November 26, 1990
TO: SEC RULES COMMITTEE NO. 63-90
INTERNATIONAL FUNDS TASK FORCE NO. 28-90
RE: INSTITUTE COMMENT LETTER ON PROPOSED AMENDMENTS TO
RULE 6c-9
__________________________________________________________
Attached is a copy of the Institute's comment letter on the
proposed amendments to Rule 6c-9 under the 1940 Act. A draft of
the letter was previously circulated to you. (See Memorandum to
SEC Rules Committee No. 58-90 and International Funds Task Force
No. 26-90, dated November 7, 1990.)
The Institute's letter is substantially the same as the
draft. It endorses the proposed amendments, which would broaden
the exemption from registration under Rule 6c-9 to include equity
securities issued by foreign banks and their finance subsidiaries
and debt and equity securities issued by foreign insurance
companies and their finance subsidiaries and parent holding
companies of foreign banks and insurance companies. It also
recommends that similar amendments be made to Rule 12d1-1 to
permit registered investment companies to purchase securities
issued by parent holding companies of foreign banks and foreign
insurance companies and U.S. branches and agencies of foreign
banks free from the restrictions contained in Section
12(d)(1)(A). The letter was revised to also request that the
staff reconsider its position that the freedom of money market
funds to concentrate in bank instruments is limited to domestic
banks. (See footnote 9 on page 4.)
We will keep you informed of developments.
Craig S. Tyle
Associate General Counsel
Attachment