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Division of Investment Management
Staff No-Action and Interpretive 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 copy and processing fee. Please refer to information on How to Request Public Documents.
 Subject Categories
Subject Category List of No-Action Letters
Alphabetical List of No-Action Letters
Chronological List of No-Action Letters
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Subject Category List of No-Action Letters
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12b-1 Fees
12b-1 Plans
Acquisition of Securities in Affiliated Underwriting
Advertising — Investment Advisers
- The TCW Group, Inc., November 7, 2008
- Investment Adviser Association, December 2, 2005
- Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004
- Investment Counsel Association of America, Inc., March 1, 2004
- Jennison Associates LLC, July 6, 2000
Advertising — Investment Company
Advisory Contracts
- Fortis Group, et al., January 27, 2009
- First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008
- Mellon Equity Associates, LLP April 1, 2005
- Eaton Vance Special Investment Trust, et al March 30, 2004
- Gartmore Mutual Funds, March 19, 2004
- PIMCO Funds: Multi-Manager Series, August 6, 2002
- Metropolitan Life Insurance Company, November 13, 1999
- Wells Fargo Bank, N.A., March 31, 1998
Advisory Fees
- Constellation Financial Management LLC, January 9, 2003
- Seligman New Technologies Fund II, Inc., February 7, 2002
- R.O.C. Taiwan Fund, February 11, 2000
- BISYS Fund Services, Inc., September 2, 1999
Advisory Representatives
Affiliated Persons
Affiliated Transactions
- Mount Vernon Securities Lending Trust, January 8, 2009
- Columbia Funds, et al., December 23, 2008
- Master Portfolio Trust — Liquid Reserves Portfolio, December 8, 2008
- BNY Mellon Funds Trust, December 2, 2008
- Franklin Templeton Investments, November 21, 2008
- Reserve New York Municipal Money-Market Trust — New York Municipal Money-Market Fund, November 18, 2008
- SEI Daily Income Trust — Prime Obligation Fund, November 18, 2008
- Mount Vernon Securities Lending Trust, October 24, 2008
- Russell Investment Company, October 24, 2008
- USAA Mutual Funds Trust, October 22, 2008
- Columbia Funds Series Trust, October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- MainStay VP Cash Management Portfolio, October 22, 2008
- Morgan Stanley Institutional Liquidity Funds, October 22, 2008
- Morgan Stanley Money Market Funds, October 22, 2008
- Mount Vernon Securities Lending Trust, October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Phoenix Opportunities Trust, October 22, 2008
- RidgeWorth Funds, October 22, 2008
- Touchstone Variable Series Trust, October 22, 2008
- Advantus Series Fund, October 20, 2008
- Dreyfus Cash Management Plus, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Russell Investment Company, October 20, 2008
- Highbridge Statistical Market Neutral Fund, September 29, 2008
- Dreyfus Cash Management, et al., September 25, 2008
- Investment Company Institute, September 25, 2008
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 2008
- Northern Institutional Fund, July 16, 2008
- T. Rowe Price Associates, Inc., July 10, 2008
- Western Asset Money Market
Fund, June 27, 2008
- Western Asset Institutional Money Market
Fund, June 27, 2008
- Munder Series Trust, June 23, 2008
- HSBC Investor Funds, June 25, 2008
- Allianz Dresdner Daily Asset Fund, May 5, 2008
- Institutional Liquidity Trust, April 30, 2008
- ING Series Fund, Inc., et al., April 30, 2008
- Master Portfolio Trust, April 18, 2008
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Master Portfolio Trust, April 4, 2008
- SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008
- Northern Institutional Funds, February 28, 2008
- Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008
- HSBC Investor Funds, January 18, 2008
- STI Classic Funds, January 2, 2008
- TDAM Money Market Portfolio, December 21, 2007
- First American Funds, Inc. – Prime Obligation Fund, December 3, 2007
- SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007
- Old Mutual Advisors Funds, November 16, 2007
- SEI Daily Income Trust — Money Market Fund, November 9, 2007
- SEI Daily Income Trust — Prime Obligation Fund, November 8, 2007
- STI Classic Funds, October 26, 2007
- Van Kampen Funds Inc., January 31, 2007
- Gartmore Variable Insurance Trust, December 29, 2006
- GuideStone Financial, et al., December 27, 2006
- Federated Municipal Funds, November 20, 2006
- Merrill Lynch & Co., Inc., September 27, 2006
- Citigroup Global Markets, Inc., September 26, 2006
- Mutual of America Investment Corporation, June 2, 2006
- GE Institutional Funds, December 21, 2005
- Investment Company Institute, December 14, 2005
- Wells Fargo Alternative Asset Management, LLC, January 26, 2005
- Neuberger Berman Management Inc., et al., April 30, 2003
- 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
- Signature Financial Group, Inc., December 28, 1999
- Drinker, Biddle & Reath, December 18, 1998
Aggregated Transactions
Annual Reports
Asset-Backed Securities
Assignments
Auction Rate Notes
Backward Pricing
Banks
Beneficial Ownership Qualified Purchaser
Board of Directors — Retirement Plans
Business and Industrial Development Companies
Business Transfers
Cash Solicitation
- Citigroup Global Markets, Inc., December 23, 2008
- UBS Securities LLC/UBS Financial Services Inc., December 23, 2008
- Prudential Financial, Inc., September 5, 2008
- Mayer Brown LLP, July 28, 2008
- Barclays Bank PLC, June 6, 2007
- Emanuel J. Friedman and EJF Capital LLC, January 16, 2007
- Ameriprise Financial Services Inc., April 5, 2006
- Millennium Partners, L.P., et al, March 9, 2006
- American International Group, Inc., February 21, 2006
