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Division of Investment Management
Staff No-Action and Interpretive Letters
Important Note: This page contains Division of Investment Management no-action letters dated on or after January 1, 2001. Division of Investment Management no-action letters issued before that date may be obtained for a copy and processing fee. Please refer to information on How to Request Public Documents.
 Subject Categories
Subject Category List of No-Action Letters
Alphabetical List of No-Action Letters
Chronological List of No-Action Letters
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Subject Category List of No-Action Letters
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12b-1 Fees
12b-1 Plans
Acquisition of Securities in Affiliated Underwriting
Advertising — Investment Advisers
- Investment Adviser Association, December 2, 2005
- Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004
- Investment Counsel Association of America, Inc., March 1, 2004
Advertising — Investment Company
Advisory Contracts
- First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008
- Mellon Equity Associates, LLP April 1, 2005
- Eaton Vance Special Investment Trust, et al March 30, 2004
- Gartmore Mutual Funds, March 19, 2004
- PIMCO Funds: Multi-Manager Series, August 6, 2002
Advisory Representatives
Advisory Fees
Affiliated Transactions
- Northern Institutional Fund, July 16, 2008
- T. Rowe Price Associates, Inc., July 10, 2008
- Western Asset Money Market
Fund, June 27, 2008
- Western Asset Institutional Money Market
Fund, June 27, 2008
- HSBC Investor Funds, June 25, 2008
- Allianz Dresdner Daily Asset Fund, May 5, 2008
- Institutional Liquidity Trust, April 30, 2008
- ING Series Fund, Inc., et al., April 30, 2008
- Master Portfolio Trust, April 18, 2008
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Master Portfolio Trust, April 4, 2008
- SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008
- Northern Institutional Funds, February 28, 2008
- Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008
- HSBC Investor Funds, January 18, 2008
- STI Classic Funds, January 2, 2008
- TDAM Money Market Portfolio, December 21, 2007
- First American Funds, Inc. – Prime Obligation Fund, December 3, 2007
- SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007
- Old Mutual Advisors Funds, November 16, 2007
- SEI Daily Income Trust — Money Market Fund, November 9, 2007
- SEI Daily Income Trust — Prime Obligation Fund, November 8, 2007
- STI Classic Funds, October 26, 2007
- Van Kampen Funds Inc., January 31, 2007
- Gartmore Variable Insurance Trust, December 29, 2006
- GuideStone Financial, et al., December 27, 2006
- Federated Municipal Funds, November 20, 2006
- Merrill Lynch & Co., Inc., September 27, 2006
- Citigroup Global Markets, Inc., September 26, 2006
- Mutual of America Investment Corporation, June 2, 2006
- GE Institutional Funds, December 21, 2005
- Investment Company Institute, December 14, 2005
- Wells Fargo Alternative Asset Management, LLC, January 26, 2005
- Neuberger Berman Management Inc., et al., April 30, 2003
- AAL Mutual Funds, et al., December 12, 2002
- AIM Advisors, Inc., February 12, 2002
- Calvert Social Index Fund, September 4, 2001
- Evergreen Investment Management Company, LLC, February 13, 2002
- Longleaf Partners Funds Trust, April 9, 2001
Annual Reports
Assignments
Backward Pricing
Beneficial Ownership Qualified Purchaser
Business and Industrial Development Companies
Business Transfers
Cash Solicitation
- Prudential Financial, Inc., September 5, 2008
- Mayer Brown LLP, July 28, 2008
- Barclays Bank PLC, June 6, 2007
- Emanuel J. Friedman and EJF Capital LLC, January 16, 2007
- Ameriprise Financial Services Inc., April 5, 2006
- Millennium Partners, L.P., et al, March 9, 2006
- American International Group, Inc., February 21, 2006
- ING Bank N.V., August 31, 2005
- CIBC Mellon Trust Company, February 24, 2005
- Goldman, Sachs & Co., February 23, 2005
- Morgan Stanley & Co., Inc., February 4, 2005
- American International Group, Inc., December 8, 2004
- Deutsche Bank Securities Inc., September 24, 2004
- Thomas Weisel Partners LLC, September 24, 2004
- J.P. Morgan Securities Inc., October 31, 2003
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- Goldman, Sachs & Company, October 31, 2003
- Lehman Brothers, October 31, 2003
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Bear, Stearns & Co. Inc., October 31, 2003
- Morgan Stanley & Company, October 31, 2003
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- James DeYoung, October 24, 2003
- J.P. Morgan Securities Inc., October 8, 2003
- Dougherty & Company LCC, July 3, 2003
- Fahnestock & Company Inc., April 21, 2003
- Dougherty & Company LLC, March 21, 2003
- Legg Mason Wood Walker, Inc., June 11, 2001
- National Football League Players Association, January 25, 2002
- Prudential Securities Inc., February 7, 2001
- Stephens Inc., December 27, 2001
