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Investment Company Act of 1940 — Section 3(c)(1) and 3(c)(7)
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RESPONSE OF THE OFFICE OF CHIEF COUNSEL |
Our Ref. No. 2008331640 |
Based on the facts and representations in your letter dated February 27, 2008, we cannot assure you that we would not recommend enforcement action to the Securities and Exchange Commission under section 7 of the Investment Company Act of 1940, as amended (the "1940 Act"), against the 3(c)(1) Plus Fund (as defined in your letter) if the 3(c)(1) Plus Fund proceeds as described in your letter1 without registering under the 1940 Act. This position is consistent with the Division's long-standing views on this issue.2
Holly Hunter-Ceci
Attorney-Adviser
The Incoming Letter is in Acrobat format.
http://www.sec.gov/divisions/investment/noaction/2008/townsendgroup070908-sec7.htm
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