April 6, 1993
TO: TRANSFER AGENT ADVISORY COMMITTEE NO. 25-93
RE: RECORD RETENTION SCHEDULE
__________________________________________________________
At the most recent meeting of the Transfer Agent Advisory
Committee, certain members expressed an interest in sharing
record retention schedules with other committee members in order
to assess their record retention policies relative to other firms
in the industry.
As you know, Rule 31a-2 of the Investment Company Act of
1940 requires certain books and records to be maintained
permanently and certain others to be preserved for a period of
not less than six years. However, paragraph (f)(3) of Rule 31a-2
provides that any record, book or other document may be destroyed
in accordance with a plan previously submitted to and approved by
the Commission. Further, a plan shall be deemed to have been
approved by the Commission if notice to the contrary has not been
received within 90 days after submission of the plan to the
Commission.
If you would like to share your record retention schedules
with other committee members, please forward them to the
undersigned. If you would like to maintain the confidentiality
of your schedules, please indicate such and the Institute will
"white out" firm names prior to distributing the schedules to the
Transfer Agent Advisory Committee.
Gregory M. Smith
Director - Operations/Compliance