REVISED INSTITUTE DRAFT LETTER TO SEC REQUESTING STAFF MODIFICATION OF BOARD RESPONSIBILITIES REGARDING REPURCHASE AGREEMENTS

[9656] February 9, 1998 TO: SEC RULES COMMITTEE No. 7-98 RE: REVISED INSTITUTE DRAFT LETTER TO SEC REQUESTING STAFF MODIFICATION OF BOARD RESPONSIBILITIES REGARDING REPURCHASE AGREEMENTS ______________________________________________________________________________ Based on the comments received from members, we have revised our 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. A copy of the revised draft is attached. The letter will be discussed at the upcoming meeting on Wednesday, February 18th. If you are unable to attend, please call me at (202) 326-5923, fax (202) 326-5827, or e-mail (simmonbe@ici.org) by Tuesday, February 17th with your comments. Barry E. Simmons Assistant Counsel Attachment