June 23, 1989
TO: SEC RULES COMMITTEE NO. 31-89
UNIT INVESTMENT TRUST COMMITTEE NO. 28-89
CLOSED-END FUND COMMITTEE NO. 21-89
BROKER/DEALER ADVISORY COMMITTEE NO. 29-89
MARKETING COMMITTEE NO. 19-89
RE: LEGAL INVESTMENT LAWS SURVEY
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The Institute is in the process of preparing a survey
of the laws of the various states of the United States, the
District of Columbia and the Commonwealth of Puerto Rico
concerning the legality for certain entities to invest in
investment company shares (i.e., mutual funds, closed-end funds
and unit investment trusts). The survey is intended to obtain
information on various issues including: (1) the types of
entities that are restricted from or are subject to limitations
with respect to investing in investment company shares; (2) the
nature of those restrictions and limitations; (3) the applicable
requirements for investment companies whose shares are
permissible investments; and (4) the limitations, if any, on the
portfolio securities of those companies.
We are interested in any suggestions or comments that
you may have for the survey. For example, please let us know
if there are specific issues in which you are particularly
interested. Upon completion of the survey, the Institute
will distribute the findings which will be updated periodically.
We also will determine whether the Institute should seek to
modify restrictive legal investment laws in certain states.
Please provide me with your suggestions or comments
concerning the survey by July 21, 1989. My direct number
is (202) 955-3523.
Amy B. Rosenblum
Assistant General Counsel