- ING Bank N.V., August 31, 2005
- CIBC Mellon Trust Company, February 24, 2005
- Goldman, Sachs & Co., February 23, 2005
- Morgan Stanley & Co., Inc., February 4, 2005
- American International Group, Inc., December 8, 2004
- Deutsche Bank Securities Inc., September 24, 2004
- Thomas Weisel Partners LLC, September 24, 2004
- J.P. Morgan Securities Inc., October 31, 2003
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- Goldman, Sachs & Company, October 31, 2003
- Lehman Brothers, October 31, 2003
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Bear, Stearns & Co. Inc., October 31, 2003
- Morgan Stanley & Company, October 31, 2003
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- James DeYoung, October 24, 2003
- J.P. Morgan Securities Inc., October 8, 2003
- Dougherty & Company LCC, July 3, 2003
- Fahnestock & Company Inc., April 21, 2003
- Dougherty & Company LLC, March 21, 2003
- Legg Mason Wood Walker, Inc., June 11, 2001
- National Football League Players Association, January 25, 2002
- Prudential Securities Inc., February 7, 2001
- Stephens Inc., December 27, 2001
Change of Control
Charitable Exclusions
- Goldman Sachs Asset Management, L.P., March 13, 2007
- American Bible Society, June 1, 2004
- Mercy Investment Program, Inc., June 12, 2003
- Daughters of Charity National Health System, Inc., April 3, 1998
Closed-End Investment Companies
Code of Ethics
Collective Investment Trusts
Commerical Paper
Compliance Policies and Procedures Rule
Consolidation
Control
Custodial Receipts
Custody - Investment Advisers
Custody - Investment Companies
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Austraclear Limited, April 28, 2004
- Fixed Income Clearing Corporation, March 13, 2003
- Government Securities Clearing Corporation, October 19, 2001
- Investment Company Institute, June 15, 1999
Definitions
Director
Disclosure
Distributions
Distribution Fees
Distribution Plans
Diversification
Eligible Foreign Custodian
Emergencies
Employee Benefit Plans
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Lear Corporation Retirement Savings Plan Trusts, March 16, 2007
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003
- Honeywell International Inc Savings Plan Trust, October 7, 2002
ETFs
Exchange Offer
Exemptive Applications and Orders
Face-Amount Certificate
Fees & Expenses
Fiduciary Duties
Filing Procedure - Fees
Finance Subsidiaries
Foreign Banks
Foreign Custodian
Foreign Government Securities
Forward Contract
Fraud
Fraud - Investment Advisers Act
Funds of Funds - Affiliated
- iShares Trust, et al., October 22, 2008
- Merrill Lynch & Co., Inc., September 27, 2006
- Principal Investors Fund Inc., May 13, 2005
- Neuberger Berman Management Inc., et al., April 30, 2003
- MassMutual Institutional Funds, Inc., October 19, 1998
Funds of Funds - Foreign Investment Companies
- ASA (Bermuda) Limited, December 13, 2006
- Alternative Investment Partners Absolute Return Fund STS, July 10, 2006
- France Growth Fund, Inc., July 15, 2003
- Man-Glenwood Lexington TEI, LLC and Man-Glenwood Lexington TEI, LDC, April 30, 2004
Fund Supermarkets
Government Instrumentalities
Government Securities
Hedge Clauses
Hedge Funds
- The Townsend Group, Inc., July 9, 2008
- ABA Subcommittee on Private Investment Entities, August 10, 2006
- ABA Subcommittee on Private Investment Entities, December 8, 2005
- The Goldman Sachs Group, Inc., March 8, 2005
Hub and Spoke Funds
Inadvertent Investment Companies
Independent Directors
Independent Legal Counsel
Inspections — Investment Advisers
Insurance Companies
Insurance Products
- IDS Life Insurance Company, et al., December 14, 2006
- American Home Assurance Company, et al., October 17, 2005
- GE Life and Annuity Assurance Company, June 25, 2004
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Acacia National Life Insurance Company, December 19, 2003
- 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 - American International Life Assurance Company of New York, November 6, 2001
- AIG Life Insurance Company, August 16, 2001
- Manufacturers Life Insurance Company, The, December 27, 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
- Credit Agricole Asset Management Alternative Investments, Inc., August 7, 2006
- Morgan, Lewis & Bockius LLP, November 17, 2005
- UBS Financial Services, Inc., September 29, 2005
- Ark Therapeutics Group plc, April 15, 2005
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- The Goldman Sachs Group, Inc., March 8, 2005
- Gulf Coast Venture Forum, Inc., August 21, 2002
- Thomson Financial Inc., July 10, 2002
- BISYS Fund Services, Inc., September 2, 1999
Investment Company
Investment Company Act Status
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Dexia Municipal Agency, December 26, 2007
- Exelon Corporation, September 13, 2007
- Cooley Godward & Kronish, July 12, 2007
- MACRO Securities Depositor, LLC, December 1, 2006
- Willkie Farr & Gallagher, October 23, 2000
- Pengrowth Energy Trust, January 27, 2000
- HOLDRs, September 3, 1999
- Mutual of Omaha Insurance Company, November 27, 1998
- Credit Suisse First Boston, September 9, 1998
Investment Restrictions
Investment Securities
Joint Transactions
- Highbridge Statistical Market Neutral Fund, September 29, 2008
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Neuberger Berman Management Inc., et al., April 30, 2003
- The Chase Manhattan Bank, July 24, 2001
- Investment Company Institute, April 15, 1998
Mergers and Reorganizations Combinations
- Janus Aspen Series, April 10, 2008
- CUNA Mutual Life Insurance Company, et al., December 27, 2007
- Ameritas Life Insurance Corp., April 5, 2007
- Mutual of America Investment Corporation, June 2, 2006
- GE Life and Annuity Assurance Company, June 25, 2004
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Acacia National Life Insurance Company, December 19, 2003
