Last Updated July 18, 2023
The staff of the Division of Investment Management (the “staff”) issues staff no-action letters and other staff statements (“Staff Statements”). Both this list and the referenced Staff Statements represent the views of staff of the Division of Investment Management and are not a rule, regulation, or statement of the Securities and Exchange Commission. Furthermore, the Commission has neither approved nor disapproved the content of this list or the referenced Staff Statements. Like all staff guidance, neither the list nor any referenced Staff Statement has any legal force or effect: they do not alter or amend applicable law, and they create no new or additional obligations for any person.
Certain Staff Statements have been modified or withdrawn over time. A list of these Staff Statements is included below. Hyperlinks to Staff Statements have been included where such Staff Statements have previously been available on our website.
This list is not exhaustive and is intended solely as a resource. There may be other Staff Statements that have been modified or withdrawn that are not reflected below or that are no longer applicable. Accordingly, a Staff Statement should be considered in light of regulatory changes that may have occurred since the Staff Statement was issued. The staff expects to update this list periodically, but may not issue separate informational updates or announcements for each update. Therefore, you may wish to use the form on the right to subscribe to email bulletins that will notify subscribers of updates to this web page.
If you have questions, please see the Division of Investment Management’s contact page.
| Item Description | Date Issued | Date Modified or Withdrawn |
Notes | Topic(s) |
|---|---|---|---|---|
| Valuation; Fair Value Pricing; Pricing – Fair Value Pricing | ||||
| Paul Revere Investors, Inc., SEC Staff Letter | Feb. 21, 1973 | Sept. 8, 2022 | Withdrawn. See Investment Company Act Rel. No. 34128 (Dec. 3, 2020) for more information. | Valuation |
| The Putnam Growth Fund and Putnam International Equities Fund, Inc., SEC Staff Letter | Jan. 23, 1981 | Sept. 8, 2022 | Withdrawn. See Investment Company Act Rel. No. 34128 (Dec. 3, 2020) for more information. | Valuation |
| Form N-7 for Registration of Unit Investment Trusts under the Securities Act of 1933 and the Investment Company Act of 1940, Investment Company Act Release No. 15612, Appendix B, Guide 2 | Mar. 17, 1987 | Sept. 8, 2022 | Withdrawn. See Investment Company Act Rel. No. 34128 (Dec. 3, 2020) for more information. | Valuation |
| Investment Company Institute, SEC Staff Letter | Dec. 8, 1999 | Sept. 8, 2022 | Withdrawn. See Investment Company Act Rel. No. 34128 (Dec. 3, 2020) for more information. | Valuation; Fair Value Pricing; Pricing – Fair Value Pricing |
| Investment Company Institute, SEC Staff Letter |
Apr. 30, 2001 |
Sept. 8, 2022 | Withdrawn. See Investment Company Act Rel. No. 34128 (Dec. 3, 2020) for more information. | Valuation; Fair Value Pricing; Pricing – Fair Value Pricing |
| Valuation Guidance Frequently Asked Questions (FAQ 1 only) | 2014 | Sept. 8, 2022 | Withdrawn. See Investment Company Act Rel. No. 34128 (Dec. 3, 2020) for more information. | Valuation |
| Advertising | ||||
|
A.R. Schmeidler & Co., Inc., SEC |
June 1, 1976 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Amherst Financial Services Inc., |
May 23, 1995 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Anametrics Investment Mgmt., |
May 5, 1977 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Bradford Hall, SEC Staff Letter |
July 19, 1991 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
BullBear Indicator, Inc., SEC |
Apr. 14, 1973 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Bypass Wall Street, SEC Staff |
Jan. 7, 1992 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Cambiar Investors, Inc., SEC |
Aug. 28, 1997 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
CIGNA Securities, Inc., SEC Staff |
May 8, 1991 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Clover Capital Management, |
July 19, 1991 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Clover Capital Management, |
Oct. 28, 1986 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Conway Asset Management, |
Jan. 27, 1989 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Covato/Lipsitz, Inc., SEC Staff |
Oct. 23, 1981 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
DALBAR, Inc., SEC Staff Letter |
Mar. 24, 1998 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Denver Investment Advisors, |
July 30, 1993 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Donaldson, Lufkin & Jenrette |
Mar. 2, 1977 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Dow Theory Forecasts, Inc., SEC |
May 21, 1986 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Dow Theory Forecasts, Inc., SEC |
Nov. 7, 1985 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Dow Theory Forecasts, Inc., SEC |
Aug. 23, 1983 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Edward F. O’Keefe, SEC Staff |
Apr. 13, 1978 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Executive Analysts, Inc., SEC |
Aug. 6, 1972 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
F. Eberstadt & Co., Inc., SEC |
July 2, 1978 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Ferris & Company, Inc., SEC |
