February 4, 1994
TO: COMPLIANCE COMMITTEE NO. 3-94
INVESTMENT ADVISERS COMMITTEE NO. 11-94
RE: ALLOCATION PROCEDURES
__________________________________________________________
At the last meetings of the Investment Advisers and Compliance Committees,
we discussed two recent SEC enforcement actions involving the allocation
procedures of an investment adviser to mutual funds and an investment adviser to
private accounts. In light of these cases, the Institute is interested in
obtaining copies of members' allocation procedures to compare the procedures
adopted in different types of firms and to determine whether there are any
industry standards in this area. If you are interested, we could discuss our
findings at the next committee meetings.
Please provide me with a copy of your firm's allocation procedures by
February 18, 1994. All procedures will remain strictly confidential.
Amy B.R. Lancellotta
Associate Counsel