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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, 1993. 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 Category List of No-Action Letters
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12b-1 Fees
12b-1 Plans
Accounting
Acquisition Trust
Acquisition of Securities in Affiliated Underwriting
Administrative Fees
Advertising — Investment Advisers
- The TCW Group, Inc., November 7, 2008
- 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
- Jennison Associates LLC, July 6, 2000
- Franklin Management, Inc., December 10, 1998
- DALBAR, Inc., March 24, 1998
- Association for Investment Management and Research, December 18, 1996
- Horizon Asset Management, LLC, September 13, 1996
- Munder Capital Management, May 17, 1996
- J.P. Morgan Investment Management, Inc., May 7, 1996
- Clover Capital Management, Inc., October 28, 1986
Advertising — Investment Company
- Department of Labor, October 26, 2011
- Lindbergh Funds, October 30, 2002
- Salomon Brothers Asset Management Inc and Salomon Brothers Asset Management Asia Pacific Limited, July 23, 1999
- Dr. William Greene, Stern School of Business, February 3, 1997
- GE Funds, February 7, 1997
- ITT Hartford Mutual Funds, February 7, 1997
- Nicholas-Applegate Mutual Funds, February 7, 1997
- Bramwell Growth Fund, August 7, 1996
- Nicholas-Applegate Mutual Funds, August 6, 1996
- Blanchard Global Growth Fund, May 7, 1996
- MassMutual Institutional Funds, September 28, 1995
Advisory Contracts
- Hatteras Alternative Mutual Funds Trust, et al., September 25, 2012
- Nationwide Mutual Funds, et al., April 5, 2011
- Claymore Advisors, LLC, April 27, 2010
- Boulder Growth and Income Fund, Inc., March 5, 2010
- Boulder Total Return Fund, Inc., March 5, 2010
- Madison Asset Management, LLC, et al., June 30, 2009
- Iridian Asset Management LLC, April 14, 2009
- Bank of Ireland Asset Management (U.S.) Ltd., April 2, 2009
- Fortis Group, et al., January 27, 2009
- 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
- Metropolitan Life Insurance Company, November 13, 1999
- Wells Fargo Bank, N.A., March 31, 1998
- Franklin Templeton Group of Funds, July 23, 1997
- American Odyssey Funds, Inc., October 7, 1996
- Century Shares Trust, May 4, 1994
- Shearson Lehman Brothers Inc. and Smith Barney, Harris Upham & Co. Incorporated, June 8, 1993
- Washington Mutual Investors Fund, Inc., May 14, 1993
Advisory Fees
- Constellation Financial Management LLC, January 9, 2003
- Seligman New Technologies Fund II, Inc., February 7, 2002
- R.O.C. Taiwan Fund, February 11, 2000
- BISYS Fund Services, Inc., September 2, 1999
- INVESCO Funds Group, Inc., August 5, 1997
- Franklin Templeton Group of Funds, July 23, 1997
- American Odyssey Funds, Inc., October 7, 1996
- Lazard Freres Asset Management, February 12, 1996
- George Colman, July 18, 1995
- Benson White & Company, June 14, 1995
Advisory Representatives
Affiliated Persons
- UBS AG, July 29, 2009
- Investment Company Institute, March 12, 2009
- Auction Rate Securities, January 6, 2009
- Drinker, Biddle & Reath, December 18, 1998
- First Financial Fund, Inc., at al., June 5, 1997
- Mark A. Bush, August 8, 1995
- The One Group, May 23, 1995
- North American Security Trust and NASL Series Trust, February 2, 1993
Affiliated Transactions — Money Market Fund Letters
- Fifth Street Finance Corp., February 25, 2010
- Allianz Funds, August 3, 2009
- The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., August 3, 2009
- Mount Vernon Securities Lending Trust, August 3, 2009
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Fund, August 3, 2009
- SEI Daily Income Trust ? Prime
Obligation Fund, April 20, 2009
- SEI Liquid Asset Trust ? Prime Obligation Fund, April 20, 2009
- Columbia Funds Series Trust — Columbia Cash Reserves, March 2, 2009
- Columbia Funds Series Trust — Columbia Money Market Reserves, March 2, 2009
- Master Portfolio Trust — Liquid Reserves Portfolio and Legg Mason Partners Money Market Trust — Western Asset Money Market Fund, March 2, 2009
- Northern Institutional Funds — Diversified Assets Portfolio, Liquid Assets Portfolio and Prime Obligations Portfolio and Northern Funds — Money Market Fund, March 2, 2009
- SEI Liquid Asset Trust — Prime Obligation Fund, March 2, 2009
- Mount Vernon Securities Lending Trust, January 8, 2009
- Master Portfolio Trust — Liquid Reserves Portfolio, December 8, 2008
- Reserve New York Municipal Money-Market Trust — New York Municipal Money-Market Fund, November 18, 2008
- SEI Daily Income Trust — Prime Obligation Fund, November 18, 2008
- Mount Vernon Securities Lending Trust, October 24, 2008
- Russell Investment Company, October 24, 2008
- Columbia Funds Series Trust, October 22, 2008
- ING Funds Trust, ING Investors Trust, and ING Series Fund, Inc., October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- MainStay VP Cash Management Portfolio, October 22, 2008
- Morgan Stanley Institutional Liquidity Funds, October 22, 2008
- Morgan Stanley Money Market Funds, October 22, 2008
- Mount Vernon Securities Lending Trust, October 22, 2008
- Northwestern Mutual Series Fund, Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Phoenix Opportunities Trust, October 22, 2008
- Principal Funds, Inc. and Principal Variable Contracts Funds, Inc., October 22, 2008
- RidgeWorth Funds, October 22, 2008
- Tamarack Funds Trust, October 22, 2008
- Touchstone Variable Series Trust, October 22, 2008
- USAA Mutual Funds Trust, October 22, 2008
- The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., October 20, 2008
- Sun Capital Advisers Trust, October 20, 2008
- Advantus Series Fund, October 20, 2008
- Dreyfus Cash Management Plus, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Russell Investment Company, October 20, 2008
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 2008
- Northern Institutional Fund, July 16, 2008
- Western Asset Money Market
Fund, June 27, 2008
- Western Asset Institutional Money Market
Fund, June 27, 2008
- Munder Series Trust, June 23, 2008
- HSBC Investor Funds, June 25, 2008
- Allianz Dresdner Daily Asset Fund, May 5, 2008
- Institutional Liquidity Trust, April 30, 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
Affiliated Transactions — Other
- Morgan Stanley Institutional Fund of Hedge Funds, October 7, 2011
- Investment Company Institute, April 2, 2010
- T. Rowe Price Associates, Inc., October 8, 2009
- Regions Morgan Keegan Funds, March 30, 2009
- Columbia Funds, et al., December 23, 2008
- BNY Mellon Funds Trust, December 2, 2008
- Franklin Templeton Investments, November 21, 2008
- Highbridge Statistical Market Neutral Fund, September 29, 2008
- Dreyfus Cash Management, et al., September 25, 2008
- Investment Company Institute, September 25, 2008
- T. Rowe Price Associates, Inc., July 10, 2008
- ING Series Fund, Inc., et al., April 30, 2008
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Old Mutual Advisors Funds, November 16, 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
- Signature Financial Group, Inc., December 28, 1999
- Drinker, Biddle & Reath, December 18, 1998
- The Eaton Vance Group of Investment Companies, July 25, 1997
- Merrill Lynch Asset Management, April 28, 1997
- Dean Witter World Wide Investment Trust, September 17, 1996
- Morgan Grenfell Investment Trust, September 13, 1996
- Rowe Price-Fleming International Inc., April 12, 1996
- DFA Investment Trust, March 21, 1996
- DFA Investment Trust Company, October 17, 1995
- Norwest Funds — Municipal Money Market Fund, August 8, 1995
- ACM Institutional Reserves, Inc., July 14, 1995
- Alliance Municipal Trust, July 14, 1995
- Municipal Fund for California Investors, Inc., July 12, 1995
- California Municipal Cash Trust, July 11, 1995
- Lehman Brothers Daily Income Fund, July 7, 1995
- Benham California Tax-Free and Municipal Funds, June 30, 1995
- Kemper Money Market Funds, June 23, 1995
- The One Group, May 23, 1995
- Twentieth Century Mutual Funds, July 7, 1995
- Wells Fargo Money Market Funds, July 7, 1995
- Salomon Brothers Inc., April 25, 1995
- PaineWebber Managed Investments Trust, August 4, 1994
- Century Shares Trust, May 4, 1994
- The Capitol Mutual Funds and Nations Fund Trust, February 24, 1994
- North American Security Trust and NASL Series Trust, February 2, 1993
Agency Cross Transactions
Aggregated Transactions
Annual Reports
Annuity Contracts
Anti-Takeover Statutes
Asset-Backed Securities
- New Center Asset Trust, November 5, 1998
- Nebraska Higher Education Loan Program, April 3, 1998
- ESI S.A., February 2, 1995
- Global Exempt Certificates of Ownership in NHA MBS Securities Inc., December 30, 1994
- Donaldson, Lufkin & Jenrette Securities Corporation, May 26, 1994
Assignments
- American Century Investment Management, Inc., February 2, 2012
- Fortis Group, et al., January 27, 2009
- First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008
- American Century Companies, Inc. / J.P. Morgan & Co., December 23, 1997
Attribution
Auction Rate Notes
Automatic Bar
Backward Pricing
Banks
Banks — Affiliated Mutual Funds
Banks — Collective Trust Funds
Banks — Investment Advisory Activities
Beneficial Ownership Qualified Purchaser
- Trusts under the Will of Marion Searle, March 29, 2005
- H.E.B. Investment and Retirement Plan (H.E. Butt Grocery Company), May 18, 2001
- Caxton Corporation, December 28, 1994
- Latham & Watkins, December 28, 1994
- Wm. S. Barnickel & Company, November 1, 1994
- Owens-Illinois, Inc., June 24, 1994
- PanAgora Group Trust, April 29, 1994
Board of Directors
Board of Directors — Retirement Plans
Borrowings
Broker Dealer — Special Compensation
Broker-Dealers
Brokerage Activities
Bunching
Business Development Companies
Business and Industrial Development Companies
- American Capital, Ltd, June 30, 2009
- Kohlberg Capital Corporation, March 12, 2009
- NGP Capital Resources Company (Corrected), December 28, 2007
- Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001
- Plymouth Commercial Mortgage Fund, July 13, 1998
- Plymouth Commercial Mortgage Fund, December 3, 1996
Business Transfers
Capital Structures (BDC)
Cash Solicitation
- J.P. Morgan Securities LLC, January 9, 2013
- Wells Fargo Bank, N.A., September 21, 2012
- J.P. Turner & Company, L.L.C., et al, September 10, 2012
- GE Funding Capital Market Services, Inc., January 25, 2012
- Wells Fargo Bank, N.A., December 12, 2011
- J.P. Morgan Securities LLC, July 11, 2011
- J.P. Morgan Securities LLC, June 29, 2011
- BAC Home Loans Servicing, LP (formerly Countrywide Home Loans Servicing LP), June 2, 2011
- UBS Financial Services Inc., May 9, 2011
- Citigroup Inc., October 22, 2010
- General Electric Company, August 2, 2010
- Goldman, Sachs & Co., July 22, 2010
- General Electric Company, August 12, 2009
- Banc of America Securities LLC, June 10, 2009
- RBC Capital Markets Corporation, June 10, 2009
- Deutsche Bank Securities Inc., June 9, 2009
- UBS AG, March 20, 2009
- Automated Trading Desk Specialists, LLC, March 13, 2009
- E*Trade Capital Markets LLC, March 12, 2009
- Wachovia Securities LLC, February 18, 2009
- Citigroup Global Markets, Inc., December 23, 2008
- UBS Securities LLC/UBS Financial Services Inc., December 23, 2008
- 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
Cash Solicitation — Solicitors
Change of Control
Charitable Exclusions
- Deutsche Bank Microcredit Development Fund, Inc., April 8, 2011
- Goldman Sachs Asset Management, L.P., March 13, 2007
- American Bible Society, June 1, 2004
- Mercy Investment Program, Inc., June 12, 2003
- Daughters of Charity National Health System, Inc., April 3, 1998
Clearing Agency
Closed-End Investment Companies
- Aberdeen Australia Equity Fund, Inc., Aberdeen Chile Fund, Inc. and Aberdeen Global Income Fund, Inc., April 12, 2012
- Bank of America Corporation and Affiliates ("BAC"), April 29, 2011
- Calamos Convertible Opportunities and Income Fund, Calamos Convertible and High Income Fund, and Calamos Global Total Return Fund, February 14, 2011
- Boulder Total Return Fund, Inc., November 15, 2010
- Nuveen Municipal High Income Opportunity Fund, Nuveen Municipal High Income Opportunity Fund 2, Nuveen Floating Rate Income Opportunity Fund, Nuveen Senior Income Fund, Nuveen Floating Rate Income Fund, and Nuveen Municipal Value Fund, Inc., November 9, 2010
- Energy Income and Growth Fund and First Trust Active Dividend Income Fund, July 27, 2010
- Tortoise Energy Infrastructure Corporation and Tortoise Energy Capital Corporation, April 23, 2010
- Investment Company Institute, March 12, 2009
- BlackRock Advisers LLC and Affiliates, November 4, 2008
- Nuveen Virginia Premium Income Municipal Fund, October 6, 2006
- Investment Company Institute, November 10, 2004