May 23, 1972 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Fiduciary Management |
Mar. 5, 1984 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Foster & Marshall, Inc., SEC Staff |
Feb. 18, 1977 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Franklin Management, Inc.. SEC Staff Letter |
Dec. 10, 1998 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Gallagher and Associates, Ltd.. SEC Staff Letter |
July 10, 1995 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Great Lakes Advisors, Inc., SEC Staff Letter |
Apr. 3, 1992 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Horizon Asset Mgmt. LLC., SEC |
Sept. 13, 1996 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Investment Adviser Association, |
Dec. 2, 2005 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Investment Company Institute, |
Sept. 23, 1988 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Investment Company Institute, |
Aug. 24, 1987 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Investment Counsel Association |
Mar. 1, 2004 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Investor Intelligence (John |
Apr. 18, 1975 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
J.D. Minnick & Co., SEC Staff |
Apr. 30, 1975 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
J.P. Morgan Investment Mgmt., |
May 7, 1996 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
James Maratta, SEC Staff Letter |
June 3, 1977 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Kurtz Capital Management, SEC |
Jan. 18, 1988 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Mark Eaton, SEC Staff Letter |
June 9, 1977 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Munder Capital Mgmt., SEC |
May 17, 1996 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
National Corporate Sciences, |
July 24, 1976 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
New York Investors Group, Inc., |
Sept. 7, 1982 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Norman L. Yu, SEC Staff Letter |
Apr. 12, 1971 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Oberweis Securities, Inc., SEC |
July 25, 1983 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Richard Silverman, SEC Staff |
Mar. 27, 1985 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Securities Industry Association, |
Nov. 27, 1989 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
South State Bank, SEC Staff |
May 8, 2018 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Stalker Advisory Services, SEC |
Jan. 18, 1994 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Starr & Kuehl, Inc., SEC Staff |
Apr. 17, 1976 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Taurus Advisory Group, Inc., |
July 15, 1993 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
The Mottin Forecast, SEC Staff |
Nov. 29, 1975 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
The TCW Group, SEC Staff |
Nov. 7, 2008 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Triad Asset Management, SEC |
Apr. 22, 1993 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Alphadex Corp., SEC Staff |
Feb. 21, 1971 |
Nov. 4, 2022 |
Modified. |
Advertising |
|
Analytic Investment |
Mar. 22, 1971 |
Nov. 4, 2022 |
Modified. |
Advertising |
|
Association for Investment |
Dec. 18, 1996 |
Nov. 4, 2022 |
Modified. |
Advertising |
|
Bache & Company, SEC Staff |
Feb. 5, 1976 |
Nov. 4, 2022 |
Modified. |
Advertising |
|
Cubitt-Nichols Associates, SEC |
Dec. 22, 1971 |
Nov. 4, 2022 |
Modified. |
Advertising |
|
Scientific Market Analysis, SEC |
Mar. 24, 1976 |
Nov. 4, 2022 |
Modified. |
Advertising |
|
Guidance on the Testimonial |
Mar. 2014 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
| Solicitation | ||||
|
Allen Isaacson, SEC Staff Letter* |
Dec. 17, 1979 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
AMA Investment Advisers, Inc., |
Oct. 28, 1993 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Ameriprise Financial Services, |
Apr. 5, 2006 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Bond Timing Securities |
Nov. 29, 1984 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Charles Schwab & Co. Inc., SEC |
Apr. 29, 1998 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Dechert Price and Rhoads, SEC |
Dec. 4, 1990 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
E. Magnus Oppenheim & Co., |
Mar. 25, 1985 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
E.F. Hutton and Co. Inc., SEC |
Sept. 21, 1987 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Excellence in Advertising, Ltd., |
Dec. 15, 1986 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Fried, Frank, Harris, Shriver & |
Dec. 17, 1979 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Heys, Robert J., SEC Staff Letter |
May 12, 1986 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
International Association for |
June 1, 1998 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
JMB Financial Managers, Inc., |
June 23, 1993 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Lincoln National Investment |
Mar. 26, 1992 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Mayer Brown LLP, SEC Staff |
July 15, 2008 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Merchants Capital Management, |
Oct. 4, 1991 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Mid-States Capital Planning, |
