RegAlert2007-01-26
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SEC Division of Investment Management staff letter: Investment Company Institute
The SEC staff agrees not to recommend enforcement action under rule 22c-2 against funds that execute shareholder information agreements with foreign financial intermediaries domiciled in jurisdictions prohibiting the sharing of government-issued identifiers without explicit customer consent. This assurance permits intermediaries to supply transaction information linked to unique identifying numbers generated by the intermediary, rather than government-issued identifiers, for shareholder accounts established before January 1, 2008. The relief requires that the unique number identify accounts with the same beneficial owner and that the intermediary agree to restrict or prohibit further share purchases upon request.
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January 26, 2007
Robert E. Plaze, Esquire
Associate Director
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549
Re: No-Action Request Regarding Shareholder Information Agreements with Foreign Financial Intermediaries Under Rule 22c-2 Dear Mr. Plaze:
The Investment Company Institute (ICI) and the Institute of International Bankers (IIB)1 are seeking assurances from the staff of the Division of Investment Management that it will not recommend enforcement action to the Securities and Exchange Commission under rule 22c-2 under the Investment Company Act of 1940 in the circumstances described in this letter. More specifically, we request that certain foreign intermediaries be permitted to supply transaction information linked to unique identification numbers generated by a financial intermediary rather than to the government-issued identification numbers required under rule 22c-2, with respect to shareholder accounts established before January 1, 2008. As discussed below, the provision under rule 22c-2 that requires financial intermediaries to provide U.S. funds taxpayer identification numbers or other government-issued identifiers for their customers raises serious concerns under foreign privacy laws for foreign financial intermediaries.
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