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Division of Investment Management
Staff No-Action 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 fee. Please call (202) 942-8090, or email publicinfo@sec.gov.
Subject Categories
Subject Category List of No-Action Letters
Alphabetical List of No-Action Letters
Chronological List of No-Action Letters
| List of No-Action Letters by Subject Category |
Advertising Investment Company
Advisory Contract
Advisory Representatives
12b-1 Fees
Advisory Fees
Affiliated Transaction
- 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
Annual Reports
Backward Pricing
Beneficial Ownership Qualified Purchaser
Business and Industrial Development Companies
Cash Solicition
Closed-End Investment Companies
Code of Ethics
Commerical Paper
Custody-Investment Company
Director
Electronic Filings
Employee Benefit Plans
Exchange Offer
Fiduciary Duties
Fraud
Government Instrumentalities
Government Securities
Hub and Spoke Funds
Independent Directors
Independent Legal Counsel
Insurance Products
- 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, August 16, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- ING Mutual Funds Management Co. LLC, ING Funds Distributor Inc. and Reich & Tang Distributors, Inc, February 9, 2001
- Investec Ernst & Company, April 24, 2001
- Manufacturers Life Insurance Company, The, December 27, 2001
- Prudential Investment Management Services LLC, April 19, 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
Investment Securities
Joint Transactions
Mergers and Combinations
Money Market Funds
Money Market Liquidity
Performance Fees
Pre-Paid Tuition Plans
Prospectuses Delivery
Prospectuses Disclosure
Public Offering
Public Utility Holding Companies
Redeemable Securities
Redemption Fees
Redemptions
Registration
- 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
Regulation S-P
Reimbursement of Proxy Expenses
Reorganization
Reporting Requirements Investment Advisers
Reporting Requirements Investment Companies
Sales of Fund Shares below NAV
Securities Definition
Securities Lending
Separate Accounts
Senior Securities
Shareholder Proposals
- Asia Pacific Fund, Inc (The), June 8, 2001
- Asia Tiger Fund, Inc., The, December 28, 2001
- Asia Tiger Fund, Inc., The, January 31, 2002
- 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
- MuniYield Insured Fund, Inc., March 11, 2002
- Pioneer Interest Shares, June 20, 2001
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
Shareholders Votes
Solicitors
| Alphabetical List of No-Action Letters |
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AAL Mutual Funds, et al., December 12, 2002
- 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
- Allstate Life Insurance Company, December 23, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- Arizona Electric Power Cooperative Inc., July 27, 2001
- 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
- Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002
- Calvert Social Index Fund, September 24, 2001
- The Chase Manhattan Bank, July 24, 2001
- Constellation Financial Management LLC, January 9, 2003
- Current Income Shares, Inc., July 10, 2001
- Electronic Filing for Investment Advisers on IARD: Staff Responses to Questions About Regulation S-P, April 9, 2001
- Evergreen Investment Management Company, LLC, February 13, 2002
- Federal Home Loan Mortgage Corporation, July 12, 2002
- Federal National Mortgage Association, July 12, 2002
- Federated Core Trust II, L.P., February 6, 2002
- 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
- Frank Russell Investment Company, et al., October 18, 2002
- General Electric Capital Corporation, April 26, 2002
- Government Securities Clearing Corporation, October 19, 2001
- Gulf Coast Venture Forum, Inc., August 21, 2002
- H.E.B. Investment and Retirement Plan (H.E. Butt Grocery Company), May 18, 2001
- Honeywell International Inc Savings Plan Trust, October 7, 2002
- 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
- Investec Ernst & Company, April 24, 2001
- Investment Company Institute, February 12, 2002
- Investment Company Institute, June 14, 2001
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- Legg Mason Wood Walker, Inc., June 11, 2001
- 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
- Longleaf Partners Funds Trust, April 9, 2001
- Manufacturers Adviser Corp, September 10, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
- Merrill Lynch Investment Managers, May 10, 2002
- Mexico Equity and Income Fund, The, November 15, 2001
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- MuniYield Insured Fund, Inc., March 11, 2002
- Mutual Fund Directors Forum, May 9, 2002
- National Association for Variable Annunities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001
- National Football League Players Association, January 25, 2002