Change of Control
Charitable Exclusions
Closed-End Investment Companies
Code of Ethics
Commerical Paper
Compliance Policies and Procedures Rule
Consolidation
Custody - Investment Advisers
Custody - Investment Companies
Director
Disclosure
Distributions
Distribution Fees
Distribution Plans
Employee Benefit Plans
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Lear Corporation Retirement Savings Plan Trusts, March 16, 2007
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003
- Honeywell International Inc Savings Plan Trust, October 7, 2002
Exchange Offer
Exemptive Applications and Orders
Face-Amount Certificate
Fees & Expenses
Fiduciary Duties
Foreign Banks
Fraud
Fraud - Investment Advisers Act
Funds of Funds - Affiliated
Funds of Funds - Foreign Investment Companies
- ASA (Bermuda) Limited, December 13, 2006
- Alternative Investment Partners Absolute Return Fund STS, July 10, 2006
- France Growth Fund, Inc., July 15, 2003
- Man-Glenwood Lexington TEI, LLC and Man-Glenwood Lexington TEI, LDC, April 30, 2004
Government Instrumentalities
Government Securities
Hedge Clauses
Hedge Funds
- The Townsend Group, Inc., July 9, 2008
- ABA Subcommittee on Private Investment Entities, August 10, 2006
- ABA Subcommittee on Private Investment Entities, December 8, 2005
- The Goldman Sachs Group, Inc., March 8, 2005
Hub and Spoke Funds
Inadvertent Investment Companies
Independent Directors
Independent Legal Counsel
Insurance Products
- IDS Life Insurance Company, et al., December 14, 2006
- American Home Assurance Company, et al., October 17, 2005
- GE Life and Annuity Assurance Company, June 25, 2004
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Acacia National Life Insurance Company, December 19, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- AIG Life Insurance Company, August 16, 2001
- Manufacturers Life Insurance Company, The, December 27, 2001
- National Association for Variable Annunities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001
- Nationwide Life Insurance Company, March 16, 2001
Interested Person
Internet
Investment Advisers
Investment Advisers Act Status
- Credit Agricole Asset Management Alternative Investments, Inc., August 7, 2006
- Morgan, Lewis & Bockius LLP, November 17, 2005
- UBS Financial Services, Inc., September 29, 2005
- Ark Therapeutics Group plc, April 15, 2005
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- The Goldman Sachs Group, Inc., March 8, 2005
- Gulf Coast Venture Forum, Inc., August 21, 2002
- Thomson Financial Inc., July 10, 2002
Investment Company
Investment Company Act Status
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Dexia Municipal Agency, December 26, 2007
- Exelon Corporation, September 13, 2007
- Cooley Godward & Kronish, July 12, 2007
- MACRO Securities Depositor, LLC, December 1, 2006
Investment Securities
Joint Transactions
Mergers and Reorganizations Combinations
- Janus Aspen Series, April 10, 2008
- CUNA Mutual Life Insurance Company, et al., December 27, 2007
- Ameritas Life Insurance Corp., April 5, 2007
- Mutual of America Investment Corporation, June 2, 2006
- GE Life and Annuity Assurance Company, June 25, 2004
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Acacia National Life Insurance Company, December 19, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
Money Market Funds
- Northern Institutional Fund, July 16, 2008
- Western Asset Money Market
Fund, June 27, 2008
- Western Asset Institutional Money Market
Fund, June 27, 2008
- HSBC Investor Funds, June 25, 2008
- Eaton Vance Management, June 13, 2008
- Allianz Dresdner Daily Asset Fund, May 5, 2008
- Master Portfolio Trust, April 18, 2008
- Master Portfolio Trust, April 4, 2008
- SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008
- Northern Institutional Funds, February 28, 2008
- Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008
- HSBC Investor Funds, January 18, 2008
- STI Classic Funds, January 2, 2008
- TDAM Money Market Portfolio, December 21, 2007
- First American Funds, Inc. – Prime Obligation Fund, December 3, 2007
- SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007
- SEI Daily Income Trust — Money Market Fund, November 9, 2007
- SEI Daily Income Trust — Prime Obligation Fund, November 8, 2007
- STI Classic Funds, October 26, 2007
- Evergreen Investment Management Company LLC, October 11, 2005
- Merrill Lynch Investment Managers, May 10, 2002
- AIM Advisors, Inc., February 12, 2002
Money Market Liquidity
Periodic Payment Plan Certificate
Performance Fees
- Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004
- Pacific Select Fund, et al., December 23, 2004
- Seligman New Technologies Fund II, Inc., February 7, 2002
Pre-Paid Tuition Plans
Personal Securities Transaction
Principal Transaction
Principal Underwriters
Prospectuses — Delivery
Prospectuses — Disclosure
Proxy Voting
Public Offering
Public Utility Holding Companies
- Section 2(a)(3)
- Bonneville Power Administration, February 10, 2004
