February 16, 1993
TO: CLOSED-END FUND COMMITTEE NO. 4-93
RE: CLOSED-END FUND ISSUANCE OF LONG-TERM STOCKY WARRANTS
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At the meeting of the Closed-End Fund Committee held on
February 2, 1993, the Committee discussed whether it would be
appropriate for the Institute to approach the SEC staff with a
proposal for regulatory and/or legislative changes that would
permit closed-end funds to issue long-term warrants. Shortly
before the meeting, we had distributed to the Committee a
memorandum prepared by outside counsel on issues relating to this
matter. (See Memorandum to Closed-End Fund Committee No. 3-93,
dated January 28, 1993.) Committee members present at the
meeting expressed the desire to further reflect on the memorandum
before deciding whether the Institute should work on a proposal
to present to the SEC staff. In addition, these Committee
members wished to discuss with marketing personnel at their firms
whether the potential benefits of having the ability to issue
long-term warrants would be so significant as to suggest that the
Institute should devote its resources to this project at this
time. The Institute agreed to follow up with a survey of the
Committee to determine if there is sufficient interest in going
forward and, in particular, whether Committee members anticipate
that they would take advantage of the ability to issue long-term
warrants if it were available.
Accordingly, please indicate your position below, and
return the completed form to me by mail or fax (202/659-1519) by
Monday, March 1.
Frances M. Stadler
Assistant Counsel
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The Institute should seek regulatory and/or legislative changes
that would permit closed-end funds to issue long-term warrants.
YES NO
Name Firm Date