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Division of Investment Management
Staff No-Action and Interpretive Letters
Important Note: This page contains Division of Investment Management no-action letters dated on or after January 1, 2001. Division of Investment Management no-action letters issued before that date may be obtained for a copy and processing fee. Please refer to information on How to Request Public Documents.
 Subject Categories
Subject Category List of No-Action Letters
Alphabetical List of No-Action Letters
Chronological List of No-Action Letters
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Subject Category List of No-Action Letters
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12b-1 Fees
12b-1 Plans
Acquisition of Securities in Affiliated Underwriting
Advertising — Investment Advisers
- 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
Advertising — Investment Company
Advisory Contracts
- First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008
- Mellon Equity Associates, LLP April 1, 2005
- Eaton Vance Special Investment Trust, et al March 30, 2004
- Gartmore Mutual Funds, March 19, 2004
- PIMCO Funds: Multi-Manager Series, August 6, 2002
Advisory Representatives
Advisory Fees
Affiliated Transactions
- 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
- Mount Vernon Securities Lending Trust, October 24, 2008
- Russell Investment Company, October 24, 2008
- Columbia Funds Series Trust, October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- Legg Mason Partners Institutional Trust, 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
- Penn Series Funds Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Phoenix Opportunities Trust, October 22, 2008
- RidgeWorth Funds, October 22, 2008
- Touchstone Variable Series 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
- Russell Investment Company, October 20, 2008
- Investment Company Institute, September 25, 2008
- Northern Institutional Fund, July 16, 2008
- T. Rowe Price Associates, Inc., July 10, 2008
- Western Asset Money Market
Fund, June 27, 2008
- Western Asset Institutional Money Market
Fund, June 27, 2008
- 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
- ING Series Fund, Inc., et al., April 30, 2008
- Master Portfolio Trust, April 18, 2008
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Master Portfolio Trust, April 4, 2008
- SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008
- Northern Institutional Funds, February 28, 2008
- Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008
- HSBC Investor Funds, January 18, 2008
- STI Classic Funds, January 2, 2008
- TDAM Money Market Portfolio, December 21, 2007
- First American Funds, Inc. – Prime Obligation Fund, December 3, 2007
- SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007
- Old Mutual Advisors Funds, November 16, 2007
- SEI Daily Income Trust — Money Market Fund, November 9, 2007
- SEI Daily Income Trust — Prime Obligation Fund, November 8, 2007
- STI Classic Funds, October 26, 2007
- Van Kampen Funds Inc., January 31, 2007
- Gartmore Variable Insurance Trust, December 29, 2006
- GuideStone Financial, et al., December 27, 2006
- Federated Municipal Funds, November 20, 2006
- Merrill Lynch & Co., Inc., September 27, 2006
- Citigroup Global Markets, Inc., September 26, 2006
- Mutual of America Investment Corporation, June 2, 2006
- GE Institutional Funds, December 21, 2005
- Investment Company Institute, December 14, 2005
- Wells Fargo Alternative Asset Management, LLC, January 26, 2005
- Neuberger Berman Management Inc., et al., April 30, 2003
- AAL Mutual Funds, et al., December 12, 2002
- AIM Advisors, Inc., February 12, 2002
- Calvert Social Index Fund, September 4, 2001
- Evergreen Investment Management Company, LLC, February 13, 2002
- Longleaf Partners Funds Trust, April 9, 2001
Aggregated Transactions
Annual Reports
Assignments
Auction Rate Notes
Backward Pricing
Banks
Beneficial Ownership Qualified Purchaser
Business and Industrial Development Companies
Business Transfers
Cash Solicitation
- Prudential Financial, Inc., September 5, 2008
