August 14, 1992
TO: SEC RULES COMMITTEE NO. 58-92
RE: PROPOSED LETTER TO THE SEC REGARDING CHANGES IN
EXEMPTIVE PROCEDURES
__________________________________________________________
As you may recall, at the Committee’s June 10th meeting the
members generally objected to the SEC staff’s proposal to amend
the SEC’s exemptive procedures. The members suggested that we
reiterate to the SEC our recommendation for streamlining the
exemptive process.
Attached is a draft letter from the Institute to the
Division of Investment Management, which would urge adoption of a
procedure for the automatic issuance of orders after a stated
period of time. The letter recommends a 30-day period in the
case of applications with precedent and a 90-day period in the
case of other applications, although it would allow for some
flexibility on the time periods if the automatic nature of the
procedure were retained.
Please let me know if you have any comments on the letter.
I would appreciate your suggestions by Friday, August 28th.
Thomas M. Selman
Assistant Counsel
Attachment