January 22, 1990
TO: CLOSED-END FUND COMMITTEE NO. 4-90
SMALL FUNDS COMMITTEE NO. 2-90
UNIT INVESTMENT TRUST COMMITTEE NO. 3-90
RE: FORMATION OF COMPLIANCE COMMITTEE
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At the SEC Rules Committee meeting held on January 11,
1990, the Institute proposed forming a committee to address
compliance issues. The members at the meeting agreed that a
compliance committee would be useful and expressed a high level
of interest in the Institute establishing such a committee. The
purpose of the committee would be to give members an opportunity
to exchange views on compliance related issues and to consider
industry positions. However, there are several issues that have
arisen in determining how this committee should be structured and
how it should operate.
First, the scope of the committee needs to be defined.
There are numerous topics which the compliance committee could
consider, e.g., tax, operations, insider trading and portfolio
compliance. We are therefore interested in suggestions from you
as to what topics this committee should cover. If it is
recommended that the committee cover a broad array of numerous
issues, perhaps we would then select several related topics to be
covered at each committee meetings.
Second, many members have expressed concern that within
their company there is more than one person responsible for
handling compliance matters. We would recommend that each fund
group select one person to be on the committee, and to send an
alternate if there are topics that will be covered at a meeting
for which someone other than the committee member is responsible.
Please provide me with your suggestions on the issues that
the compliance committee should cover and any other comments that
you may have concerning the committee by February 16, 1990. My
direct number is (202) 955-3523.
Amy B. Rosenblum
Assistant General Counsel