- RealEnergy, Inc., et al., August 12, 2003
- Dominion Equipment II, Inc., et al., March 25, 2003
- Juniper Capital L.P., June 23, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- Sections 2(a)(3) and 2(a)(7)
- EIF Neptune, LLC Starwood Energy Investors, LLC & Atlantic Energy Parts, July 29, 2005
- DTE Heritage, LLC, et. al., July 30, 2003
- Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003
- Sections 2(a)(7)
- Sections 2(a)(7) and 2(a)(11)(A)
- Section 17(c) and Rule 70
Qualified Purchase Definition - Investment Company Act Status Determination
- Cabot Wellington, LLC, June 17, 2008
- McDermott, Will & Emery, July 26, 2007
- Goldman Sachs Asset Management, L.P., March 13, 2007
- SCP Private Equity Partners II, L.P., June 6, 2006
Qualified Purchaser Fund
Real Estate
Redeemable Securities
Redemption Fees
Redemptions
Registration
- IDS Life Insurance Company, et al., December 14, 2006
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- Thomson Financial Inc., July 10, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
Registration — Investment Advisers
Registration — Investment Companies
- Exelon Corporation, September 13, 2007
- MACRO Securities Depositor, LLC, December 1, 2006
- Shee Atika Investments, LLC, January 20, 2004
- First Data Corporation, January 13, 2004
- Mercy Investment Program, Inc., June 12, 2003
- Metropolitan Insurance and Annuity Company, June 6, 2003
Regulation S-P
Reimbursement of Proxy Expenses
Reorganization
Reporting Requirements — Investment Advisers
Reporting Requirements — Investment Companies
- NGP Capital Resources Company (Corrected), December 28, 2007
- American Home Assurance Company, et. al., October 17, 2005
- College and University Facility Loan Trust One, et al., November 29, 2004
- Westford Technology Ventures, L.P., January 28, 2004
- Equus Capital Partners L.P., November 14, 2003
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- Manufacturers Adviser Corp, September 10, 2002
Safe Harbors
Sales of Fund Shares below NAV
Securities — Definition
Securities Lending
Self Custody - Investment Companies
Separate Accounts
- First Great-West Life & Annuity Insurance Company & Canada Life Insurance Company of New York, December 22, 2005
- GE Life and Annuity Assurance Company, June 25, 2004
- Acacia National Life Insurance Company, December 19, 2003
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- AIG Life Insurance Company, August 16, 2001
Senior Securities
Shareholder Proposals
- College Retirement Equities Fund, May 19, 2008
- Fidelity Funds, January 22, 2008
- Franklin Universal Trust, December 18, 2007
- Alliance World Dollar Government Fund, Inc., October 19, 2006
- Putnam Premier Income Trust, March 14, 2006
- Putnam High Income Securities Fund, March 14, 2006
- Putnam Tax-Free Health Care Fund, August 8, 2005
- Fidelity Magellan Fund, March 15, 2005
- Medallion Financial Corp., May 11, 2004
- Tri-Continental Corporation, March 15, 2004
- Robert P. Laukat Regarding Tri-Continental Corporation , March 15, 2004
- The New Ireland Fund, Inc., March 15, 2004
- College Retirement Equities Fund - Stone, May 3, 2004
- College Retirement Equities Fund - Belth, May 3, 2004
- College Retirement Equities Fund - Fuller, May 3, 2004
- College Retirement Equities Fund - Buchman, May 3, 2004
- Tri-Continental Corporation, March 25, 2003
- MuniYield Insured Fund, Inc., March 11, 2002
- Asia Tiger Fund, Inc., The, January 31, 2002
- Pioneer Interest Shares, June 20, 2001
- Asia Pacific Fund, Inc (The), June 8, 2001
- Asia Tiger Fund, Inc., The, December 28, 2001
- Current Income Shares, Inc., July 10, 2001
- Fidelity Advisor Korea Fund, Inc, March 7, 2001
- France Growth Fund, Inc, April 6, 2001
- France Growth Fund, Inc.; Advantage Partners LP, April 6, 2001
- France Growth Fund, Inc.; Strome Hedgecap Fund, April 6, 2001
- Lincoln National Convertible Securities Fund, Inc. - Walter S. Baer, September 28, 2001
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
Shareholders Votes
Short Sales
Solicitors
Tender Offers
Voting Security
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Alphabetical List of No-Action Letters
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- AAL Mutual Funds, et al., December 12, 2002
- ABA Subcommittee on Private Investment Entities, August 10, 2006
- ABA Subcommittee on Private Investment Entities, December 8, 2005
- Aberdeen Australia Equity Fund, Inc., July 13, 2006
- Acacia National Life Insurance Company, December 19, 2003
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company, August 16, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- AIM Advisors, Inc., February 12, 2002
- Alliance World Dollar Government Fund, Inc., October 19, 2006
- Allianz Dresdner Daily Asset Fund, May 5, 2008
- Allstate Life Insurance Company, December 23, 2002
- Alternative Investment Partners Absolute Return Fund STS, July 10, 2006
- American Bible Society, June 1, 2004
