December 17, 1990
TO: CLOSED-END FUND COMMITTEE NO. 27-90
OPERATIONS COMMITTEE NO. 27-90
SEC RULES COMMITTEE NO. 65-90
ACCOUNTING/TREASURERS COMMITTEE NO. 38-90
INDEPENDENT ACCOUNTANTS ADVISORY GROUP
TRANSFER AGENT ADVISORY COMMITTEE NO. 52-90
INTERNATIONAL FUNDS TASK FORCE NO. 30-90
COMPLIANCE COMMITTEE NO. 2-90
RE: SEC PROPOSED AMENDMENT TO RULE 31a-2
__________________________________________________________
Enclosed for your information is a copy of the Institute's
comment letter on the recent SEC proposal to amend Rule 31a-2 of
the '40 Act. The proposal itself is also enclosed only for those
committees that did not receive it previously.
We solicited comments from members of a number of committees
for the preparation of the letter and would like to thank
everyone that provided input on this proposal.
At the SEC/ICI Procedures Conference on December 6 and 7, a
representative of the Commission announced that they would be
interested in receiving additional responses on the 31a-2
proposal through the end of the year despite the official due
date of December 10, 1990. If you have any additional comments
please forward them to the undersigned. Also, if you have
submitted or plan to submit comments to the SEC directly, please
forward a copy of your comment letter for our records.
Diane Butler
Director - Operations/
Fund Custody
Enclosure