June 30, 1993
TO: SEC RULES COMMITTEE NO. 58-93
RE: INSTITUTE COMMENT LETTER ON SEC PROPOSED EXPEDITED REVIEW
PROCEDURE
__________________________________________________________
The Institute has submitted the attached comment letter on the SEC's
proposed expedited review procedure for routine applications for a Commission
order. Our 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 letter
also urges that, if adopted, the expedited procedure not become a substitute
for appropriate exemptive rulemaking.
In addition, the Institute offers a number of specific comments on the
proposed expedited review procedure. For example, we recommend that the
proposal be expanded so that expedited review is available for applications
that seek only a portion of the relief granted in a prior order, and for
applications that seek relief under any section of the 1940 Act. The letter
also requests modification of certain of the time periods proposed.
We will keep you informed of developments.
Angela C. Goelzer
Associate Counsel
Attachment