- Mayer Brown LLP, July 28, 2008
- Barclays Bank PLC, June 6, 2007
- Emanuel J. Friedman and EJF Capital LLC, January 16, 2007
- Ameriprise Financial Services Inc., April 5, 2006
- Millennium Partners, L.P., et al, March 9, 2006
- American International Group, Inc., February 21, 2006
- ING Bank N.V., August 31, 2005
- CIBC Mellon Trust Company, February 24, 2005
- Goldman, Sachs & Co., February 23, 2005
- Morgan Stanley & Co., Inc., February 4, 2005
- American International Group, Inc., December 8, 2004
- Deutsche Bank Securities Inc., September 24, 2004
- Thomas Weisel Partners LLC, September 24, 2004
- J.P. Morgan Securities Inc., October 31, 2003
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- Goldman, Sachs & Company, October 31, 2003
- Lehman Brothers, October 31, 2003
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Bear, Stearns & Co. Inc., October 31, 2003
- Morgan Stanley & Company, October 31, 2003
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- James DeYoung, October 24, 2003
- J.P. Morgan Securities Inc., October 8, 2003
- Dougherty & Company LCC, July 3, 2003
- Fahnestock & Company Inc., April 21, 2003
- Dougherty & Company LLC, March 21, 2003
- Legg Mason Wood Walker, Inc., June 11, 2001
- National Football League Players Association, January 25, 2002
- Prudential Securities Inc., February 7, 2001
- Stephens Inc., December 27, 2001
Change of Control
Charitable Exclusions
Closed-End Investment Companies
Code of Ethics
Collective Investment Trusts
Commerical Paper
Compliance Policies and Procedures Rule
Consolidation
Custody - Investment Advisers
Custody - Investment Companies
Definitions
Director
Disclosure
Distributions
Distribution Fees
Distribution Plans
Employee Benefit Plans
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Lear Corporation Retirement Savings Plan Trusts, March 16, 2007
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003
- Honeywell International Inc Savings Plan Trust, October 7, 2002
ETFs
Exchange Offer
Exemptive Applications and Orders
Face-Amount Certificate
Fees & Expenses
Fiduciary Duties
Finance Subsidiaries
Foreign Banks
Fraud
Fraud - Investment Advisers Act
Funds of Funds - Affiliated
- 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
Funds of Funds - Foreign Investment Companies
- ASA (Bermuda) Limited, December 13, 2006
- Alternative Investment Partners Absolute Return Fund STS, July 10, 2006
- France Growth Fund, Inc., July 15, 2003
- Man-Glenwood Lexington TEI, LLC and Man-Glenwood Lexington TEI, LDC, April 30, 2004
Government Instrumentalities
Government Securities
Hedge Clauses
Hedge Funds
- The Townsend Group, Inc., July 9, 2008
- ABA Subcommittee on Private Investment Entities, August 10, 2006
- ABA Subcommittee on Private Investment Entities, December 8, 2005
- The Goldman Sachs Group, Inc., March 8, 2005
Hub and Spoke Funds
Inadvertent Investment Companies
Independent Directors
Independent Legal Counsel
Inspections — Investment Advisers
Insurance Products
- IDS Life Insurance Company, et al., December 14, 2006
- American Home Assurance Company, et al., October 17, 2005
- GE Life and Annuity Assurance Company, June 25, 2004
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Acacia National Life Insurance Company, December 19, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- AIG Life Insurance Company, August 16, 2001
- Manufacturers Life Insurance Company, The, December 27, 2001
- National Association for Variable Annunities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001
- Nationwide Life Insurance Company, March 16, 2001
Interested Person
Internet
Investment Advisers
Investment Advisers Act Status
- Credit Agricole Asset Management Alternative Investments, Inc., August 7, 2006
- Morgan, Lewis & Bockius LLP, November 17, 2005
- UBS Financial Services, Inc., September 29, 2005
- Ark Therapeutics Group plc, April 15, 2005
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- The Goldman Sachs Group, Inc., March 8, 2005
- Gulf Coast Venture Forum, Inc., August 21, 2002
- Thomson Financial Inc., July 10, 2002
Investment Company
Investment Company Act Status
