[15967]
April 29, 2003
TO: CLOSED-END INVESTMENT COMPANY COMMITTEE No. 31-03
SEC RULES COMMITTEE No. 41-03
RE: ICI COMMENT LETTER ON PROPOSED AMENDMENTS TO CFTC RULE 4.5
As we previously advised you, in March, the Commodity Futures Trading Commission
proposed for comment revisions to Rule 4.5 under the Commodity Exchange Act.1 These
revisions are intended to expand the current exclusions from the definition of “commodity pool
operator” for registered investment companies and other regulated entities to accommodate the
trading of security futures and stock index futures.
In response to the CFTC’s request for comments, the Institute has filed the attached
letter supporting the adoption of the proposed revisions and commending the CFTC for
recognizing the need to update Rule 4.5 in this manner. The letter, which is identical to the
draft previously circulated,2 notes that the revisions will provide registered investment
companies increased flexibility to invest in security futures and stock index futures when
appropriate in the interests of their shareholders.
Tamara K. Salmon
Senior Associate Counsel
Attachment (in .pdf format)
1 See Memorandum No. 15822, dated March 29, 2003.
2 See Memorandum No. 15933, dated April 23, 2003.