Apr. 11, 1983 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Moneta Group Investment |
Oct. 12, 1993 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Stein, Roe and Farnham, Inc., |
June 29, 1990 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Stein, Roe and Farnham Inc., |
May 26, 1987 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Stonebridge Capital |
Dec. 12, 1979 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
The Lowry Management Corp., |
Sept. 7, 1982 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Trident Investment |
Dec. 18, 1981 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Trinity Investment Management |
Mar. 7, 1980 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Van Eerden Investment |
May 21, 1984 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Dana Investment Advisors, Inc., |
Oct. 12, 1994 |
Nov. 4, 2022 |
Modified. |
Solicitation |
|
Denver Credit Union, SEC Staff |
Sept. 15, 1988 |
Nov. 4, 2022 |
Modified. |
Solicitation |
|
National Football League |
Jan. 25, 2002 |
Nov. 4, 2022 |
Modified. |
Solicitation |
|
Roy Heybrock, SEC Staff Letter |
Apr. 5, 1982 |
Nov. 4, 2022 |
Modified. |
Solicitation |
|
Shareholder Service |
Feb. 3, 1989 |
Nov. 4, 2022 |
Modified. |
Solicitation |
| Solicitation - Solicitor Disqualification Letters | ||||
|
Aeltus Investment Management, |
July 17, 2000 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
American International Group, |
Dec. 8, 2004 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
American International Group, |
Feb. 21, 2006 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Automated Trading Desk |
Mar. 13, 2009 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Banc of America Securities LLC, |
June 10, 2009 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Barclays Bank, PLC, SEC Staff |
June 6, 2007 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Bear Sterns & Co., Inc., and |
Jan. 1, 1999 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Bear, Stearns & Company Inc., |
Oct. 31, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Bear, Stearns Securities Corp., |
Aug. 5, 1999 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
BT Alex. Brown Inc., SEC Staff |
Nov. 17, 1999 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
BT Securities Corp., SEC Staff |
Mar. 30, 1992 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Carnegie Asset Management, |
July 11, 1994 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Charles Schwab & Co., Inc., SEC |
Aug. 7, 2018 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
CIBC Mellon Trust Company, |
Feb. 24, 2005 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Citigroup Global Markets, Inc., |
Aug. 6, 2014 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Citigroup Global Markets, Inc., |
Dec. 23, 2008 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Citigroup Global Markets Inc., |
Oct. 31, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Citigroup Inc., SEC Staff Letter |
Oct. 22, 2010 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Credit Suisse, SEC Staff Letter |
May 20, 2014 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Credit Suisse First Boston Corp., |
Aug. 24, 2000 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Credit Suisse First Boston LLC, |
Oct. 31, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Deutsche Bank Securities Inc., |
Sept. 24, 2004 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Deutsche Bank Securities Inc., |
June 9, 2009 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Dougherty & Company LLC, |
July 3, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Dougherty & Company LLC, |
Mar. 21, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Dreyfus Corp., SEC Staff Letter |
Mar. 9, 2001 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
E*Trade Capital Markets LLC, |
Mar. 12, 2009 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
E-Invest, Inc., SEC Staff Letter |
Sept. 22, 2000 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Emanuel J. Friedman; EJF |
Jan. 16, 2007 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
F. Porter Stansberry, SEC Staff |
Sept. 30, 2015 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Fahnestock & Company Inc., |
Apr. 21, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
First City Capital Corp., SEC |
Feb. 9, 1990 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Founders Asset Management |
Nov. 8, 2000 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
General Electric Company, SEC |
Aug. 12, 2009 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
General Electric Company, SEC |
Aug. 2, 2010 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
GE Funding Capital Market |
Jan. 25, 2012 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Goldman, Sachs & Co., SEC |
Feb. 23, 2005 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Goldman, Sachs & Co., SEC |
July 22, 2010 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Goldman, Sachs & Co., SEC |
Oct. 31, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Gruntal & Co., SEC Staff Letter |
July 17, 1996 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Hickory Capital Management, |
Feb. 11, 1993 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
In re William R. Hough & Co./In |
