February 10, 1994
TO: SEC RULES COMMITTEE NO. 15-94
STATE LIAISON COMMITTEE NO. 13-94
UNIT INVESTMENT TRUST COMMITTEE NO. 10-94
RE: REQUEST FOR COMMENTS ISSUED BY MASSACHUSETTS STAFF
__________________________________________________________
Last August, the Institute requested members of the State Liaison and Unit
Investment Trust Committees to provide the Institute with samples of specific
comments issued by the staff of the Massachusetts Securities Division that were
either inconsistent with federal requirements or non-uniform with the regulations
imposed by other states. This information would have been used to illustrate the
difficulties funds and trusts have experienced in registering their securities
with Massachusetts. (See Memorandum to State Liaison Committee No. 39-93 and
Unit Investment Trust Committee No. 41-93 dated August 27, 1993.) Due to the
small number of responses received, the Institute has not yet scheduled a meeting
with the Securities Division.
At the February committee meetings, several members again expressed
frustration with the Massachusetts review process. The Institute would like to
schedule a meeting with the Director and Assistant Director of the Securities
Division as soon as possible to discuss the problems associated with the review
process and to try to resolve any recurring comments or issues on an industry-
wide basis. Prior to doing so, however, we need to know the types of comments
that have been issued by the staff and any other problems associated with the
registration process. Please provide me with copies of specific comments issued
by the staff of the Securities Division that are inconsistent with federal
requirements or non-uniform with the other states and your responses (or any
other pertinent information) to me no later than Friday, February 25, 1994. My
direct telephone number is 202/326-5821.
Patricia Louie
Associate Counsel