March 1, 1989
TO: SEC RULES COMMITTEE NO. 14-89
OPTIONS AND FUTURES TASK FORCE NO. 2-89
RE: COMMODITY POOL OPERATORS
__________________________________________________________
Attached are copies of releases published by the SEC and
CFTC concerning performance disclosure by commodity pool
operators ("CPOs"). The SEC and CFTC are seeking comments on,
among other things, whether CPOs should be required to present
prior performance data for more than three years, how often such
performance data should be updated, how the rate of return should
be calculated and how the impact of expenses and fees should be
presented. Comments are due April 7. If there are comments you
feel the Institute should make, please contact the undersigned no
later than March 31, 1989.
Craig S. Tyle
Assistant General Counsel
Attachment