June 10, 1993
TO: SEC RULES COMMITTEE NO. 53-93
RE: DRAFT COMMENT LETTER ON THE SEC'S PROPOSED EXPEDITED
REVIEW PROCEDURE
__________________________________________________________
Attached is a draft Institute comment letter on the
Commission's proposals for an expedited procedure for routine
applications and an expansion of the authority delegated to the
Director of the Division of Investment Management to act on
applications. The draft letter recommends that the Commission 1)
adopt procedures that would result in more timely processing of
all applications, not only routine requests, and 2) reconsider
the Institute's proposal that applications be declared effective
automatically after a stated period of time. The draft also
urges that, if adopted, the expedited procedure not become a
substitute for appropriate exemptive rulemaking. Finally, the
draft requests modification of certain of the time periods
proposed.
We would appreciate any comments that you might have on the
Institute's draft letter. Comment letters are due to the SEC on
or before June 29th. Please contact me at 202/955-8419 by June
22nd with your comments. My fax number is 202/659-1519.
Angela C. Goelzer
Associate Counsel - International
Attachment