August 15, 1989
TO: ACCOUNTING/TREASURERS COMMITTEE NO. 32-89
CLOSED-END FUND MEMBERS NO. 38-89
INVESTMENT ADVISER MEMBERS NO. 43-89
INVESTMENT ADVISER ASSOCIATE MEMBERS NO. 43-89
SEC RULES MEMBERS NO. 43-89
RE: SEC ADOPTS EXAMINATION CERTIFICATE FORMS FOR ACCOUNTANTS
__________________________________________________________
On August 2, 1988, the Securities and Exchange Commission
published for comment certain proposed forms under the Investment
Company Act 1940 and the Investment Advisers Act of 1940 and
proposed amendments to rules under those acts requiring the filing
of accountant's certificates. (See Institute Memorandum to SEC
Rules Committee No. 43-88, Investment Adviser Committee No. 18-88,
Accounting/Treasurers Advisory Committee No. 30-88 and Closed-End
Fund Committee No. 20-88, dated August 15, 1988.) In the attached
release, the Commission adopted the forms and rule amendments as
proposed. These forms and rules become effective on September 25,
1989.
Pursuant to Rules 17f-1 and 17f-2 under the Investment
Company Act of 1940 and Rule 206(4)-2 under the Investment Advisers
Act of 1940, an independent public accountant currently must verify
the actual examination of client securities or funds in the custody
of the investment company or investment adviser. After the
examination, the accountant must promptly file with the Commission
a certificate stating that it has made the appropriate examination
and describe the extent of the examination. The forms adopted will
serve as cover sheets for the examination certificates that the
Commission rules now require. The examination certificates will be
attached to the cover sheets which will simply verify that an
accountant has actually inspected either (1) securities or similar
investments of a management investment company that are placed in
the custody of a member of a national securities exchange (see Rule
17f-1(b)(4) of the 1940 Act); (2) securities and similar
investments of a management investment company maintained in the
custody of the investment company (see Rule 17f-2(f) of the 1940
Act); or (3) securities and funds of clients in the custody of an
investment adviser (see Rule 206(4)-2(a)(5)).
The Commission believes that the adopted forms and rules will
result in greater accessibility of information for investors and
will facilitate staff verification of compliance with examination
requirements.
Robert L. Bunnen, Jr.
Assistant General Counsel
Attachment