October 19, 1992
TO: SEC RULES COMMITTEE NO. 77-92
CLOSED-END FUND COMMITTEE NO. 26-92
CLOSED-END FUND DIVISIONAL COMMITTEE
RE: DRAFT INSTITUTE LETTER ON SEC INTERVAL FUND PROPOSAL
__________________________________________________________
Attached is a draft of the Institute’s letter on the SEC’s
proposal to permit closed-end fund repurchases and open-end fund
periodic redemptions (with a delayed payment feature). (See
Memorandum to SEC Rules Committee No. 52-92 and Closed-End Fund
Committee No. 13-92, dated August 3, 1992).
The Institute held several meetings of members to discuss
the policy and technical issues raised by the SEC’s proposals.
(See Memorandum to SEC Rules Committee No. 60-92, Closed-End Fund
Divisional Committee and Closed-End Fund Committee No. 15-92,
dated August 18, 1992). The letter reflects the positions of the
attendees discussed and voted on at those meetings.
The comment period for the SEC’s proposals expires on
November 4, 1992. Please provide me with your comments on the
Institute’s letter by October 29, 1992. My direct number is
202/955-3523.
Amy B.R. Lancellotta
Associate Counsel
Attachment