Apr. 13, 2000 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
In the Matter of Market Making |
Jan. 11, 1999 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
ING Bank N.V., SEC Staff Letter |
Aug. 31, 2005 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Interstate/Johnson Lane Corp., |
Apr. 21, 1997 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
J.B. Hanauer, SEC Staff Letter |
Apr. 27, 1999 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
J.B. Hanauer, SEC Staff Letter |
Dec. 12, 2000 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
JPMorgan Chase & Co., SEC |
May 20, 2015 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
J.P. Morgan Securities Inc., SEC |
Oct. 31, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
J.P. Morgan Securities Inc., SEC |
Oct. 8, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
J.P. Morgan Securities Inc., SEC |
Jan. 9, 2013 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
J.P. Morgan Securities Inc., SEC |
July 11, 2011 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
J.P. Morgan Securities Inc., SEC |
June 29, 2011 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
J.P. Turner & Company, L.L.C., et |
Sept. 10, 2012 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
James DeYoung, SEC Staff |
Oct. 24, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Janney Montgomery Scott LLC |
July 18, 2000 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Kidder Peabody & Co., SEC |
Mar. 30, 1992 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Kidder Peabody & Co., Inc., SEC |
Oct. 11, 1990 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Legg Mason Wood Walker, Inc., |
June 11, 2001 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Lehman Brothers, SEC Staff |
Oct. 31, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Macquarie Capital (USA) Inc., |
June 1, 2017 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
McDonald Investments Inc., SEC |
Apr. 2, 1999 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Merrill Lynch, Pierce, Fenner & |
Sept. 15, 1999 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Merrill Lynch, Pierce, Fenner & |
Aug. 7, 1997 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Merrill Lynch, Pierce, Fenner & |
Oct. 31, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Millennium Partners, L.P., SEC |
Mar. 9, 2006 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Mitchell Hutchins Asset |
Jan. 2, 1998 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Morgan Keegan & Co., Inc., SEC |
Jan. 9, 1998 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Morgan Stanley & Co., |
May 15, 2006 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Morgan Stanley & Co., Inc., SEC |
Feb. 4, 2005 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Morgan Stanley & Co., SEC Staff |
Oct. 31, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Nationsbanc Investments, Inc., |
May 6, 1998 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Norman Zadeh and Prime |
Nov. 8, 2001 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Oppenheimer & Co., Inc., SEC |
June 5, 1992 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
PaineWebber Inc., SEC Staff |
Dec. 22, 1998 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Paul Laude, CFP, SEC Staff |
June 22, 2000 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Prudential Financial, Inc., SEC |
Sept. 5, 2008 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Prudential Securities Inc., SEC |
Sept. 5, 2008 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Prudential Securities Inc., SEC |
Feb. 7, 2001 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Ramius Capital Management, |
Apr. 5, 1996 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
RBC Capital Markets Corp., SEC |
June 10, 2009 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Nov. 26, 2013 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
|
RNC Capital Management Inc., |
Feb. 7, 1989 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Royal Bank of Canada, SEC |
Dec. 19, 2014 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Salomon Brothers, Inc., SEC |
Jan. 26, 1994 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Stein Roe & Farnham Inc., SEC |
Aug. 25, 1988 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Stein Roe Farnham - Touche |
Jan. 20, 1990 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Stephanie Hibler, SEC Staff |
Jan. 24, 2014 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Stephens Inc., SEC Staff Letter |
Dec. 27, 2001 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Stifel, Nicolaus & Company, Inc., |
Dec. 6, 2016 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
The Dreyfus Corp., SEC Staff |
Mar. 9, 2001 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Thomas Weisel Partners LLC, |
Sept. 24, 2004 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Tucker Anthony Inc., SEC Staff |
Dec. 21, 2000 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
U.S. Bancorp Piper Jaffray Inc., |
Oct. 31, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
UBS AG, SEC Staff Letter |
May 20, 2015 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
UBS AG, SEC Staff Letter |
Mar. 20, 2009 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
UBS Financial Services Inc., SEC |
May 9, 2011 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