- American Enterprise Life Insurance Company, April 30, 2002
- Ameritas Life Insurance Corp., April 5, 2007
- Arizona Electric Power Cooperative Inc., July 27, 2001
- American Home Assurance Company, et. al., October 17, 2005
- American International Group, Inc., February 21, 2006
- American International Group, Inc., December 8, 2004
- American Skandia Life Assurance Corporation, May 16, 2005
- Ameriprise Financial Services Inc., April 5, 2006
- Ark Therapeutics Group plc, April 15, 2005
- ASA (Bermuda) Limited, December 13, 2006
- Asia Pacific Fund, Inc (The), June 8, 2001
- Asia Pacific Fund, Inc (The) - Thomas A. Kornfeld, June 8, 2001
- Asia Tiger Fund, Inc., The, December 28, 2001
- Asia Tiger Fund, Inc., The, January 31, 2002
- Austraclear Limited, April 28, 2004
- Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002
- Bear, Stearns & Co. Inc., October 31, 2003
- Bonneville Power Administration, February 10, 2004
- Cabot Wellington, LLC, June 17, 2008
- Calvert Social Index Fund, September 24, 2001
- Cantor Fitzgerald & Company, February 17, 2004
- Capital Trust, Inc., May 24, 2007
- The Chase Manhattan Bank, July 24, 2001
- CIBC Mellon Trust Company, February 24, 2005
- Citigroup Global Markets, Inc., September 26, 2006
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- Citigroup Inc., July 26, 2006
- College and University Facility Loan Trust One, et al., November 29, 2004
- College Retirement Equities Fund, May 19, 2008
- College Retirement Equities Fund - Stone, May 3, 2004
- College Retirement Equities Fund - Belth, May 3, 2004
- College Retirement Equities Fund - Fuller, May 3, 2004
- College Retirement Equities Fund - Buchman, May 3, 2004
- Constellation Financial Management LLC, January 9, 2003
- Cooley Godward & Kronish, July 12, 2007
- Credit Agricole Asset Management Alternative Investments, Inc., August 7, 2006
- Credit Suisse First Boston, LLC, August 31, 2005
- Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003
- CUNA Mutual Life Insurance Company, et al., December 27, 2007
- Current Income Shares, Inc., July 10, 2001
- Deloitte & Touche LLP, August 28, 2006
- Deutsche Bank Securities Inc., September 24, 2004
- Dexia Municipal Agency, December 26, 2007
- Dominion Equipment II, Inc., et al., March 25, 2003
- Dougherty & Company LCC, July 3, 2003
- Dougherty & Company LLC, March 21, 2003
- DTE Heritage, LLC, et. al., July 30, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- Eaton Vance Management, June 13, 2008
- Eaton Vance Special Investment Trust, et al March 30, 2004
- Egan-Jones Proxy Services, May 27, 2004
- EIF Neptune, LLC Starwood Energy Investors, LLC & Atlantic Energy Parts, July 29, 2005
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- Enron Corporation, March 11, 2004
- Equus Capital Partners L.P., November 14, 2003
- E*TRADE Securities, LLC, November 30, 2005
- Evercore METC Investment Inc., et. al., November 25, 2003
- Evergreen Investment Management Company LLC, October 11, 2005
- Evergreen Investment Management Company, LLC, February 13, 2002
- Exelon Corporation, September 13, 2007
- Fahnestock & Company Inc., April 21, 2003
- Federal Home Loan Mortgage Corporation, July 12, 2002
- Federal National Mortgage Association, July 12, 2002
- Federated Core Trust II, L.P., February 6, 2002
- Federated Municipal Funds, November 20, 2006
- Fidelity Select Portfolio, April 29, 2008
- Fidelity Advisor Korea Fund, Inc, March 7, 2001
- Fidelity Funds, January 22, 2008
- Fidelity Magellan Fund, March 15, 2005
- First American Funds, Inc. – Prime Obligation Fund, December 3, 2007
- First Data Corporation, January 13, 2004
- First Great-West Life & Annuity Insurance Company & Canada Life Insurance Company of New York, December 22, 2005
- First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008
- Fixed Income Clearing Corporation, March 13, 2003
- Fixed Income Securities, L.P., April 29, 2004
- France Growth Fund, Inc., April 6, 2001
- France Growth Fund, Inc., July 15, 2003
- France Growth Fund, Inc.; Advantage Partners LP, April 6, 2001
- France Growth Fund, Inc.; Strome Hedgecap Fund, April 6, 2001
- Frank Russell Investment Company, et al., October 18, 2002
- Franklin Universal Trust, December 18, 2007
- Emanuel J. Friedman and EJF Capital LLC, January 16, 2007
- Gardner Russo & Gardner, June 7, 2006
- Gartmore Mutual Funds, March 19, 2004
- Gartmore Variable Insurance Trust, December 29, 2006
- GE Institutional Funds, December 21, 2005
- GE Life and Annuity Assurance Company, June 25, 2004
- General Electric Capital Corporation, April 26, 2002
- Goldman, Sachs & Co., February 23, 2005
- Goldman, Sachs & Company, October 31, 2003
- Goldman Sachs Asset Management, L.P., March 13, 2007
- The Goldman Sachs Group, Inc., March 8, 2005
- Goldman Sachs Trust, August 19, 2008
- Government Securities Clearing Corporation, October 19, 2001
- GuideStone Financial, et al., December 27, 2006
- Gulf Coast Venture Forum, Inc., August 21, 2002