- 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
- Manufacturers Life Insurance Company, The, December 27, 2001
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- Nuveen Flagship Multistate Trust I, July 10, 1998
- Neuberger & Berman Income Funds, February 27, 1998
Money Market Funds
- Mount Vernon Securities Lending Trust, January 8, 2009
- Master Portfolio Trust — Liquid Reserves Portfolio, December 8, 2008
- Reserve New York Municipal Money-Market Trust — New York Municipal Money-Market Fund, November 18, 2008
- SEI Daily Income Trust — Prime Obligation Fund, November 18, 2008
- Mount Vernon Securities Lending Trust, October 24, 2008
- Russell Investment Company, October 24, 2008
- USAA Mutual Funds Trust, October 22, 2008
- MainStay VP Cash Management Portfolio, October 22, 2008
- Morgan Stanley Money Market Funds, October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Columbia Funds Series Trust, October 22, 2008
- J.P. Morgan Securities Inc., October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- Mount Vernon Securities Lending Trust, October 22, 2008
- Phoenix Opportunities Trust, October 22, 2008
- RidgeWorth Funds, October 22, 2008
- Touchstone Variable Series Trust, October 22, 2008
- Advantus Series Fund, October 20, 2008
- Dreyfus Cash Management Plus, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Russell Investment Company, October 20, 2008
- Investment Company Institute, October 10, 2008
- Investment Company Institute, October 8, 2008
- Investment Company Institute, September 25, 2008
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 2008
- Northern Institutional Fund, July 16, 2008
- Western Asset Money Market
Fund, June 27, 2008
- Western Asset Institutional Money Market
Fund, June 27, 2008
- HSBC Investor Funds, June 25, 2008
- Munder Series Trust, June 23, 2008
- Eaton Vance Management, June 13, 2008
- Allianz Dresdner Daily Asset Fund, May 5, 2008
- Master Portfolio Trust, April 18, 2008
- Master Portfolio Trust, April 4, 2008
- SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008
- Northern Institutional Funds, February 28, 2008
- Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008
- HSBC Investor Funds, January 18, 2008
- STI Classic Funds, January 2, 2008
- TDAM Money Market Portfolio, December 21, 2007
- First American Funds, Inc. – Prime Obligation Fund, December 3, 2007
- SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007
- SEI Daily Income Trust — Money Market Fund, November 9, 2007
- SEI Daily Income Trust — Prime Obligation Fund, November 8, 2007
- STI Classic Funds, October 26, 2007
- Evergreen Investment Management Company LLC, October 11, 2005
- Merrill Lynch Investment Managers, May 10, 2002
- AIM Advisors, Inc., February 12, 2002
- SSGA International Liquidity Fund, December 2, 1998
- ICI Mutual Insurance Company, July 27, 1998
- Investment Company Institute, April 15, 1998
Money Market Liquidity
Offshore Funds
Periodic Payment Plan Certificate
Performance Fees
- Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004
- Pacific Select Fund, et al., December 23, 2004
- Seligman New Technologies Fund II, Inc., February 7, 2002
Personal Securities Transaction
Pre-Paid Tuition Plans
Pricing — Fair Value Pricing
Principal Transaction
- Auction Rate Securities, January 6, 2009
- Barclays Capital Inc., September 19, 2008
- JPMorgan Chase; Bear Stearns Asset Management II, March 16, 2008
- Gardner Russo & Gardner, June 7, 2006
- Credit Suisse First Boston, LLC, August 31, 2005
Principal Underwriters
Private Investment Companies
- Frankin Templeton Group of Funds, et al., May 21, 1999
- American Bar Association, April 22, 1999
- Service Corporation International, October 6, 1998
- Lamp Technologies, Inc., May 29, 1998
Private Offering
Prospectuses — Delivery
Prospectuses — Disclosure
Proxy Voting
Public Offering
Public Utility Holding Companies
- Section 2(a)(3)
- Bonneville Power Administration, February 10, 2004
- RealEnergy, Inc., et al., August 12, 2003
- Dominion Equipment II, Inc., et al., March 25, 2003
- Juniper Capital L.P., June 23, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- Sections 2(a)(3) and 2(a)(7)
- EIF Neptune, LLC Starwood Energy Investors, LLC & Atlantic Energy Parts, July 29, 2005
- DTE Heritage, LLC, et. al., July 30, 2003
- Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003
- Sections 2(a)(7)
- Sections 2(a)(7) and 2(a)(11)(A)
- Section 17(c) and Rule 70
Qualified Purchase Definition - Investment Company Act Status Determination
- Cabot Wellington, LLC, June 17, 2008
- McDermott, Will & Emery, July 26, 2007
- Goldman Sachs Asset Management, L.P., March 13, 2007
- SCP Private Equity Partners II, L.P., June 6, 2006
- American Bar Association, April 22, 1999
Qualified Purchaser Fund
- The Townsend Group, Inc., July 9, 2008
- Cabot Wellington, LLC, June 17, 2008
- Goldman Sachs Asset Management, L.P., March 13, 2007
- Service Corporation International, October 6, 1998
Real Estate
Recordkeeping Requirements — Investment Advisers
Redeemable Securities
Redemption Fees
Redemptions
Registration
- IDS Life Insurance Company, et al., December 14, 2006
- 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
Registration — Investment Advisers
Registration — Investment Companies
- Exelon Corporation, September 13, 2007
- MACRO Securities Depositor, LLC, December 1, 2006
- Shee Atika Investments, LLC, January 20, 2004
- First Data Corporation, January 13, 2004
- Mercy Investment Program, Inc., June 12, 2003
- Metropolitan Insurance and Annuity Company, June 6, 2003
- Brown & Wood, February 24, 2000
Regulation S-P
Reimbursement of Proxy Expenses
Reorganization
Reporting Requirements — Investment Advisers
Reporting Requirements — Investment Companies
