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Communications from the Institute do not constitute, and should not be considered a substitute for, legal advice.
[19094]
August 12, 2005
TO: CLOSED-END INVESTMENT COMPANY COMMITTEE No. 27-05
RE: AMEX PROPOSAL REGARDING LISTING FEES; YOUR VIEWS REQUESTED BY
AUGUST 19TH
The Securities and Exchange Commission recently published for comment an American
Stock Exchange proposal regarding listing fees for closed-end funds.∗ Comments are due to the
Commission by September 1st.
The Institute is considering whether to file a comment letter on the proposal. If you
have comments that you would like us to consider including in such a letter, please provide
them to me by phone (202.218-3563) or email (ddonohue@ici.org) no later than August 19th.
The proposal would amend Section 140 of the Amex Company Guide to permit the
Amex Board of Governors or its designee to defer, waive, or rebate all or any part of the initial
listing fees applicable to a closed-end fund that transfers to the Amex from another
marketplace. The Release states that Amex expects that fee reductions would be granted only
infrequently to attract an important listing that is likely to generate significant transaction fee
revenue. It also states that the waiver, deferral or rebate of closed-end fund listing fees will not
impact the Amex’s resource commitment to regulatory oversight of the listing, or other
regulatory, programs.
Dorothy M. Donohue
Associate Counsel
∗ Securities Exchange Act Release No. 52216 (August 5, 2005), 70 FR 46896 (August 11, 2005) (“Release”).