IAA Requests that Missouri Remove CIC Designation from Proposed Amendment
July 31, 2026
Via Electronic Transmission
Office of Secretary of State
Securities Division
PO Box 1276
Jefferson City, MO 65102
Re: Proposed Amendment to 15 CSR 30-51.030 – Examination Requirement
To Whom It May Concern:
The Investment Adviser Association (IAA)[1] submits this comment on the Missouri Secretary of State’s Proposed Amendment to Rule 30-51.030 (Proposed Amendment)[2] for the limited purpose of addressing the Proposed Amendment’s reference to the Chartered Investment Counselor (CIC) designation.
The Proposed Amendment would automatically waive the examination requirement for investment adviser representatives who hold certain professional designations. Included in the list of designations is “Chartered Investment Counselor (CIC) awarded by the Investment Counsel Association of America, Inc.”[3] The CIC designation has been discontinued as of January 1, 2025, and we therefore ask that you remove reference to the designation from the Proposed Amendment.
We appreciate your consideration of our comments. Please do not hesitate to contact the undersigned at (202) 293-4222 if we can be of further assistance.
Respectfully Submitted,
/s/ Gail C. Bernstein
Gail C. Bernstein
General Counsel and Head of Public Policy
[1] The IAA is the leading organization dedicated to advancing the interests of fiduciary investment advisers. For nearly 90 years, the IAA has been advocating for advisers before Congress and U.S. and global regulators, promoting best practices and providing education and resources to empower advisers to effectively serve their clients, the capital markets, and the U.S. economy. Together, the IAA’s member firms manage more than $57 trillion in assets for a wide variety of individual and institutional clients, including pension plans, trusts, mutual funds, private funds, endowments, foundations, and corporations. For more information, please visit www.investmentadviser.org and see the IAA’s Investment Adviser Industry Snapshot (Snapshot).
[2] See Proposed Amendment, Chapter 51, Missouri Code of State Regulations (July 1, 2026), available at https://www.sos.mo.gov/CMSImages/AdRules/moreg/2026/v51n13July1/v51_n13.pdf.
[3] The Investment Counsel Association of America, Inc. is now the IAA.