January 5, 1989
TO: INVESTMENT ADVISERS COMMITTEE NO. 2-89
SEC RULES COMMITTEE NO. 1-89
BROKER/DEALER ADVISORY COMMITTEE NO. 1-89
RE: ICI COMMENTS ON NASD PROPOSAL ON CUSTOMER ACCOUNT
INFORMATION
__________________________________________________________
Attached is an Institute comment letter on a NASD proposal
to amend Section 21(c) of Article III of the Rules of Fair
Practice, requiring that certain additional information be
obtained from a customer prior to settlement of an initial
transaction in that account.
While such information may be appropriate in establishing a
full service broker-dealer retail account, the Institute
questions whether certain information (such as the customer's
occupation and name and address of the employer) is necessary
when the account is solely for the purpose of effecting
transactions in the securities of open-end investment companies.
Accordingly, the Institute has requested that the NASD refer the
proposal to the NASD's Investment Companies Committee for its
consideration of what information should be required for accounts
solely for effecting transactions in investment company
securities.
Susan P. Hart
Assistant General Counsel
Attachment