June 4, 1993
TO: SEC RULES COMMITTEE NO. 52-93
RE: DRAFT COMMENT LETTER ON THE COMMISSION'S OFF-THE-PAGE
PROSPECTUS PROPOSAL
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Attached is a draft of the Institute's comment letter on
the Commission's off-the-page prospectus proposal. The letter,
which was developed by the Subcommittee on Advertising, generally
supports the Commission's proposal. However, the letter raises
the Institute's concerns about the proposed exclusion of
"unseasoned" funds and funds with multiclass or two-tier
structures. The letter also discusses certain of the disclosure
requirements in the proposal.
We would appreciate any comments that you might have on the
Institute's draft letter. We also encourage you to submit your
own comments. As you may know, the comment period ends on June
23rd. Please call me at 202/955-6251 with any comments you might
have on the draft letter by June 16, 1993. If I am unavailable,
you may give your comments to Craig Tyle at 202/955-3522.
Thomas M. Selman
Assistant Counsel
Attachment