1 Memorandum to Closed-End Fund Committee No. 26-96, dated August 5, 1996.
September 6, 1996
TO: CLOSED-END FUND COMMITTEE No. 28-96
RE: INSTITUTE COMMENT LETTER ON PROPOSED REGULATION M
______________________________________________________________________________
As we previously informed you, the Securities and Exchange Commission recently
published for comment new Regulation M containing trading practices rules regarding
securities offerings.1 In the release proposing Regulation M, the Commission stated that
exemptions granted under Rule 10b-6 under the Securities Exchange Act of 1934 no longer
would be in effect upon adoption of Regulation M.
Attached is a copy of the Institutes comment letter on the proposal. The letter urges the
Commission to preserve exemptive relief granted under Rule 10b-6 to closed-end investment
companies that conduct periodic tender offers to purchase their shares while continuously
offering their shares under Rule 415 under the Securities Act of 1933.
Dorothy M. Donohue
Assistant Counsel
Attachment