- NGP Capital Resources Company (Corrected), December 28, 2007
- American Home Assurance Company, et. al., October 17, 2005
- College and University Facility Loan Trust One, et al., November 29, 2004
- Westford Technology Ventures, L.P., January 28, 2004
- Equus Capital Partners L.P., November 14, 2003
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- Manufacturers Adviser Corp, September 10, 2002
- Select Sector SPDR Trust, May 6, 1999
Repurchase Agreement
Reverse Repurchase Agreement
Safe Harbors
Sales of Fund Shares below NAV
Security — Definition
Securities Lending
Self Custody - Investment Companies
Senior Securities
Separate Accounts
- First Great-West Life & Annuity Insurance Company & Canada Life Insurance Company of New York, December 22, 2005
- GE Life and Annuity Assurance Company, June 25, 2004
- Acacia National Life Insurance Company, December 19, 2003
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- 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
- Manufacturers Life Insurance Company, The, December 27, 2001
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- AIG Life Insurance Company, August 16, 2001
Shareholder Proposals
- American Capital, Ltd., February 5, 2009
- College Retirement Equities Fund, May 19, 2008
- Fidelity Funds, January 22, 2008
- Franklin Universal Trust, December 18, 2007
- Alliance World Dollar Government Fund, Inc., October 19, 2006
- Putnam Premier Income Trust, March 14, 2006
- Putnam High Income Securities Fund, March 14, 2006
- Putnam Tax-Free Health Care Fund, August 8, 2005
- Fidelity Magellan Fund, March 15, 2005
- Medallion Financial Corp., May 11, 2004
- Tri-Continental Corporation, March 15, 2004
- Robert P. Laukat Regarding Tri-Continental Corporation , March 15, 2004
- The New Ireland Fund, Inc., March 15, 2004
- College Retirement Equities Fund - Stone, May 3, 2004
- College Retirement Equities Fund - Belth, May 3, 2004
- College Retirement Equities Fund - Fuller, May 3, 2004
- College Retirement Equities Fund - Buchman, May 3, 2004
- Tri-Continental Corporation, March 25, 2003
- MuniYield Insured Fund, Inc., March 11, 2002
- Asia Tiger Fund, Inc., The, January 31, 2002
- Pioneer Interest Shares, June 20, 2001
- Asia Pacific Fund, Inc (The), June 8, 2001
- Asia Tiger Fund, Inc., The, December 28, 2001
- 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
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
Shareholders Votes
- First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008
- Swiss Helvetia Fund, Inc., March 6, 2001
- R.O.C. Taiwan Fund, February 11, 2000
- Wells Fargo Bank, N.A., March 31, 1998
Short Sales or Short Selling
Solicitors
State Regulation
Structured Financing
Student Loans
Subsidiaries
Successor registration
Taxation
Tender Offers
Tracking Stock
Transient Investment Company
Voting Security
Voting Trust
Wrap Fee Arrangements
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Alphabetical List of No-Action Letters
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- AAL Mutual Funds, et al., December 12, 2002
- ABA Subcommittee on Private Investment Entities, August 10, 2006
- ABA Subcommittee on Private Investment Entities, December 8, 2005
- Aberdeen Australia Equity Fund, Inc., July 13, 2006
- Acacia National Life Insurance Company, December 19, 2003
- Advantus Series Fund, October 20, 2008
- 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
- AIM Advisors, Inc., February 12, 2002
- Alliance World Dollar Government Fund, Inc., October 19, 2006
- Allianz Dresdner Daily Asset Fund, May 5, 2008
- Allstate Life Insurance Company, December 23, 2002
- Alternative Investment Partners Absolute Return Fund STS, July 10, 2006
- American Bar Association, April 22, 1999
- American Bible Society, June 1, 2004
- American Capital, Ltd., February 5, 2009
- American Enterprise Life Insurance Company, April 30, 2002
- Ameritas Life Insurance Corp., April 5, 2007
- Arizona Electric Power Cooperative Inc., July 27, 2001
- American Home Assurance Company, et. al., October 17, 2005
- American International Group, Inc., February 21, 2006
- American International Group, Inc., December 8, 2004
- American Skandia Life Assurance Corporation, May 16, 2005
- Ameriprise Financial Services Inc., April 5, 2006
- Ark Therapeutics Group plc, April 15, 2005
- ASA (Bermuda) Limited, December 13, 2006
- 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
- Auction Rate Securities, January 6, 2009
- Austraclear Limited, April 28, 2004
- Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002
- Barclays Capital Inc., September 19, 2008
- Bear, Stearns & Co. Inc., October 31, 2003
- BISYS Fund Services, Inc., September 2, 1999
- BNY Mellon Funds Trust, December 2, 2008
- Bonneville Power Administration, February 10, 2004
- Brown & Wood, February 24, 2000
- Cabot Wellington, LLC, June 17, 2008
- Calvert Social Index Fund, September 24, 2001
- Cantor Fitzgerald & Company, February 17, 2004
- Capital Trust, Inc., February 3, 2009
- Capital Trust, Inc., May 24, 2007
- The Chase Manhattan Bank, July 24, 2001
- Chase Manhattan Bank, June 12, 1998
- CIBC Mellon Trust Company, February 24, 2005
- Citigroup Global Markets, Inc., December 23, 2008
- Citigroup Global Markets, Inc., September 26, 2006
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- Citigroup Inc., July 26, 2006
- College and University Facility Loan Trust One, et al., November 29, 2004
- College Retirement Equities Fund, May 19, 2008
- College Retirement Equities Fund - Stone, May 3, 2004
- College Retirement Equities Fund - Belth, May 3, 2004
- College Retirement Equities Fund - Fuller, May 3, 2004
- College Retirement Equities Fund - Buchman, May 3, 2004
- Columbia Funds, et al., December 23, 2008
- Columbia Funds Series Trust, October 22, 2008
