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Division of Investment Management: Chief Counsel's Office

The Chief Counsel’s Office (CCO) provides assistance to the Division, the Commission, and the public interpreting the Investment Company Act of 1940 (Investment Company Act), the Investment Advisers Act of 1940 (Advisers Act), their related rules, and other federal securities laws that apply to investment companies and investment advisers.

CCO is primarily responsible for issuing no-action letters, interpretive letters and other staff positions under the securities laws that apply to investment companies and advisers. In addition, CCO reviews and analyzes applications requesting exemptive relief under these laws and recommends to the Commission to grant or deny the request for relief, if appropriate.

CCO also responds to interpretive and legal questions concerning the laws that apply to investment companies and investment advisers. In consultation with staff across the Division, CCO coordinates with the Commission’s Office of Legislative and Intergovernmental Affairs to provide technical assistance on proposed legislation and respond to Congressional inquiries. CCO also collaborates with non-U.S. securities regulators and international regulatory bodies on international matters relating to investment companies, investment advisers and the protection of investors.

Within CCO, the IM Liaison Office (ILO) provides assistance and a central point of contact in IM to the Division of Enforcement (ENF) and EXAMS (EXAMS). The ILO assists ENF on investigations that involve potential violations of the Investment Company Act and the Investment Advisers Act, or that relate to the Division's policies and programs. It assists EXAMS with questions about compliance with the Investment Company Act and the Investment Advisers Act that arise in the course of their examinations. The ILO also assists ENF with applications submitted by barred individuals to re-enter the financial services industry, particularly when seeking to associate with investment advisers.

For interpretive questions regarding investment adviser registration, exempt reporting adviser reports, and Forms ADV,
ADV-E, ADV-H, ADV-NR, and ADV-W, contact IARDLIVE@sec.gov

For interpretive questions regarding Form PF, contact FormPF@sec.gov

For all other interpretive questions, contact IMOCC@sec.gov or (202) 551-6825

Modified: March 23, 2022

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