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Division of Investment Management Staff No-Action and Interpretive Letters

June 19, 2019

Important Note: This page contains Division of Investment Management no-action letters dated on or after January 1, 1993. 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.

A non-exhaustive list of no-action letters and other staff statements that have been modified or withdrawn is available on our Modified or Withdrawn Staff Statements webpage.

The no-action and interpretive letter web intake form and specific procedures for submitting requests can be found here:

Subject Categories

Subject Category List of No-Action Letters

12b-1 Fees

12b-1 Plans


Acquisition Trust

Acquisition of Securities in Affiliated Underwriting

Administrative Fees

Advertising - Investment Advisers

Advertising - Investment Company

Advisory Contracts

Advisory Fees

Advisory Representatives

Affiliated Persons

Affiliated Transactions - Money Market Fund Letters

Affiliated Transactions - Other

Agency Cross Transactions

Aggregated Transactions

Annual Reports

Annuity Contracts

Anti-Takeover Statutes

Asset-Backed Securities



Auction Rate Notes

Automatic Bar

Backward Pricing


Banks - Affiliated Mutual Funds

Banks - Collective Trust Funds

Banks - Investment Advisory Activities

Beneficial Ownership Qualified Purchaser

Board of Directors

Board of Directors - Retirement Plans


Broker Dealer - Special Compensation


Brokerage Activities


Business Development Companies

Business and Industrial Development Companies

Business Transfers

Capital Structures (BDC)

Cash Solicitation

Cash Solicitation - Solicitors

Change of Control

Charitable Exclusions

Clearing Agency

Closed-End Investment Companies

Code of Ethics

Collective Investment Trusts

Commercial Paper

Commodity Pools

Commodity Trading Advisors

Compliance Policies and Procedures Rule




Custodial Receipts

Custodial Requirements


Custody - Investment Advisers

Custody - Investment Companies

Defined Contribution Plans


Derivative Securities



Disqualification - Investment Companies


Distribution Fees

Distribution Plans


Eligible Foreign Custodian


Employee Benefit Plans

Employee Securities Companies


Exchange-Traded Funds (ETFs)

Exchange-Traded Products

Exchange Offer

Exchange Privilege

Exemptive Applications and Orders

Face-Amount Certificate


Fair Value Pricing

Family Office Exclusion

Fees & Expenses

Fidelity Bonds - Investment Companies

Fiduciary Duties

Filing - Dates

Filing Procedure - Fees

Filing Procedures

Finance Subsidiaries

Financial Statement

Floating Rate Securities

Foreign Banks

Foreign Custodian

Foreign Government Securities

Foreign Investment Advisers

Foreign Investment Companies

Form 13F

Forward Contract


Fraud - Investment Advisers Act

Funds of Funds - Affiliated

Funds of Funds - Foreign Investment Companies

Fund Supermarkets

Generic Comment Lette>Chief Financial Officer, November 1, 1994

Government Agency

Government Instrumentalities

Government Securities

Governmental Plans

Hedge Clauses

Hedge Funds

Hub and Spoke Funds

Illiquid Securities

Inadvertent Investment Companies

Independent Directors

Independent Legal Counsel

Independent Public Accountant


Inspections - Investment Advisers

Insurance Companies

Insurance Company Regulation

Insurance Products


Interested Person

Internationalization of Securities Markets


Interval Funds

Investment Advisers

Investment Advisers Act Status

Investment Advisers Act Status - Broker-Dealers

Investment Advisers Act Status - Publishers

Investment Adviser Registration

Investment Company

Investment Company Act Status

Investment Restrictions

Investment Securities

Joint Transactions


Liquidating Trusts

Limited Partnership Interest

Mergers and Reorganizations Combinations

Mini-account Program

Money Market Funds

Mixed and Shared Funding

Model Portfolio

Money Market Liquidity

Money Market - Liquidity Puts

Money Market Portfolio Valuation

Mortgages/Real Estate/REITs

Multiple Classes

Municipal Bond

Names - Misleading

National Securities Market Improvement Act of 1996

No-Action Request Procedures

Offshore Funds

Oil & Gas

Pay to Play

Periodic Payment Plan Certificate

Performance Allocation

Performance Fees

Personal Securities Transaction

Pre-Paid Tuition Plans

Pricing - Fair Value Pricing

Principal Transaction

Principal Underwriters

Private Investment Companies

Private Investment Companies - Attribution

Private Offering

Prospectuses - Delivery

Prospectuses - Disclosure

Proxy Statement

Proxy Voting

Public Offering

Public Utility Holding Companies

Qualified Purchase Definition - Investment Company Act Status Determination

Qualified Purchaser Fund

Real Estate

Real Estate Investment Trusts

Recordkeeping Requirements - Investment Advisers

Recordkeeping Requirements - Investment Adviser Separate Accounts

Recordkeeping Requirements - Investment Adviser Suitability

Recordkeeping Requirements - Investment Companies

Redeemable Securities

Redemption Fees



Registration - Investment Advisers

Registration - Investment Companies

Regulation S-P

Reimbursement of Proxy Expenses


Reporting Requirements - Investment Advisers

Reporting Requirements - Investment Companies

Repurchase Agreement

Reverse Repurchase Agreement

Safe Harbors

Sales Financing

Sales Load

Sales Load - Contingent Deferred

Sales of Fund Shares below NAV

Security - Definition

Securities Lending

Securities Related Business

Self Custody - Investment Companies

Senior Securities

Separate Accounts

Series Companies

Shareholder Meetings

Shareholder Proposals

Shareholders Votes

Short Sales or Short Selling

Soft Dollar Arrangements


Spin Offs Assignment

Stapled Securities

State Regulation

Status of Investment Company

Structured Financing

Student Loans


Successor registration


Tender Offers

Territorial Exemption

Tracking Stock

Transient Investment Company


Unit Investment Trust


Variable Annuities Contract

Variable Rate Securities

Voting Security

Voting Trust


Wrap Fee Arrangements

Alphabetical List of No-Action Letters

Chronological List of No-Action Letters

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