April 6, 1989
TO: UNIT INVESTMENT TRUST COMMITTEE NO. 16-89
RE: PLAN OF ACTION TO OBTAIN AND DEFEND STATE EXEMPTIONS FOR
RESALE OF UNITS
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At the meeting on March 21, 1989, the Unit Investment Trust
Committee discussed problems concerning the use of the "manual"
exemption for resales in the states. As you are aware, the
manual exemption is being challenged by several states. The
Committee decided that the Institute should continue to be
proactive in seeking the "blue chip" exemption in as many states
as possible every year and should be prepared to be reactive to
any challenge to existing exemptions for resales.
In order for the Institute to be fully prepared to react to
a challenge to an existing exemption, we must have certain
readily accessible information. Such information, for each
state, includes: the name and telephone number of a lobbyist
and/or attorney, any contacts in the legislature and/or
governor's office, the number of state series that you have
deposited, the amount of underlying portfolio securities
purchased, an estimate of the number of unit holders, and any
exemption, no-action letter or Order, that is relied upon for
resales. Scott Martin, Van Kampen Merritt, Inc., developed the
attached chart which requests such information. Each sponsor
should complete and return this chart to the Institute by April
28, 1989.
In addition, in January, each sponsor was asked to provide
the Institute with information concerning "blue sky" fees and
costs. Please check to see that this information has been sent
to the Institute. Finally, each sponsor should be able to supply
the following information to the Institute upon request: the
principal firms from whom you purchase portfolio securities
contained in the trusts, attorneys or government officials with
whom you work on a regular basis when purchasing portfolio
securities and the name and phone number of every broker-dealer
branch manager.
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The information requested above is crucial to an effective
defense of any exemption for resales that is challenged. Please
contact the Institute if you have any questions.
Natalie Shirley
Associate General Counsel
Attachment