- Frank Russell Investment Company, et al., October 18, 2002
- R.O.C. Taiwan Fund, February 11, 2000
Code of Ethics
- WilmerHale, LLP, July 28, 2010
- M&G Investment Management Ltd., March 1, 2007
- National Compliance Service, November 30, 2005
- Prudential Insurance Company of America, March 1, 2005
- Manufacturers Adviser Corp, September 10, 2002
Collective Investment Trusts
Commercial Paper
Commodity Pools
Commodity Trading Advisors
Compliance Policies and Procedures Rule
Consolidation
Control
Custodial Receipts
Custodial Requirements
Custody
Custody — Investment Advisers
- Investment Company Institute, September 5, 2012
- Seward & Kissel LLP, July 21, 2011
- American Institute of Certified Public Accountants, December 23, 2010
- Seward & Kissell, October 12, 2010
- Investment Adviser Association, September 20, 2007
- Deloitte & Touche LLP, August 28, 2006
- ABA Subcommittee on Private Investment Entities, August 10, 2006
- American Skandia Life Assurance Corporation, May 16, 2005
Custody — Investment Companies
- Chicago Mercantile Exchange, September 27, 2012
- Chicago Mercantile Exchange, September 27, 2012
- ICE Clear Credit LLC, September 27, 2012
- LCH.Clearnet Limited, September 27, 2012
- ICE Clear Credit LLC, July 29, 2011
- Chicago Mercantile Exchange, July 29, 2011
- Chicago Mercantile Exchange, July 29, 2011
- Chicago Mercantile Exchange, March 24, 2011
- LCH.Clearnet Limited, March 16, 2011
- ICE Trust U.S. LLC, March 1, 2011
- CME Group, Inc., December 3, 2010
- CME Group, Inc., July 16, 2010
- Franklin Templeton Investments, June 19, 2009
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Austraclear Limited, April 28, 2004
- Fixed Income Clearing Corporation, March 13, 2003
- Government Securities Clearing Corporation, October 19, 2001
- Investment Company Institute, June 15, 1999
- ING Bank N.V., et al., May 24, 1999
- Investment Company Institute, October 3, 1997
- AmSouth Mutual Funds, July 8, 1997
- ASX Settlement & Transfer Corporation, August 13, 1996
- National Securities Clearing Corp., May 24, 1996
- Kavilco, Inc., April 4, 1996
- Morgan Guaranty Trust Company of New York, November 17, 1995
- The Riverfront Funds, Inc., November 8, 1995
- Hongkong Securities Clearing Company Limited, July 13, 1995
- The Canadian Depository
for Securities Limited, August 4, 1994
- ASX Settlement and Transfer Corporation, April 19, 1994
- David S. Butterworth, January 27, 1994
Definitions
Derivative Securities
Director
- Boulder Growth and Income Fund, Inc., March 5, 2010
- Boulder Total Return Fund, Inc., March 5, 2010
- Federated Core Trust II, L.P., February 6, 2002
- Mexico Equity and Income Fund, The, November 15, 2001
Disclosure
- Department of Labor, October 26, 2011
- Kirkpatrick & Lockhart LLP, January 28, 2004
- Janus Adviser Series, August 28, 2000
- Eaton Vance Master Portfolio, December 11, 1996
- National Association for Variable Annuities, June 4, 1996
- Investment Company Registrant General Letter, February 15, 1996
- Letter to Investment Company Registrants, February 3, 1995
- Mutual Funds and Derivative Instruments, September 26, 1994
- Pershing Division of Donaldson, Lufkin & Jenrette Securities Corp., September 15, 1994
Disqualification — Investment Companies
Distributions
Distribution Fees
Distribution Plans
Diversification
Eligible Foreign Custodian
- Moscow Municipal Bank, April 8, 1998
- Stock Holding Corporation of Indian Ltd., January 21, 1998
- K. K. Rajendran, November 21, 1997
- Bucharest Stock Exchange, June 3, 1997
- Depository Clearing Company, December 19, 1997
- Russia Growth Fund, Inc., May 20, 1997
- National Securities Depository Ltd., February 25, 1997
- ASX Settlement & Transfer Corporation, August 13, 1996
- Financial Services Board, April 24, 1996
- Templeton Russia
Fund, Inc., April 18, 1995
- State Street Bank & Trust Company, February 28, 1995
- Warsaw Stock Exchange, October 20, 1994
- Japan Securities Depository Center, August 31, 1993
- Stock Exchange of
Thailand, August 26, 1993
- Malaysian Central
Depository Sdn. Bhd., May 19, 1993
- Korea Securities Depository Corporation, May 14, 1993
- Austraclear Limited, April 6, 1993
- Reserve Bank of New Zealand, May 24, 1993
- Custody of B Shares Trading on the Shenzhen and Shanghai Securities Exchanges, April 26, 1993
Emergencies
Employee Benefit Plans
- ING Life Insurance and Annuity Company, August 30, 2012
- 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
- World Financial Network National Bank, May 28, 1996
- U.S. Department of Labor, February 22, 1996
- Total, January 26, 1996
- Department of Labor, December 5, 1995
- Caxton Corporation, December 28, 1994
- Latham & Watkins, December 28, 1994
- Edward H. Fleischman, June 30, 1994
- Owens-Illinois, Inc., June 24, 1994
- PanAgora Group Trust, April 29, 1994
- County of Los Angeles, January 27, 1993
ERISA
Exchange-Traded Funds (ETFs)
- Derivatives Use by Actively-Managed ETFs, December 6, 2012
- FQF Trust, et al., December 13, 2011
- Barclays Global Fund Advisors et al., March 12, 2009
- iShares Trust, et al., October 22, 2008
Exchange-Traded Products
Exchange Offer
Exchange Privilege
Exemptive Applications and Orders
- Maxim Series Fund, Inc., et al., July 31, 2009
- Fixed Income Securities, L.P., April 29, 2004
- MTB Group of Funds, October 21, 2003
- Chase Manhattan Bank, June 12, 1998
Face-Amount Certificate
Factoring
Fair Value Pricing
Family Office Exclusion
Fees & Expenses
Fidelity Bonds — Investment Companies
Fiduciary Duties
- BNY ConvergEx Group, September 21, 2010
- Boulder Growth and Income Fund, Inc., March 5, 2010
- Boulder Total Return Fund, Inc., March 5, 2010
- Constellation Financial Management LLC, January 9, 2003
Filing — Dates
Filing Procedure — Fees
- GMO Trust, May 24, 2012
- AXA Equitable Life Insurance Company, February 27, 2009
- Nuveen Flagship Multistate Trust I, July 10, 1998
- American Council of Life Insurance, June 20, 1995
- The Victory Funds and The Victory Portfolios, April 24, 1995
- Kemper Total Return Fund, February 6, 1995
Filing Procedures
Finance Subsidiaries
- Brown & Wood, February 24, 2000
- KDSM, Inc. and Sinclair Capital, February 21, 1997
- Hewlett-Packard Finance Company, July 17, 1996
- Queensland Treasury Corporation, September 26, 1995
- Goldman Sachs & Co., April 27, 1995
- Andrews & Kurth L.L.P., April 5, 1994
- Lehman Brothers Inc., March 8, 1994
Financial Statement
Floating Rate Securities
Foreign Banks
Foreign Custodian
- Chase Manhattan Bank, June 12, 1998
- Investment Company Institute and the Global Custodians, February 19, 1998
- Reserve Bank of Australia, January 30, 1998
- Societatea Nationala de Compensare, January 28, 1998
- K. K. Rajendran, November 21, 1997
- The Canadian Depository
for Securities Limited, August 4, 1994
- ASX Settlement and Transfer Corporation, April 19, 1994
Foreign Government Securities
Foreign Investment Advisers
- Royal Bank of Canada, et al., June 3, 1998
- ABN AMRO Bank N.V., July 1, 1997
- Murray Johnstone Holdings Limited; Murray Johnstone Limited; Murray Johnstone International Limited, July 21, 1994
- Mercury Asset Management plc, April 16, 1993
- Uniao de Bancos de Brasileiros S.A., July 28, 1992
- Richard Ellis, Inc., March 19, 1981
Foreign Investment Companies
- Red Rocks Capital, LLC, June 3, 2011
- Dechert LLP, August 24, 2009
- Mike Krichew, November 5, 1997
- Bradley A. Veld, August 15, 1997
- Eaton Vance South Asia Portfolio, March 12, 1997
- Goodwin, Procter & Hoar, February 28, 1997
- Indosuez Asset Management Asia Limited, February 14, 1997
- Templeton Vietnam Opportunities Fund, Inc., September 6, 1996
- Investment Funds Institute of Canada, February 6, 1996
- Fiduciary Trust Global Fund, August 2, 1995
- The South America Fund N.V., September 2, 1993
- Pasadena Investment Trust, January 22, 1993
Form 13F
Forward Contract
Fraud
Fraud — Investment Advisers Act
Funds of Funds — Affiliated
- John Hancock Trust, et al, April 12, 2012
- FQF Trust, et al., December 13, 2011
- New Mountain Finance Corporation, April 27, 2011
- Madison Asset Management, LLC, et al., June 30, 2009
- iShares Trust, et al., October 22, 2008
- Merrill Lynch & Co., Inc., September 27, 2006
- Principal Investors Fund Inc., May 13, 2005
- Neuberger Berman Management Inc., et al., April 30, 2003
- MassMutual Institutional Funds, Inc., October 19, 1998
- Eaton Vance South Asia Portfolio, March 12, 1997
- Lazard Freres Asset Management, January 10, 1997
- Mutual Series Fund Inc., November 7, 1995
Funds of Funds — Foreign Investment Companies
- Red Rocks Capital, LLC, June 3, 2011
- Dechert LLP, August 24, 2009
- 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
- Templeton Vietnam Opportunities Fund, Inc., September 6, 1996
Fund Supermarkets
Generic Comment Letters
Government Agency
Government Instrumentalities
Government Securities
- Straight-A Funding, LLC, July 28, 2009
- Federal National Mortgage Association, July 12, 2002
- Federal Home Loan Mortgage Corporation, July 12, 2002
- J.P. Morgan Structured Obligations Corporation, July 27, 1994
- T. Rowe Price Tax-Free Funds, June 24, 1993
Governmental Plans
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
- PIMCO Funds, July 9, 2002
- Signature Financial Group, Inc., December 28, 1999
- Neuberger & Berman Income Funds, February 27, 1998
- The Eaton Vance Group of Investment Companies, July 25, 1997
- Principle Preservation Portfolios, Inc., December 6, 1995
Illiquid Securities
Inadvertent Investment Companies
Independent Directors
Independent Legal Counsel
Independent Public Accountant
Injunctions
Inspections — Investment Advisers
Insurance Companies
Insurance Company Regulation
Insurance Products
- Integrity Life Insurance Co., National Integrity Life Insurance Co., Western-Southern Life Assurance Co., Touchtone Securities, Inc., December 21, 2011
- 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
Integration
- Mark A. Bush, August 8, 1995
- Shoreline Fund, L.P., November 14, 1994
- Shoreline Fund, L.P., April 11, 1994
- Welsh, Carson, Anderson & Stowe, June 18, 1993
Interested Person
- Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002
- First Financial Fund, Inc., at al., June 5, 1997
- G.T. Global Growth Series et al., February 2, 1996
- Colonial Trust I et al., October 20, 1995
- Founders Funds, Inc., August 4, 1992
Internationalization of Securities Markets
Internet
Interval Funds
Investment Advisers
Investment Advisers Act Status
- Sisters of Mercy of the Americas, Inc., October 1, 2009
- 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
- BISYS Fund Services, Inc., September 2, 1999
- Sacha Stawski, August 9, 1996
- PerfectData Corporation, August 5, 1996
- Mr. Frank Mason, July 3, 1996
- Real Goods Trading Corporation, June 24, 1996
- Russell H. Smith, May 2, 1996
- RDM Infodustries, Inc., March 25, 1996
- U.S. Department of Labor, February 22, 1996
- Department of Labor, December 5, 1995
- InTouch Global, LLC, November 14, 1995
Investment Advisers Act Status — Broker-Dealers
Investment Advisers Act Status — Publishers
- Missouri Innovation Center, Inc., October 17, 1995
- Alfred A. Zurl, August 7, 1995
- Venture Search Technology Inc., July 11, 1995
- Louis Russo, June 16, 1994
- Stephen R. Kelly, July 28, 1994
Investment Adviser Registration
- TACT Asset Management Inc., October 24, 2012
- Allianz of America, Inc., May 25, 2012
- Peter Adamson III, April 3, 2012
- Industrial Alliance, Investment Management Inc., March 14, 2012
- American Bar Association, Business Law Section, January 18, 2012
- Zenkyoren Asset Management of America Inc., June 30, 2011
Investment Company
Investment Company Act Status
- Erste Abwicklungsanstalt, October 10, 2012
- Linn Energy, LLC, August 30, 2012
- Xplornet Communications Inc., January 11, 2012
- Royalty Pharma, August 13, 2010
- Accor Services, June 7, 2010
- Sisters of Mercy of the Americas, Inc., October 1, 2009
- Emeriti Consortium for Retirement Health Solutions, September 3, 2009
- 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
- Willkie Farr & Gallagher, October 23, 2000
- Pengrowth Energy Trust, January 27, 2000
- HOLDRs, September 3, 1999
- Mutual of Omaha Insurance Company, November 27, 1998
- Credit Suisse First Boston, September 9, 1998
- Puerto Rico Balanced Fund, Inc., April 29, 1997
- Managed Futures Association, July 11, 1996
- Mr. Frank Mason, July 3, 1996
- American Mutual Life Insurance, June 13, 1996
- World Financial Network National Bank, May 28, 1996
- Total, January 26, 1996
- Maxine Harry, December 6, 1995
- Kake Tribal Corporation, May 25, 1994
Investment Restrictions
Investment Securities
Joint Transactions
- Nuveen Asset Management, Inc., et al., December 30, 2010
- Investment Company Institute, April 2, 2010
- Highbridge Statistical Market Neutral Fund, September 29, 2008