UBS Securities LLC (f/k/a UBS |
Oct. 31, 2003 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
UBS Securities LLC/UBS |
Dec. 23, 2008 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Wachovia Securities LLC, SEC |
Feb. 18, 2009 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Wells Fargo Bank, N.A., SEC |
July 15, 2013 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Wells Fargo Bank, N.A., SEC |
Sept. 21, 2012 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
|
Wells Fargo Bank, N.A., SEC |
Dec. 12, 2011 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation – Solicitor Disqualification Letters |
| Advertising or Solicitation & Other Topics | ||||
|
Andrew M. Rich, SEC Staff |
Feb. 22, 1989 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Charles Schwab & Co., SEC Staff |
Dec. 17, 1980 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Charles Swanson, SEC Staff |
Apr. 10, 1972 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Cunningham Advisory Services, |
Apr. 27, 1987 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
J.Y. Barry Arbitrage |
Oct. 18, 1989 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
James B. Peeke & Co., Inc., SEC |
Sept. 13, 1982 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Koyen, Clarke and Assoc. Inc., |
Nov. 10, 1986 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Mills-Price & Associates, Inc., |
July 15, 1992 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Multi-Financial Securities Corp., |
Nov. 9, 1995 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
S. H. Dike & Co., Inc., SEC Staff |
Apr. 20, 1975 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
|
Securities International, Ltd., |
Mar. 14, 1989 |
Nov. 4, 2022 |
Withdrawn. |
Solicitation |
|
Schield Stock Services, Inc., SEC |
Feb. 26, 1972 |
Nov. 4, 2022 |
Withdrawn. |
Advertising |
| Affiliated Transactions | ||||
|
March 19, 2020 |
Nov. 4, 2022 |
Withdrawn. See Staff Statement Regarding Termination Notice For Exemptive Relief and Withdrawal of Staff Letters Related To COVID-19 Response for more information. |
||
|
March 19, 2020 |
Nov. 4, 2022 |
Withdrawn. See Staff Statement Regarding Termination Notice For Exemptive Relief and Withdrawal of Staff Letters Related To COVID-19 Response for more information. |
||
|
March 26, 2020 |
Nov. 4, 2022 |
Withdrawn. See Staff Statement Regarding Termination Notice For Exemptive Relief and Withdrawal of Staff Letters Related To COVID-19 Response for more information. |
Money Market Funds |
|
| Anti-Takeover Statutes | ||||
| Boulder Total Return Fund, Inc., SEC Staff Letter | Nov. 15, 2010 | May 27, 2020 | Withdrawn See Staff Statement: Control Share Acquisition Statutes for more information. | Anti-Takeover Statutes; Closed-End Investment Companies; Voting Security |
| Staff Letters including Statements Relating to Section 18 of the Investment Company Act | ||||
|
Merrill Lynch Asset Management, L.P., SEC |
July 2, 1996 |
August 19, 2022 |
Withdrawn. |
Senior Securities |
|
Robertson Stephens Investment Trust, SEC |
Aug. 24, 1995 |
August 19, 2022 |
Withdrawn. |
Senior Securities |
|
Sanford C. Bernstein Fund, Inc, SEC |
June 25, 1990 |
August 19, 2022 |
Withdrawn. |
Senior Securities |
|
Hutton Options Trading LP, SEC |
Feb. 2, 1989 |
August 19, 2022 |
Withdrawn. |
Senior Securities |
|
Dreyfus Strategic Investing and Dreyfus Strategic Income, SEC |
June 22, 1987 |
August 19, 2022 |
Withdrawn. |
Senior Securities |
|
SAFECO Municipal Bond Fund, Inc., SEC |
Nov. 26, 1982 |
August 19, 2022 |
Withdrawn. |
Senior Securities |
| Staff Issue of Interest including Statements Relating to Section 18 of the Investment Company Act | ||||
|
Funds Using Tender Option Bond (TOB) Financings, Investment Management Staff Issue of Interest |
Mar. 29, 2012 |
August 19, 2022 |
Withdrawn. |
Senior Securities |
| Staff Letters including Statements Relating to Section 12(a) and Section 18 of the Investment Company Act | ||||
|
DataConcepts Fund, Inc., SEC Staff Letter |
Aug. 25, 1980 |
August 19, 2022 |
Withdrawn. |
Senior Securities |
|
Emerald Mgt. Co, SEC Staff Letter |
Jan. 21, 1978 |
August 19, 2022 |
Withdrawn. |
Senior Securities |
| Staff Letters including Statements Relating to Section 12(a), Section 18, and Section 17(f) of the Investment Company Act | ||||
|
Claremont Capital Corp., SEC Staff Letter |
Sept. 16, 1979 |
August 19, 2022 |
Modified. |
Senior Securities |
| Staff Letters including Statements Relating to Section 18 and Section 17(f) of the Investment Company Act | ||||
|
Investment Company Institute and SIFMA AMG, SEC Staff Letter |
May 27, 2020 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Franklin Templeton Investments, SEC Staff Letter |
June 19, 2009 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Prudential-Bache IncomeVertible Plus Fund, Inc., SEC Staff Letter |
Nov. 20, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
State Street Income Fund, State Street Balanced Fund, SEC Staff Letter |
Oct. 21, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
New England Life Government Securities Trust, SEC Staff Letter |
Sept. 26, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Thomson McKinnon Investment Trust, SEC Staff Letter |
Sept. 23, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Putnam Option Income Trust II, SEC Staff Letter |
