* See Memorandum to SEC Rules Committee No. 71-97, Accounting/Treasurers Committee No. 19-97, and Unit
Investment Trust Committee No. 47-97, dated July 16, 1997.
[9135]
August 6, 1997
TO: ACCOUNTING/TREASURERS COMMITTEE No. 24-97
SEC RULES COMMITTEE No. 77-97
UNIT INVESTMENT TRUST COMMITTEE No. 51-97
RE: DRAFT INSTITUTE COMMENT LETTER ON PROPOSED AMENDMENTS TO
RULE 24f-2
______________________________________________________________________________
As we previously informed you, the Securities and Exchange Commission recently
issued a release seeking comment on proposed rule and form amendments relating to the
calculation of registration fees for certain investment companies.* Attached for your review is
the Institutes draft letter to the Commission. While the Institutes draft letter is generally
supportive of the proposal, it suggests several changes to the proposal and objects to the
Commissions proposed treatment of certain business combinations.
The letter suggests that the Commission amend Form 24F-2 to ask funds to identify the
number of securities registered other than pursuant to Section 24(f) in a prior fiscal year which
were unsold at the end of the fiscal year for which the Form is being filed. The letter reasons
that requiring this information would assist fund compliance personnel in determining
whether fund shares sold by the fund have been appropriately registered. The letter also
supports the proposed elimination of the rule 24f-2 opinion of counsel requirement and further
recommends that similar requirements in investment company registration forms be
eliminated.
The comment letter must be filed with the Commission by August 18th. Therefore,
please contact me by phone at 202/326-5821, fax at 202/326-5827, or e-mail at donohue@ici.org
as soon as possible but no later than Thursday, August 14th with any comments on the
attached draft letter.
Dorothy M. Donohue
Associate Counsel
Attachment (in .pdf format)