1993-07-19
Added · Updated
The Division of Investment Management will not recommend enforcement action under section 4(2) of the Investment Company Act of 1940 if PaineWebber sponsors unit investment trusts requiring the automatic disposition of a portfolio security upon its rating dropping below level 3 on a 1-to-5 scale. The trust indenture mandates that proceeds from such dispositions are not reinvested in substitute securities but are distributed directly to unitholders, with no discretion granted to the sponsor or trustee regarding sales or reinvestment. This relief applies to future series of PaineWebber Equity Trusts where the proposal is fully disclosed in the prospectus and sales literature.
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JUL 1 91993 p Our Ref. No. 93-375-CC PaineWebber Equity RESPONSE OF THE OFFICE OF CHIEF COUNSEL Trusts DIVISION OF INVESTMENT MANAGEMENT File No. 811-3722
By letter dated June 22, 1993, you request our assurance
that we would not recommend enforcement action to the Commission
under section 4 (2) of the Investment Company Act of 1940 (the
"1940 Act") if, as more fully described in your letter,
PaineWebber Inc. ~,',~PaineWebberll) sponsors unit investment trusts
("UITs") that inclûde a provision in their trust indenture
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