Nebraska state capitol building in Lincoln, Nebraska

Nebraska Proposes Rule Changes that Allow Investment Advisers to Utilize Client Testimonials & IARs to Dual License

October 09, 2021

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The Nebraska Department of Banking & Finance recently published proposed revisions to its rules for investment advisers under the Securities Act of Nebraska.

The most significant change appears to be that Nebraska is proposing to follow the U.S. Securities and Exchange Commission’s new marketing rule (Rule 206(4)-1) which allows investment advisers to utilize client testimonials. The proposed rule also memorializes the now informal process of allowing an investment adviser representative (“IAR”) without a disciplinary history to dually register at two different investment advisers while transitioning between such firms.

It should be noted that the proposed rule changes did not include the model rule of North American Securities Administrators Association (“NASAA”) requiring investment adviser representatives to complete continuing education (“IAR CE”) each year. In addition, Nebraska’s proposed rule changes for investment advisers didn’t include NASAA’s model rule requiring written policies and procedures for investment advisers covering compliance, supervision, proxy voting, privacy policy, code of ethics, personal securities trading, insider trading, annual compliance review and designating a CCO.

The hearing on the rule proposal is November 10, 2021, at the offices of the Department of Banking and Finance in Lincoln, Nebraska.

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The information contained in this blog post is general in nature intended for educational purposes only and is not intended to be a comprehensive analysis of this topic. It is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation. Please consult the applicable securities regulator’s rules and published guidance for more details about the topics referenced above.  For more information about the limitations of this blog post and information on our website, please see our Disclosures webpage.

Posted by Bryan Hill
Labels: Advertising, Dual Registrations, IAR Licensing, Marketing, NASAA, Nebraska
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