October 7, 1991
TO: STATE SECURITIES MEMBERS NO. 46-91
RE: DELAWARE TO RECONSIDER ADOPTION OF PROPOSED MUTUAL FUND
RENEWAL FORM
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Based upon the Institute's efforts, the Delaware Securities
Division is reconsidering adoption of proposed Delaware Form D-3,
the mutual fund registration form. As we previously informed
you, the Division had proposed Form D-3 for adoption and the
Institute strongly objected to the adoption of such inasmuch as
the information sought to be required in the form is non-uniform
with all other states and is not required to be included in an
application for either the initial registration of securities or
renewal of a registration in any other jurisdiction. Moreover,
the information proposed to be required is provided in documents
already filed with the Division, either for the registration of
the fund's securities or registration of the fund's adviser.
(See Memorandum to State Securities Members No. 39-91, dated
August 26, 1991.)
According to the staff of the Division, the Division will
maintain the current procedure of requiring a completed Form U-1,
a letter of intent to renew, a copy of the most current
prospectus and the appropriate fee to renew a mutual fund
registration.
* * *
We will keep you advised of further developments.
Patricia Louie
Assistant General Counsel