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Neuberger Berman Management Inc., et al., April 30, 2003
- The Chase Manhattan Bank, July 24, 2001
- Investment Company Institute, April 15, 1998
- PNC Bank N.A., June 10, 1997
- Alliance Funds, April 25, 1997
- The T. Rowe Price Funds, July 31, 1995
Leverage
Liquidating Trusts
- Celina Financial Corporation, February 19, 1993
- I.C.H. Corporation, February 26, 1997
- Integrated Resources, Inc., August 5, 1994
- First Coastal Corporation, July 28, 1994
- MPC Liquidating Trust, March 10, 1994
- Oppenheimer Landmrk Properties, March 9, 1993
Limited Partnership Interest
Mergers and Reorganizations Combinations
- Integrity Life Insurance Co., National Integrity Life Insurance Co., Western-Southern Life Assurance Co., Touchtone Securities, Inc., December 21, 2011
- 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
- Nuveen Flagship Multistate Trust I, July 10, 1998
- Neuberger & Berman Income Funds, February 27, 1998
- Equitable Life Assurance Society, December 18, 1996
- Dreyfus Asset Allocation Fund, Inc., June 14, 1996
- Massachusetts Mutual Life, February 15, 1996
- The Capitol Mutual Funds and Nations Fund Trust, February 24, 1994
Mini-account Program
Money Market Funds
- Investment Company Institute Designated NRSROs, August 19, 2010
- Investment Company Institute (Corrected), August 10, 2010
- The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., August 3, 2009
- Mount Vernon Securities Lending Trust, August 3, 2009
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Fund, August 3, 2009
- Straight-A Funding, LLC, July 28, 2009
- Citigroup Global Markets, Inc, May 28, 2009
- SEI Daily Income Trust ? Prime Obligation Fund, April 20, 2009
- SEI Liquid Asset Trust ? Prime Obligation Fund, April 20, 2009
- College Retirement Equities Fund (CREF), April 13, 2009
- Columbia Funds Series Trust — Columbia Cash Reserves, March 2, 2009
- Columbia Funds Series Trust — Columbia Money Market Reserves, March 2, 2009
- Master Portfolio Trust — Liquid Reserves Portfolio and Legg Mason Partners Money Market Trust — Western Asset Money Market Fund, March 2, 2009
- Northern Institutional Funds — Diversified Assets Portfolio, Liquid Assets Portfolio and Prime Obligations Portfolio and Northern Funds — Money Market Fund, March 2, 2009
- SEI Liquid Asset Trust — Prime Obligation Fund, March 2, 2009
- Mount Vernon Securities Lending Trust, January 8, 2009
- Master Portfolio Trust — Liquid Reserves Portfolio, December 8, 2008
- Reserve New York Municipal Money-Market Trust — New York Municipal Money-Market Fund, November 18, 2008
- SEI Daily Income Trust — Prime Obligation Fund, November 18, 2008
- Mount Vernon Securities Lending Trust, October 24, 2008
- Russell Investment Company, October 24, 2008
- Columbia Funds Series Trust, October 22, 2008
- ING Funds Trust, ING Investors Trust, and ING Series Fund, Inc., October 22, 2008
- J.P. Morgan Securities Inc., October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- MainStay VP Cash Management Portfolio, October 22, 2008
- Morgan Stanley Money Market Funds, October 22, 2008
- Mount Vernon Securities Lending Trust, October 22, 2008
- Northwestern Mutual Series Fund, Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Phoenix Opportunities Trust, October 22, 2008
- Principal Funds, Inc. and Principal Variable Contracts Funds, Inc., October 22, 2008
- RidgeWorth Funds, October 22, 2008
- Tamarack Funds Trust, October 22, 2008
- Touchstone Variable Series Trust, October 22, 2008
- USAA Mutual Funds Trust, October 22, 2008
- The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., October 20, 2008
- Sun Capital Advisers Trust, October 20, 2008
- Advantus Series Fund, October 20, 2008
- Dreyfus Cash Management Plus, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Russell Investment Company, October 20, 2008
- Investment Company Institute, October 10, 2008
- Investment Company Institute, October 8, 2008
- Investment Company Institute, September 25, 2008
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 2008
- 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
- Munder Series Trust, June 23, 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
- SSGA International Liquidity Fund, December 2, 1998
- ICI Mutual Insurance Company, July 27, 1998
- Investment Company Institute, April 15, 1998
- Investment Company Institute, May 9, 1996
- Norwest Funds — Municipal Money Market Fund, August 8, 1995
- California Municipal Cash Trust, July 11, 1995
- Lehman Brothers Daily Income Fund, July 7, 1995
- Twentieth Century Mutual Funds, July 7, 1995
- Wells Fargo Money Market Funds, July 7, 1995
- Benham California Tax-Free and Municipal Funds, June 30, 1995
- J.P. Morgan Structured
Obligations Corporation, July 27, 1994
- Adam W. Glass, July 20, 1994
- CBA Money Fund, et al., June 9, 1994
- Donaldson, Lufkin & Jenrette Securities Corporation, May 26, 1994
- Sean J. Egan, May 10, 1994
- Investment Company Institute, June 16, 1993
- Investment Company Institute, November 2, 1992
- Morgan Keegan & Company, Inc., July 24, 1992
Mixed and Shared Funding
Model Portfolio
Money Market Liquidity
Money Market — Liquidity Puts
Money Market Portfolio Valuation
Multiple Classes
Municipal Bond
Names — Misleading
National Securities Market Improvement Act of 1996
No-Action Request Procedures
Offshore Funds
Oil & Gas
Pay to Play
Periodic Payment Plan Certificate
Performance Allocation
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
- Lazard Freres Asset Management, February 12, 1996
- James R. Waters, June 1, 1995
- George Colman, July 18, 1995
- Gerald Zuckerman, February 1, 1994
Personal Securities Transaction
Pre-Paid Tuition Plans
Pricing — Fair Value Pricing
- Investment Company Institute, December 8, 1999
- Charles Schwab & Co., Inc., July 7, 1997
- M.S.B. Fund, Inc., February 10, 1995
- United Municipal Bond Fund, January 27, 1995
Principal Transaction
- BNY ConvergEx Group, September 21, 2010
- Auction Rate Securities, January 6, 2009
- Barclays Capital Inc., September 19, 2008
- JPMorgan Chase; Bear Stearns Asset Management II, March 16, 2008
- Gardner Russo & Gardner, June 7, 2006
- Credit Suisse First Boston, LLC, August 31, 2005
Principal Underwriters
Private Investment Companies
- Frankin Templeton Group of Funds, et al., May 21, 1999
- American Bar Association, April 22, 1999
- Service Corporation International, October 6, 1998
- Lamp Technologies, Inc., May 29, 1998
- Wilkie Farr & Gallagher, June 11, 1996
- Cornish & Carey Commercial Inc., February 26, 1996
- Maxine Harry, December 6, 1995
- Caxton Corporation, December 28, 1994
- Latham & Watkins, December 28, 1994
- Glenwood Investment Corp., August 10, 1994
- Edward H. Fleischman, June 30, 1994
- PanAgora Group Trust, April 29, 1994
- Long-Term Capital Management, L.P., April 28, 1994
Private Investment Companies — Attribution
Private Offering
- Lamp Technologies, Inc., May 29, 1998
- Goodwin, Procter & Hoar, February 28, 1997
- Merrill Lynch Asset Management, April 28, 1997
- Indosuez Asset Management Asia Limited, February 14, 1997
- Investment Funds Institute of Canada, February 6, 1996
Prospectuses — Delivery
Prospectuses — Disclosure
- Lindbergh Funds, October 30, 2002
- Nationwide Life Insurance Company, March 16, 2001
- Investment Company Institute, July 29, 1996
- John Hancock Fund, Inc., June 25, 1996
- Australian Securities Commission, October 23, 1996
- Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, November 8, 1989
- Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, January 24, 1989
- Frank Russell Investment Management Company, August 30, 1993
Proxy Statement
Proxy Voting
Public Offering
- ING Bank, N.V., July 8, 2002
- Wilmer, Cutler & Pickering and Davis Polk & Wardell, October 5, 1998
- Goodwin, Procter & Hoar, October 5, 1998
- Lamp Technologies, Inc., May 29, 1997
- Dean Witter, Discover & Co., February 8, 1993
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
- American Bar Association, April 22, 1999
- Sullivan and Cromwell, December 29, 1997
Qualified Purchaser Fund
- The Townsend Group, Inc., July 9, 2008
- Cabot Wellington, LLC, June 17, 2008
- Goldman Sachs Asset Management, L.P., March 13, 2007
- Service Corporation International, October 6, 1998
- BSC Employee Fund, L.P., October 14, 1997
- Redwood Investment Fund, LLC, October 14, 1997
- Davis, Polk & Wardwell, April 24, 1997
Real Estate
Real Estate Investment Trusts
Recordkeeping Requirements — Investment Advisers
- Investment Company Institute, September 12, 2011
- Omgeo LLC, August 14, 2009
- Jennison Associates LLC, July 6, 2000
- Salomon Brothers Asset Management Inc and Salomon Brothers Asset Management Asia Pacific Limited, July 23, 1999
- John Bowen Investment Management, May 13, 1997
- Horizon Asset Management, LLC, September 13, 1996
- First Call Corporation, September 6, 1995
Recordkeeping Requirements — Investment Adviser Separate Accounts
Recordkeeping Requirements — Investment Adviser Suitability
Recordkeeping Requirements — Investment Companies
Redeemable Securities
- ING Life Insurance and Annuity Company, August 30, 2012
- Eaton Vance Management, June 13, 2008
- Nationwide Life Insurance Company, March 16, 2001
- Credit Suisse First Boston, September 9, 1998
- Nebraska Higher Education Loan Program, April 3, 1998
- Donaldson, Lufkin & Jenrette Securities Corporation, May 26, 1994
- Brown & Wood, February 24, 1994
Redemption Fees
Redemptions
- ReFlow Fund, LLC, July 15, 2002
- Signature Financial Group, Inc., December 28, 1999
- Investment Company Institute, December 8, 1999
- M.S.B. Fund, Inc., February 10, 1995
- CBA Money Fund, et al., June 9, 1994
- Travelers Insurance Company et al., September 3, 1993
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
- Lockheed Martin Investment Management Company, June 6, 2006
- Royal Bank of Canada, et al., June 3, 1998
- ABN AMRO Bank N.V., July 1, 1997
- David Parkinson, October 19, 1995
- Thomson Advisory Group L.P., September 26, 1995
- Mark A. Bush, August 8, 1995
- Gilbert G. Beezley, July 17, 1995
- Venture Search Technology Inc., July 11, 1995
- Dana Investment Advisors, Inc., October 12, 1994
- Arthur Andersen & Co., July 8, 1994
Registration — Investment Companies
- Linn Energy, LLC, August 30, 2012
- ABA Retirement Funds Program, June 7, 2010
- Seward & Kissel LLP, April 15, 2009
- 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
- Brown & Wood, February 24, 2000
- Richard L. Mertz, April 1, 1993
Regulation S-P
Reimbursement of Proxy Expenses
Reorganization
- IDS Life Insurance Company, et al., December 14, 2006
- The Eaton Vance Group of Investment Companies, July 25, 1997
- Dreyfus Asset Allocation Fund, Inc., June 14, 1996
- Principle Preservation Portfolios, Inc., December 6, 1995
- The Capitol Mutual Funds and Nations Fund Trust, February 24, 1994
Reporting Requirements — Investment Advisers
Reporting Requirements — Investment Companies
- Bank of America Corporation and Affiliates ("BAC"), April 29, 2011
- Berthel Growth & Income
Trust I, May 5, 2009
- BlackRock Advisers LLC and Affiliates, November 4, 2008
- 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
- Select Sector SPDR Trust, May 6, 1999
Repurchase Agreement
Reverse Repurchase Agreement
Safe Harbors
Sales Financing
Sales Load
Sales Load — Contingent Deferred
Sales of Fund Shares below NAV
Security — Definition
Securities Lending
- Nuveen Asset Management, Inc., et al., December 30, 2010
- USB Global Asset Management (US), Inc., November 21, 2002
- UAM Funds Inc., September 24, 2001
- U.S. Bancorp Asset Management Inc., et al., December 11, 2001
- Brinson Funds, et al., November 25, 1997
- Bear, Stearns & Co. Inc., September 16, 1997
- Morgan Guaranty Trust Company of New York, November 17, 1995
- United Services Funds, April 23, 1993
Securities Related Business
- Vanguard Group, Inc., May 22, 2009
- Select Sector SPDR Fund and Diamonds Trust, July 6, 2000
- Victory Stock Index Fund, February 7, 1995
- The Royce Fund, January 24, 1995
- Kidder Peabody Investment Trust, May 14, 1993
Self Custody — Investment Companies
Senior Securities
- American Capital, Ltd, June 30, 2009
- Investment Company Institute, October 8, 2008
- ReFlow Fund, LLC, July 15, 2002
- New America High Income Fund, Inc., July 29, 1993
Separate Accounts
- Integrity Life Insurance Co., National Integrity Life Insurance Co., Western-Southern Life Assurance Co., Touchtone Securities, Inc., December 21, 2011
- 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
- Massachusetts Mutual Life Insurance Company, August 10, 1998
- Gary E. Hughes, American Council of Life Insurance, May 26, 1996
- Metropolitan Life Insurance Company,
