[18426]
January 19, 2005
TO: EQUITY MARKETS ADVISORY COMMITTEE No. 5-05
SEC RULES MEMBERS No. 12-05
RE: SEC EXTENDS COMMENT PERIOD ON NYSE AND NASD PROPOSED RULES
RELATING TO IPOS
As we previously informed you,1 the Securities and Exchange Commission has
published for comment proposed rules filed by the New York Stock Exchange and the National
Association of Securities Dealers governing the allocation and distribution of initial public
offerings.2 Similar to the SEC’s proposed amendments to Regulation M,3 the proposed rules
would prohibit certain inappropriate conduct in allocating and distributing IPOs in order to
provide investors with a greater degree of confidence in the IPO process and the capital markets
as a whole. In order to give the public additional time to consider the proposed rules, the SEC
has extended the comment period until February 15, 2005.4
Jane G. Heinrichs
Assistant Counsel
1 Memorandum to Equity Markets Advisory Committee No. 3-05 and SEC Rules Members No. 6-05, dated January
12, 2005 [18391].
2 Securities Exchange Act Release No. 50896 (Dec. 20, 2004), 69 Fed. Reg. 77804 (Dec. 28, 2004). The NYSE and NASD
proposed rules can be found on the SEC’s website at http://www.sec.gov/rules/sro/nyse/34-50896.pdf.
3 For a summary of the SEC’s proposed amendments to Regulation M, see Institute Memorandum to Equity Markets
Advisory Committee No. 53-04 and SEC Rules Members No. 177-04, dated December 22, 2004 [18342].
4 This is also the deadline for comments on the SEC’s proposed amendments to Regulation M.