- H.E.B. Investment and Retirement Plan (H.E. Butt Grocery Company), May 18, 2001
- Heitman Capital Management, LLC, February 12, 2007
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Honeywell International Inc Savings Plan Trust, October 7, 2002
- HSBC Investor Funds, June 25, 2008
- HSBC Investor Funds, January 18, 2008
- IDS Life Insurance Company, et al., December 14, 2006
- ING Bank N.V., August 31, 2005
- ING Bank, N.V., July 8, 2002
- ING Mutual Funds Management Co. LLC; ING Funds Distributors Inc. and Reich & Tang Distributors Inc., February 9, 2001
- ING Series Fund, Inc., et al, April 30, 2008
- Institutional Liquidity Trust, April 30, 2008
- Institutional Shareholder Services, Inc., September 15, 2004
- Investec Ernst & Company, April 24, 2001
- Investment Adviser Association, September 20, 2007
- Investment Adviser Association, December 2, 2005
- Investment Company Institute, February 1, 2007
- Investment Company Institute, December 14, 2005
- Investment Company Institute, November 10, 2004
- Investment Company Institute, February 12, 2002
- Investment Counsel Association of America, Inc., March 1, 2004
- JPMorgan Chase; Bear Stearns Asset Management I,, July 14, 2008
- JPMorgan Chase; Bear Stearns Asset Management II, March 16, 2008
- J.P. Morgan Securities Inc., October 8, 2003
- J.P. Morgan Securities Inc., October 31, 2003
- James DeYoung, October 24, 2003
- Janus Aspen Series, April 10, 2008
- Juniper Capital L.P., June 23, 2003
- k1 Ventures, et. al., July 28, 2003
- Kirkpatrick & Lockhart LLP, January 28, 2004
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- Lear Corporation Retirement Savings Plan Trusts, March 16, 2007
- Legg Mason Wood Walker, Inc., June 11, 2001
- Lehman Brothers, October 31, 2003
- Lincoln National Convertible Securities Fund, Inc. - Walter S. Baer, September 28, 2001
- Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003
- Lindbergh Funds, October 30, 2002
- Lockheed Martin Investment Management Company, June 6, 2006
- Longleaf Partners Funds Trust, April 9, 2001
- M&G Investment Management Ltd., March 1, 2007
- MACRO Securities Depositor, LLC, December 1, 2006
- Mahaffy, Edward , March 6, 2003
- Man-Glenwood Lexington TEI, LLC and Man-Glenwood Lexington TEI, LDC, April 30, 2004
- Manufacturers Adviser Corp, September 10, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
- Master Portfolio Trust, April 18, 2008
- Master Portfolio Trust, April 4, 2008
- Maxim Series Fund Inc., January 14, 2004
- Mayer Brown LLP, July 28, 2008
- McDermott, Will & Emery, July 26, 2007
- Medallion Financial Corp., May 11, 2004
- Mellon Equity Associates, LLP April 1, 2005
- Mercy Investment Program, Inc., June 12, 2003
- Merrill Lynch & Co., Inc., September 27, 2006
- Merrill Lynch Investment Managers, May 10, 2002
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Metropolitan Insurance and Annuity Company, June 6, 2003
- Mexico Equity and Income Fund, The, November 15, 2001
- Millennium Partners, L.P., et al, March 9, 2006
- Missouri Bankers Association, August 18, 2008
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- Morgan, Lewis & Bockius LLP, November 17, 2005
- Morgan Stanley & Co., Inc., February 4, 2005
- MTB Group of Funds, October 21, 2003
- MuniYield Insured Fund, Inc., March 11, 2002
- Mutual Fund Directors Forum, May 9, 2002
- Mutual of America Investment Corporation, June 2, 2006
- National Association for Variable Annunities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001
- National Compliance Service, November 30, 2005
- National Football League Players Association, January 25, 2002
- Nationwide Life Insurance Company, March 16, 2001
- Neuberger Berman Management Inc., et al., April 30, 2003
- NGP Capital Resources Company (Corrected), December 28, 2007
- Northern Institutional Fund, July 16, 2008
- Northern Institutional Funds, February 28, 2008
- Nuveen Virginia Premium Income Municipal Fund, October 6, 2006
- Old Dominion Electric Cooperative, et al., October 13, 2004
- Old Mutual Advisors Funds, November 16, 2007
- Pacific Select Fund, et al., December 23, 2004
- Peninsular & Oriental Steam Navigation Company, October 15, 2003
- PIMCO Funds: Multi-Manager Series, August 6, 2002
- PIMCO Funds, July 9, 2002
- Pioneer Funds, December 20, 2005
- Pioneer Interest Shares, June 20, 2001
- Principal Investors Fund Inc., May 13, 2005
- Prudential Financial, Inc., September 5, 2008
- Prudential Insurance Company of America, March 1, 2005
- Prudential Investment Management Services LLC, April 19, 2001
- Prudential Securities Incorporated, February 7, 2001
- Putnam High Income Securities Fund, March 14, 2006
- Putnam Premier Income Trust, March 14, 2006
- Putnam Tax-Free Health Care Fund, August 8, 2005
- RealEnergy, Inc., et al., August 12, 2003
- ReFlow Fund, LLC, July 15, 2002
- Royal Dutch Shell plc, May 17, 2005
- SCP Private Equity Partners II, L.P., June 6, 2006
- SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008