- Comdisco, Inc., October 25, 2000
- Constellation Financial Management LLC, January 9, 2003
- Cooley Godward & Kronish, July 12, 2007
- Credit Agricole Asset Management Alternative Investments, Inc., August 7, 2006
- Credit Suisse First Boston, LLC, August 31, 2005
- Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003
- Credit Suisse First Boston, September 9, 1998
- CUNA Mutual Life Insurance Company, et al., December 27, 2007
- Current Income Shares, Inc., July 10, 2001
- Daughters of Charity National Health System, Inc., April 3, 1998
- Defined Asset Funds, December 23, 1998
- Deloitte & Touche LLP, August 28, 2006
- Deutsche Bank Securities Inc., September 24, 2004
- Dexia Municipal Agency, December 26, 2007
- Dominion Equipment II, Inc., et al., March 25, 2003
- Dougherty & Company LCC, July 3, 2003
- Dougherty & Company LLC, March 21, 2003
- Dreyfus Cash Management Plus, October 20, 2008
- Dreyfus Cash Management, et al., September 25, 2008
- Dreyfus Money Funds, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Drinker, Biddle & Reath, December 18, 1998
- DTE Heritage, LLC, et. al., July 30, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- Eaton Vance Management, June 13, 2008
- Eaton Vance Special Investment Trust, et al March 30, 2004
- Egan-Jones Proxy Services, May 27, 2004
- EIF Neptune, LLC Starwood Energy Investors, LLC & Atlantic Energy Parts, July 29, 2005
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- Enron Corporation, March 11, 2004
- Equus Capital Partners L.P., November 14, 2003
- E*TRADE Securities, LLC, November 30, 2005
- Evercore METC Investment Inc., et. al., November 25, 2003
- Evergreen Investment Management Company LLC, October 11, 2005
- Evergreen Investment Management Company, LLC, February 13, 2002
- Exelon Corporation, September 13, 2007
- Fahnestock & Company Inc., April 21, 2003
- Federal Home Loan Mortgage Corporation, July 12, 2002
- Federal National Mortgage Association, July 12, 2002
- Federated Core Trust II, L.P., February 6, 2002
- Federated Municipal Funds, November 20, 2006
- Fidelity Select Portfolio, April 29, 2008
- Fidelity Advisor Korea Fund, Inc, March 7, 2001
- Fidelity Funds, January 22, 2008
- Fidelity Magellan Fund, March 15, 2005
- First American Funds, Inc. – Prime Obligation Fund, December 3, 2007
- The First Australia Fund, Inc., July 29, 1999
- First Data Corporation, January 13, 2004
- First Great-West Life & Annuity Insurance Company & Canada Life Insurance Company of New York, December 22, 2005
- First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008
- Fixed Income Clearing Corporation, March 13, 2003
- Fixed Income Securities, L.P., April 29, 2004
- Fortis Group, et al., January 27, 2009
- France Growth Fund, Inc., April 6, 2001
- France Growth Fund, Inc., July 15, 2003
- 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
- Frankin Templeton Group of Funds, et al., May 21, 1999
- Franklin Templeton Investments, November 21, 2008
- Franklin Universal Trust, December 18, 2007
- Emanuel J. Friedman and EJF Capital LLC, January 16, 2007
- Gardner Russo & Gardner, June 7, 2006
- Gartmore Mutual Funds, March 19, 2004
- Gartmore Variable Insurance Trust, December 29, 2006
- GE Institutional Funds, December 21, 2005
- GE Life and Annuity Assurance Company, June 25, 2004
- General Electric Capital Corporation, April 26, 2002
- General Motors Investment Management, February 20, 2000
- Goldman, Sachs & Co., February 23, 2005
- Goldman, Sachs & Company, October 31, 2003
- Goldman Sachs Asset Management, L.P., March 13, 2007
- The Goldman Sachs Group, Inc., March 8, 2005
- Goldman Sachs Trust, August 19, 2008
- Goodwin, Procter & Hoar, October 5, 1998
- Government Securities Clearing Corporation, October 19, 2001
- GuideStone Financial, et al., December 27, 2006
- Gulf Coast Venture Forum, Inc., August 21, 2002
- H.E.B. Investment and Retirement Plan (H.E. Butt Grocery Company), May 18, 2001
- Heitman Capital Management, LLC, February 12, 2007
- Highbridge Statistical Market Neutral Fund, September 29, 2008
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- HOLDRs, September 3, 1999
- Honeywell International Inc Savings Plan Trust, October 7, 2002
- HSBC Investor Funds, June 25, 2008
- HSBC Investor Funds, January 18, 2008
- ICI Mutual Insurance Company, July 27, 1998
- IDS Life Insurance Company, et al., December 14, 2006
- ING Bank N.V., August 31, 2005
- ING Bank, N.V., July 8, 2002
- ING Bank N.V., et al., May 24, 1999
- ING Mutual Funds Management Co. LLC; ING Funds Distributors Inc. and Reich & Tang Distributors Inc., February 9, 2001
- ING Series Fund, Inc., et al, April 30, 2008
- Institutional Liquidity Trust, April 30, 2008
- Institutional Shareholder Services, Inc., September 15, 2004
- Investec Ernst & Company, April 24, 2001
- Investment Adviser Association, September 20, 2007
- Investment Adviser Association, December 2, 2005
- Investment Company Institute, October 10, 2008
- Investment Company Institute, October 8, 2008
- Investment Company Institute, September 25, 2008
- Investment Company Institute, February 1, 2007
- Investment Company Institute, December 14, 2005
- Investment Company Institute, November 10, 2004
- Investment Company Institute, February 12, 2002
- Investment Company Institute, December 8, 1999
- Investment Company Institute, June 15, 1999
- Investment Company Institute, October 30, 1998
- Investment Company Institute, April 15, 1998
- Investment Company Institute and the Global Custodians, February 19, 1998
- Investment Counsel Association of America, Inc., March 1, 2004
- iShares Trust, et al., October 22, 2008
- JPMorgan Chase; Bear Stearns Asset Management I,, July 14, 2008
- JPMorgan Chase; Bear Stearns Asset Management II, March 16, 2008
- J.P. Morgan Securities Inc., October 22, 2008
