September 1, 1989
TO: BOARD OF GOVERNORS NO. 55-89
MONEY MARKET FUND CHIEF EXECUTIVE OFFICERS NO. 7-89
RE: OKLAHOMA SECURITIES COMMISSION MEETING ON MONEY
MARKET FUND ADVERTISING
__________________________________________________________
On Wednesday, August 30, the Institute appeared at a
meeting of the Oklahoma Securities Commission. The Commission
was considering whether an advertisement by a money market fund
that mentioned check writing privileges was misleading because it
did not disclose that the account on which the checks were drawn
was maintained by a bank. Certain Oklahoma banks had complained
about the advertisement.
Attached is a copy of the Institute's remarks, which were
submitted at the meeting. The Institute stated that the
advertisement was in full compliance with federal law and was not
misleading since the checks could be used in the same manner as
other checking accounts. It also noted that full disclosure
concerning check writing and other aspects of the fund was
contained in the fund's prospectus.
At the meting, the Commission decided to take no action,
although they indicated it was possible they would schedule
hearings in the future on whether to review mutual fund
advertising.
We will keep you informed of developments.
Craig S. Tyle
Assistant General Counsel
Attachment