Scudder Kemper Investments


Scudder Kemper Investments, Inc.
345 Park Avenue
New York, NY 10154-0010
212 326 6200 telephone

November 8, 1999

Mr. Jonathan G. Katz
Securities and Exchange Commission
450 Fifth Street, N.W.
Stop 6-9
Washington, D.C. 20549

Re: Release IA-1812, File No. S7-19-99, Political Contributions by Certain Investment Advisers

Dear Mr. Katz:

Scudder Kemper Investments leads the global investment management business of the Zurich Financial Group, one of the world's foremost providers of risk management, asset management, and other financial services.

With more than $280 billion currently under management and almost 80 years of experience, Scudder Kemper Investments is among the world's largest and most experienced asset managers. Scudder Kemper's client base includes institutions, individual investors and financial intermediaries worldwide. Scudder Kemper appreciates the opportunity to comment on the Securities and Exchange Commissions proposed new rule under the Investment Advisers Act of 1940 regarding political contributions by certain investment advisers, known as "pay to play."

Scudder Kemper strongly agrees with the position of the SEC in opposing any practice by which investment professionals try to gain access to business through political contributions. We applaud the Commission in its effort to eradicate pay-to-play practices in the financial services industry. However, we believe the current proposal is too sweeping and burdensome for the industry, with the potential effect of being costly and disruptive to our clients as well. We believe that a more narrowly tailored approach would be appropriate to address "pay to play" issues. In that regard, Scudder Kemper strongly endorses the Investment Counsel Association of America (ICAA) letter commenting on this important proposal and supports the comments and suggestions made therein.

Please do not hesitate to contact us if you need further information regarding this issue.


Kathryn L. Quirk
General Counsel and Managing Director