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U.S. Securities and Exchange Commission

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

Subject Categories

List of No-Action Letters by Subject Category

Advertising — Investment Company

Advisory Contract

Advisory Representatives

12b-1 Fees

Advisory Fees

Affiliated Transaction

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


Electronic Filings

Employee Benefit Plans

Exchange Offer

Fiduciary Duties


Government Instrumentalities

Government Securities

Hub and Spoke Funds

Independent Directors

Independent Legal Counsel

Insurance Products

Interested Person


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



Regulation S-P

Reimbursement of Proxy Expenses


Reporting Requirements — Investment Advisers

Reporting Requirements — Investment Companies

Sales of Fund Shares below NAV

Securities — Definition

Securities Lending

Separate Accounts

Senior Securities

Shareholder Proposals

Shareholders Votes


Alphabetical List of No-Action Letters

Chronological List of No-Action Letters



Modified: 03/17/2003