July 30, 1990
TO: SEC RULES COMMITTEE NO. 39-90
INVESTMENT ADVISERS COMMITTEE NO. 24-90
RE: INSTITUTE COMMENT LETTER ON NEW JERSEY CASINO CONTROL ACT
__________________________________________________________
As we previously informed you, the New Jersey Casino
Control Commission scheduled a hearing on July 24, 1990 to
consider whether the Casino Control Act should be amended to
exempt or waive certain institutional investors from having to
submit to the qualification process. (See Memorandum to SEC
Rules Committee No. 36-90 and Investment Advisers Committee No.
22-90, dated June 29, 1990).
Attached is a copy of the Institute's comment letter. In
its comment letter, the Institute recommended that given the
detailed and stringent reporting requirements that institutional
investors are subject to pursuant to the provisions of the
Securities Exchange Act of 1934, the Casino Control Act could be
amended to allow investment by passive institutional investors of
up to 10% of a class of equity securities and 20% of a class of
debt securities of publicly-held casino companies without
sacrificing the integrity of the casino licensing process.
The Commission has scheduled additional hearings August
2-3, 1990 in Atlantic City to receive additional testimony as to
whether amendments to the Casino Control Act are necessary in
order to encourage investment in casino holding company
securities.
We will keep you advised of developments.
Patricia Louie
Assistant General Counsel
Attachment