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Dexia Municipal Agency, December 26, 2007
- Exelon Corporation, September 13, 2007
- Cooley Godward & Kronish, July 12, 2007
- MACRO Securities Depositor, LLC, December 1, 2006
- Willkie Farr & Gallagher, October 23, 2000
- Pengrowth Energy Trust, January 27, 2000
Investment Securities
Joint Transactions
Mergers and Reorganizations Combinations
- Janus Aspen Series, April 10, 2008
- CUNA Mutual Life Insurance Company, et al., December 27, 2007
- Ameritas Life Insurance Corp., April 5, 2007
- Mutual of America Investment Corporation, June 2, 2006
- GE Life and Annuity Assurance Company, June 25, 2004
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Acacia National Life Insurance Company, December 19, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
Money Market Funds
- 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
- Morgan Stanley Money Market Funds, October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Columbia Funds Series Trust, 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
- Mount Vernon Securities Lending Trust, October 22, 2008
- Phoenix Opportunities Trust, October 22, 2008
- RidgeWorth Funds, October 22, 2008
- Touchstone Variable Series 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
- Russell Investment Company, October 20, 2008
- Investment Company Institute, October 10, 2008
- Investment Company Institute, October 8, 2008
- Investment Company Institute, September 25, 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
Money Market Liquidity
Periodic Payment Plan Certificate
Performance Fees
- Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004
- Pacific Select Fund, et al., December 23, 2004
- Seligman New Technologies Fund II, Inc., February 7, 2002
Personal Securities Transaction
Pre-Paid Tuition Plans
Principal Transaction
Principal Underwriters
Prospectuses — Delivery
Prospectuses — Disclosure
Proxy Voting
Public Offering
Public Utility Holding Companies
- Section 2(a)(3)
- Bonneville Power Administration, February 10, 2004
- RealEnergy, Inc., et al., August 12, 2003
- Dominion Equipment II, Inc., et al., March 25, 2003
- Juniper Capital L.P., June 23, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- Sections 2(a)(3) and 2(a)(7)
- EIF Neptune, LLC Starwood Energy Investors, LLC & Atlantic Energy Parts, July 29, 2005
- DTE Heritage, LLC, et. al., July 30, 2003
- Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003
- Sections 2(a)(7)
- Sections 2(a)(7) and 2(a)(11)(A)
- Section 17(c) and Rule 70
Qualified Purchase Definition - Investment Company Act Status Determination
- Cabot Wellington, LLC, June 17, 2008
- McDermott, Will & Emery, July 26, 2007
- Goldman Sachs Asset Management, L.P., March 13, 2007
- SCP Private Equity Partners II, L.P., June 6, 2006
Qualified Purchaser Fund
Real Estate
Recordkeeping Requirements — Investment Advisers
Redeemable Securities
Redemption Fees
Redemptions
Registration
- IDS Life Insurance Company, et al., December 14, 2006
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- Thomson Financial Inc., July 10, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
Registration — Investment Advisers
Registration — Investment Companies
- Exelon Corporation, September 13, 2007
- MACRO Securities Depositor, LLC, December 1, 2006
- Shee Atika Investments, LLC, January 20, 2004
- First Data Corporation, January 13, 2004
- Mercy Investment Program, Inc., June 12, 2003
- Metropolitan Insurance and Annuity Company, June 6, 2003
- Brown & Wood, February 24, 2000
Regulation S-P
Reimbursement of Proxy Expenses
Reorganization
Reporting Requirements — Investment Advisers
Reporting Requirements — Investment Companies
- NGP Capital Resources Company (Corrected), December 28, 2007
- American Home Assurance Company, et. al., October 17, 2005
- College and University Facility Loan Trust One, et al., November 29, 2004
- Westford Technology Ventures, L.P., January 28, 2004
- Equus Capital Partners L.P., November 14, 2003
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- Manufacturers Adviser Corp, September 10, 2002
Safe Harbors
Sales of Fund Shares below NAV