- Nationwide Life Insurance Company, March 16, 2001
- Pioneer Interest Shares, June 20, 2001
- PIMCO Funds: Multi-Manager Series, August 6, 2002
- PIMCO Funds, July 9, 2002
- Prudential Investment Management Services LLC, April 19, 2001
- Prudential Securities Incorporated, February 7, 2001
- ReFlow Fund, LLC, July 15, 2002
- Seligman New Technologies Fund II, Inc., February 7, 2002
- Stephens Inc., December 27, 2001
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- Swiss Helvetia Fund, Inc., March 6, 2001
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
- Thomson Financial Inc., July 10, 2002
- Tuition Plan Consortium, LLP, February 4, 2003
- UAM Inc., September 24, 2001
- USB Global Asset Management (US), Inc., November 21, 2002
- U.S. Bancorp Asset Management Inc., et al., December 11, 2001
- Western Farmers Electric Cooperative, February 23, 2001
- Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001
| Chronological List of No-Action Letters |
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- Tuition Plan Consortium, LLP, February 4, 2003
- Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003
- Constellation Financial Management LLC, January 9, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- AAL Mutual Funds, et al., December 12, 2002
- USB Global Asset Management (US), Inc., November 21, 2002
- Lindbergh Funds, October 30, 2002
- Frank Russell Investment Company, et al., October 18, 2002
- Honeywell International Inc Savings Plan Trust, October 7, 2002
- Manufacturers Adviser Corp, September 10, 2002
- Gulf Coast Venture Forum, Inc., August 21, 2002
- PIMCO Funds: Multi-Manager Series, August 6, 2002
- ReFlow Fund, LLC, July 15, 2002
- Federal National Mortgage Association, July 12, 2002
- Federal Home Loan Mortgage Corporation, July 12, 2002
- Thomson Financial Inc., July 10, 2002
- PIMCO Funds, July 9, 2002
- ING Bank, N.V., July 8, 2002
- Merrill Lynch Investment Managers, May 10, 2002
- Mutual Fund Directors Forum, May 9, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- General Electric Capital Corporation, April 26, 2002
- Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002
- MuniYield Insured Fund, Inc., March 11, 2002
- Evergreen Investment Management Company, LLC, February 13, 2002
- AIM Advisors, Inc., February 12, 2002
- Investment Company Institute, February 12, 2002
- Seligman New Technologies Fund II, Inc., February 7, 2002
- Federated Core Trust II, L.P., February 6, 2002
- National Football League Players Association, January 25, 2002
- Asia Tiger Fund, Inc., The, January 31, 2002
- Asia Tiger Fund, Inc., The, December 28, 2001
- Manufacturers Life Insurance Company, The, December 27, 2001
- Stephens Inc., December 27, 2001
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- U.S. Bancorp Asset Management Inc., et al., December 11, 2001
- Mexico Equity and Income Fund, The, November 15, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- Government Securities Clearing Corporation, October 19, 2001
- Lincoln National Convertible Securities Fund, Inc. - Walter S. Baer, September 28, 2001
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
- UAM Inc., September 24, 2001
- Calvert Social Index Fund, September 24, 2001
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- AIG Life Insurance Company, August 16, 2001
- Arizona Electric Power Cooperative Inc., July 27, 2001
- The Chase Manhattan Bank, July 24, 2001
- Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001
- Current Income Shares, Inc., July 10, 2001
- Pioneer Interest Shares, June 20, 2001
- National Association for Variable Annunities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001
- Investment Company Institute, June 14, 2001
- Asia Pacific Fund, Inc (The), June 8, 2001
- Asia Pacific Fund, Inc (The) - Thomas A. Kornfeld, June 8, 2001
- Legg Mason Wood Walker, Inc., June 11, 2001
- H.E.B. Investment and Retirement Plan (H.E. Butt Grocery Company), May 18, 2001
- Investec Ernst & Company, April 24, 2001
- Prudential Investment Management Services LLC, April 19, 2001
- Electronic Filing for Investment Advisers on IARD: Staff Responses to Questions About Regulation S-P, April 9, 2001
- Longleaf Partners Funds Trust, April 9, 2001
- France Growth Fund, Inc, April 6, 2001
- France Growth Fund, Inc.; Advantage Partners LP, April 6, 2001
- France Growth Fund, Inc.; Strome Hedgecap Fund, April 6, 2001
- Nationwide Life Insurance Company, March 16, 2001
- Fidelity Advisor Korea Fund, Inc, March 7, 2001
- Swiss Helvetia Fund, Inc., March 6, 2001
- Western Farmers Electric Cooperative, February 23, 2001
- ING Mutual Funds Management Co. LLC; ING Funds Distributors Inc. and Reich & Tang Distributors Inc., February 9, 2001
- Prudential Securities Incorporated, February 7, 2001
http://www.sec.gov/divisions/investment/noaction.htm
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