Sept. 23, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
GMO Core Trust, SEC Staff Letter |
Aug. 19, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Bartlett Capital Trust, SEC Staff Letter |
Aug. 19, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Continental Option Income Plus Fund,, SEC Staff Letter |
Aug. 12, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Colonial High Yield Securities Trust, Colonial Enhanced Mortgage Trust, SEC Staff Letter |
July 25, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Putnam High Income Government Trust, SEC Staff Letter |
June 3, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Bartlett Management Trust, SEC Staff Letter |
May 17, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Drexel Series Trust – Government Securities Series, SEC Staff Letter |
Apr. 25, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Koenig Tax-Advantaged Liquidity Fund, Inc, SEC Staff Letter |
Mar. 27, 1985 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Colonial Tax-Exempt High Yield Trust, SEC Staff Letter |
Dec. 31, 1984 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Monitrend Fund, SEC Staff Letter |
Nov. 14, 1984 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Pilot Fund, Inc, SEC Staff Letter |
Sept. 14, 1984 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Colonial Government Securities Plus Trust, SEC Staff Letter |
June 15, 1984 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Z-Seven Fund, Inc, SEC Staff Letter |
May 21, 1984 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Pension Hedge Fund Inc, SEC Staff Letter |
Jan. 20, 1984 |
August 19, 2022 |
Modified. |
Senior Securities |
|
SteinRoe Bond Fund, Inc., SEC Staff Letter |
Jan. 17, 1984 |
August 19, 2022 |
Modified. |
Senior Securities |
|
IDS Bond Fund, Inc., SEC Staff Letter |
Apr. 11, 1983 |
August 19, 2022 |
Modified. |
Senior Securities |
|
Montgomery Street Income Securities, Inc., SEC Staff Letter |
Apr. 11, 1983 |
August 19, 2022 |
Modified. |
Senior Securities |
| Staff Letters including Statements Relating to Section 18 of the Investment Company Act as it relates to fund (i) use of options and (ii) engagement in securities lending activities | ||||
|
SIFE Trust Fund, SEC Staff Letter |
Feb. 17, 1982 |
August 19, 2022 |
Modified. |
Senior Securities |
| Staff Letters including Statements Relating to Section 18 of the Investment Company Act as it relates to fund engagement in securities lending activities | ||||
|
Salomon Brothers, SEC Staff Letter |
May 4, 1975 |
August 19, 2022 |
Modified. |
Senior Securities |
|
The Brinson Funds, et al., SEC Staff Letter |
Nov. 25, 1997 |
August 19, 2022 |
Modified. |
Senior Securities |
| ETFs | ||||
| SPDR Series Trust, et al., Staff Letter | Jun. 24, 2015 | Dec. 23, 2020 | Withdrawn See Staff Statement: Withdrawal of Staff Letters Related To Exchange-Traded Funds (ETFs) for more information. | ETFs |
| Derivatives Use by Actively-Managed ETFs, Staff Letter | Dec. 6, 2012 | Dec. 23, 2020 | Withdrawn See Staff Statement: Withdrawal of Staff Letters Related To Exchange-Traded Funds (ETFs) for more information. | ETFs |
| Barclays Global Fund Advisors et al., Staff Letter | Mar. 12, 2009 | Dec. 23, 2020 | Withdrawn See Staff Statement: Withdrawal of Staff Letters Related To Exchange-Traded Funds (ETFs) for more information. | ETFs |
| iShares Trust, et al., Staff Letter | Oct. 22, 2008 | Dec. 23, 2020 | Withdrawn See Staff Statement: Withdrawal of Staff Letters Related To Exchange-Traded Funds (ETFs) for more information. | ETFs |
| 486(b) Staff Letters | ||||
| BlackRock Science and Technology Trust and BlackRock Utilities, Infrastructure & Power Opportunities Trust, SEC Staff Letter | Mar. 3, 2020 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Eaton Vance Tax-Advantaged Dividend Income Fund et al., SEC Staff Letter | Dec. 16, 2019 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| XAI Octagon Floating Rate & Alternative Income Term Trust, SEC Staff Letter | Aug. 6, 2019 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Cushing MLP & Infrastructure Total Return Fund et al., SEC Staff Letter | Aug. 6, 2019 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Nuveen S&P 500 Dynamic Overwrite Fund et al., SEC Staff Letter | Apr. 26, 2019 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Voya Prime Rate Trust, SEC Staff Letter | Apr. 8, 2019 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| PIMCO Income Strategy Fund et al., SEC Staff Letter | Jan. 30, 2019 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Eaton Vance Tax-Managed Buy-Write Opportunities Fund et al., SEC Staff Letter | Oct. 29, 2018 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| DNP Select Income Fund Inc., SEC Staff Letter | Oct. 4, 2018 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| PIMCO Corporate & Income Opportunity Fund et al., SEC Staff Letter | Sep. 13, 2018 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Eagle Point Credit Company Inc., SEC Staff Letter | Feb. 14, 2018 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| PIMCO Dynamic Income Fund, SEC Staff Letter | Dec. 12, 2017 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Nuveen California Select Tax-Free Income Portfolio, SEC Staff Letter | Nov. 21, 2017 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Nuveen