Securities — Definition
Securities Lending
Self Custody - Investment Companies
Senior Securities
Separate Accounts
- First Great-West Life & Annuity Insurance Company & Canada Life Insurance Company of New York, December 22, 2005
- GE Life and Annuity Assurance Company, June 25, 2004
- Acacia National Life Insurance Company, December 19, 2003
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- AIG Life Insurance Company, August 16, 2001
Shareholder Proposals
- College Retirement Equities Fund, May 19, 2008
- Fidelity Funds, January 22, 2008
- Franklin Universal Trust, December 18, 2007
- Alliance World Dollar Government Fund, Inc., October 19, 2006
- Putnam Premier Income Trust, March 14, 2006
- Putnam High Income Securities Fund, March 14, 2006
- Putnam Tax-Free Health Care Fund, August 8, 2005
- Fidelity Magellan Fund, March 15, 2005
- Medallion Financial Corp., May 11, 2004
- Tri-Continental Corporation, March 15, 2004
- Robert P. Laukat Regarding Tri-Continental Corporation , March 15, 2004
- The New Ireland Fund, Inc., March 15, 2004
- College Retirement Equities Fund - Stone, May 3, 2004
- College Retirement Equities Fund - Belth, May 3, 2004
- College Retirement Equities Fund - Fuller, May 3, 2004
- College Retirement Equities Fund - Buchman, May 3, 2004
- Tri-Continental Corporation, March 25, 2003
- MuniYield Insured Fund, Inc., March 11, 2002
- Asia Tiger Fund, Inc., The, January 31, 2002
- Pioneer Interest Shares, June 20, 2001
- Asia Pacific Fund, Inc (The), June 8, 2001
- Asia Tiger Fund, Inc., The, December 28, 2001
- Current Income Shares, Inc., July 10, 2001
- Fidelity Advisor Korea Fund, Inc, March 7, 2001
- France Growth Fund, Inc, April 6, 2001
- France Growth Fund, Inc.; Advantage Partners LP, April 6, 2001
- France Growth Fund, Inc.; Strome Hedgecap Fund, April 6, 2001
- Lincoln National Convertible Securities Fund, Inc. - Walter S. Baer, September 28, 2001
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
Shareholders Votes
Short Sales
Solicitors
Subsidiaries
Successor registration
Tender Offers
Tracking Stock
Voting Security
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Alphabetical List of No-Action Letters
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- AAL Mutual Funds, et al., December 12, 2002
- ABA Subcommittee on Private Investment Entities, August 10, 2006
- ABA Subcommittee on Private Investment Entities, December 8, 2005
- Aberdeen Australia Equity Fund, Inc., July 13, 2006
- Acacia National Life Insurance Company, December 19, 2003
- 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
- Alliance World Dollar Government Fund, Inc., October 19, 2006
- Allianz Dresdner Daily Asset Fund, May 5, 2008
- Allstate Life Insurance Company, December 23, 2002
- Alternative Investment Partners Absolute Return Fund STS, July 10, 2006
- American Bible Society, June 1, 2004
- American Enterprise Life Insurance Company, April 30, 2002
- Ameritas Life Insurance Corp., April 5, 2007
- Arizona Electric Power Cooperative Inc., July 27, 2001
- American Home Assurance Company, et. al., October 17, 2005
- American International Group, Inc., February 21, 2006
- American International Group, Inc., December 8, 2004
- American Skandia Life Assurance Corporation, May 16, 2005
- Ameriprise Financial Services Inc., April 5, 2006
- Ark Therapeutics Group plc, April 15, 2005
- ASA (Bermuda) Limited, December 13, 2006
- Asia Pacific Fund, Inc (The), June 8, 2001
- Asia Pacific Fund, Inc (The) - Thomas A. Kornfeld, June 8, 2001
- Asia Tiger Fund, Inc., The, December 28, 2001
- Asia Tiger Fund, Inc., The, January 31, 2002
- Austraclear Limited, April 28, 2004
- Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002
- Barclays Capital Inc., September 19, 2008
- Bear, Stearns & Co. Inc., October 31, 2003
- BNY Mellon Funds Trust, December 2, 2008
- Bonneville Power Administration, February 10, 2004
- Brown & Wood, February 24, 2000
- Cabot Wellington, LLC, June 17, 2008
- Calvert Social Index Fund, September 24, 2001
- Cantor Fitzgerald & Company, February 17, 2004
- Capital Trust, Inc., May 24, 2007
- The Chase Manhattan Bank, July 24, 2001