New England Mutual Life Insurance Company, and New England Variable Life Insurance Company, May 17, 1996
- The Equitable Life Assurance Society of the United States, December 22, 1995
Series Companies
Shareholder Meetings
Shareholder Proposals
- Pacholder High Yield Fund, Inc., January 18, 2013
- Foxby Corp., September 17, 2012
- Liberty All-star Growth Fund, Inc., May 10, 2012
- ING Emerging Countries Fund, May 7, 2012
- Guggenheim Enhanced Equity Strategy Fund, March 21, 2012
- College Retirement Equities Fund ("Fund") Shareholder Proposal of Aaron Levitt, May 6, 2011
- Omission of Shareholder Proposal Pursuant to Rule 14a-8 for H&Q Life Sciences Investors, March 24, 2011
- Lazard Global Total Return and Income Fund, Inc. and Lazard World Dividend & Income Fund, Inc., February 15, 2011
- H & Q Life Sciences Investors, February 4, 2011
- Adams Express Company, January 26, 2011
- The Ibero-America Fund, Inc., September 9, 2010
- The Swiss Helvetia Fund, Inc., May 5, 2010
- TS&W/Claymore Tax-Advantaged Balanced Fund, April 27, 2009
- U.S. Government Reserves and Fidelity Cash Reserves, April 27, 2009
- American Capital, Ltd., February 5, 2009
- 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
- Main Street Capital Corporation, June 20, 2011
- First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008
- Swiss Helvetia Fund, Inc., March 6, 2001
- R.O.C. Taiwan Fund, February 11, 2000
- Wells Fargo Bank, N.A., March 31, 1998
- Dessauer Global Equity Fund, April 3, 1997
Short Sales or Short Selling
Soft Dollar Arrangements
Solicitors
Spin Offs Assignment
Stapled Securities
State Regulation
Status of Investment Company
Structured Financing
Student Loans
Subsidiaries
Successor registration
Taxation
Tender Offers
Territorial Exemption
Tracking Stock
Transient Investment Company
Trustee
Unit Investment Trust
Variable Annuities Contract
Variable Rate Securities
Voting Security
- Boulder Total Return Fund, Inc., November 15, 2010
- Wells Fargo Alternative Asset Management, LLC, January 26, 2005
- Wilkie Farr & Gallagher, June 11, 1996
- Philadelphia Ventures Liberty Fund, L.P., February 14, 1995
Voting Trust
Warrants
Wrap Fee Arrangements
Alphabetical List of No-Action Letters
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- AAL Mutual Funds, et al., December 12, 2002
- ABA Retirement Funds Program, June 7, 2010
- 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
- Aberdeen Australia Equity Fund, Inc., Aberdeen Chile Fund, Inc. and Aberdeen Global Income Fund, Inc., April 12, 2012
- Accor Services, June 7, 2010
- ABN AMRO Bank N.V., July 1, 1997
- Acacia National Life Insurance Company, December 19, 2003
- Accounting Comment Letter, November 2, 1995
- ACM Institutional Reserves, Inc., July 14, 1995
- Adams Express Company, January 26, 2011
- Adams Express Company, September 7, 1984
- Peter Adamson III, April 3, 2012
- Advantus Series Fund, October 20, 2008
- 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
- Alameda Contra Costa Medical Association Collective Investment Trust for Retirement Plans, August 26, 1993
- Allianz of America, Inc., May 25, 2012
- Alliance Capital
Management L.P., April 7, 1993
- Alliance Funds, April 25, 1997
- Alliance Municipal Trust, July 14, 1995
- Alliance World Dollar Government Fund, Inc., October 19, 2006
- Allianz Dresdner Daily Asset Fund, May 5, 2008
- Allianz Funds, August 3, 2009
- Allstate Life Insurance Company, December 23, 2002
- Alternative Investment Partners Absolute Return Fund STS, July 10, 2006
- American Bar Association, Business Law Section, January 18, 2012
- American Bar Association, April 22, 1999
- American Bible Society, June 1, 2004
- American Capital, Ltd, June 30, 2009
- American Capital, Ltd., February 5, 2009
- American Century Companies, Inc. / J.P. Morgan & Co., December 23, 1997
- American Century Investment Management, Inc., February 2, 2012
- American Council of Life Insurance, June 20, 1995
- American Enterprise Life Insurance Company, April 30, 2002
- American Home Assurance Company, et. al., October 17, 2005
- American Institute of Certified Public Accountants, December 23, 2010
- American International Group, Inc., February 21, 2006
- American International Group, Inc., December 8, 2004
- American International Group, Inc., July 18, 1997
- American Mutual Life Insurance, June 13, 1996
- American Odyssey Funds, Inc., October 7, 1996
- American Skandia Life Assurance Corporation, May 16, 2005
- Ameriprise Financial Services Inc., April 5, 2006
- Ameritas Life Insurance Corp., April 5, 2007
- AmSouth Mutual Funds, July 8, 1997
- Andrews & Kurth L.L.P., April 5, 1994
- Arizona Electric Power Cooperative Inc., July 27, 2001
- Ark Therapeutics Group plc, April 15, 2005
- Arthur Andersen & Co., July 8, 1994
- ASA Limited, July 23, 2010
- 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
- Association for Investment Management and Research, December 18, 1996
- ASX Settlement & Transfer Corporation, August 13, 1996
- ASX Settlement and Transfer Corporation, April 19, 1994
- Auction Rate Securities, January 6, 2009
- Auction Rate Securities — Global Exemptive Relief, September 22, 2008
- Austraclear Limited, April 28, 2004
- Austraclear Limited, April 6, 1993
- Australian Securities Commission, October 23, 1996
- Automated Trading Desk Specialists, LLC, March 13, 2009
- AXA Equitable Life Insurance Company, February 27, 2009
- BAC Home Loans Servicing, LP (formerly Countrywide Home Loans Servicing LP), June 2, 2011
- Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002
- Bancafe/Juan Vico, May 22, 1996
- Banc of America Securities LLC, June 10, 2009
- Bank of America Corporation and Affiliates ("BAC"), April 29, 2011
- Bank of Ireland Asset Management (U.S.) Ltd., April 2, 2009
- Barclays Capital Inc., September 19, 2008
- Barclays Global Fund Advisors et al., March 12, 2009
- Wm. S. Barnickel & Company, November 1, 1994
- Bear, Stearns & Co. Inc., October 31, 2003
- Bear, Stearns & Co. Inc., September 16, 1997
- Bear, Stearns & Co. Inc., January 28, 1992
- Benham California Tax-Free and Municipal Funds, June 30, 1995
- Benson White & Company, June 14, 1995
- Berthel Growth & Income
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- Gilbert G. Beezley, July 17, 1995
- BISYS Fund Services, Inc., September 2, 1999
- BlackRock Advisers LLC and Affiliates, November 4, 2008
- Blanchard Global Growth Fund, May 7, 1996
- BNY ConvergEx Group, September 21, 2010
- BNY Mellon Funds Trust, December 2, 2008
- Bonneville Power Administration, February 10, 2004
- Boulder Total Return Fund, Inc., November 15, 2010
- Boulder Growth and Income Fund, Inc., March 5, 2010
- Boulder Total Return Fund, Inc., March 5, 2010
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- Bramwell Growth Fund, August 7, 1996
- Brinson Funds, et al., November 25, 1997
- Brown & Wood, February 24, 2000
- Brown & Wood, February 24, 1994
- BSC Employee Fund, L.P., October 14, 1997
- Bucharest Stock Exchange, June 3, 1997
- Mark A. Bush, August 8, 1995
- David S. Butterworth, January 27, 1994
- Cabot Wellington, LLC, June 17, 2008
- Calamos Convertible Opportunities and Income Fund, Calamos Convertible and High Income Fund, and Calamos Global Total Return Fund, February 14, 2011
- California Municipal Cash Trust, July 11, 1995
- Calvert Group, January 7, 1993
- Calvert Social Index Fund, September 24, 2001
- The Canadian Depository for Securities Limited, August 4, 1994
- Cantor Fitzgerald & Company, February 17, 2004
- Capital Trust, Inc., February 3, 2009
- Capital Trust, Inc., May 24, 2007
- The Capitol Mutual Funds and Nations Fund Trust, February 24, 1994
- Caxton Corporation, December 28, 1994
- CBA Money Fund, et al., June 9, 1994
- Celina Financial Corporation, February 19, 1993
- Century Shares Trust, May 4, 1994
- Charles Schwab & Co., Inc., July 7, 1997
- The Chase Manhattan Bank, July 24, 2001
- Chase Manhattan Bank, June 12, 1998
- Chicago Mercantile Exchange, September 27, 2012
- Chicago Mercantile Exchange, September 27, 2012
- Chicago Mercantile Exchange, July 29, 2011
- Chicago Mercantile Exchange, July 29, 2011
- Chicago Mercantile Exchange, March 24, 2011
- Chief Financial Officer, November 7, 1997
- Chief Financial Officer, November 1, 1994
- Chief Financial Officer of Investment Company Registrants, February 3, 1995
- CIBC Mellon Trust Company, February 24, 2005
- Citigroup Global Markets, Inc, May 28, 2009
- Citigroup Global Markets, Inc., December 23, 2008
- Citigroup Global Markets, Inc., September 26, 2006
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- Citigroup Inc., October 22, 2010
- Citigroup Inc., July 26, 2006
- Claymore Advisors, LLC, April 27, 2010
- Clover Capital Management, Inc., October 28, 1986
- CME Group, Inc., December 3, 2010
- CME Group, Inc., July 16, 2010
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- College Retirement Equities Fund, May 19, 2008
- College Retirement Equities Fund (CREF), April 13, 2009
- College Retirement Equities Fund ("Fund") Shareholder Proposal of Aaron Levitt, May 6, 2011
- 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
- College Retirement Equities Fund Real Estate Account, July 22, 1993
- Colonial Trust I et al., October 20, 1995
- Columbia Funds, December 12, 2011
- Columbia Funds, et al., December 23, 2008
- Columbia Funds Series Trust — Columbia Cash Reserves, March 2, 2009
- Columbia Funds Series Trust — Columbia Money Market Reserves, March 2, 2009
- Columbia Funds Series Trust, October 22, 2008
- Comdisco, Inc., October 25, 2000
- Continental
of Illinois (Delaware), Ltd., March 14, 1973
- Constellation Financial Management LLC, January 9, 2003
- Cooley Godward & Kronish, July 12, 2007
- Cornish & Carey Commercial Inc., February 26, 1996
- County of Los Angeles, January 27, 1993
- 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
- Credit Suisse First Boston, September 9, 1998
- CUNA Mutual Life Insurance Company, et al., December 27, 2007
- Current Income Shares, Inc., July 10, 2001
- Custody of B Shares Trading on the Shenzhen and Shanghai Securities Exchanges, April 26, 1993
- DALBAR, Inc., March 24, 1998
- Dana Investment Advisors, Inc., October 12, 1994
- Davis, Polk & Wardwell, April 24, 1997
- Daughters of Charity National Health System, Inc., April 3, 1998
- Dean Witter, Discover & Co., February 8, 1993
- Dean Witter World Wide Investment Trust, September 17, 1996
- Dechert LLP, August 24, 2009
- Defined Asset Funds, December 23, 1998
- Defined Asset Funds — Equity Income Fund — Select Ten Series, May 5, 1993
- Deloitte & Touche LLP, August 28, 2006
- Department of Labor, October 26, 2011
- Department of Labor, December 5, 1995
- Depository Clearing Company, December 19, 1997
- Derivatives Use by Actively-Managed ETFs, December 6, 2012
- Dessauer Global Equity Fund, April 3, 1997
- Deutsche Bank Microcredit Development Fund, Inc., April 8, 2011
- Deutsche Bank Securities Inc., June 9, 2009
- Deutsche Bank Securities Inc., September 24, 2004
- Dexia Municipal Agency, December 26, 2007
- DFA Investment Trust, March 21, 1996
- DFA Investment Trust Company, October 17, 1995
- Dominion Equipment II, Inc., et al., March 25, 2003
- Donaldson, Lufkin & Jenrette Securities Corporation, May 26, 1994
- Dougherty & Company LCC, July 3, 2003
- Dougherty & Company LLC, March 21, 2003
- Dreyfus Asset Allocation Fund, Inc., June 14, 1996
- Dreyfus Cash Management Plus, October 20, 2008
- Dreyfus Cash Management, et al., September 25, 2008
- Dreyfus Money Funds, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
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- DTE Heritage, LLC, et. al., July 30, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- The Eaton Vance Group of Investment Companies, July 25, 1997
- Eaton Vance Management, June 13, 2008
- Eaton Vance Master Portfolio, December 11, 1996
- Eaton Vance Special Investment Trust, et al March 30, 2004
- Eaton Vance South Asia Portfolio, March 12, 1997
- Egan-Jones Proxy Services, May 27, 2004
- Sean J. Egan, May 10, 1994
- EIF Neptune, LLC Starwood Energy Investors, LLC & Atlantic Energy Parts, July 29, 2005
- Emeriti Consortium for Retirement Health Solutions, September 3, 2009
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- Energy Income and Growth Fund and First Trust Active Dividend Income Fund, July 27, 2010
- Enron Corporation, March 11, 2004
- Equitable Life Assurance Society, December 18, 1996
- The Equitable Life Assurance Society of the United States, December 22, 1995
- Equus Capital Partners L.P., November 14, 2003
- Erste Abwicklungsanstalt, October 10, 2012
- ESI S.A., February 2, 1995
- E*Trade Capital Markets LLC, March 12, 2009
- 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 Investors, April 21, 1994
- 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
