May 24, 1990
TO: UNIT INVESTMENT TRUST MEMBERS NO. 29-90
RE: INSTITUTE COMMENT LETTER ON PROPOSED VIRGINIA REFUND RULE
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The Virginia Corporations Commission recently proposed an
administrative rule that provides for the refund of a portion of
the registration fees paid by a unit investment trust. The
proposed rule would require a Request for Refund to be submitted
within sixty days of the Virginia effective date of registration
and that a shareholders list be submitted. (See Memorandum to
Unit Investment Trust Members No. 27-90, dated May 15, 1990).
In its comments on the proposal, the Institute expressed
opposition to the proposed requirement that the Request for
Refund be submitted within sixty days of the Virginia effective
date of registration and recommended that the appropriate time
period be "within sixty days of the close of the offering." In
the alternative, the Institute recommended that the time period
to submit the request be extended to "within twelve months from
the Virginia effective date."
The Institute also expressed strong opposition to the
requirement that a shareholders list be submitted, stating that
it was unnecessary, jeopardizes client confidentiality and
imposes a requirement that cannot be met by sponsors of unit
trusts.
A copy of the Institute's letter is attached. We will keep
you informed of developments.
Patricia Louie
Assistant General Counsel
Attachment