Institute Comments on U.K. Web Communications Proposal

Washington, DC, May 12, 1999 - On April 30, 1999, the Institute submitted a comment letter to the U.K. government on its proposed approach to financial promotions under the draft Financial Services and Markets Bill. The Institute's comments focus on the proposed exclusion in the Consultation Draft for website communications not directed at the U.K. ICI filed comments on the bill itself last November.

The Institute's letter supports the Treasury's decision to first invite comment on the general approach to Internet communications set out in the Consultation Draft and then, after consideration of the comments, to publish a detailed draft order for further comment. The letter supports the proposed exclusion for website communications not directed at the U.K. The Consultation Draft set forth three alternative approaches for the exclusion. The Institute's letter recommends the approach that would provide a list of non-exclusive indicators for use in determining whether a financial promotion is directed at the UK.

The Institute's letter also urges the Treasury to preserve the substance of current exemptions, including the exemption for advertisements contained in periodicals and broadcasts circulated or transmitted primarily outside the UK, and the exemption that permits investment companies to send promotional material to existing shareholders. The Institute's letter also urges the Treasury to permit a company to make solicitations to those persons to whom it can sell its securities on a non-public basis.