[13761]
July 24, 2001
TO: SEC RULES COMMITTEE No. 62-01
RE: DRAFT INSTITUTE LETTER ON REVIEW OF DIVISION OF INVESTMENT
MANAGEMENT
As we previously informed you,1 Paul Roye, Director of the Securities and Exchange
Commission’s Division of Investment Management, announced during his keynote address at
the 2001 Mutual Funds and Investment Management Conference that the Division’s Deputy
Director is undertaking a review of the Division’s systems and procedures “to make
recommendations as to how we can improve the way in which we service registrants, respond
to investors and fulfill our responsibilities.” The Institute has prepared the attached draft letter
in order to provide industry recommendations concerning this review.
The letter includes suggestions concerning each individual office within the Division,
coordination among the offices, staff turnover, training and recusal, interaction with other
Divisions, and the Office of Compliance Inspections and Examinations (OCIE). Throughout the
draft, we have included language that indicates that we would like to add examples of the
substantive difficulties and procedural delays that members have experienced in their dealings
with the Division.
Please forward representative examples of your experiences with the various functions
of the Division, as well as any other comments you may have on the draft letter, to the
undersigned by phone at (202) 371-5432, by fax at (202) 326-5827, or by e-mail at
kireland@ici.org no later than Tuesday, August 7.
Kathy D. Ireland
Associate Counsel
Attachment
Attachment (in .pdf format)
1 See Memorandum to Board of Governors No. 15-01, Director Services Committee No. 3-01, Primary Contacts –
Member Complex No. 25-01, and SEC Rules Members No. 27-01, dated April 2, 2001.