Institute Files Comment Letter on NYSE's Closed-End Fund Listing Criteria

Washington, DC, February 25, 1999 - The New York Stock Exchange (NYSE) has filed a proposed rule change instituting a pilot program relating to the listing eligibility criteria for closed-end funds. The Institute has filed a comment letter with the Securities and Exchange Commission (SEC) opposing this proposal.

In particular, the Institute's letter states that, while it may be advisable to codify specific eligibility listing criteria for closed-end funds, the Institute opposes the proposed rule change for two reasons. First, the SEC has granted accelerated approval to allow the pilot program to be instituted without first allowing the industry the opportunity to comment. Second, adopting any listing criteria should be done in a more careful and deliberate manner and with greater specificity and less uncertainty. For example, it is unclear from the release the rationale for the proposed listing requirement; how this requirement will be applied; and whether there are any other listing standards and requirements.