March 23, 1994
TO: SEC RULES COMMITTEE NO. 39-94
UNIT INVESTMENT TRUST COMMITTEE NO. 25-94
RE: SEC PROPOSAL TO REQUIRE DISCLOSURE OF SIPC STATUS ON
CONFIRM
__________________________________________________________
The Securities and Exchange Commission has proposed amendments to Rule 10b-
10 under the Securities Exchange Act of 1934. The rule generally requires
broker-dealers to send a written confirmation to their customers at or before the
completion of a transaction, and specifies information that must be included on
the confirm. According to the proposing release, a copy of which is attached,
the proposed amendments "are designed to enhance the disclosure given to
customers so that customers can better evaluate their securities transactions."
Most of the proposed changes would require additional disclosures that are
not relevant to transactions in investment company securities. One proposed new
provision, however, would require disclosure on the confirmation that the broker
or dealer transmitting the confirmation is not a member of the Securities
Investor Protection Corporation ("SIPC"), or that the broker or dealer clearing
or carrying the customer account is not a member of SIPC, if such is the case.
Other proposed amendments include restructuring the rule and adding a preliminary
note to indicate that the rule's requirements do not limit disclosures necessary
under the antifraud provisions of the federal securities laws.
Comments on the proposed amendments to Rule 10b-10 must be filed within 90
days of their publication in the Federal Register. If there are issues you would
like the Institute to consider including in a comment letter, please contact me
at (202) 326-5822 by Friday, April 29.
Frances M. Stadler
Associate Counsel
Attachment