[12107]
June 26, 2000
TO: CLOSED-END INVESTMENT COMPANY COMMITTEE No. 21-00
SEC RULES COMMITTEE No. 92-00
SMALL FUNDS COMMITTEE No. 3-00
RE: INSTITUTE COMMENT LETTER ON PROPOSED CHANGES TO MUTUAL FUND
QUOTATION SERVICE
The Institute has filed with the Securities and Exchange Commission the attached comment letter
concerning a proposal by the Nasdaq Stock Market, Inc. to amend the minimum listing requirements for
inclusion and maintenance of open-end and closed-end funds in its Mutual Fund Quotation Service
(MFQS). The amendments would lower both the initial and maintenance requirements for the inclusion
of closed-end funds in the News Media List from $100 million and $60 million in net assets, to $60
million and $30 million in net assets, respectively. In addition, the proposal would amend the inclusion
criteria for the Supplemental List with respect to both open-end and closed-end funds to add an
alternative under which a fund would qualify if the investment management firm that manages the fund
has at least one other fund listed in the MFQS that has at least $10 million in net assets and the firm has at
least $15 million from open-end, closed-end and/or money market funds under management.*
The Institute's comment letter supports the proposed changes, but recommends that the proposed
third alternative criterion for the Supplemental List use a more established concept, such as "fund
complex" or "family of investment companies" to identify related funds.
Kathy D. Ireland
Associate Counsel
Attachment
Attachment (in .pdf format)
* SEC Release No. 34-42831 (May 25, 2000), 65 Fed. Reg. 35693 (June 5, 2000).