- Fiduciary Trust Global Fund, August 2, 1995
- Fifth Street Finance Corp., February 25, 2010
- Financial Services Board, April 24, 1996
- First American Funds, Inc. – Prime Obligation Fund, December 3, 2007
- The First Australia Fund, Inc., July 29, 1999
- First Call Corporation, September 6, 1995
- First Coastal Corporation, July 28, 1994
- First Data Corporation, January 13, 2004
- First Financial Fund, Inc., at al., June 5, 1997
- 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
- Five Arrows Short-Term Investment Trust, September 26, 1997
- Edward H. Fleischman, June 30, 1994
- Fortis Group, et al., January 27, 2009
- Founders Funds, Inc., August 4, 1992
- Foxby Corp., September 17, 2012
- 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
- Frank Russell Investment Management Company, August 30, 1993
- Frankin Templeton Group of Funds, et al., May 21, 1999
- Franklin Management, Inc., December 10, 1998
- Franklin Templeton Group of Funds, July 23, 1997
- Franklin Templeton Investments, June 19, 2009
- Franklin Templeton Investments, November 21, 2008
- Franklin Universal Trust, December 18, 2007
- Emanuel J. Friedman and EJF Capital LLC, January 16, 2007
- FQF Trust, et al., December 13, 2011
- Gardner Russo & Gardner, June 7, 2006
- Gartmore Mutual Funds, March 19, 2004
- Gartmore Variable Insurance Trust, December 29, 2006
- GE Funding Capital Market Services, Inc., January 25, 2012
- GE Funds, February 7, 1997
- GE Institutional Funds, December 21, 2005
- GE Life and Annuity Assurance Company, June 25, 2004
- General Electric Capital Corporation, April 26, 2002
- General Electric Company, August 2, 2010
- General Electric Company, August 12, 2009
- General Motors Investment Management, February 20, 2000
- Adam W. Glass, July 20, 1994
- Glenwood Investment Corp., August 10, 1994
- Global Exempt Certificates of Ownership in NHA MBS Securities Inc., December 30, 1994
- GMO Trust, May 24, 2012
- Goldman, Sachs & Co., July 22, 2010
- Goldman, Sachs & Co., February 23, 2005
- Goldman, Sachs & Company, October 31, 2003
- Goldman Sachs & Co., April 27, 1995
- Goldman Sachs Asset Management, L.P., March 13, 2007
- The Goldman Sachs Group, Inc., March 8, 2005
- Goldman Sachs Trust, August 19, 2008
- Goodwin, Procter & Hoar, October 5, 1998
- Goodwin, Procter & Hoar, February 28, 1997
- Government Securities Clearing Corporation, October 19, 2001
- Dr. William Greene, Stern School of Business, February 3, 1997
- G.T. Global Growth Series et al., February 2, 1996
- Guggenheim Enhanced Equity Strategy Fund, March 21, 2012
- GuideStone Financial, et al., December 27, 2006
- Gulf Coast Venture Forum, Inc., August 21, 2002
- H & Q Life Sciences Investors, February 4, 2011
- Maxine Harry, December 6, 1995
- The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., August 3, 2009
- The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., October 20, 2008
- Hatteras Alternative Mutual Funds Trust, et al., September 25, 2012
- H.E.B. Investment and Retirement Plan (H.E. Butt Grocery Company), May 18, 2001
- Heitman Capital Management, LLC, February 12, 2007
- Hewlett-Packard Finance Company, July 17, 1996
- Highbridge Statistical Market Neutral Fund, September 29, 2008
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- HOLDRs, September 3, 1999
- Honeywell International Inc Savings Plan Trust, October 7, 2002
- Hongkong Securities Clearing Company Limited, July 13, 1995
- Horizon Asset Management, LLC, September 13, 1996
- HSBC Investor Funds, June 25, 2008
- HSBC Investor Funds, January 18, 2008
- W.R. Huff Asset Management Co., L.P., August 10, 1994
- Gary E. Hughes, American Council of Life Insurance, May 26, 1996
- The Ibero-America Fund, Inc., September 9, 2010
- ICE Clear Credit LLC, September 27, 2012
- ICE Clear Credit LLC, July 29, 2011
- ICE Trust U.S. LLC, March 1, 2011
- I.C.H. Corporation, February 26, 1997
- ICI Mutual Insurance Company, July 27, 1998
- ICI Mutual Insurance Company, February 28, 1994
- IDS Life Insurance Company, et al., December 14, 2006
- Independent Directors Council and Mutual Fund Directors Forum, November 2, 2010
- Indosuez Asset Management Asia Limited, February 14, 1997
- Industrial Alliance, Investment Management Inc., March 14, 2012
- ING Bank N.V., August 31, 2005
- ING Bank, N.V., July 8, 2002
- ING Bank N.V., et al., May 24, 1999
- ING Emerging Countries Fund, May 7, 2012
- ING Funds Trust, ING Investors Trust, and ING Series Fund, Inc., October 22, 2008
- ING Life Insurance and Annuity Company, August 30, 2012
- 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
- Integrated Resources, Inc., August 5, 1994
- Integrity Life Insurance Co., National Integrity Life Insurance Co., Western-Southern Life Assurance Co., Touchtone Securities, Inc., December 21, 2011
- Interbolsa, August 5, 1996
- InTouch Global, LLC, November 14, 1995
- INVESCO Funds Group, Inc., August 5, 1997
- Investec Ernst & Company, April 24, 2001
- Investment Adviser Association, September 20, 2007
- Investment Adviser Association, December 2, 2005
- Investment Company Institute, September 5, 2012
- Investment Company Institute, September 12, 2011
- Investment Company Institute (Corrected), August 10, 2010
- Investment Company Institute, April 2, 2010
- Investment Company Institute, March 12, 2009
- Investment Company Institute, October 10, 2008
- Investment Company Institute, October 8, 2008
- Investment Company Institute, September 25, 2008
- 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 Company Institute, December 8, 1999
- Investment Company Institute, June 15, 1999
- Investment Company Institute, October 30, 1998
- Investment Company Institute, April 15, 1998
- Investment Company Institute, May 9, 1996
- Investment Company Institute, October 3, 1997
- Investment Company Institute, July 29, 1996
- Investment Company Institute, May 26, 1995
- Investment Company Institute, June 15, 1993
- Investment Company Institute, June 16, 1993
- Investment Company Institute, November 2, 1992
- Investment Company Institute and the Global Custodians, February 19, 1998
- Investment Company Institute Designated NRSROs, August 19, 2010
- Investment Company Institute: Letter to the ICI Regarding Valuation Issues, April 2001
- Investment Company Registrant General Letter, February 15, 1996
- Investment Counsel Association of America, Inc., March 1, 2004
- Investment Funds Institute of Canada, February 6, 1996
- Iridian Asset Management LLC, April 14, 2009
- iShares Trust, et al., October 22, 2008
- ITT Hartford Mutual Funds, February 7, 1997
- JPMorgan Chase; Bear Stearns Asset Management I,, July 14, 2008
- JPMorgan Chase; Bear Stearns Asset Management II, March 16, 2008
- J.P. Morgan Investment Management, Inc., May 7, 1996
- J.P. Morgan Securities Inc., October 22, 2008
- J.P. Morgan Securities Inc., October 8, 2003
- J.P. Morgan Securities Inc., October 31, 2003
- J.P. Morgan Securities LLC, January 9, 2013
- J.P. Morgan Securities LLC, July 11, 2011
- J.P. Morgan Securities LLC, June 29, 2011
- J.P. Morgan Structured Obligations Corporation, July 27, 1994
- J.P. Turner & Company, L.L.C., et al, September 10, 2012
- James DeYoung, October 24, 2003
- Janus Adviser Series, August 28, 2000
- Janus Aspen Series, April 10, 2008
- Japan Securities Depository Center, August 31, 1993
- Jennison Associates LLC, July 6, 2000
- John Bowen Investment Management, May 13, 1997
- John Hancock Fund, Inc., June 25, 1996
- John Hancock Trust, et al, April 12, 2012
- Juniper Capital L.P., June 23, 2003
- k1 Ventures, et. al., July 28, 2003
- Kake Tribal Corporation, May 25, 1994
- Kavilco, Inc., April 4, 1996
- KDSM, Inc. and Sinclair Capital, February 21, 1997
- Keene Corporation, June 2, 1993
- Stephen R. Kelly, July 28, 1994
- Kemper Money Market Funds, June 23, 1995
- Kemper Total Return Fund, February 6, 1995
- Kidder Peabody Investment Trust, May 14, 1993
- Kirkpatrick & Lockhart LLP, January 28, 2004
- Kohlberg Capital Corporation, March 12, 2009
- Korea Securities Depository Corporation, May 14, 1993
- Lamp Technologies, Inc., May 29, 1998
- Lamp Technologies, Inc., May 29, 1997
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- Latham & Watkins, December 28, 1994
- Lazard Freres Asset Management, January 10, 1997
- Lazard Freres Asset Management, February 12, 1996
- Lazard Global Total Return and Income Fund, Inc. and Lazard World Dividend & Income Fund, Inc., February 15, 2011
- LCH.Clearnet Limited, September 27, 2012
- LCH Clearnet Limited, July 29, 2011
- LCH.Clearnet Limited, March 16, 2011
- Lear Corporation Retirement Savings Plan Trusts, March 16, 2007
- Legg Mason Partners Institutional Trust, October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- Legg Mason Wood Walker, Inc., June 11, 2001
- Lehman Brothers, October 31, 2003
- Lehman Brothers Daily Income Fund, July 7, 1995
- Lehman Brothers Inc., March 8, 1994
- Letter to Investment Company Registrants, February 3, 1995
- Letter to Investment Advisers, October 25, 1994
- Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, November 8, 1989
- Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, January 24, 1989
- Liberty All-star Growth Fund, Inc., May 10, 2012
- 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
- Linn Energy, LLC, August 30, 2012
- Linsco/Private Ledger Corp., November 1, 1994
- LNC Equity Sales Corporation, August 8, 1997
- Lockheed Martin Investment Management Company, June 6, 2006
- Longleaf Partners Funds Trust, April 9, 2001
- Long-Term Capital Management, L.P., April 28, 1994
- M.S.B. Fund, Inc., February 10, 1995
- M&G Investment Management Ltd., March 1, 2007
- Macedonian Stock Exchange, July 10, 1997
- Mackenzie Investment Managment et al., August 8, 2000
- MACRO Securities Depositor, LLC, December 1, 2006
- Madison Asset Management, LLC, et al., June 30, 2009
- Mahaffy, Edward , March 6, 2003
- MainStay VP Cash Management Portfolio, October 22, 2008
- Main Street Capital Corporation, June 20, 2011
- Malaysian Central
Depository Sdn. Bhd., May 19, 1993
- Managed Futures Association, July 11, 1996
- 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
- Market Vectors ETF Trust, et al., March 26, 2012
- Mr. Frank Mason, July 3, 1996
- Massachusetts Mutual Life, June 7, 2000
- Massachusetts Mutual Life, February 15, 1996
- Massachusetts Mutual Life Insurance Company, August 10, 1998
- MassMutual Institutional Funds, Inc., October 19, 1998
- MassMutual Institutional Funds, September 28, 1995
- Master Portfolio Trust, April 18, 2008
- Master Portfolio Trust, April 4, 2008
- Master Portfolio Trust — Liquid Reserves Portfolio, December 8, 2008
- Master Portfolio Trust — Liquid Reserves Portfolio and Legg Mason Partners Money Market Trust — Western Asset Money Market Fund, March 2, 2009
- Maxim Series Fund, Inc., et al., July 31, 2009
- 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
- Mercury Asset Management plc, April 16, 1993
- Mercy Investment Program, Inc., June 12, 2003
- Merrill Lynch Asset Management, April 28, 1997
- Merrill Lynch & Co., Inc., September 27, 2006
- Merrill Lynch Investment Managers, May 10, 2002
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Richard L. Mertz, April 1, 1993
- Metropolitan Insurance and Annuity Company, June 6, 2003
- Metropolitan Life Insurance Company, November 13, 1999
- Metropolitan Life Insurance Company, April 26, 1995
- Metropolitan Life Insurance Company,
New England Mutual Life Insurance Company, and New England Variable Life Insurance Company, May 17, 1996
- Mexico Equity and Income Fund, The, November 15, 2001
- Mike Krichew, November 5, 1997
- Millennium Partners, L.P., et al, March 9, 2006
- Missouri Bankers Association, August 18, 2008
- Missouri Family Trust Fund, September 22, 1992
- Missouri Innovation Center, Inc., October 17, 1995
- MLC Limited, July 21, 1997
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- Morgan Grenfell Investment Trust, September 13, 1996
- Morgan Guaranty Trust Company of New York, November 17, 1995
- Morgan Keegan & Company, Inc., July 24, 1992
- Morgan, Lewis & Bockius LLP, November 17, 2005
- Morgan Stanley & Co., Inc., February 4, 2005
- Morgan Stanley Institutional Fund of Hedge Funds, October 7, 2011
- Morgan Stanley Institutional Liquidity Funds, October 22, 2008
- Morgan Stanley Money Market Funds, October 22, 2008
- Morgan Stanley Smith Barney LLC, May 29, 2009
- Moscow Municipal Bank, April 8, 1998
- Mount Vernon Securities Lending Trust, August 3, 2009
- Mount Vernon Securities Lending Trust, January 8, 2009
- Mount Vernon Securities Lending Trust, October 24, 2008
- Mount Vernon Securities Lending Trust, October 22, 2008
- MPC Liquidating Trust, March 10, 1994
- MTB Group of Funds, October 21, 2003
