[12284]
July 18, 2000
TO: INVESTMENT ADVISERS COMMITTEE No. 19-00
PENSION COMMITTEE No. 49-00
AD HOC COMMITTEE ON CROSS-TRADES
RE: JOINT SUBMISSION TO DEPARTMENT OF LABOR ON CROSS-TRADES
As you are aware, the Institute, in conjunction with the Investment Counsel Association of
America (“ICAA”), the Association for Investment Management (“AIMR”) and the Securities Industry
Association (“SIA”), drafted a joint letter to the Department of Labor to address issues raised by
Department representatives at the February hearing on active cross-trades issues.1 Attached is a final
copy of the letter that was recently submitted to the Department. In particular, the letter discusses the
respective duties of plan fiduciaries and investment company board of directors and proposes a disclosure
regime to enable plan fiduciaries to review cross-trades activities.
We anticipate scheduling a meeting involving ICI, ICAA, AIMR, SIA representatives and
Department staff to discuss the issues raised in the letter in greater detail. If you have any questions or
comments about the letter, please call me at (202) 218-3563 or Russ Galer at (202) 326-5835.
Kathryn A. Ricard
Associate Counsel
Attachment
Attachment (in .pdf format)
1 See Institute Memorandum to Investment Advisers Committee No. 16-00 and Pension Committee No. 36-00, dated May 22,
2000.