March 10, 1992
TO: UNIT INVESTMENT TRUST COMMITTEE NO. 14-92
RE: INSTITUTE COMMENTS ON PROPOSED MISSOURI FEE CHANGE
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As we previously informed you, the Missouri Securities
Division had proposed an amendment to 15 CSR 30-50.030(2)(A)(5)
to require sponsors of unit trusts to register a definite, rather
than indefinite, amount of units in Missouri. (See Memorandum to
Unit Investment Trust Committee No. 9-92, dated February 18,
1992.)
According to a staff member of the Securities Division, the
proposed amended rule will be modified so that unit trust
sponsors will be able to register an indefinite amount of
securities and fall under the $1,000 maximum registration fee
that is available for non-investment company issuers. Under the
modified proposed amendment, a unit trust sponsor would register
$100,000 of securities for an initial registration fee of $100.
At the end of the registration period, a sales report must be
filed and additional registration fees of 1/20th of 1% of actual
sales in excess of $100,000 must be paid.
The Institute submitted a comment letter in support of the
modified proposed amendment. The Institute noted that under the
modified proposal, unit trust sponsors will not have to predict
the number of sales that may occur in each series of a trust or
register more units than is expected to be sold in Missouri in
order to avoid the problem of oversales. Thus, the most positive
attributes of the two types of registration in Missouri for unit
trust sponsors.
A copy of the Institute's comment letter is attached. We
will keep you advised of developments.
Patricia Louie
Assistant General Counsel
Attachment