March 31, 1994
TO: INVESTMENT ADVISERS COMMITTEE NO. 27-94
INVESTMENT ISSUES COMMITTEE NO. 6-94
SEC RULES COMMITTEE NO. 43-94
UNIT INVESTMENT TRUST COMMITTEE NO. 27-94
RE: DRAFT COMMENT LETTER ON LARGE TRADER REPORTING REPROPOSAL
__________________________________________________________
As we previously informed you, the Securities and Exchange Commission has
reproposed Rule 13h-1 under the Securities Exchange Act of 1934, which would
establish an activity-based large trader reporting system. (See Memorandum to
Investment Advisers Committee No. 14-94, Investment Issues Committee No. 3-94,
SEC Rules Committee No. 19-94 and Unit Investment Trust Committee No. 14-94,
dated February 24, 1994.) The reproposal addresses many of the concerns raised
by the Institute in its comment letter on the Commission's original large trader
reporting proposal. (See Memorandum to Investment Issues Committee No. 22-91,
SEC Rules Committee No. 71-91, Investment Advisers Committee No. 60-91 and Unit
Investment Trust Committee No. 45-91, dated December 12, 1991.)
Attached for your review is a draft comment letter to the Commission on the
reproposed large trader reporting system. The draft letter (1) recommends
certain changes with respect to the information that investment advisers would
have to provide on Schedules 7a and 7b to Form 13H concerning brokerage accounts,
(2) suggests that the Commission eliminate an inconsistency between the
definition of "identifying activity level" in reproposed Rule 13h-1(a)(8) and the
definition of that term in the General Instructions to Form 13H, and (3) repeats
the Institute's previous recommendation concerning voluntary large trader report
filings.
If you have any comments on the attached draft letter, or there are other
issues you would like the Institute to consider including in the letter, please
contact the undersigned at (202) 326-5822 by Thursday, April 14.
Frances M. Stadler
Associate Counsel
Attachment