1 See Memorandum to SEC Rules Members No. 19-98, dated March 19, 1998.
[9862]
April 20, 1998
TO: ACCOUNTING/TREASURERS COMMITTEE No. 19-98
RE: INSTITUTE NO-ACTION REQUEST REGARDING ELIMINATION OF 4 TO 6
MONTH UPDATE
______________________________________________________________________________
As you know, as part of the recent amendments to Form N-1A, the Securities and Exchange
Commission (“SEC”) eliminated the requirement that a fund undertake to file a post-effective
amendment to its registration statement containing updated financial statements within 4 to 6 months
after the effective date of a registration statement (“4 to 6 month undertaking”).1 All new registration
statements filed on or after December 1, 1998 must comply with the amendments to Form N-1A.
Attached is a copy of a letter to the SEC staff requesting that any new fund (or new series) filing
a registration statement (or post-effective amendment thereto) on current Form N-1A before December
1, 1998 be permitted to omit the 4 to 6 month undertaking. The letter also requests that any fund (or
series) with a pending or an effective registration statement that has made the 4 to 6 month undertaking
be permitted to forego filing the update.
Dorothy M. Donohue
Associate Counsel
Attachment