February 1, 1994
TO: BOARD OF GOVERNORS NO. 10-94
RE: INSTITUTE SURVEY OF MEMBERS' CODES OF ETHICS
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At the recent meeting, all members of the Board were asked to send to the
Institute a copy of their codes of ethics governing personal securities trading.
This will allow the Institute to prepare a survey of existing practices in the
industry, the results of which will be reported to the Board as soon as possible.
Survey results will be reported only on an aggregated basis and no individual
fund complex will be identified by name.
This is to request, if you have not already done so, that you please send
your code to the Institute as soon as possible. We would appreciate your
including any related materials that explain how the code is administered and
enforced (e.g., explanation of pre-clearance procedures, description of
securities for which pre-clearance is denied). Of course, the codes and all
other materials provided to the Institute will be kept strictly confidential.
You may send your code to Tom Selman. In case you have any questions about
the project, Tom may be reached directly at 202/326-5819.
Paul Schott Stevens
General Counsel