April 28, 1994
TO: SEC RULES COMMITTEE NO. 50-94
RE: FORMATION OF 6c-10 SUBCOMMITTEE; MEETING ON MAY 12
__________________________________________________________
At the meeting of the SEC Rules Committee on April 12, there
was a discussion of whether significant issues remain under
proposed Rule 6c-10 concerning non-contingent deferred sales
charges (in particular, installment loads). A memorandum was sent
to the Committee before the meeting summarizing issues identified
by the Institute in its 1989 comment letter on proposed Rule 6c-10,
recent comment letters filed in support of the proposal, and
certain developments in the area of mutual fund distribution since
Rule 6c-10 was proposed. (See Memorandum to SEC Rules Committee
No. 44-94, dated April 4, 1994.) As noted in that memorandum, the
SEC staff has indicated that Rule 6c-10 may be adopted in some form
in conjunction with the adoption of the SEC's proposal regarding
multiple class funds.
As agreed at the April 12 meeting, the Institute is forming a
subcommittee to focus on remaining concerns raised by proposed Rule
6c-10. A meeting of the subcommittee has been scheduled for
Thursday, May 12, at 10:00 a.m. in the Institute's David Silver
Conference Room on the 12th floor at 1401 H Street, N.W.,
Washington, D.C. Please indicate on the attached form if you plan
to attend.
In addition to the SEC Rules Committee, the Institute is
inviting members of its Accounting/Treasurers, Operations and Tax
Committees to join the subcommittee. Those committees received a
revised version of the memorandum referred to above that previously
was circulated to you. A copy of the revised memorandum, which
focuses primarily on tax, accounting and operational issues, is
attached for your information.
Frances M. Stadler
Associate Counsel
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