- Munder Capital Management, May 17, 1996
- Munder Series Trust, June 23, 2008
- Municipal Fund for California Investors, Inc., July 12, 1995
- Municipality Finance Ltd., April 28, 1994
- MuniYield Insured Fund, Inc., March 11, 2002
- Murray Johnstone Holdings Limited; Murray Johnstone Limited; Murray Johnstone International Limited, July 21, 1994
- Mutual Fund Directors Forum, May 9, 2002
- Mutual Funds and Derivative Instruments, September 26, 1994
- Mutual of America Investment Corporation, June 2, 2006
- Mutual of America Life Insurance Company, June 17, 1993
- Mutual of Omaha Insurance Company, November 27, 1998
- Mutual Series Fund Inc., November 7, 1995
- National Association for Variable Annuities, June 4, 1996
- 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
- National Securities Clearing Corp., May 24, 1996
- National Securities Depository Ltd., February 25, 1997
- Nationwide Life Insurance Company, March 16, 2001
- Nationwide Mutual Funds, et al., April 5, 2011
- Nebraska Higher Education Loan Program, April 3, 1998
- Neuberger Berman Management Inc., et al., April 30, 2003
- Neuberger & Berman Income Funds, February 27, 1998
- New America High Income Fund, Inc., July 29, 1993
- New Center Asset Trust, November 5, 1998
- New England Education Loan Marketing Corp, May 22, 1998
- New Mountain Finance Corporation, April 27, 2011
- NGP Capital Resources Company (Corrected), December 28, 2007
- Nicholas-Applegate Mutual Funds, February 7, 1997
- Nicholas-Applegate Mutual Funds, August 6, 1996
- North American Security Trust and NASL Series Trust, February 2, 1993
- Northern Institutional Fund, July 16, 2008
- Northern Institutional Funds, February 28, 2008
- Northern Institutional Funds — Diversified Assets Portfolio, Liquid Assets Portfolio and Prime Obligations Portfolio and Northern Funds — Money Market Fund, March 2, 2009
- Northwestern Mutual Series Fund, Inc., October 22, 2008
- Norwest Funds — Municipal Money Market Fund, August 8, 1995
- Nuveen Asset Management, Inc., et al., December 30, 2010
- Nuveen Flagship Multistate Trust I, July 10, 1998
- Nuveen Municipal High Income Opportunity Fund, Nuveen Municipal High Income Opportunity Fund 2, Nuveen Floating Rate Income Opportunity Fund, Nuveen Senior Income Fund, Nuveen Floating Rate Income Fund, and Nuveen Municipal Value Fund, Inc., November 9, 2010
- 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
- Omgeo LLC, August 14, 2009
- Omission of Shareholder Proposal Pursuant to Rule 14a-8 for H&Q Life Sciences Investors, March 24, 2011
- The One Group, May 23, 1995
- One Point Communications Corp, June 12, 1998
- Oppenheimer Landmrk Properties, March 9, 1993
- Owens-Illinois, Inc., June 24, 1994
- Pacholder High Yield Fund, Inc., January 18, 2013
- Pacific Select Fund, et al., December 23, 2004
- PaineWebber Equity Trusts, July 19, 1993
- PaineWebber Incorporated, January 27, 1995
- PaineWebber Managed Investments Trust, August 4, 1994
- PanAgora Group Trust, April 29, 1994
- David Parkinson, October 19, 1995
- Pasadena Investment Trust, January 22, 1993
- Pengrowth Energy Trust, January 27, 2000
- Peninsular & Oriental Steam Navigation Company, October 15, 2003
- Penn Series Funds Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- PerfectData Corporation, August 5, 1996
- Pershing Division of Donaldson, Lufkin & Jenrette Securities Corp., September 15, 1994
- Philadelphia Stock
Exchange, Inc., October 18, 1994
- Philadelphia Ventures Liberty Fund, L.P., February 14, 1995
- Phoenix Opportunities Trust, October 22, 2008
- PIMCO Funds: Multi-Manager Series, August 6, 2002
- PIMCO Funds, July 9, 2002
- Pioneer Funds, December 20, 2005
- Pioneer Interest Shares, June 20, 2001
- Plymouth Commercial Mortgage Fund, July 13, 1998
- Plymouth Commercial Mortgage Fund, December 3, 1996
- PNC Bank N.A., June 10, 1997
- PNC Fund, et al., April 2, 1993
- Pretzel & Stouffer, December 1, 1995
- Principal Funds, Inc. and Principal Variable Contracts Funds, Inc., October 22, 2008
- Principal Investors Fund Inc., May 13, 2005
- Principle Preservation Portfolios, Inc., December 6, 1995
- 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
- Public Employees' Retirement Board of the State of Oregon, March 3, 1998
- Puerto Rico Balanced Fund, Inc., April 29, 1997
- Putnam High Income Securities Fund, March 14, 2006
- Putnam Premier Income Trust, March 14, 2006
- Putnam Tax-Free Health Care Fund, August 8, 2005
- Queensland Treasury Corporation, September 26, 1995
- K. K. Rajendran, November 21, 1997
- RBC Capital Markets Corporation, June 10, 2009
- RealEnergy, Inc., et al., August 12, 2003
- Real Goods Trading Corporation, June 24, 1996
- Red Rocks Capital, LLC, June 3, 2011
- Redwood Investment Fund, LLC, October 14, 1997
- ReFlow Fund, LLC, July 15, 2002
- Regions Morgan Keegan Funds, March 30, 2009
- Reserve Bank of Australia, January 30, 1998
- Reserve Bank of New Zealand, May 24, 1993
- Reserve New York Municipal Money-Market Trust — New York Municipal Money-Market Fund, November 18, 2008
- RDM Infodustries, Inc., March 25, 1996
- Richard Ellis, Inc., March 19, 1981
- RidgeWorth Funds, October 22, 2008
- The Riverfront Funds, Inc., November 8, 1995
- Robertson, Stephens & Company, January 12, 1993
- R.O.C. Taiwan Fund, February 11, 2000
- Rowe Price-Fleming International Inc., April 12, 1996
- Royal Bank of Canada, et al., June 3, 1998
- Royal Dutch Shell plc, May 17, 2005
- Royalty Pharma, August 13, 2010
- The Royce Fund, January 24, 1995
- Russell Investment Company, October 24, 2008
- Russell Investment Company, October 20, 2008
- Russia Growth Fund, Inc., May 20, 1997
- Louis Russo, June 16, 1994
- Safra Republic Holdings, April 21, 1998
- Salomon Brothers Asset Management Inc and Salomon Brothers Asset Management Asia Pacific Limited, July 23, 1999
- Salomon Brothers Inc., April 25, 1995
- SCP Private Equity Partners II, L.P., June 6, 2006
- Scudder Investment Trust, March 23, 1994
- Sedgwick Consulting Group, May 17, 1993
- SEI Daily Income Trust ? Prime Obligation Fund, April 20, 2009
- SEI Daily Income Trust — Prime Obligation Fund, November 18, 2008
- 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, April 20, 2009
- SEI Liquid Asset Trust — Prime Obligation Fund, March 2, 2009
- SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007
- Select Sector SPDR Fund and Diamonds Trust, July 6, 2000
- Select Sector SPDR Trust, May 6, 1999
- Seligman New Technologies Fund II, Inc., February 7, 2002
- Service Corporation International, October 6, 1998
- Seward & Kissel LLP, July 21, 2011
- Seward & Kissell, October 12, 2010
- Seward & Kissel LLP, April 15, 2009
- Seward & Kissel, October 12, 2005
- Shearson Lehman Brothers Inc. and Smith Barney, Harris Upham & Co. Incorporated, June 8, 1993
- Shee Atika Investments, LLC, January 20, 2004
- Shoreline Fund, L.P., November 14, 1994
- Shoreline Fund, L.P., April 11, 1994
- Signature Financial Group, Inc., December 28, 1999
- Sisters of Mercy of the Americas, Inc., October 1, 2009
- SMC Capital, Inc., September 5, 1995
- Russell H. Smith, May 2, 1996
- Societatea Nationala de Compensare, January 28, 1998
- The South America Fund N.V., September 2, 1993
- SSGA International Liquidity Fund, December 2, 1998
- Staff Responses to Questions About Regulation S-P, January 23, 2003
- Standard Shares, Inc., July 29, 1974
- State Street Bank & Trust, August 1, 1996
- State Street Bank & Trust Company, February 28, 1995
- Sacha Stawski, August 9, 1996
- Stephens Inc., December 27, 2001
- STI Classic Funds, January 2, 2008
- STI Classic Funds, October 26, 2007
- Stock Exchange of
Thailand, August 26, 1993
- Stock Holding Corporation of Indian Ltd., January 21, 1998
- R. Bryan Stoker, May 13, 1994
- Straight-A Funding, LLC, July 28, 2009
- Sullivan and Cromwell, December 29, 1997
- Summit Advisors, Inc., March 1, 1994
- Sun Capital Advisers Trust, October 20, 2008
- 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
- The Swiss Helvetia Fund, Inc., May 5, 2010
- Swiss Helvetia Fund, Inc., March 6, 2001
- TACT Asset Management Inc., October 24, 2012
- Tamarack Funds Trust, October 22, 2008
- Michael Tannenbaum, January 5, 1993
- The TCW Group, Inc., November 7, 2008
- TDAM Money Market Portfolio, December 21, 2007
- Templeton Russia
Fund, Inc., April 18, 1995
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
- Templeton Vietnam Opportunities Fund, Inc., September 6, 1996
- Thomas Weisel Partners LLC, September 24, 2004
- Thomson Advisory Group L.P., September 26, 1995
- Thomson Financial Inc., July 10, 2002
- Thomson Fund Group, et al., January 28, 1993
- TIAA Real Estate Account, May 1, 1996
- Tortoise Energy Infrastructure Corporation and Tortoise Energy Capital Corporation, April 23, 2010
- Total, January 26, 1996
- The Townsend Group, Inc., July 9, 2008
- Touchstone Variable Series Trust, October 22, 2008
- Townsend and Associates, Inc., September 21, 1994
- Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004
- Transamerica Series, Inc., November 7, 1994
- Transamerica Series, Inc., November 7, 1994
- Travelers Insurance Company et al., September 3, 1993
- Tri-Continental Corporation, March 25, 2003
- Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003
- T. Rowe Price Associates, Inc., October 8, 2009
- T. Rowe Price Associates, Inc., July 10, 2008
- The T. Rowe Price Funds, July 31, 1995
- T. Rowe Price Tax-Free Funds, June 24, 1993
- Trusts under the Will of Marion Searle, March 29, 2005
- TS&W/Claymore Tax-Advantaged Balanced Fund, April 27, 2009
- Tuition Plan Consortium, LLP, February 4, 2003
- Twentieth Century Mutual Funds, July 7, 1995
- UAM Inc., September 24, 2001
- UBS AG, July 29, 2009
- UBS AG, March 20, 2009
- UBS Financial Services Inc., May 9, 2011
- UBS Financial Services, Inc., September 29, 2005
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- UBS Securities LLC/UBS Financial Services Inc., December 23, 2008
- USB Global Asset Management (US), Inc., November 21, 2002
- Uniao de Bancos de Brasileiros S.A., July 28, 1992
- United Missouri Bank of Kansas City, January 23, 1995
- United Municipal Bond Fund, January 27, 1995
- United Services Funds, April 23, 1993
- Unit Investment Trust Organizational Expenses, May 9, 1995
- University of Alaska Advance College Tuition Payment, March 2, 1992
- USAA Mutual Funds Trust, October 22, 2008
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- U.S. Bancorp Asset Management Inc., et al., December 11, 2001
- U.S. Department of Labor, February 22, 1996
- U.S. Government Reserves and Fidelity Cash Reserves, April 27, 2009
- Vanguard Group, Inc., May 22, 2009
- Van Kampen Funds Inc., January 31, 2007
- Venture Search Technology Inc., July 11, 1995
- The Victory Funds and The Victory Portfolios, April 24, 1995
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Fund, August 3, 2009
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 2008
- Victory Stock Index Fund, February 7, 1995
- Wachovia Securities LLC, February 18, 2009
- Wall Street Preferred Money Managers, Inc., April 10, 1992
- Warsaw Stock Exchange, October 20, 1994
- Washington Capital Joint Master Trust, September 25, 2006
- Washington Mutual Investors Fund, Inc., May 14, 1993
- James R. Waters, June 1, 1995
- Wells Fargo Alternative Asset Management, LLC, January 26, 2005
- Wells Fargo Bank, N.A., September 21, 2012
- Wells Fargo Bank, N.A., December 12, 2011
- Wells Fargo Bank, N.A., March 31, 1998
- Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008
- Wells Fargo Money Market Funds, July 7, 1995
- Welsh, Carson, Anderson & Stowe, June 18, 1993
- 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
- Willkie Farr & Gallagher, October 23, 2000
- Wilkie Farr & Gallagher, June 11, 1996
- Wilmer, Cutler & Pickering and Davis Polk & Wardell, October 5, 1998
- WilmerHale, LLP, July 28, 2010
- Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001
- World Financial Network National Bank, May 28, 1996
- Xplornet Communications Inc., January 11, 2012
- Zenkyoren Asset Management of America Inc., June 30, 2011
- Gerald Zuckerman, February 1, 1994
- Alfred A. Zurl, August 7, 1995
Chronological List of No-Action Letters
|
- Pacholder High Yield Fund, Inc., January 18, 2013
- J.P. Morgan Securities LLC, January 9, 2013
- Derivatives Use by Actively-Managed ETFs, December 6, 2012
- TACT Asset Management Inc., October 24, 2012
- Erste Abwicklungsanstalt, October 10, 2012
- Chicago Mercantile Exchange, September 27, 2012
- Chicago Mercantile Exchange, September 27, 2012
- ICE Clear Credit LLC, September 27, 2012
- LCH.Clearnet Limited, September 27, 2012
- Hatteras Alternative Mutual Funds Trust, et al., September 25, 2012
- Wells Fargo Bank, N.A., September 21, 2012
