due to an anticipated high number of filings, the State of Michigan has stated that licensing may take 60 days from the time a filing is submitted.   Therefore, it is recommended that individuals submit their investment adviser representative application prior to September 1, 2010 to prevent any  lapse in registration.  If you need advice or assistance regarding the filing of an investment adviser registration  application, any of our compliance consultants are willing to assist you.