October 11, 1991
TO: SEC RULES COMMITTEE NO. 62-91
INVESTMENT ADVISERS COMMITTEE NO. 52-91
RE: MEETING TO DISCUSS SEC LARGE TRADER REPORTING PROPOSAL
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The Institute has scheduled a meeting for October 31, 1991
to discuss the SEC's recent proposal to establish an activity-
based large trader reporting system. (See Memorandum to SEC
Rules Committee No. 52-91, dated August 30, 1991 and Memorandum
to Investment Advisers Committee No. 44-91, dated September 12,
1991.)
Several members have expressed concern about the
significant administrative burdens and costs that would be
imposed upon investment advisers and fund complexes under the
proposed reporting system. It would be helpful if you could
bring estimates of these costs to the October 31 meeting. In
addition, we recommend that, in preparation for the meeting, you
discuss the proposal with the relevant persons in your firm.
The comment period for this proposal expires on November
26, 1991. Therefore, if you or anyone in your firm is unable to
attend the meeting, please provide me with your comments by
October 30, 1991.
The October 31 meeting will be held at the Institute at
10:00 a.m. Please contact Michele Dugue at 202/955-3515 by
October 25 to let her know whether or not you will attend the
meeting.
Amy B.R. Lancellotta
Associate General Counsel