Memo #
9331
INSTITUTE PREPARES DRAFT LETTER REQUESTING STAFF MODIFICATION OF BOARDS OF DIRECTORS' REVIEW RESPONSIBILITIES REGARDING REPURCHASE AGREEMENTS
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[9331]
October 10, 1997
TO: SEC RULES COMMITTEE No. 101-97
RE: INSTITUTE PREPARES DRAFT LETTER REQUESTING STAFF
MODIFICATION OF BOARDS OF DIRECTORS’ REVIEW
RESPONSIBILITIES REGARDING REPURCHASE AGREEMENTS
______________________________________________________________________________
As was discussed at the last committee meeting, we have prepared a draft letter to the
SEC staff requesting that they modify the review responsibilities of investment company
boards of directors regarding repurchase agreements, particularly the evaluation requirement
with respect to the creditworthiness of broker or dealer repo counterparties, and the review
requirement with respect to the form of repurchase agreement. Attached is the Institutes draft
letter.
The draft letter will be discussed at the upcoming meeting on Wednesday, October
22nd. If you are unable to attend, please call (202) 326-5923, fax (202) 326-5828, or e-mail
(simmonbe@ici.org) me with your comments by Tuesday, October 21st.
Barry E. Simmons
Assistant Counsel
Attachment (in .pdf format)