Municipal Income Fund, Inc. et al., SEC Staff Letter | Jul. 27, 2017 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Guggenheim Credit Allocation Fund, SEC Staff Letter | Apr. 5, 2017 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Invesco Senior Income Trust et al., SEC Staff Letter | Jan. 26, 2017 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| The Herzfeld Caribbean Basin Fund, Inc., SEC Staff Letter | Sep. 21, 2016 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| BlackRock Health Sciences Trust, SEC Staff Letter | Feb. 25, 2016 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Fiduciary/Claymore MLP Opportunity Fund, SEC Staff Letter | Jan. 7, 2016 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| BlackRock Limited Duration Income Trust et al., SEC Staff Letter | Oct. 19, 2015 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Nuveen Credit Strategies Income Fund et al., SEC Staff Letter | Nov. 7, 2014 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Guggenheim Strategic Opportunities Fund, SEC Staff Letter | Oct. 2, 2014 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| The Gabelli Convertible & Income Securities Fund Inc., SEC Staff Letter | Apr. 18, 2014 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| The Mexico Fund, Inc., SEC Staff Letter | Dec. 31, 2013 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Aberdeen Asia-Pacific Income Fund, Inc., SEC Staff Letter | Jun. 26, 2013 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Credit Suisse High Yield Bond Fund et al., SEC Staff Letter | Jun. 26, 2013 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Eaton Vance Floating-Rate Income Trust et al., SEC Staff Letter | Jun. 26, 2013 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| First Trust Strategic High Income Fund II et al., SEC Staff Letter | Jun. 26, 2013 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| John Hancock Investors Trust et al., SEC Staff Letter | Jun. 26, 2013 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| NexPoint Credit Strategies Fund, SEC Staff Letter | Jun. 26, 2013 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Nuveen Select Quality Municipal Fund et al., SEC Staff Letter | Jun. 26, 2013 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Aberdeen Australia Equity Fund, Inc. et al., SEC Staff Letter | Apr. 12, 2012 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Calamos Convertible Opportunities and Income Fund et al., SEC Staff Letter | Feb. 14, 2011 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Nuveen Municipal High Income Opportunity Fund et al., SEC Staff Letter | Nov. 9, 2010 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Energy Income and Growth Fund et al., SEC Staff Letter | Jul. 27, 2010 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Tortoise Energy Infrastructure Corporation et al., SEC Staff Letter | Apr. 23, 2010 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Closed-End Fund Shelf Offerings | ||||
| Nuveen Virginia Premium Income Municipal Fund, SEC Staff Letter | Oct. 6, 2006 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Pilgrim America Prime Rate Trust, SEC Staff Letter | May 1, 1998 | Aug. 1, 2021 | Withdrawn (effective: Aug. 1, 2021). See Investment Company Act Rel. No. 33836 (Apr. 8, 2020) and IM Information Update 2020-04 for more information. | Closed-End Funds |
| Variable Annuity and Variable Life Insurance Contracts | ||||
| Nationwide Life Insurance Company, SEC Staff Letter | Mar. 16, 2001 | Jan. 1, 2022 | Withdrawn (effective: January 1, 2022). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Disclosure; Insurance Products |
| Cova Financial Services Life Insurance Co., SEC Staff Letter | Apr. 15, 1996 | Jan. 1, 2022 | Withdrawn (effective: January 1, 2022). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Disclosure; Insurance Products |
| Metropolitan Life Insurance Co., SEC Staff Letter | Apr. 26, 1995 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Monarch Life Insurance Company, SEC Staff Letter | Jun. 9, 1992 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Great-West Life and Annuity Insurance Company, SEC Staff Letter | Oct. 23, 1990 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| The Equitable Life Assurance Society of the United States, SEC Staff Letter | Aug. 30, 1990 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| MML Bay State Life Ins. Co., SEC Staff Letter | Apr. 12, 1990 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Transamerica Occidental Life Insurance Co., SEC Staff Letter | Mar. 16, 1990 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Connecticut Mutual Life Insurance Company, SEC Staff Letter | Mar. 7, 1990 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| MONY Life Insurance Company of America, SEC Staff Letter | Feb. 27, 1990 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Century Life of America, SEC Staff Letter | Jan. 17, 1990 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| New York Life Insurance and Annuity Corp., SEC Staff Letter | Nov. 15, 1989 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Bankers National Life Insurance Co., SEC Staff Letter | Apr. 28, 1989 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Volunteer State Life Insurance Company, SEC Staff Letter | Feb. 10, 1989 