- CIBC Mellon Trust Company, February 24, 2005
- Citigroup Global Markets, Inc., September 26, 2006
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- Citigroup Inc., July 26, 2006
- College and University Facility Loan Trust One, et al., November 29, 2004
- College Retirement Equities Fund, May 19, 2008
- College Retirement Equities Fund - Stone, May 3, 2004
- College Retirement Equities Fund - Belth, May 3, 2004
- College Retirement Equities Fund - Fuller, May 3, 2004
- College Retirement Equities Fund - Buchman, May 3, 2004
- Columbia Funds Series Trust, October 22, 2008
- Comdisco, Inc., October 25, 2000
- Constellation Financial Management LLC, January 9, 2003
- Cooley Godward & Kronish, July 12, 2007
- Credit Agricole Asset Management Alternative Investments, Inc., August 7, 2006
- Credit Suisse First Boston, LLC, August 31, 2005
- Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003
- CUNA Mutual Life Insurance Company, et al., December 27, 2007
Current Income Shares, Inc., July 10, 2001
- Deloitte & Touche LLP, August 28, 2006
- Deutsche Bank Securities Inc., September 24, 2004
- Dexia Municipal Agency, December 26, 2007
- Dominion Equipment II, Inc., et al., March 25, 2003
- Dougherty & Company LCC, July 3, 2003
- Dougherty & Company LLC, March 21, 2003
- Dreyfus Cash Management Plus, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- DTE Heritage, LLC, et. al., July 30, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- Eaton Vance Management, June 13, 2008
- Eaton Vance Special Investment Trust, et al March 30, 2004
- Egan-Jones Proxy Services, May 27, 2004
- EIF Neptune, LLC Starwood Energy Investors, LLC & Atlantic Energy Parts, July 29, 2005
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- Enron Corporation, March 11, 2004
- Equus Capital Partners L.P., November 14, 2003
- E*TRADE Securities, LLC, November 30, 2005
- Evercore METC Investment Inc., et. al., November 25, 2003
- Evergreen Investment Management Company LLC, October 11, 2005
- Evergreen Investment Management Company, LLC, February 13, 2002
- Exelon Corporation, September 13, 2007
- Fahnestock & Company Inc., April 21, 2003
- Federal Home Loan Mortgage Corporation, July 12, 2002
- Federal National Mortgage Association, July 12, 2002
- Federated Core Trust II, L.P., February 6, 2002
- Federated Municipal Funds, November 20, 2006
- Fidelity Select Portfolio, April 29, 2008
- Fidelity Advisor Korea Fund, Inc, March 7, 2001
- Fidelity Funds, January 22, 2008
- Fidelity Magellan Fund, March 15, 2005
- First American Funds, Inc. – Prime Obligation Fund, December 3, 2007
- First Data Corporation, January 13, 2004
- First Great-West Life & Annuity Insurance Company & Canada Life Insurance Company of New York, December 22, 2005
- First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008
- Fixed Income Clearing Corporation, March 13, 2003
- Fixed Income Securities, L.P., April 29, 2004
- France Growth Fund, Inc., April 6, 2001
- France Growth Fund, Inc., July 15, 2003
- France Growth Fund, Inc.; Advantage Partners LP, April 6, 2001
- France Growth Fund, Inc.; Strome Hedgecap Fund, April 6, 2001
- Frank Russell Investment Company, et al., October 18, 2002
- Franklin Templeton Investments, November 21, 2008
- Franklin Universal Trust, December 18, 2007
- Emanuel J. Friedman and EJF Capital LLC, January 16, 2007
- Gardner Russo & Gardner, June 7, 2006
- Gartmore Mutual Funds, March 19, 2004
- Gartmore Variable Insurance Trust, December 29, 2006
- GE Institutional Funds, December 21, 2005
- GE Life and Annuity Assurance Company, June 25, 2004
- General Electric Capital Corporation, April 26, 2002
- General Motors Investment Management, February 20, 2000
- Goldman, Sachs & Co., February 23, 2005
- Goldman, Sachs & Company, October 31, 2003
- Goldman Sachs Asset Management, L.P., March 13, 2007
- The Goldman Sachs Group, Inc., March 8, 2005
- Goldman Sachs Trust, August 19, 2008
- Government Securities Clearing Corporation, October 19, 2001
- GuideStone Financial, et al., December 27, 2006
- Gulf Coast Venture Forum, Inc., August 21, 2002
