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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

Subject Categories

Subject Category List of No-Action Letters

12b-1 Fees

12b-1 Plans

Acquisition of Securities in Affiliated Underwriting

Advertising — Investment Advisers

Advertising — Investment Company

Advisory Contracts

Advisory Representatives

Advisory Fees

Affiliated Transactions

Annual Reports


Backward Pricing

Beneficial Ownership Qualified Purchaser

Business and Industrial Development Companies

Business Transfers

Cash Solicitation

Change of Control

Charitable Exclusions

Closed-End Investment Companies

Code of Ethics

Commerical Paper

Compliance Policies and Procedures Rule


Custody - Investment Advisers

Custody - Investment Companies




Distribution Fees

Distribution Plans

Employee Benefit Plans

Exchange Offer

Exemptive Applications and Orders

Face-Amount Certificate

Fees & Expenses

Fiduciary Duties

Foreign Banks


Fraud - Investment Advisers Act

Funds of Funds - Affiliated

Funds of Funds - Foreign Investment Companies

Government Instrumentalities

Government Securities

Hedge Clauses

Hedge Funds

Hub and Spoke Funds

Inadvertent Investment Companies

Independent Directors

Independent Legal Counsel

Insurance Products

Interested Person


Investment Advisers

Investment Advisers Act Status

Investment Company

Investment Company Act Status

Investment Securities

Joint Transactions

Mergers and Reorganizations Combinations

Money Market Funds

Money Market Liquidity

Periodic Payment Plan Certificate

Performance Fees

Pre-Paid Tuition Plans

Personal Securities Transaction

Principal Transaction

Principal Underwriters

Prospectuses — Delivery

Prospectuses — Disclosure

Proxy Voting

Public Offering

Public Utility Holding Companies

Qualified Purchase Definition - Investment Company Act Status Determination

Qualified Purchaser Fund

Real Estate

Redeemable Securities

Redemption Fees



Registration — Investment Advisers

Registration — Investment Companies

Regulation S-P

Reimbursement of Proxy Expenses


Reporting Requirements — Investment Advisers

Reporting Requirements — Investment Companies

Safe Harbors

Sales of Fund Shares below NAV

Securities — Definition

Securities Lending

Self Custody - Investment Companies

Separate Accounts

Senior Securities

Shareholder Proposals

Shareholders Votes

Short Sales


Tender Offers

Voting Security

Alphabetical List of No-Action Letters
Chronological List of No-Action Letters

Modified: 09/10/2008