April 3, 1992
TO: OPERATIONS COMMITTEE NO. 9-92
TRANSFER AGENT ADVISORY COMMITTEE NO. 19-92
RE: REQUEST FOR SIGNATURE GUARANTEE POLICIES & PROCEDURES UNDER
RULE 17Ad-15
__________________________________________________________
Participants at the March 21, Operations Committee meeting
and the January 31, special Transfer Agent Advisory Committee
meeting agreed to provide to the Institute copies of their
written standards and procedures that have been implemented in
connection with the new Rule 17Ad-15 under the Securities and
Exchange Act of 1934 regarding the acceptance of signature
guarantees.
As you may recall a special meeting of the Transfer Agent
Advisory Committee (TAAC) was held on January 31, 1992 in
Washington, DC to identify problems and discuss compliance
options under the new rule. The rule was effective February 24,
1992. (For a copy of the final rule, see Operations Memorandum
No. 2-92 and TAAC Memorandum No. 2-92. For a synopsis of the
rule and summary of the January 31, 1992 special meeting, see
Operations Memorandum No. 5-92 and TAAC Memorandum No. 7-92.)
An analysis of the written standards and procedures received
with respect to the acceptance of signature guarantees under the
new rule will be performed to determine if there are any
generally accepted approaches and associated language among the
industry. To date written standards have only been received from
6 Transfer Agent Advisory Committee members. If you have not
already done so, please forward copies of your written standards
and procedures to Kathy Joaquin at the Institute, preferably by
fax (202/293-1058) as soon as possible. A summary of the
analysis performed will be presented to both Committees in the
near future.
Your response to this request is appreciated.
Donald E. O'Connor
Vice President -Operations