October 25, 1993
TO: SEC RULES COMMITTEE NO. 94-93
STATE LIAISON COMMITTEE NO. 48-93
RE: INSTITUTE DRAFT COMMENT LETTER ON MISSOURI PROPOSAL
__________________________________________________________
As we previously advised you, the Missouri Office of the Secretary of State
issued a proposed rule for registration of securities of a mutual fund that would
require, among other items, the filing of a Missouri supplement to the prospectus
containing certain specified information. (See Memorandum to SEC Rules Committee
No. 87-93 and State Liaison Committee No. 46-93, dated October 6, 1993.)
Attached is a copy of the Institute’s draft comment letter on the Missouri
proposal. The draft letter generally opposes adoption of the proposed rule. In
particular, the draft letter vehemently opposes the provision that would require
mutual funds to prepare a separate and unique disclosure document for Missouri
investors as a precondition for registering their securities for sale in
Missouri.
If adopted, the proposed rule would have severe consequences for mutual
funds. Accordingly, the Institute is strongly encouraging members to submit
individual comment letters opposing adoption of the proposed rule to the
Commissioner of Securities. The comment period for the proposed rule official
ends on November 1, 1993 (although it is our understanding that the Commissioner
of Securities will accept comments through November 5, 1993). Please call me at
202/955-3517 with any comments you might have on the Institute’s draft letter by
Thursday, October 28th.
Patricia Louie
Associate Counsel
Attachment