June 22, 1994
TO: ACCOUNTING/TREASURERS COMMITTEE NO. 34-94
SEC RULES COMMITTEE NO. 68-94
DERIVATIVE INSTRUMENTS SUBCOMMITTEE
RE: JULY 13TH MEETING ON SEC PROPOSED RULE 17f-6
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As we previously informed you, the Securities and Exchange
Commission recently proposed Rule 17f-6 under the Investment
Company Act of 1940, which would permit futures commission
merchants and commodity clearing organizations to hold custody of
margin in connection with certain futures and options transactions
by investment companies. (See Memorandum to Accounting/Treasurers
Committee No. 27-94 and SEC Rules Committee No. 59-94, dated May
31, 1994.) In the proposing release, the SEC requests comments on
numerous aspects of the proposal.
To discuss the proposed rule generally, as well as specific
issues that the Institute may address in its comment letter, we
have scheduled a meeting for Wednesday, July 13th, at 10:00 am.
The meeting will be held in the Institute's David Silver Conference
Room at 1401 H Street, N.W., Washington, D.C. Please call Chimeme
Taylor at (202) 326-5823 by Wednesday, July 6 to let her know if
you will attend the meeting.
Frances M. Stadler
Associate Counsel