[10643]
January 14, 1999
TO: CLOSED-END INVESTMENT COMPANY MEMBERS No. 4-99
COMPLIANCE ADVISORY COMMITTEE No. 1-99
INTERNATIONAL MEMBERS No. 1-99
SEC RULES MEMBERS No. 5-99
RE: POSSIBLE EXTENSION OF FEBRUARY 1 COMPLIANCE DATE FOR RULE
17f-5 AMENDMENTS
______________________________________________________________________________
The Institute has been informally advised by a member of the SEC’s Division of Investment
Management that the staff intends to recommend that the Commission extend the February 1, 1999
compliance date for the 1997 amendments to Rule 17f-5 under the Investment Company Act of 1940,
and that a formal pronouncement on this matter should be issued shortly. We do not have any
information concerning how long the extension may be. The extension of the compliance date would
provide the staff with additional time to consider further amendments to Rule 17f-5, as requested by the
Institute, to address issues related to the use of securities depositories.
Amy B.R. Lancellotta
Senior Counsel