1 See Memorandum to Closed-End Fund Committee No. 39-97, dated October 24, 1997.
[9399]
November 7, 1997
TO: CLOSED-END INVESTMENT COMPANY COMMITTEE No. 42-97
RE: ICI LETTER TO SEC ON CALCULATION OF EXPENSE RATIO
______________________________________________________________________________
The Institute has sent the Securities and Exchange Commission the attached letter
concerning calculation of expense ratios for closed-end funds that have preferred shares
outstanding. The letter is substantially similar to the draft that we recently circulated to you.1
The letter argues that the forthcoming generic comment letter should not require closed-end
funds to deduct the value of preferred shares outstanding from average net assets when
calculating the funds expense ratio to be included in the financial highlights table.
We expect the "Dear CFO" generic comment letter to be issued shortly. We will circulate
the letter when it becomes available.
Gregory M. Smith
Director - Operations/
Compliance & Fund Accounting
Attachment