November 18, 1992
TO: INTERNATIONAL COMMITTEE NO. 24-92
RE: SEC COMMISSIONER ROBERTS COMMENTS ON OFFSHORE TRADES
__________________________________________________________
In an October 23 speech on Shareholder Voting and
Transparency before the New York Stock Exchange’s Legal Advisory
Committee, SEC Commissioner Richard Y. Roberts stated that the
integrity of the U.S. markets is compromised when U.S. securities
firms send trades offshore to be executed in order to circumvent
exchange regulations or to avoid reporting transactions in the
U.S. Commissioner Roberts noted that the Commission takes the
position that transactions in U.S. securities that are negotiated
in the U.S. and sent abroad for execution are subject to U.S.
securities laws, and that Sections 11A and 17(a) of the Exchange
Act authorize the Commission to compel reporting of such trades.
A copy of Commissioner Roberts’ speech is attached. We
will keep you informed of developments.
Angela C. Goelzer
Associate Counsel
Attachment