- J.P. Morgan Securities Inc., October 8, 2003
- J.P. Morgan Securities Inc., October 31, 2003
- James DeYoung, October 24, 2003
- Janus Aspen Series, April 10, 2008
- Jennison Associates LLC, July 6, 2000
- Juniper Capital L.P., June 23, 2003
- k1 Ventures, et. al., July 28, 2003
- Kirkpatrick & Lockhart LLP, January 28, 2004
- Lamp Technologies, Inc., May 29, 1998
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- Lear Corporation Retirement Savings Plan Trusts, March 16, 2007
- Legg Mason Partners Institutional Trust, October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- Legg Mason Wood Walker, Inc., June 11, 2001
- Lehman Brothers, October 31, 2003
- 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
- Lockheed Martin Investment Management Company, June 6, 2006
- Longleaf Partners Funds Trust, April 9, 2001
- M&G Investment Management Ltd., March 1, 2007
- Mackenzie Investment Managment et al., August 8, 2000
- MACRO Securities Depositor, LLC, December 1, 2006
- Mahaffy, Edward , March 6, 2003
- MainStay VP Cash Management Portfolio, October 22, 2008
- Man-Glenwood Lexington TEI, LLC and Man-Glenwood Lexington TEI, LDC, April 30, 2004
- Manufacturers Adviser Corp, September 10, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
- Massachusetts Mutual Life, June 7, 2000
- MassMutual Institutional Funds, Inc., October 19, 1998
- Master Portfolio Trust — Liquid Reserves Portfolio, December 8, 2008
- Master Portfolio Trust, April 18, 2008
- Master Portfolio Trust, April 4, 2008
- Maxim Series Fund Inc., January 14, 2004
- Mayer Brown LLP, July 28, 2008
- McDermott, Will & Emery, July 26, 2007
- Medallion Financial Corp., May 11, 2004
- Mellon Equity Associates, LLP April 1, 2005
- Mercy Investment Program, Inc., June 12, 2003
- Merrill Lynch & Co., Inc., September 27, 2006
- Merrill Lynch Investment Managers, May 10, 2002
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Metropolitan Insurance and Annuity Company, June 6, 2003
- Metropolitan Life Insurance Company, November 13, 1999
- Mexico Equity and Income Fund, The, November 15, 2001
- Millennium Partners, L.P., et al, March 9, 2006
- Missouri Bankers Association, August 18, 2008
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- Morgan, Lewis & Bockius LLP, November 17, 2005
- Morgan Stanley & Co., Inc., February 4, 2005
- Morgan Stanley Institutional Liquidity Funds, October 22, 2008
- Morgan Stanley Money Market Funds, October 22, 2008
- Moscow Municipal Bank, April 8, 1998
- Mount Vernon Securities Lending Trust, January 8, 2009
- Mount Vernon Securities Lending Trust, October 24, 2008
- Mount Vernon Securities Lending Trust, October 22, 2008
- MTB Group of Funds, October 21, 2003
- Munder Series Trust, June 23, 2008
- MuniYield Insured Fund, Inc., March 11, 2002
- Mutual Fund Directors Forum, May 9, 2002
- Mutual of America Investment Corporation, June 2, 2006
- Mutual of Omaha Insurance Company, November 27, 1998
- National Association for Variable Annunities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001
- National Compliance Service, November 30, 2005
- National Football League Players Association, January 25, 2002
- Nationwide Life Insurance Company, March 16, 2001
- Nebraska Higher Education Loan Program, April 3, 1998
- Neuberger Berman Management Inc., et al., April 30, 2003
- Neuberger & Berman Income Funds, February 27, 1998
- New Center Asset Trust, November 5, 1998
- New England Education Loan Marketing Corp, May 22, 1998
- NGP Capital Resources Company (Corrected), December 28, 2007
- Northern Institutional Fund, July 16, 2008
- Northern Institutional Funds, February 28, 2008
- Nuveen Flagship Multistate Trust I, July 10, 1998
- Nuveen Virginia Premium Income Municipal Fund, October 6, 2006
- Old Dominion Electric Cooperative, et al., October 13, 2004
- Old Mutual Advisors Funds, November 16, 2007
- One Point Communications Corp, June 12, 1998
- Pacific Select Fund, et al., December 23, 2004
- Pengrowth Energy Trust, January 27, 2000
- Peninsular & Oriental Steam Navigation Company, October 15, 2003
- Penn Series Funds Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Phoenix Opportunities Trust, October 22, 2008
- PIMCO Funds: Multi-Manager Series, August 6, 2002
- PIMCO Funds, July 9, 2002
- Pioneer Funds, December 20, 2005
- Pioneer Interest Shares, June 20, 2001
- Plymouth Commercial Mortgage Fund, July 13, 1998
- Principal Investors Fund Inc., May 13, 2005
- Prudential Financial, Inc., September 5, 2008
- Prudential Insurance Company of America, March 1, 2005
- Prudential Investment Management Services LLC, April 19, 2001
- Prudential Securities Incorporated, February 7, 2001
- Public Employees' Retirement Board of the State of Oregon, March 3, 1998
- Putnam High Income Securities Fund, March 14, 2006
- Putnam Premier Income Trust, March 14, 2006
- Putnam Tax-Free Health Care Fund, August 8, 2005
- RealEnergy, Inc., et al., August 12, 2003
- ReFlow Fund, LLC, July 15, 2002
- Reserve Bank of Australia, January 30, 1998
- Reserve New York Municipal Money-Market Trust — New York Municipal Money-Market Fund, November 18, 2008
- RidgeWorth Funds, October 22, 2008
- R.O.C. Taiwan Fund, February 11, 2000
- Royal Dutch Shell plc, May 17, 2005
- Russell Investment Company, October 24, 2008
- Russell Investment Company, October 20, 2008
- Safra Republic Holdings, April 21, 1998
- Salomon Brothers Asset Management Inc and Salomon Brothers Asset Management Asia Pacific Limited, July 23, 1999
- SCP Private Equity Partners II, L.P., June 6, 2006
- SEI Daily Income Trust — Prime Obligation Fund, November 18, 2008
- SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008
- SEI Daily Income Trust — Money Market Fund, November 9, 2007
- SEI Daily Income Trust — Prime Obligation Fund, November 8, 2007
- SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007
- Select Sector SPDR Trust, May 6, 1999
- Seligman New Technologies Fund II, Inc., February 7, 2002
- Service Corporation International, October 6, 1998
- Seward & Kissel, October 12, 2005
- Shee Atika Investments, LLC, January 20, 2004
- Signature Financial Group, Inc., December 28, 1999
- Societatea Nationala de Compensare, January 28, 1998
- SSGA International Liquidity Fund, December 2, 1998
- Staff Responses to Questions About Regulation S-P, January 23, 2003
- Stephens Inc., December 27, 2001
- STI Classic Funds, January 2, 2008
- STI Classic Funds, October 26, 2007
- Stock Holding Corporation of Indian Ltd., January 21, 1998
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- Swiss Helvetia Fund, Inc., March 6, 2001
- The TCW Group, Inc., November 7, 2008
- TDAM Money Market Portfolio, December 21, 2007
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
- Thomas Weisel Partners LLC, September 24, 2004
- Thomson Financial Inc., July 10, 2002
- The Townsend Group, Inc., July 9, 2008
- Touchstone Variable Series Trust, October 22, 2008
- Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004
- Tri-Continental Corporation, March 25, 2003
- Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003
- T. Rowe Price Associates, Inc., July 10, 2008
- Trusts under the Will of Marion Searle, March 29, 2005
- Tuition Plan Consortium, LLP, February 4, 2003
- UAM Inc., September 24, 2001
- UBS Financial Services, Inc., September 29, 2005
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- UBS Securities LLC/UBS Financial Services Inc., December 23, 2008
- USB Global Asset Management (US), Inc., November 21, 2002
- USAA Mutual Funds Trust, October 22, 2008
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- U.S. Bancorp Asset Management Inc., et al., December 11, 2001
- Van Kampen Funds Inc., January 31, 2007
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 2008
- Washington Capital Joint Master Trust, September 25, 2006
- Wells Fargo Alternative Asset Management, LLC, January 26, 2005
- Wells Fargo Bank, N.A., March 31, 1998
- Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008
- Westford Technology Ventures, L.P., January 28, 2004
- Western Asset Money Market
Fund, June 27, 2008
- Western Asset Institutional Money Market
Fund, June 27, 2008
- Western Farmers Electric Cooperative, February 23, 2001
- Willkie Farr & Gallagher, October 23, 2000
- Wilmer, Cutler & Pickering and Davis Polk & Wardell, October 5, 1998
- Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001
|
Chronological List of No-Action Letters
|
- American Capital, Ltd., February 5, 2009
- Capital Trust, Inc., February 3, 2009
- Fortis Group, et al., January 27, 2009
- Mount Vernon Securities Lending Trust, January 8, 2009
- Auction Rate Securities, January 6, 2009
- Citigroup Global Markets, Inc., December 23, 2008
- Columbia Funds, et al., December 23, 2008
- UBS Securities LLC/UBS Financial Services Inc., December 23, 2008
- Master Portfolio Trust — Liquid Reserves Portfolio, December 8, 2008
- BNY Mellon Funds Trust, December 2, 2008
- Franklin Templeton Investments, November 21, 2008
- Reserve New York Municipal Money-Market Trust — New York Municipal Money-Market Fund, November 18, 2008
- SEI Daily Income Trust — Prime Obligation Fund, November 18, 2008
- The TCW Group, Inc., November 7, 2008
- Mount Vernon Securities Lending Trust, October 24, 2008
- Russell Investment Company, October 24, 2008
- USAA Mutual Funds Trust, October 22, 2008
- Columbia Funds Series Trust, October 22, 2008
- iShares Trust, et al., October 22, 2008
- J.P. Morgan Securities Inc., October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- Legg Mason Partners Institutional Trust, October 22, 2008
- MainStay VP Cash Management Portfolio, October 22, 2008
- Morgan Stanley Institutional Liquidity Funds, October 22, 2008
- Morgan Stanley Money Market Funds, October 22, 2008
- Mount Vernon Securities Lending Trust, October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Penn Series Funds Inc., October 22, 2008
- Phoenix Opportunities Trust, October 22, 2008
- RidgeWorth Funds, October 22, 2008
- Touchstone Variable Series Trust, October 22, 2008
- Advantus Series Fund, October 20, 2008
- Dreyfus Cash Management Plus, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Dreyfus Money Funds, October 20, 2008
- Russell Investment Company, October 20, 2008
- Investment Company Institute, October 10, 2008
- Investment Company Institute, October 8, 2008
- Highbridge Statistical Market Neutral Fund, September 29, 2008
- Dreyfus Cash Management, et al., September 25, 2008
- Investment Company Institute, September 25, 2008
- Barclays Capital Inc., September 19, 2008
- Prudential Financial, Inc., September 5, 2008
- Goldman Sachs Trust, August 19, 2008
- Missouri Bankers Association, August 18, 2008
- Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 2008
- Mayer Brown LLP, July 28, 2008
- Northern Institutional Fund, July 16, 2008
- JPMorgan Chase; Bear Stearns Asset Management I, July 14, 2008
- First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008
- T. Rowe Price Associates, Inc., July 10, 2008
- The Townsend Group, Inc., July 9, 2008
- Western Asset Money Market
Fund, June 27, 2008
- Western Asset Institutional Money Market
Fund, June 27, 2008
- HSBC Investor Funds, June 25, 2008
- Munder Series Trust, June 23, 2008
- Cabot Wellington, LLC, June 17, 2008
- Emeriti Consortium for Retirement Health Solutions, June 16, 2008
- Eaton Vance Management, June 13, 2008
- College Retirement Equities Fund, May 19, 2008
- Allianz Dresdner Daily Asset Fund, May 5, 2008
- Institutional Liquidity Trust, April 30, 2008
- ING Series Fund, Inc., et al, April 30, 2008
