This special exhibit features a 24-videotape "compliance course" produced by the U.S. Securities and Exchange Commission during August 20 - 24, 1979. The series of videos captures then-Director of the Division of Investment Management, Sydney H. Mendelsohn leading SEC staff experts through a discussion of the provisions of the Investment Company Act of 1940 in what Mendelsohn calls, "A walk through the statute."
According to donor James H. Perry* (former Assistant District Administrator in the Fort Worth Regional Office), Mendelsohn had the videotapes made and distributed to each of the SEC's regional offices to be viewed by Investment Company and Investment Adviser examiners and any enforcement staff who were interested.
The videotapes were not directed for use with any public audience. Each video runs from 45-60 minutes in length and covers specific sections of the 1940 Investment Company Act. The 24th tape is of Mendelsohn providing an in-person "report" to the regional offices from headquarters on the activities of the Investment Management Division in the context of the deregulatory climate in Washington at that time.
Originally recorded in Betamax format, these 24 videotapes were preserved and converted to VHS by James Perry, then donated to the SEC Historical Society in 2017.
* James H. Perry began his career with the Fort Worth Office of the U.S. Securities and Exchange Commission on September 28, 1969. On November 30, 2003, he was promoted to Assistant District Administrator IC/IA Examinations. Prior to that, he spent 27 years as an IC/IA Branch Chief and 7 years as either an Enforcement Staff Accountant or a Securities Compliance Examiner. He also worked for over two years for the U.S. Treasury Department. Mr. Perry graduated from Baylor University in 1967 with a B.B.A. in Accounting. He retired from the SEC on January 3, 2007.
Purposes and policy of the Investment Company Act - Section 1(b) Definition of an investment company and the exclusions and exemptions therefrom (Section 3)
SEC Staff: Sydney H. Mendelsohn, Sidney L. Cimmet, Stanley B. Judd, Lawrence R. Bardfeld
SEC Staff: Sydney H. Mendelsohn, Sidney L. Cimmet, Stanley B. Judd, Lawrence R. Bardfeld
SEC Staff: Sydney H. Mendelsohn, Sidney L. Cimmet, Stanley B. Judd, Lawrence R. Bardfeld
SEC Staff: Sydney H. Mendelsohn, Sidney L. Cimmet, Stanley B. Judd, Lawrence R. Bardfeld
Classifications of investment companies (Section 4)
Subclassification of investment companies (Section 5)
The unregistered investment company:
Prohibitions against unregistered companies (Section 7)
Enforcement of prohibitions (Section 42(e))
SEC Staff: Sydney H. Mendelsohn, Sidney L. Cimmet, Stanley B. Judd, Lawrence R. Bardfeld
When is a company a registered company? (Section 8(a))
Registration under the Securiites Act of 1933 (Section 24)
SEC Staff: Sydney H. Mendelsohn, Joel H. Goldberg, W. Burrell Ellis, Anthony A. Vertuno, Jeremiah J. DeMichaelis
SEC Staff: Sydney H. Mendelsohn, Joel H. Goldberg, Anthony A. Vertuno, Jeremiah J. DeMichaelis
Subchapter M Status under IRS Code
Selection and ratification of independent accountants (Section 32)
SEC Staff: Sydney H. Mendelsohn, +Dennis M. Gurtz
Unit investment trusts and variable annuities (Sections 26 and 27)
SEC Staff: Sydney H. Mendelsohn, Melville B. (Tim) Cox, Laura Boughan
Management:
Voting securities (Section 18(i))
Voting and proxy solicitation (Section 20)
Election of directors (Section 16)
Ownership reports and short-term profits
(Section 30(f) (closed-end companies)
SEC Staff: Sydney H. Mendelsohn, Jeremiah J. DeMichaelis, Melville B. (Tim) Cox, Laura Boughan
Open-end companies and unit trusts (Section 22)
Closed-end companies (Section 23)
Anti-competitive rule (Section 22(d))
SEC Staff: Sydney H. Mendelsohn, Melville B. (Tim) Cox, Richard W. Grant, Joel H. Goldberg
SEC Staff: Sydney H. Mendelsohn, Arthur J. Brown, Glen A. Payne, Houghton Hallock, Jr., Mark B. Goldfus
SEC Staff: Sydney H. Mendelsohn, Arthur J. Brown, Glen A. Payne, Houghton Hallock, Jr., Mark B. Goldfus
SEC Staff: Sydney H. Mendelsohn, Arthur J. Brown, Glen A. Payne, Houghton Hallock, Jr., Mark B. Goldfus
SEC Staff: Sydney H. Mendelsohn, Arthur J. Brown, Glen A. Payne, Houghton Hallock, Jr., Mark B. Goldfus
SEC Staff: Sydney H. Mendelsohn, Arthur J. Brown, Glen A. Payne, Houghton Hallock, Jr., Mark B. Goldfus
Sales, purchases, and loans to or from the company (Section 17(a))
Exemptions and exceptions (Sections 17(b) and (c))
Joint transactions (Section 17(d))
SEC Staff: Sydney H. Mendelsohn, Arthur J. Brown, Glen A. Payne, Houghton Hallock, Jr., Mark B. Goldfus
Compensation
Give-ups and Reciprocal Business (Section 17(e))
Prohibition against investment company purchasing from or through affiliated underwriters (Section 10(f))
SEC Staff: Sydney H. Mendelsohn, Arthur J. Brown, Glen A. Payne, Houghton Hallock, Jr., Mark B. Goldfus
Distribution (Section 12(b))
Investment restrictions (Sections 12(c) through (g))
SEC Staff: Sydney H. Mendelsohn, Richard W. Grant, Gene A. Gohlke
Margin, short sales (Section 12(a))
Senior securities (Section 18)
SEC Staff: Sydney H. Mendelsohn, Richard W. Grant, Arthur J. Brown, Gene A. Gohlke
What records must be maintained (Section 31(c) authorization) (Rules 31a-l, 2 and 3)
SEC Staff: Sydney H. Mendelsohn, R. Michael Parker, Robert J. Holden, Frank M. Morrison
How long must records be maintained (Section 31(a))
Determining net asset value (Section 2(a)(41) and Rule 2a-4)
SEC Staff: Sydney H. Mendelsohn, R. Michael Parker, Robert J. Holden, Frank M. Morrison
Ineligible persons (Section 9)
Nonfeasance of directors (Section 36)
Larceny and embezzlement (Section 37)
Commission's authority to inspect and investigate
Power to inspect (Section 31(b))
Power to investigate (Sections 42(a) through (d))
Validity of contracts (Section 47)
Enforcement of Act:
Civil: breach of fiduciary duties (Section 36)
Administrative
Criminal
SEC Staff: Sydney H. Mendelsohn, Frank M. Morrison, Michael Berenson
SEC Staff: Sydney H. Mendelsohn