- SEI Daily Income Trust — Money Market Fund, November 9, 2007
- SEI Daily Income Trust — Prime Obligation Fund, November 8, 2007
- SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007
- Seligman New Technologies Fund II, Inc., February 7, 2002
- Seward & Kissel, October 12, 2005
- Shee Atika Investments, LLC, January 20, 2004
- Staff Responses to Questions About Regulation S-P, January 23, 2003
- Stephens Inc., December 27, 2001
- STI Classic Funds, January 2, 2008
- STI Classic Funds, October 26, 2007
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- Swiss Helvetia Fund, Inc., March 6, 2001
- TDAM Money Market Portfolio, December 21, 2007
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
- Thomas Weisel Partners LLC, September 24, 2004
- Thomson Financial Inc., July 10, 2002
- The Townsend Group, Inc., July 9, 2008
- Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004
- Tri-Continental Corporation, March 25, 2003
- Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003
- T. Rowe Price Associates, Inc., July 10, 2008
- Trusts under the Will of Marion Searle, March 29, 2005
- Tuition Plan Consortium, LLP, February 4, 2003
- UAM Inc., September 24, 2001
- UBS Financial Services, Inc., September 29, 2005
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- USB Global Asset Management (US), Inc., November 21, 2002
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- U.S. Bancorp Asset Management Inc., et al., December 11, 2001
- Van Kampen Funds Inc., January 31, 2007
- Washington Capital Joint Master Trust, September 25, 2006
- Wells Fargo Alternative Asset Management, LLC, January 26, 2005
- Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008
- Westford Technology Ventures, L.P., January 28, 2004
- Western Asset Money Market
Fund, June 27, 2008
- Western Asset Institutional Money Market
Fund, June 27, 2008
- Western Farmers Electric Cooperative, February 23, 2001
- Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001
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Chronological List of No-Action Letters
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- Prudential Financial, Inc., September 5, 2008
- Goldman Sachs Trust, August 19, 2008
- Missouri Bankers Association, August 18, 2008
- Mayer Brown LLP, July 28, 2008
- Northern Institutional Fund, July 16, 2008
- JPMorgan Chase; Bear Stearns Asset Management I, July 14, 2008
- First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008
- T. Rowe Price Associates, Inc., July 10, 2008
- The Townsend Group, Inc., July 9, 2008
- Western Asset Money Market
Fund, June 27, 2008
- Western Asset Institutional Money Market
Fund, June 27, 2008
- HSBC Investor Funds, June 25, 2008
- Cabot Wellington, LLC, June 17, 2008
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Eaton Vance Management, June 13, 2008
- College Retirement Equities Fund, May 19, 2008
- Allianz Dresdner Daily Asset Fund, May 5, 2008
- Institutional Liquidity Trust, April 30, 2008
- ING Series Fund, Inc., et al, April 30, 2008
- Fidelity Select Portfolio, April 29, 2008
- Master Portfolio Trust, April 18, 2008
- Janus Aspen Series, April 10, 2008
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Master Portfolio Trust, April 4, 2008
- JPMorgan Chase; Bear Stearns Asset Management II, March 16, 2008
- SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008
- Northern Institutional Funds, February 28, 2008
- Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008
- Fidelity Funds, January 22, 2008
- HSBC Investor Funds, January 18, 2008
- STI Classic Funds, January 2, 2008
- NGP Capital Resources Company (Corrected), December 28, 2007
- CUNA Mutual Life Insurance Company, et al., December 27, 2007
- Dexia Municipal Agency, December 26, 2007
- TDAM Money Market Portfolio, December 21, 2007
- Franklin Universal Trust, December 18, 2007
- First American Funds, Inc. – Prime Obligation Fund, December 3, 2007
- SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007
- Old Mutual Advisors Funds, November 16, 2007
- SEI Daily Income Trust — Money Market Fund, November 9, 2007
- SEI Daily Income Trust — Prime Obligation Fund, November 8, 2007
- STI Classic Funds, October 26, 2007
- Investment Adviser Association, September 20, 2007
- Exelon Corporation, September 13, 2007
- McDermott, Will & Emery, July 26, 2007
- Cooley Godward & Kronish, July 12, 2007
- Capital Trust, Inc., May 24, 2007
- Ameritas Life Insurance Corp., April 5, 2007
- Lear Corporation Retirement Savings Plan Trusts, March 16, 2007
- Goldman Sachs Asset Management, L.P., March 13, 2007
- M&G Investment Management Ltd., March 1, 2007
- Heitman Capital Management, LLC, February 12, 2007
- Investment Company Institute, February 1, 2007
- Van Kampen Funds Inc., January 31, 2007
- Emanuel J. Friedman and EJF Capital LLC, January 16, 2007
- Gartmore Variable Insurance Trust, December 29, 2006
- GuideStone Financial, et al., December 27, 2006
