October 8, 1996
TO: BOARD OF GOVERNORS No. 56-96
RE: REPORT ON IMPLEMENTATION OF INSTITUTE’S RECOMMENDATIONS ON
PERSONAL INVESTING
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As directed at the October 4, 1996 Board meeting, we are forwarding all Governors a
copy of the Report on the Implementation of the Institutes Recommendations on Personal Investing.
The Report was prepared by the Institute in response to the Division of Investment
Managements October 12, 1994 request for a comprehensive survey of the industrys efforts to
adopt the Institutes recommendations on personal investing. The survey demonstrates that
the vast majority of member fund complexes have voluntarily implemented the Institutes
recommendations, following appropriate consideration of how best to do so in light of their
own specific business activities, structures, and operations.
As was also discussed at the meeting, the SEC has proposed rule changes that would,
among other things, require all mutual funds to file their Codes of Ethics as exhibits to their
registration statements, thus making each funds Code publicly available. Upon adoption of
the amended rule, members should anticipate continued media scrutiny of the provisions of
their Codes, especially insofar as they fail to implement fully the Institutes recommendations
on personal investing.
Paul Schott Stevens
Senior Vice President
General Counsel
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