SEC Issues Final Rules on Certification of Investment Company Shareholder Reports and Disclosure of Codes

CLIENT MEMORANDUM SEC ISSUES FINAL RULES ON CERTIFICATION OF INVESTMENT COMPANY SHAREHOLDER REPORTS AND DISCLOSURE OF CODES OF ETHICS AND AUDIT COMMITTEE FINANCIAL EXPERTS The Securities and Exchange Commission (the “SEC”) has adopted rule and form amendments that require mutual funds and other registered management investment companies to file shareholder reports on Form N-CSR and require each investment company’s principal executive and financial officers 1to certify the information contained in these reports in the manner specified by Section 302 of the Sarbanes-Oxley Act of 2002 (the “Sarbanes-Oxley Act”). In addition, mutual funds and other registered management investment companies will now be required to include new disclosures on Form N-CSAR in order to implement the “code of ethics” and “financial expert” disclosure requirements of Sections 406 and 407 of the Sarbanes-Oxley Act. The amendments become effective on March 1, 2003, except that the effective date of the removal of the certification requirement from Form N-SAR is May 1, 2003. The text of the adopting release is available at http://www.sec.gov/rules/final/34-47262.htm. Certified Shareholder Reports on Form N-CSR Form N-SAR currently is the form designated for registered investment companies to comply with their reporting requirements under Sections 13(a) and 15(d) of the Securities Exchange Act of 1934 (the “Exchange Act”). Rule 30a-2 under the Investment Company Act ...