- IDS Life Insurance Company, et al., December 14, 2006
- ASA (Bermuda) Limited, December 13, 2006
- MACRO Securities Depositor, LLC, December 1, 2006
- Federated Municipal Funds, November 20, 2006
- Alliance World Dollar Government Fund, Inc., October 19, 2006
- Nuveen Virginia Premium Income Municipal Fund, October 6, 2006
- Merrill Lynch & Co., Inc., September 27, 2006
- Citigroup Global Markets, Inc., September 26, 2006
- Washington Capital Joint Master Trust, September 25, 2006
- Deloitte & Touche LLP, August 28, 2006
- ABA Subcommittee on Private Investment Entities, August 10, 2006
- Credit Agricole Asset Management Alternative Investments, Inc., August 7, 2006
- Citigroup Inc., July 26, 2006
- Aberdeen Australia Equity Fund, Inc., July 13, 2006
- Alternative Investment Partners Absolute Return Fund STS, July 10, 2006
- Gardner Russo & Gardner, June 7, 2006
- SCP Private Equity Partners II, L.P., June 6, 2006
- Lockheed Martin Investment Management Company, June 6, 2006
- Mutual of America Investment Corporation, June 2, 2006
- Ameriprise Financial Services Inc., April 5, 2006
- Putnam Premier Income Trust, March 14, 2006
- Putnam High Income Securities Fund, March 14, 2006
- Millennium Partners, L.P., et al, March 9, 2006
- American International Group, Inc., February 21, 2006
- First Great-West Life & Annuity Insurance Company & Canada Life Insurance Company of New York, December 22, 2005
- GE Institutional Funds, December 21, 2005
- Pioneer Funds, December 20, 2005
- Investment Company Institute, December 14, 2005
- ABA Subcommittee on Private Investment Entities, December 8, 2005
- Investment Adviser Association, December 2, 2005
- National Compliance Service, November 30, 2005
- E*TRADE Securities, LLC, November 30, 2005
- Morgan, Lewis & Bockius LLP, November 17, 2005
- American Home Assurance Company, et. al., October 17, 2005
- Seward & Kissel, October 12, 2005
- Evergreen Investment Management Company LLC, October 11, 2005
- UBS Financial Services, Inc., September 29, 2005
- Credit Suisse First Boston, LLC, August 31, 2005
- ING Bank N.V., August 31, 2005
- Putnam Tax-Free Health Care Fund, August 8, 2005
- EIF Neptune, LLC Starwood Energy Investors, LLC & Atlantic Energy Parts, July 29, 2005
- Royal Dutch Shell plc, May 17, 2005
- American Skandia Life Assurance Corporation, May 16, 2005
- Principal Investors Fund Inc., May 13, 2005
- Ark Therapeutics Group plc, April 15, 2005
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- Mellon Equity Associates, LLP April 1, 2005
- Trusts under the Will of Marion Searle, March 29, 2005
- Fidelity Magellan Fund, March 15, 2005
- The Goldman Sachs Group, Inc., March 8, 2005
- Prudential Insurance Company of America, March 1, 2005
- CIBC Mellon Trust Company, February 24, 2005
- Goldman, Sachs & Co., February 23, 2005
- Morgan Stanley & Co., Inc., February 4, 2005
- Wells Fargo Alternative Asset Management, LLC, January 26, 2005
- Pacific Select Fund, et al., December 23, 2004
- American International Group, Inc., December 8, 2004
- Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004
- College and University Facility Loan Trust One, et al., November 29, 2004
- Investment Company Institute, November 10, 2004
- Old Dominion Electric Cooperative, et al., October 13, 2004
- Deutsche Bank Securities Inc., September 24, 2004
- Thomas Weisel Partners LLC, September 24, 2004
- Institutional Shareholder Services, Inc., September 15, 2004
- GE Life and Annuity Assurance Company, June 25, 2004
- American Bible Society, June 1, 2004
- Egan-Jones Proxy Services, May 27, 2004
- Medallion Financial Corp., May 11, 2004
- College Retirement Equities Fund - Stone, May 3, 2004
- College Retirement Equities Fund - Belth, May 3, 2004
- College Retirement Equities Fund - Fuller, May 3, 2004
- College Retirement Equities Fund - Buchman, May 3, 2004
- Man-Glenwood Lexington TEI, LLC and Man-Glenwood Lexington TEI, LDC, April 30, 2004
- Fixed Income Securities, L.P., April 29, 2004
- Austraclear Limited, April 28, 2004
- Eaton Vance Special Investment Trust, et al March 30, 2004
- Dominion Equipment II, Inc., et al., March 25, 2003
- Gartmore Mutual Funds, March 19, 2004
- Enron Corporation, March 11, 2004
- Investment Counsel Association of America, Inc., March 1, 2004
- Cantor Fitzgerald & Company, February 17, 2004
- Bonneville Power Administration, February 10, 2004
- Kirkpatrick & Lockhart LLP, January 28, 2004
- Westford Technology Ventures, L.P., January 28, 2004
- Shee Atika Investments, LLC, January 20, 2004
- Maxim Series Fund Inc., January 14, 2004
- First Data Corporation, January 13, 2004
- Acacia National Life Insurance Company, December 19, 2003
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Evercore METC Investment Inc., et. al., November 25, 2003
- Equus Capital Partners L.P., November 14, 2003
- J.P. Morgan Securities Inc., October 31, 2003
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- Goldman, Sachs & Company, October 31, 2003
