October 4, 1994
TO: OPERATIONS COMMITTEE NO. 27-94
SEC RULES COMMITTEE NO. 107-94
TRANSFER AGENT ADVISORY COMMITTEE NO. 39-94
UNIT INVESTMENT TRUST COMMITTEE NO. 64-94
RE: INSTITUTE COMMENT LETTER ON PROPOSED T+3 SETTLEMENT FOR
MUNICIPAL SECURITIES
__________________________________________________________
The Institute has filed the attached comment letter with the
Securities and Exchange Commission concerning the proposal of the
Municipal Securities Rulemaking Board ("MSRB") to amend its rules
to establish three business days ("T+3") as the standard settlement
time frame for regular-way transactions in municipal securities.
The letter strongly supports adoption of the proposed
amendments to the MSRB's rules and states that, establishing three
business days as the standard settlement time frame for regular-way
transactions in municipal securities is essential to the successful
conversion to a three day settlement time frame for transactions in
securities issued by investment companies.
The letter also indicates support for the MSRB's request that
the proposed rule changes become effective in June 1995,
simultaneously with Rule 15c6-1 which will establish three business
days as the standard time frame for settlement of broker-dealer
transactions, including mutual fund share transactions.
Diane M. Butler
Director - Operations & Fund Custody
Attachment