April 4, 1990
TO: UNIT INVESTMENT TRUST COMMITTEE NO. 14-90
RE: SOUTH DAKOTA COMMENT LETTER
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As we previously informed you, the South Dakota Securities
Division recently proposed for public comment a rule that
increased the filing requirements for unit investment trusts
claiming the blue chip exemption from registration. (See Memo to
Unit Investment Trust Committee No. 12-90, dated March 19, 1990.)
Proposed section 20:08:06:21 would require a unit trust to
include a copy of its most recent audited financial statement in
its filing to claim the exemption.
The Institute objected to this requirement as unnecessary
inasmuch as the fee to claim the exemption is not tied in any
manner to information contained in the financial statement. The
Institute further noted that it is unlikely that any meaningful
information would be contained in the unit trust's initial
financial statement since deposit of the portfolio of securities
would not have generally occurred at the time of filing the
notice of claim of exemption.
A copy of the Institute's letter is attached. We will keep
you informed of developments.
Patricia Louie
Assistant General Counsel
Attachment