- Lehman Brothers, October 31, 2003
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Bear, Stearns & Co. Inc., October 31, 2003
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- James DeYoung, October 24, 2003
- MTB Group of Funds, October 21, 2003
- Peninsular & Oriental Steam Navigation Company, October 15, 2003
- J.P. Morgan Securities Inc., October 8, 2003
- Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003
- RealEnergy, Inc., et al., August 12, 2003
- DTE Heritage, LLC, et. al., July 30, 2003
- France Growth Fund, Inc., July 15, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- Dougherty & Company LCC, July 3, 2003
- Juniper Capital L.P., June 23, 2003
- Mercy Investment Program, Inc., June 12, 2003
- Metropolitan Insurance and Annuity Company, June 6, 2003
- Neuberger Berman Management Inc., et al., April 30, 2003
- Fahnestock & Company Inc., April 21, 2003
- Tri-Continental Corporation, March 25, 2003
- Dougherty & Company LLC, March 21, 2003
- Fixed Income Clearing Corporation, March 13, 2003
- Edward Mahaffy, March 6, 2003
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- Tuition Plan Consortium, LLP, February 4, 2003
- Staff Responses to Questions About Regulation S-P, January 23, 2003
- Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003
- Constellation Financial Management LLC, January 9, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- AAL Mutual Funds, et al., December 12, 2002
- USB Global Asset Management (US), Inc., November 21, 2002
- Lindbergh Funds, October 30, 2002
- Frank Russell Investment Company, et al., October 18, 2002
- Honeywell International Inc Savings Plan Trust, October 7, 2002
- Manufacturers Adviser Corp, September 10, 2002
- Gulf Coast Venture Forum, Inc., August 21, 2002
- PIMCO Funds: Multi-Manager Series, August 6, 2002
- ReFlow Fund, LLC, July 15, 2002
- Federal National Mortgage Association, July 12, 2002
- Federal Home Loan Mortgage Corporation, July 12, 2002
- Thomson Financial Inc., July 10, 2002
- PIMCO Funds, July 9, 2002
- ING Bank, N.V., July 8, 2002
- Merrill Lynch Investment Managers, May 10, 2002
- Mutual Fund Directors Forum, May 9, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- General Electric Capital Corporation, April 26, 2002
- Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002
- MuniYield Insured Fund, Inc., March 11, 2002
- Evergreen Investment Management Company, LLC, February 13, 2002
- AIM Advisors, Inc., February 12, 2002
- Investment Company Institute, February 12, 2002
- Seligman New Technologies Fund II, Inc., February 7, 2002
- Federated Core Trust II, L.P., February 6, 2002
- National Football League Players Association, January 25, 2002
- Asia Tiger Fund, Inc., The, January 31, 2002
- Asia Tiger Fund, Inc., The, December 28, 2001
- Manufacturers Life Insurance Company, The, December 27, 2001
- Stephens Inc., December 27, 2001
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- U.S. Bancorp Asset Management Inc., et al., December 11, 2001
- Mexico Equity and Income Fund, The, November 15, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- Government Securities Clearing Corporation, October 19, 2001
- Lincoln National Convertible Securities Fund, Inc. - Walter S. Baer, September 28, 2001
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
- UAM Inc., September 24, 2001
- Calvert Social Index Fund, September 24, 2001
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- AIG Life Insurance Company, August 16, 2001
- k1 Ventures, et. al., July 28, 2003
- Arizona Electric Power Cooperative Inc., July 27, 2001
- The Chase Manhattan Bank, July 24, 2001
- Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001
- Current Income Shares, Inc., July 10, 2001
- Pioneer Interest Shares, June 20, 2001
- National Association for Variable Annunities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001
- Asia Pacific Fund, Inc (The), June 8, 2001
- Asia Pacific Fund, Inc (The) - Thomas A. Kornfeld, June 8, 2001
- Legg Mason Wood Walker, Inc., June 11, 2001
- H.E.B. Investment and Retirement Plan (H.E. Butt Grocery Company), May 18, 2001
- Investec Ernst & Company, April 24, 2001
- Prudential Investment Management Services LLC, April 19, 2001
- Longleaf Partners Funds Trust, April 9, 2001
- France Growth Fund, Inc, April 6, 2001
- France Growth Fund, Inc.; Advantage Partners LP, April 6, 2001
- France Growth Fund, Inc.; Strome Hedgecap Fund, April 6, 2001
- Nationwide Life Insurance Company, March 16, 2001
- Fidelity Advisor Korea Fund, Inc, March 7, 2001
- Swiss Helvetia Fund, Inc., March 6, 2001
- Western Farmers Electric Cooperative, February 23, 2001
- ING Mutual Funds Management Co. LLC; ING Funds Distributors Inc. and Reich & Tang Distributors Inc., February 9, 2001
- Prudential Securities Incorporated, February 7, 2001
http://www.sec.gov/divisions/investment/im-noaction.shtml
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