- Foxby Corp., September 17, 2012
- J.P. Turner & Company, L.L.C., et al, September 10, 2012
- Investment Company Institute, September 5, 2012
- ING Life Insurance and Annuity Company, August 30, 2012
- Linn Energy, LLC, August 30, 2012
- Allianz of America, Inc., May 25, 2012
- GMO Trust, May 24, 2012
- Liberty All-star Growth Fund, Inc., May 10, 2012
- ING Emerging Countries Fund, May 7, 2012
- Aberdeen Australia Equity Fund, Inc., Aberdeen Chile Fund, Inc. and Aberdeen Global Income Fund, Inc., April 12, 2012
- John Hancock Trust, et al, April 12, 2012
- Peter Adamson III, April 3, 2012
- Market Vectors ETF Trust, et al., March 26, 2012
- Guggenheim Enhanced Equity Strategy Fund, March 21, 2012
- Industrial Alliance, Investment Management Inc., March 14, 2012
- American Century Investment Management, Inc., February 2, 2012
- GE Funding Capital Market Services, Inc., January 25, 2012
- American Bar Association, Business Law Section, January 18, 2012
- Xplornet Communications Inc., January 11, 2012
- Integrity Life Insurance Co., National Integrity Life Insurance Co., Western-Southern Life Assurance Co., Touchtone Securities, Inc., December 21, 2011
- FQF Trust, et al., December 13, 2011
- Columbia Funds, December 12, 2011
- Wells Fargo Bank, N.A., December 12, 2011
- Department of Labor, October 26, 2011
- Morgan Stanley Institutional Fund of Hedge Funds, October 7, 2011
- Investment Company Institute, September 12, 2011
- LCH Clearnet Limited, July 29, 2011
- ICE Clear Credit LLC, July 29, 2011
- Chicago Mercantile Exchange, July 29, 2011
- Chicago Mercantile Exchange, July 29, 2011
- Seward & Kissel LLP, July 21, 2011
- J.P. Morgan Securities LLC, July 11, 2011
- Zenkyoren Asset Management of America Inc., June 30, 2011
- J.P. Morgan Securities LLC, June 29, 2011
- Main Street Capital Corporation, June 20, 2011
- Red Rocks Capital, LLC, June 3, 2011
- BAC Home Loans Servicing, LP (formerly Countrywide Home Loans Servicing LP), June 2, 2011
- UBS Financial Services Inc., May 9, 2011
- College Retirement Equities Fund ("Fund") Shareholder Proposal of Aaron Levitt, May 6, 2011
- Bank of America Corporation and Affiliates ("BAC"), April 29, 2011
- New Mountain Finance Corporation, April 27, 2011
- Deutsche Bank Microcredit Development Fund, Inc., April 8, 2011
- Nationwide Mutual Funds, et al., April 5, 2011
- Chicago Mercantile Exchange, March 24, 2011
- Omission of Shareholder Proposal Pursuant to Rule 14a-8 for H&Q Life Sciences Investors, March 24, 2011
- LCH.Clearnet Limited, March 16, 2011
- ICE Trust U.S. LLC, March 1, 2011
- Lazard Global Total Return and Income Fund, Inc. and Lazard World Dividend & Income Fund, Inc., February 15, 2011
- Calamos Convertible Opportunities and Income Fund, Calamos Convertible and High Income Fund, and Calamos Global Total Return Fund, February 14, 2011
- H & Q Life Sciences Investors, February 4, 2011
- Adams Express Company, January 26, 2011
- Nuveen Asset Management, Inc., et al., December 30, 2010
- American Institute of Certified Public Accountants, December 23, 2010
- CME Group, Inc., December 3, 2010
- Boulder Total Return Fund, Inc., November 15, 2010
- Nuveen Municipal High Income Opportunity Fund, Nuveen Municipal High Income Opportunity Fund 2, Nuveen Floating Rate Income Opportunity Fund, Nuveen Senior Income Fund, Nuveen Floating Rate Income Fund, and Nuveen Municipal Value Fund, Inc., November 9, 2010
- Independent Directors Council and Mutual Fund Directors Forum, November 2, 2010
- Citigroup Inc., October 22, 2010
- Seward & Kissell, October 12, 2010
- BNY ConvergEx Group, September 21, 2010
- The Ibero-America Fund, Inc., September 9, 2010
- Investment Company Institute Designated NRSROs, August 19, 2010
- Royalty Pharma, August 13, 2010
- Investment Company Institute (Corrected), August 10, 2010
- General Electric Company, August 2, 2010
- WilmerHale, LLP, July 28, 2010
- Energy Income and Growth Fund and First Trust Active Dividend Income Fund, July 27, 2010
- ASA Limited, July 23, 2010
- Goldman, Sachs & Co., July 22, 2010
- CME Group, Inc., July 16, 2010
- ABA Retirement Funds Program, June 7, 2010
- Accor Services, June 7, 2010
- The Swiss Helvetia Fund, Inc., May 5, 2010
- Claymore Advisors, LLC, April 27, 2010
- Tortoise Energy Infrastructure Corporation and Tortoise Energy Capital Corporation, April 23, 2010
- Investment Company Institute, April 2, 2010
- Boulder Growth and Income Fund, Inc., March 5, 2010
- Boulder Total Return Fund, Inc., March 5, 2010
- Fifth Street Finance Corp., February 25, 2010
- T. Rowe Price Associates, Inc., October 8, 2009
- Sisters of Mercy of the Americas, Inc., October 1, 2009
- Emeriti Consortium for Retirement Health Solutions, September 3, 2009
- Dechert LLP, August 24, 2009
- Omgeo LLC, August 14, 2009
- General Electric Company, August 12, 2009
- Allianz Funds, August 3, 2009
- The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., August 3, 2009
- Mount Vernon Securities Lending Trust, August 3, 2009
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Fund, August 3, 2009
- Maxim Series Fund, Inc., et al., July 31, 2009
- UBS AG, July 29, 2009
- Straight-A Funding, LLC, July 28, 2009
- American Capital, Ltd, June 30, 2009
- Madison Asset Management, LLC, et al., June 30, 2009
- Franklin Templeton Investments, June 19, 2009
- Banc of America Securities LLC, June 10, 2009
- RBC Capital Markets Corporation, June 10, 2009
- Deutsche Bank Securities Inc., June 9, 2009
- Morgan Stanley Smith Barney LLC, May 29, 2009
- Citigroup Global Markets, Inc, May 28, 2009
- Vanguard Group, Inc., May 22, 2009
- Berthel Growth & Income
Trust I, May 5, 2009
- TS&W/Claymore Tax-Advantaged Balanced Fund, April 27, 2009
- U.S. Government Reserves and Fidelity Cash Reserves, April 27, 2009
- SEI Daily Income Trust ? Prime Obligation Fund, April 20, 2009
- SEI Liquid Asset Trust ? Prime Obligation Fund, April 20, 2009
- Seward & Kissel LLP, April 15, 2009
- Iridian Asset Management LLC, April 14, 2009
- College Retirement Equities Fund (CREF), April 13, 2009
- Bank of Ireland Asset Management (U.S.) Ltd., April 2, 2009
- Regions Morgan Keegan Funds, March 30, 2009
- UBS AG, March 20, 2009
- Automated Trading Desk Specialists, LLC, March 13, 2009
- Barclays Global Fund Advisors et al., March 12, 2009
- E*Trade Capital Markets LLC, March 12, 2009
- Investment Company Institute, March 12, 2009
- Kohlberg Capital Corporation, March 12, 2009
- Columbia Funds Series Trust — Columbia Cash Reserves, March 2, 2009
- Columbia Funds Series Trust — Columbia Money Market Reserves, March 2, 2009
- Master Portfolio Trust — Liquid Reserves Portfolio and Legg Mason Partners Money Market Trust — Western Asset Money Market Fund, March 2, 2009
- Northern Institutional Funds — Diversified Assets Portfolio, Liquid Assets Portfolio and Prime Obligations Portfolio and Northern Funds — Money Market Fund, March 2, 2009
- SEI Liquid Asset Trust — Prime Obligation Fund, March 2, 2009
- AXA Equitable Life Insurance Company, February 27, 2009
- Wachovia Securities LLC, February 18, 2009
- American Capital, Ltd., February 5, 2009
- Capital Trust, Inc., February 3, 2009
- Fortis Group, et al., January 27, 2009
- Mount Vernon Securities Lending Trust, January 8, 2009
- Auction Rate Securities, January 6, 2009
- Citigroup Global Markets, Inc., December 23, 2008
- Columbia Funds, et al., December 23, 2008
- UBS Securities LLC/UBS Financial Services Inc., December 23, 2008
- Master Portfolio Trust — Liquid Reserves Portfolio, December 8, 2008
- BNY Mellon Funds Trust, December 2, 2008
- Franklin Templeton Investments, November 21, 2008
- Reserve New York Municipal Money-Market Trust — New York Municipal Money-Market Fund, November 18, 2008
- SEI Daily Income Trust — Prime Obligation Fund, November 18, 2008
- The TCW Group, Inc., November 7, 2008
- BlackRock Advisers LLC and Affiliates, November 4, 2008
- Mount Vernon Securities Lending Trust, October 24, 2008
- Russell Investment Company, October 24, 2008
- Columbia Funds Series Trust, October 22, 2008
- ING Funds Trust, ING Investors Trust, and ING Series Fund, Inc., October 22, 2008
- iShares Trust, et al., October 22, 2008
- J.P. Morgan Securities Inc., October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- MainStay VP Cash Management Portfolio, October 22, 2008
- Morgan Stanley Institutional Liquidity Funds, October 22, 2008
- Morgan Stanley Money Market Funds, October 22, 2008
- Mount Vernon Securities Lending Trust, October 22, 2008
- Northwestern Mutual Series Fund, Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Phoenix Opportunities Trust, October 22, 2008
- Principal Funds, Inc. and Principal Variable Contracts Funds, Inc., October 22, 2008
- RidgeWorth Funds, October 22, 2008
- Tamarack Funds Trust, October 22, 2008
- Touchstone Variable Series Trust, October 22, 2008
- USAA Mutual Funds Trust, October 22, 2008
- Advantus Series Fund, October 20, 2008
- Dreyfus Cash Management Plus, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., October 20, 2008
- Russell Investment Company, October 20, 2008
- Sun Capital Advisers Trust, October 20, 2008
- Investment Company Institute, October 10, 2008
- Investment Company Institute, October 8, 2008
- Highbridge Statistical Market Neutral Fund, September 29, 2008
- Dreyfus Cash Management, et al., September 25, 2008
- Investment Company Institute, September 25, 2008
- Auction Rate Securities — Global Exemptive Relief, September 22, 2008
- Barclays Capital Inc., September 19, 2008
- Prudential Financial, Inc., September 5, 2008
- Goldman Sachs Trust, August 19, 2008
- Missouri Bankers Association, August 18, 2008
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 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
- Munder Series Trust, June 23, 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
- Letter to the Investment Company Institute Regarding Valuation Issues, April 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
- Comdisco, Inc., October 25, 2000
- Willkie Farr & Gallagher, October 23, 2000
- Janus Adviser Series, August 28, 2000
- Mackenzie Investment Managment et al., August 8, 2000
- Jennison Associates LLC, July 6, 2000
- Select Sector SPDR Fund and Diamonds Trust, July 6, 2000
- Massachusetts Mutual Life, June 7, 2000
- Brown & Wood, February 24, 2000
- General Motors Investment Management, February 20, 2000
- R.O.C. Taiwan Fund, February 11, 2000
- Pengrowth Energy Trust, January 27, 2000
- Signature Financial Group, Inc., December 28, 1999
- Investment Company Institute, December 8, 1999
- Metropolitan Life Insurance Company, November 13, 1999
- HOLDRs, September 3, 1999
- BISYS Fund Services, Inc., September 2, 1999
- The First Australia Fund, Inc., July 29, 1999
- Salomon Brothers Asset Management Inc and Salomon Brothers Asset Management Asia Pacific Limited, July 23, 1999
- Investment Company Institute, June 15, 1999
- ING Bank N.V., et al., May 24, 1999
- Frankin Templeton Group of Funds, et al., May 21, 1999
- Select Sector SPDR Trust, May 6, 1999
- American Bar Association, April 22, 1999
- Defined Asset Funds, December 23, 1998
- Drinker, Biddle & Reath, December 18, 1998
- Franklin Management, Inc., December 10, 1998
- SSGA International Liquidity Fund, December 2, 1998
- Mutual of Omaha Insurance Company, November 27, 1998
- New Center Asset Trust, November 5, 1998
- Investment Company Institute, October 30, 1998
- MassMutual Institutional Funds, Inc., October 19, 1998
- Service Corporation International, October 6, 1998
- Goodwin, Procter & Hoar, October 5, 1998
- Wilmer, Cutler & Pickering and Davis Polk & Wardell, October 5, 1998
- Credit Suisse First Boston, September 9, 1998
- Massachusetts Mutual Life Insurance Company, August 10, 1998
- ICI Mutual Insurance Company, July 27, 1998
- Plymouth Commercial Mortgage Fund, July 13, 1998
- Nuveen Flagship Multistate Trust I, July 10, 1998
- Chase Manhattan Bank, June 12, 1998
- One Point Communications Corp, June 12, 1998
- Royal Bank of Canada, et al., June 3, 1998
- Lamp Technologies, Inc., May 29, 1998
- New England Education Loan Marketing Corp, May 22, 1998
- Safra Republic Holdings, April 21, 1998
- Investment Company Institute, April 15, 1998
- Moscow Municipal Bank, April 8, 1998
- Daughters of Charity National Health System, Inc., April 3, 1998
- Nebraska Higher Education Loan Program, April 3, 1998
- Wells Fargo Bank, N.A., March 31, 1998
- DALBAR, Inc., March 24, 1998
- Public Employees' Retirement Board of the State of Oregon, March 3, 1998
- Neuberger & Berman Income Funds, February 27, 1998
- Investment Company Institute and the Global Custodians, February 19, 1998
- Reserve Bank of Australia, January 30, 1998
- Societatea Nationala de Compensare, January 28, 1998
