[14188]
November 30, 2001
TO: CLOSED-END INVESTMENT COMPANY COMMITTEE No. 23-01
RE: POSSIBLE SUBMISSION OF REGULATORY PROPOSALS TO SEC
In connection with plans to undertake a review of the federal securities laws, SEC
Chairman Pitt has invited the industry to make recommendations for possible regulatory
changes. In response, the ICI is developing a package of regulatory reform proposals for
submission to the SEC. We are interested in your suggestions for any regulatory changes
concerning closed-end funds that we should consider including.
In a 1995 submission to the SEC, we recommended that interval funds be permitted to
use distribution financing arrangements. Since then, interval funds have received exemptive
relief to impose contingent deferred sales charges and asset-based sales charges. Please advise
us as to whether we should seek codification of that relief and, if so, whether the conditions in
the exemptive orders are appropriate. (Attached to this memorandum is a copy of our 1995
proposal and a recent exemptive application.) In addition, please provide us with any other
suggestions for improvements to rules that affect closed-end funds.
We would appreciate receiving any comments or suggestions by Friday, December 14th.
You may provide them to the undersigned at 202/326-5824 (phone), 202/326-5827 (fax) or
amy@ici.org (email), or to Ari Burstein at 202/371-5408 (phone), 202/326-5839 (fax) or
aburstein@ici.org (e-mail).
Amy B.R. Lancellotta
Senior Counsel
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