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Metropolitan Tower Life Insurance Company, SEC Staff Letter | May 12, 1988 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Security Benefit Life Insurance Company, SEC Staff Letter | Jul. 2, 1987 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Life Insurance Company of North America, SEC Staff Letter | Jun. 16, 1986 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Pacific Fidelity Life Insurance Company, SEC Staff Letter | Jan. 27, 1986 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Federal Life Variable Annuity Account A, SEC Staff Letter | May 10, 1982 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Horace Mann Life Insurance Company, SEC Staff Letter | Mar. 31, 1982 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Horace Mann Life Insurance Company, SEC Staff Letter | Apr. 10, 1981 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020) and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Washington National Insurance Company, SEC Staff Letter | May 17, 1978 | Jul. 1, 2020 | Withdrawn (effective: July 1, 2020). See Investment Company Act Rel. No. 33814 (Mar. 11, 2020 and IM Information Update 2020-01 for more information. | Prospectuses-Delivery |
| Proxy | ||||
| Institutional Shareholder Services, Inc., SEC Staff Letter | Sep. 15, 2004 | Sep. 13, 2018 | Withdrawn. See Statement Regarding Staff Proxy Advisory Letters, Division of Investment Management (Sep. 13, 2018) for more information. | Proxy |
| Egan-Jones Proxy Services, SEC Staff Letter | May 27, 2004 | Sep. 13, 2018 | Withdrawn. See Statement Regarding Staff Proxy Advisory Letters, Division of Investment Management (Sep. 13, 2018) for more information. | Proxy |
| Standard of Conduct | ||||
| Heitman Capital Management, LLC, SEC Staff Letter | Feb. 12, 2007 | Jul. 12, 2019 | Withdrawn. See Commission Interpretation Regarding Standard of Conduct for Investment Advisers, IA Rel. No. 5248 (June 5, 2019) for more information. | Investment Advisers General |
| Auditor Independence | ||||
| Fidelity Management & Research Company et al., SEC Staff Letter | Sep. 22, 2017 | Oct. 3, 2019 | Withdrawn. See Auditor Independence With Respect to Certain Loans or Debtor-Creditor Relationships, IA Release No. 5255 (June 18, 2019) for more information. | Accounting and Auditing |
| Fidelity Management & Research Company et al., SEC Staff Letter | Jun. 20, 2016 | Dec. 20, 2017 | Expired. See Auditor Independence With Respect to Certain Loans or Debtor-Creditor Relationships, IA Release No. 5255 (June 18, 2019) for more information. | Accounting and Auditing |
| Funds Of Funds | ||||
| Dechert LLP, SEC Staff Letter |
Jan. 25, 2017 | Jan. 19, 2022 | Withdrawn See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. | Fund of Funds |
| Thrivent Financial for Lutherans and Thrivent Asset Management, LLC, SEC Staff Letter |
Sep. 27, 2016 | Jan. 19, 2022 | Withdrawn See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. | Fund of Funds |
| Northern Lights Fund Trust, SEC Staff Letter | Jun. 29, 2015 | Jan. 19, 2022 | Withdrawn See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. | Fund of Funds |
| Franklin Templeton Investments, SEC Staff Letter |
Apr. 3, 2015 | Jan. 19, 2022 | Withdrawn See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. | Fund of Funds |
| John Hancock Trust, et al., SEC Staff Letter | Apr. 12, 2012 | Jan. 19, 2022 | Withdrawn See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. | Fund of Funds |
| FQF Trust, et al., SEC Staff Letter | Dec. 13, 2011 | Jan. 19, 2022 | Withdrawn See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. | Fund of Funds |
| Evergreen Investment Management Company, LLC, et al., SEC Staff Letter | Oct. 11, 2005 | Jan. 19, 2022 | Withdrawn See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. | Fund of Funds/ Money Market Funds |
| Neuberger Berman Management Inc., et al., SEC Staff Letter | Apr. 30, 2003 | Jan. 19, 2022 | Withdrawn See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. | Fund of Funds |
| The AAL Mutual Funds, et al., SEC Staff Letter | Dec. 12, 2002 | Jan. 19, 2022 | Withdrawn See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. | Fund of Funds/ Affiliated Transactions - Other |
| Frank Russell Investment Company, et al., SEC Staff Letter | Oct. 18, 2002 | Jan. 19, 2022 | Withdrawn to the extent letter relates to the portion of the referenced order that is rescinded: See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. |
Fund of Funds/ Closed-End Investment Companies |
| Forum Financial Services, et al., SEC Staff Letter | Oct. 28, 1997 | Jan. 19, 2022 | Withdrawn See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. | Fund of Funds |
| Norwest Advantage Funds and Core Trust (Delaware), SEC Staff Letter | Jul. 1, 1997 | Jan. 19, 2022 | Withdrawn See Staff Statement Regarding Withdrawal Of Staff Letters Related To Rulemaking On Fund Of Funds Arrangements for more information. | Fund of Funds |
| Markets in Financial Instruments Directive II (MiFID II) | ||||
| Securities Industry and Financial Markets Association, SEC Staff Letter |
Oct. 26, 2017 |
July 3, 2023 | Expired. | MiFID II |
| Securities Industry and Financial Markets Association, SEC Staff Letter |
Nov. 4, 2019 |
July 3, 2023 | Expired. | MiFID II |
Last Reviewed or Updated: June 28, 2024