- Stock Holding Corporation of Indian Ltd., January 21, 1998
- Sullivan and Cromwell, December 29, 1997
- American Century Companies, Inc. / J.P. Morgan & Co., December 23, 1997
- Depository Clearing Company, December 19, 1997
- Brinson Funds, et al., November 25, 1997
- K. K. Rajendran, November 21, 1997
- Chief Financial Officer, November 7, 1997
- Mike Krichew, November 5, 1997
- BSC Employee Fund, L.P., October 14, 1997
- Redwood Investment Fund, LLC, October 14, 1997
- Investment Company Institute, October 3, 1997
- Five Arrows Short-Term Investment Trust, September 26, 1997
- Bear, Stearns & Co. Inc., September 16, 1997
- Bradley A. Veld, August 15, 1997
- LNC Equity Sales Corporation, August 8, 1997
- INVESCO Funds Group, Inc., August 5, 1997
- The Eaton Vance Group of Investment Companies, July 25, 1997
- Franklin Templeton Group of Funds, July 23, 1997
- MLC Limited, July 21, 1997
- American International Group, Inc., July 18, 1997
- Macedonian Stock Exchange, July 10, 1997
- AmSouth Mutual Funds, July 8, 1997
- Charles Schwab & Co., Inc., July 7, 1997
- ABN AMRO Bank N.V., July 1, 1997
- PNC Bank N.A., June 10, 1997
- First Financial Fund, Inc., at al., June 5, 1997
- Bucharest Stock Exchange, June 3, 1997
- Lamp Technologies, Inc., May 29, 1997
- Russia Growth Fund, Inc., May 20, 1997
- John Bowen Investment Management, May 13, 1997
- Puerto Rico Balanced Fund, Inc., April 29, 1997
- Merrill Lynch Asset Management, April 28, 1997
- Alliance Funds, April 25, 1997
- Davis, Polk & Wardwell, April 24, 1997
- Dessauer Global Equity Fund, April 3, 1997
- Eaton Vance South Asia Portfolio, March 12, 1997
- Goodwin, Procter & Hoar, February 28, 1997
- I.C.H. Corporation, February 26, 1997
- National Securities Depository Ltd., February 25, 1997
- KDSM, Inc. and Sinclair Capital, February 21, 1997
- Indosuez Asset Management Asia Limited, February 14, 1997
- GE Funds, February 7, 1997
- ITT Hartford Mutual Funds, February 7, 1997
- Nicholas-Applegate Mutual Funds, February 7, 1997
- Dr. William Greene, Stern School of Business, February 3, 1997
- Lazard Freres Asset Management, January 10, 1997
- Association for Investment Management and Research, December 18, 1996
- Equitable Life Assurance Society, December 18, 1996
- Eaton Vance Master Portfolio, December 11, 1996
- Plymouth Commercial Mortgage Fund, December 3, 1996
- Australian Securities Commission, October 23, 1996
- American Odyssey Funds, Inc., October 7, 1996
- Dean Witter World Wide Investment Trust, September 17, 1996
- Horizon Asset Management, LLC, September 13, 1996
- Morgan Grenfell Investment Trust, September 13, 1996
- Templeton Vietnam Opportunities Fund, Inc., September 6, 1996
- ASX Settlement & Transfer Corporation, August 13, 1996
- Sacha Stawski, August 9, 1996
- Bramwell Growth Fund, August 7, 1996
- Nicholas-Applegate Mutual Funds, August 6, 1996
- Interbolsa, August 5, 1996
- PerfectData Corporation, August 5, 1996
- State Street Bank & Trust, August 1, 1996
- Investment Company Institute, July 29, 1996
- Hewlett-Packard Finance Company, July 17, 1996
- Managed Futures Association, July 11, 1996
- Mr. Frank Mason, July 3, 1996
- Wilkie Farr & Gallagher, June 11, 1996
- John Hancock Fund, Inc., June 25, 1996
- Real Goods Trading Corporation, June 24, 1996
- Dreyfus Asset Allocation Fund, Inc., June 14, 1996
- American Mutual Life Insurance, June 13, 1996
- National Association for Variable Annuities, June 4, 1996
- World Financial Network National Bank, May 28, 1996
- Gary E. Hughes, American Council of Life Insurance, May 26, 1996
- National Securities Clearing Corp., May 24, 1996
- Bancafe/Juan Vico, May 22, 1996
- Metropolitan Life Insurance Company,
New England Mutual Life Insurance Company, and New England Variable Life Insurance Company, May 17, 1996
- Munder Capital Management, May 17, 1996
- Investment Company Institute, May 9, 1996
- Blanchard Global Growth Fund, May 7, 1996
- J.P. Morgan Investment Management, Inc., May 7, 1996
- Russell H. Smith, May 2, 1996
- TIAA Real Estate Account, May 1, 1996
- Financial Services Board, April 24, 1996
- Rowe Price-Fleming International Inc., April 12, 1996
- Kavilco, Inc., April 4, 1996
- RDM Infodustries, Inc., March 25, 1996
- DFA Investment Trust, March 21, 1996
- Cornish & Carey Commercial Inc., February 26, 1996
- U.S. Department of Labor, February 22, 1996
- Investment Company Registrant General Letter, February 15, 1996
- Massachusetts Mutual Life, February 15, 1996
- Lazard Freres Asset Management, February 12, 1996
- Investment Funds Institute of Canada, February 6, 1996
- G.T. Global Growth Series et al., February 2, 1996
- Total, January 26, 1996
- The Equitable Life Assurance Society of the United States, December 22, 1995
- Maxine Harry, December 6, 1995
- Principle Preservation Portfolios, Inc., December 6, 1995
- Department of Labor, December 5, 1995
- Pretzel & Stouffer, December 1, 1995
- Morgan Guaranty Trust Company of New York, November 17, 1995
- InTouch Global, LLC, November 14, 1995
- The Riverfront Funds,
Inc., November 8, 1995
- Mutual Series Fund Inc., November 7, 1995
- Accounting Comment Letter, November 2, 1995
- Colonial Trust I et al., October 20, 1995
- David Parkinson, October 19, 1995
- DFA Investment Trust Company, October 17, 1995
- Missouri Innovation Center, Inc., October 17, 1995
- MassMutual Institutional Funds, September 28, 1995
- Queensland Treasury Corporation, September 26, 1995
- Thomson Advisory Group L.P., September 26, 1995
- First Call Corporation, September 6, 1995
- SMC Capital, Inc., September 5, 1995
- Mark A. Bush, August 8, 1995
- Norwest Funds — Municipal Money Market Fund, August 8, 1995
- Alfred A. Zurl, August 7, 1995
- Fiduciary Trust Global Fund, August 2, 1995
- The T. Rowe Price Funds, July 31, 1995
- George Colman, July 18, 1995
- Gilbert G. Beezley, July 17, 1995
- ACM Institutional Reserves, Inc., July 14, 1995
- Alliance Municipal Trust, July 14, 1995
- Hongkong Securities Clearing Company Limited, July 13, 1995
- Municipal Fund for California Investors, Inc., July 12, 1995
- California Municipal Cash Trust, July 11, 1995
- Venture Search Technology Inc., July 11, 1995
- Lehman Brothers Daily Income Fund, July 7, 1995
- Twentieth Century Mutual Funds, July 7, 1995
- Wells Fargo Money Market Funds, July 7, 1995
- Benham California Tax-Free and Municipal Funds, June 30, 1995
- Kemper Money Market Funds, June 23, 1995
- American Council of Life Insurance, June 20, 1995
- Benson White & Company, June 14, 1995
- James R. Waters, June 1, 1995
- Investment Company Institute, May 26, 1995
- The One Group, May 23, 1995
- Unit Investment Trust Organizational Expenses, May 9, 1995
- Goldman Sachs & Co., April 27, 1995
- Metropolitan Life Insurance Company, April 26, 1995
- Salomon Brothers Inc., April 25, 1995
- The Victory Funds and The Victory Portfolios, April 24, 1995
- Templeton Russia
Fund, Inc., April 18, 1995
- State Street Bank & Trust Company, February 28, 1995
- Philadelphia Ventures Liberty Fund, L.P., February 14, 1995
- M.S.B. Fund, Inc., February 10, 1995
- Victory Stock Index Fund, February 7, 1995
- Kemper Total Return Fund, February 6, 1995
- Chief Financial Officer of Investment Company Registrants, February 3, 1995
- Letter to Investment Company Registrants, February 3, 1995
- ESI S.A., February 2, 1995
- PaineWebber Incorporated, January 27, 1995
- United Municipal Bond Fund, January 27, 1995
- The Royce Fund, January 24, 1995
- United Missouri Bank of Kansas City, January 23, 1995
- Global Exempt Certificates of Ownership in NHA MBS Securities Inc., December 30, 1994
- Caxton Corporation, December 28, 1994
- Latham & Watkins, December 28, 1994
- Shoreline Fund, L.P., November 14, 1994
- Transamerica Series, Inc., November 7, 1994
- Chief Financial Officer, November 1, 1994
- Linsco/Private Ledger Corp., November 1, 1994
- Wm. S. Barnickel & Company, November 1, 1994
- Letter to Investment Advisers, October 25, 1994
- Warsaw Stock Exchange, October 20, 1994
- Philadelphia Stock
Exchange, Inc., October 18, 1994
- Dana Investment Advisors, Inc., October 12, 1994
- Mutual Funds and Derivative Instruments, September 26, 1994
- Townsend and Associates, Inc., September 21, 1994
- Pershing Division of Donaldson, Lufkin & Jenrette Securities Corp., September 15, 1994
- Glenwood Investment Corp., August 10, 1994
- W.R. Huff Asset Management Co., L.P., August 10, 1994
- Integrated Resources, Inc., August 5, 1994
- PaineWebber Managed Investments Trust, August 4, 1994
- The Canadian Depository for Securities Limited, August 4, 1994
- First Coastal Corporation, July 28, 1994
- Stephen R. Kelly, July 28, 1994
- J.P. Morgan Structured
Obligations Corporation, July 27, 1994
- Murray Johnstone Holdings Limited; Murray Johnstone Limited; Murray Johnstone International Limited, July 21, 1994
- Adam W. Glass, July 20, 1994
- Arthur Andersen & Co., July 8, 1994
- Edward H. Fleischman, June 30, 1994
- Owens-Illinois, Inc., June 24, 1994
- Louis Russo, June 16, 1994
- CBA Money Fund, et al., June 9, 1994
- Donaldson, Lufkin & Jenrette Securities Corporation, May 26, 1994
- Kake Tribal Corporation, May 25, 1994
- R. Bryan Stoker, May 13, 1994
- Sean J. Egan, May 10, 1994
- Century Shares Trust, May 4, 1994
- PanAgora Group Trust, April 29, 1994
- Long-Term Capital Management, L.P., April 28, 1994
- Municipality Finance Ltd., April 28, 1994
- Federated Investors, April 21, 1994
- ASX Settlement and Transfer Corporation, April 19, 1994
- Shoreline Fund, L.P., April 11, 1994
- Andrews & Kurth L.L.P., April 5, 1994
- Scudder Investment Trust, March 23, 1994
- MPC Liquidating Trust, March 10, 1994
- Lehman Brothers Inc., March 8, 1994
- Summit Advisors, Inc., March 1, 1994
- ICI Mutual Insurance Company, February 28, 1994
- The Capitol Mutual Funds and Nations Fund Trust, February 24, 1994
- Brown & Wood, February 24, 1994
- Gerald Zuckerman, February 1, 1994
- David S. Butterworth, January 27, 1994
- Travelers Insurance Company et al., September 3, 1993
- The South America Fund N.V., September 2, 1993
- Japan Securities Depository Center, August 31, 1993
- Frank Russell Investment Management Company, August 30, 1993
- Alameda Contra Costa Medical Association Collective Investment Trust for Retirement Plans, August 26, 1993
- Stock Exchange of
Thailand, August 26, 1993
- New America High Income Fund, Inc., July 29, 1993
- College Retirement Equities Fund Real Estate Account, July 22, 1993
- PaineWebber Equity Trusts, July 19, 1993
- Welsh, Carson, Anderson & Stowe, June 18, 1993
- Mutual of America Life Insurance Company, June 17, 1993
- T. Rowe Price Tax-Free Funds, June 24, 1993
- Investment Company Institute, June 16, 1993
- Investment Company Institute, June 15, 1993
- Shearson Lehman Brothers Inc. and Smith Barney, Harris Upham & Co. Incorporated, June 8, 1993
- Keene Corporation, June 2, 1993
- Reserve Bank of New Zealand, May 24, 1993
- Malaysian Central
Depository Sdn. Bhd., May 19, 1993
- Sedgwick Consulting Group, May 17, 1993
- Kidder Peabody Investment Trust, May 14, 1993
- Korea Securities Depository Corporation, May 14, 1993
- Washington Mutual Investors Fund, Inc., May 14, 1993
- Defined Asset Funds — Equity Income Fund — Select Ten Series, May 5, 1993
- Custody of B Shares Trading on the Shenzhen and Shanghai Securities Exchanges, April 26, 1993
- United Services Funds, April 23, 1993
- Mercury Asset Management plc, April 16, 1993
- Alliance Capital Management L.P., April 7, 1993
- Austraclear Limited, April 6, 1993
- PNC Fund, et al., April 2, 1993
- Richard L. Mertz, April 1, 1993
- Oppenheimer Landmrk Properties, March 9, 1993
- Celina Financial Corporation, February 19, 1993
- Dean Witter, Discover & Co., February 8, 1993
- North American Security Trust and NASL Series Trust, February 2, 1993
- Thomson Fund Group, et al., January 28, 1993
- County of Los Angeles, January 27, 1993
- Pasadena Investment Trust, January 22, 1993
- Robertson, Stephens & Company, January 12, 1993
- Calvert Group, January 7, 1993
- Michael Tannenbaum, January 5, 1993
- Investment Company Institute, November 2, 1992
- Missouri Family Trust Fund, September 22, 1992
- Founders Funds, Inc., August 4, 1992
- Uniao de Bancos de Brasileiros S.A., July 28, 1992
- Morgan Keegan & Company, Inc., July 24, 1992
- Wall Street Preferred Money Managers, Inc., April 10, 1992
- University of Alaska Advance College Tuition Payment, March 2, 1992
- Bear, Stearns & Co. Inc., January 28, 1992
- Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, November 8, 1989
- Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, January 24, 1989
- Richard Ellis, Inc., March 19, 1981
- Continental
of Illinois (Delaware), Ltd., March 14, 1973
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