December 9, 1994
TO: SEC RULES COMMITTEE No. 129-94
RE: DRAFT LETTER TO SEC STAFF ON CONFIRM DISCLOSURE OF NON-SIPC
STATUS
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As you know, the SEC recently adopted amendments to Rule 10b-10 under the Securities
Exchange Act to require disclosure on confirmations that the broker or dealer transmitting the confirm
or clearing or carrying the customer account is not a member of the Securities Investor Protection
Corporation ("SIPC"), if such is the case. (See Memorandum to SEC Rules Members No. 84-94, dated
November 17, 1994.) This requirement will become effective on April 3, 1995. Underwriters of mutual
funds and unit investment trusts will be required to make this disclosure, unless they are eligible to rely
on the narrow exemption included in the rule. We have drafted the attached letter urging the SEC staff
to take appropriate action "to rectify the untenable situation created by [this] illogical requirement."
Please provide me with your comments on the draft letter by December 16. I can be reached
at 202/326-5824.
Amy B.R. Lancellotta
Associate Counsel
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