- H.E.B. Investment and Retirement Plan (H.E. Butt Grocery Company), May 18, 2001
- Heitman Capital Management, LLC, February 12, 2007
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Honeywell International Inc Savings Plan Trust, October 7, 2002
- HSBC Investor Funds, June 25, 2008
- HSBC Investor Funds, January 18, 2008
- IDS Life Insurance Company, et al., December 14, 2006
- ING Bank N.V., August 31, 2005
- ING Bank, N.V., July 8, 2002
- ING Mutual Funds Management Co. LLC; ING Funds Distributors Inc. and Reich & Tang Distributors Inc., February 9, 2001
- ING Series Fund, Inc., et al, April 30, 2008
- Institutional Liquidity Trust, April 30, 2008
- Institutional Shareholder Services, Inc., September 15, 2004
- Investec Ernst & Company, April 24, 2001
- Investment Adviser Association, September 20, 2007
- Investment Adviser Association, December 2, 2005
- Investment Company Institute, 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 Counsel Association of America, Inc., March 1, 2004
- iShares Trust, et al., October 22, 2008
- JPMorgan Chase; Bear Stearns Asset Management I,, July 14, 2008
- JPMorgan Chase; Bear Stearns Asset Management II, March 16, 2008
- J.P. Morgan Securities Inc., October 22, 2008
- J.P. Morgan Securities Inc., October 8, 2003
- J.P. Morgan Securities Inc., October 31, 2003
- James DeYoung, October 24, 2003
- Janus Aspen Series, April 10, 2008
- Jennison Associates LLC, July 6, 2000
- Juniper Capital L.P., June 23, 2003
- k1 Ventures, et. al., July 28, 2003
- Kirkpatrick & Lockhart LLP, January 28, 2004
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- Lear Corporation Retirement Savings Plan Trusts, March 16, 2007
- Legg Mason 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
- Lincoln National Convertible Securities Fund, Inc. - Walter S. Baer, September 28, 2001
- Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003
- Lindbergh Funds, October 30, 2002
- Lockheed Martin Investment Management Company, June 6, 2006
- Longleaf Partners Funds Trust, April 9, 2001
- M&G Investment Management Ltd., March 1, 2007
- Mackenzie Investment Managment et al., August 8, 2000
- MACRO Securities Depositor, LLC, December 1, 2006
- Mahaffy, Edward , March 6, 2003
- Man-Glenwood Lexington TEI, LLC and Man-Glenwood Lexington TEI, LDC, April 30, 2004
- Manufacturers Adviser Corp, September 10, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
- Massachusetts Mutual Life, June 7, 2000
- Master Portfolio Trust, April 18, 2008
- Master Portfolio Trust, April 4, 2008
- Maxim Series Fund Inc., January 14, 2004
- Mayer Brown LLP, July 28, 2008
- McDermott, Will & Emery, July 26, 2007
- Medallion Financial Corp., May 11, 2004
- Mellon Equity Associates, LLP April 1, 2005
- Mercy Investment Program, Inc., June 12, 2003
- Merrill Lynch & Co., Inc., September 27, 2006
- Merrill Lynch Investment Managers, May 10, 2002
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Metropolitan Insurance and Annuity Company, June 6, 2003
- Mexico Equity and Income Fund, The, November 15, 2001
- Millennium Partners, L.P., et al, March 9, 2006
- Missouri Bankers Association, August 18, 2008
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- Morgan, Lewis & Bockius LLP, November 17, 2005
- Morgan Stanley & Co., Inc., February 4, 2005
- Morgan Stanley Institutional Liquidity Funds, October 22, 2008
- Morgan Stanley Money Market Funds, October 22, 2008
- Mount Vernon Securities Lending Trust, October 24, 2008
- Mount Vernon Securities Lending Trust, October 22, 2008
- MTB Group of Funds, October 21, 2003
- Munder Series Trust, June 23, 2008
- MuniYield Insured Fund, Inc., March 11, 2002
- Mutual Fund Directors Forum, May 9, 2002
- Mutual of America Investment Corporation, June 2, 2006
- National Association for Variable Annunities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001
- National Compliance Service, November 30, 2005
- National Football League Players Association, January 25, 2002
- Nationwide Life Insurance Company, March 16, 2001
- Neuberger Berman Management Inc., et al., April 30, 2003
- NGP Capital Resources Company (Corrected), December 28, 2007
