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Asher Bearman

The Washington Department of Financial Institutions (DFI) issued a Notice to all interested parties that its Securities Division intends to propose amendments to its rules for investment advisers.  Significantly, these rules could significantly change the regulatory landscape for investment managers operating in Washington State.  In speaking with state regulators and reviewing the release, I understand that DFI currently is in the process of surveying fund managers.  If you have been contacted by DFI to complete this survey but you are not a registered investment adviser, I would very much like to hear from you as it’s not clear to us exactly who is part of the DFI analysis.

Specifically, the notice states that:

[i]n order to understand how the draft rules may affect investment advisers operating in Washington, the Securities Division is in the process of conducting a survey of registered investment advisers and a representative sample of federal notice filed advisers. After the survey is completed, the Securities Division intends to proceed with the rulemaking process by filing a rulemaking proposal and request for comments.

Again, if you have received this notice, please let me know as I am curious to see who has been contacted.

A full copy, including the proposed amendments, is attached below for reference.

DFI_Investment Adviser Rule Update.pdf