Institute Comments on NASAA Proposed Rules for Sales of Securities at Financial Institutions

Washington, DC, April 28, 1997 - The NASAA Securities Activities of Banks Committee (the "Committee") recently published for comment proposed Model Rules for Sales of Securities at Financial Institutions. The Institute submitted a comment letter opposing the proposed rules. The Institute's letter argued that the rules are unnecessary in light of existing or pending positions of the banking agencies and the NASDR on the same subject. At the very least, the rules should not be considered until pending NASDR rules are final so that consistency can be attained. The Institute letter pointed out that several provisions of the proposed rules are contrary to current industry practice and to the National Securities Markets Improvement Act of 1996.

The Committee had intended to submit the proposed rules to a vote of the NASAA membership at the NASAA Spring Conference in Washington, April 24-28. After receiving numerous comments on the proposal, the Committee has recommended to NASAA that the vote be delayed to allow the Committee time to adequately address the concerns raised in the comment letters.