- Northern Institutional Fund, July 16, 2008
- Northern Institutional Funds, February 28, 2008
- Nuveen Virginia Premium Income Municipal Fund, October 6, 2006
- Old Dominion Electric Cooperative, et al., October 13, 2004
- Old Mutual Advisors Funds, November 16, 2007
- Pacific Select Fund, et al., December 23, 2004
- 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
- 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
- Principal Investors Fund Inc., May 13, 2005
- Prudential Financial, Inc., September 5, 2008
- Prudential Insurance Company of America, March 1, 2005
- Prudential Investment Management Services LLC, April 19, 2001
- Prudential Securities Incorporated, February 7, 2001
- Putnam High Income Securities Fund, March 14, 2006
- Putnam Premier Income Trust, March 14, 2006
- Putnam Tax-Free Health Care Fund, August 8, 2005
- RealEnergy, Inc., et al., August 12, 2003
- ReFlow Fund, LLC, July 15, 2002
- Reserve New York Municipal Money-Market Trust — New York Municipal Money-Market Fund, November 18, 2008
- RidgeWorth Funds, October 22, 2008
- R.O.C. Taiwan Fund, February 11, 2000
- Royal Dutch Shell plc, May 17, 2005
- Russell Investment Company, October 24, 2008
- Russell Investment Company, October 20, 2008
- SCP Private Equity Partners II, L.P., June 6, 2006
- 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, December 3, 2007
- Seligman New Technologies Fund II, Inc., February 7, 2002
- Seward & Kissel, October 12, 2005
- Shee Atika Investments, LLC, January 20, 2004
- Staff Responses to Questions About Regulation S-P, January 23, 2003
- Stephens Inc., December 27, 2001
- STI Classic Funds, January 2, 2008
- STI Classic Funds, October 26, 2007
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- Swiss Helvetia Fund, Inc., March 6, 2001
- The TCW Group, Inc., November 7, 2008
- TDAM Money Market Portfolio, December 21, 2007
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
- Thomas Weisel Partners LLC, September 24, 2004
- Thomson Financial Inc., July 10, 2002
- The Townsend Group, Inc., July 9, 2008
- Touchstone Variable Series Trust, October 22, 2008
- Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004
- Tri-Continental Corporation, March 25, 2003
- Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003
- T. Rowe Price Associates, Inc., July 10, 2008
- Trusts under the Will of Marion Searle, March 29, 2005
- Tuition Plan Consortium, LLP, February 4, 2003
- UAM Inc., September 24, 2001
- UBS Financial Services, Inc., September 29, 2005
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- USB Global Asset Management (US), Inc., November 21, 2002
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- U.S. Bancorp Asset Management Inc., et al., December 11, 2001
- Van Kampen Funds Inc., January 31, 2007
- Washington Capital Joint Master Trust, September 25, 2006
- Wells Fargo Alternative Asset Management, LLC, January 26, 2005
- Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008
- Westford Technology Ventures, L.P., January 28, 2004
- Western Asset Money Market
Fund, June 27, 2008
- Western Asset Institutional Money Market
Fund, June 27, 2008
- Western Farmers Electric Cooperative, February 23, 2001
- Willkie Farr & Gallagher, October 23, 2000
- Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001
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Chronological List of No-Action Letters
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- 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
- Mount Vernon Securities Lending Trust, October 24, 2008
- Russell Investment Company, October 24, 2008
- Columbia Funds Series Trust, 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
- Morgan Stanley Institutional Liquidity Funds, October 22, 2008
- Morgan Stanley Money Market Funds, October 22, 2008
- Mount Vernon Securities Lending Trust, October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Phoenix Opportunities Trust, October 22, 2008
- RidgeWorth Funds, October 22, 2008
- Touchstone Variable Series 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
- Russell In
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