On August 8, 2011, the Massachusetts Securities Division (the “Division”) adopted regulations regarding the use of expert network services by investment advisers in Massachusetts (regardless of whether the adviser is registered with the Division or exempt from registration). Under new 950 CMR 12.205(9)(c)(16), investment advisers in Massachusetts will be required to obtain a written certification (see below) before engaging an expert network service (the “Expert Network Rule”). The Expert Network Rule will become effective December 1, 2011.

Use of Expert Network Services

The Expert Network Rule states that prior to obtaining Investment Consulting Services in exchange for compensation, either directly from a consultant or indirectly through a Matching or Expert Network Service, the investment adviser must obtain a written certification that...