October 4, 1989
TO: CLOSED-END FUND COMMITTEE NO. 41-89
SEC RULES COMMITTEE NO. 59-89
ADVERTISING SUBCOMMITTEE
RE: MEETING TO DISCUSS DRAFT COMMENT LETTER ON PROPOSED
REVISIONS TO FORM N-2
__________________________________________________________
Attached is a copy of the Institute's draft comment letter
on the proposed revisions to Form N-2. Since some of the
proposed changes to Form N-2 are of such significance for both
closed-end and open-end funds, such as the proposal to identify
the portfolio manager, we have scheduled another meeting to
discuss the draft comment letter.
There is a comment in the letter which should be
specifically noted. We have requested that, if the proposed
changes to the per share table are adopted in the context of
open-end funds and total return is therefore required to be
included in the prospectus, the mutual fund advertising rules be
amended to omit the requirement that total return figures be
included in advertisements.
The meeting will be held on October 10, 1989 at 1:30 p.m.
in the New York Room at the Capitol Hilton Hotel, located at 1001
16th Street, N.W., Washington, D.C. Lunch will be served before
the meeting at 12:30 p.m. in the Pan American Room. Please
contact Nancy Inman at 202/955-3515 as soon as possible to let
her know whether or not you will attend the meeting .
If you will not be attending the meeting, please provide me
with any comments you may have on the attached draft letter by
October 13, 1989.
Amy B. Rosenblum
Assistant General Counsel
Attachment