- Fidelity Select Portfolio, April 29, 2008
- Master Portfolio Trust, April 18, 2008
- Janus Aspen Series, April 10, 2008
- Highbridge Statistical Market Neutral Fund, April 7, 2008
- Master Portfolio Trust, April 4, 2008
- JPMorgan Chase; Bear Stearns Asset Management II, March 16, 2008
- SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008
- Northern Institutional Funds, February 28, 2008
- Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008
- Fidelity Funds, January 22, 2008
- HSBC Investor Funds, January 18, 2008
- STI Classic Funds, January 2, 2008
- NGP Capital Resources Company (Corrected), December 28, 2007
- CUNA Mutual Life Insurance Company, et al., December 27, 2007
- Dexia Municipal Agency, December 26, 2007
- TDAM Money Market Portfolio, December 21, 2007
- Franklin Universal Trust, December 18, 2007
- First American Funds, Inc. – Prime Obligation Fund, December 3, 2007
- SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007
- Old Mutual Advisors Funds, November 16, 2007
- SEI Daily Income Trust — Money Market Fund, November 9, 2007
- SEI Daily Income Trust — Prime Obligation Fund, November 8, 2007
- STI Classic Funds, October 26, 2007
- Investment Adviser Association, September 20, 2007
- Exelon Corporation, September 13, 2007
- McDermott, Will & Emery, July 26, 2007
- Cooley Godward & Kronish, July 12, 2007
- Capital Trust, Inc., May 24, 2007
- Ameritas Life Insurance Corp., April 5, 2007
- Lear Corporation Retirement Savings Plan Trusts, March 16, 2007
- Goldman Sachs Asset Management, L.P., March 13, 2007
- M&G Investment Management Ltd., March 1, 2007
- Heitman Capital Management, LLC, February 12, 2007
- Investment Company Institute, February 1, 2007
- Van Kampen Funds Inc., January 31, 2007
- Emanuel J. Friedman and EJF Capital LLC, January 16, 2007
- Gartmore Variable Insurance Trust, December 29, 2006
- GuideStone Financial, et al., December 27, 2006
- IDS Life Insurance Company, et al., December 14, 2006
- ASA (Bermuda) Limited, December 13, 2006
- MACRO Securities Depositor, LLC, December 1, 2006
- Federated Municipal Funds, November 20, 2006
- Alliance World Dollar Government Fund, Inc., October 19, 2006
- Nuveen Virginia Premium Income Municipal Fund, October 6, 2006
- Merrill Lynch & Co., Inc., September 27, 2006
- Citigroup Global Markets, Inc., September 26, 2006
- Washington Capital Joint Master Trust, September 25, 2006
- Deloitte & Touche LLP, August 28, 2006
- ABA Subcommittee on Private Investment Entities, August 10, 2006
- Credit Agricole Asset Management Alternative Investments, Inc., August 7, 2006
- Citigroup Inc., July 26, 2006
- Aberdeen Australia Equity Fund, Inc., July 13, 2006
- Alternative Investment Partners Absolute Return Fund STS, July 10, 2006
- Gardner Russo & Gardner, June 7, 2006
- SCP Private Equity Partners II, L.P., June 6, 2006
- Lockheed Martin Investment Management Company, June 6, 2006
- Mutual of America Investment Corporation, June 2, 2006
- Ameriprise Financial Services Inc., April 5, 2006
- Putnam Premier Income Trust, March 14, 2006
- Putnam High Income Securities Fund, March 14, 2006
- Millennium Partners, L.P., et al, March 9, 2006
- American International Group, Inc., February 21, 2006
- First Great-West Life & Annuity Insurance Company & Canada Life Insurance Company of New York, December 22, 2005
- GE Institutional Funds, December 21, 2005
- Pioneer Funds, December 20, 2005
- Investment Company Institute, December 14, 2005
- ABA Subcommittee on Private Investment Entities, December 8, 2005
- Investment Adviser Association, December 2, 2005
- National Compliance Service, November 30, 2005
- E*TRADE Securities, LLC, November 30, 2005
- Morgan, Lewis & Bockius LLP, November 17, 2005
- American Home Assurance Company, et. al., October 17, 2005
- Seward & Kissel, October 12, 2005
- Evergreen Investment Management Company LLC, October 11, 2005
- UBS Financial Services, Inc., September 29, 2005
- Credit Suisse First Boston, LLC, August 31, 2005
- ING Bank N.V., August 31, 2005
- Putnam Tax-Free Health Care Fund, August 8, 2005
- EIF Neptune, LLC Starwood Energy Investors, LLC & Atlantic Energy Parts, July 29, 2005
- Royal Dutch Shell plc, May 17, 2005
- American Skandia Life Assurance Corporation, May 16, 2005
- Principal Investors Fund Inc., May 13, 2005
- Ark Therapeutics Group plc, April 15, 2005
- Emeriti Consortium for Retirement Health Solutions, April 7, 2005
- Mellon Equity Associates, LLP April 1, 2005
- Trusts under the Will of Marion Searle, March 29, 2005
- Fidelity Magellan Fund, March 15, 2005
- The Goldman Sachs Group, Inc., March 8, 2005
- Prudential Insurance Company of America, March 1, 2005
- CIBC Mellon Trust Company, February 24, 2005
- Goldman, Sachs & Co., February 23, 2005
- Morgan Stanley & Co., Inc., February 4, 2005
- Wells Fargo Alternative Asset Management, LLC, January 26, 2005
- Pacific Select Fund, et al., December 23, 2004
- American International Group, Inc., December 8, 2004
- Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004
- College and University Facility Loan Trust One, et al., November 29, 2004
- Investment Company Institute, November 10, 2004
- Old Dominion Electric Cooperative, et al., October 13, 2004
- Deutsche Bank Securities Inc., September 24, 2004
- Thomas Weisel Partners LLC, September 24, 2004
- Institutional Shareholder Services, Inc., September 15, 2004
- GE Life and Annuity Assurance Company, June 25, 2004
- American Bible Society, June 1, 2004
- Egan-Jones Proxy Services, May 27, 2004
- Medallion Financial Corp., May 11, 2004
- College Retirement Equities Fund - Stone, May 3, 2004
- College Retirement Equities Fund - Belth, May 3, 2004
- College Retirement Equities Fund - Fuller, May 3, 2004
- College Retirement Equities Fund - Buchman, May 3, 2004
- Man-Glenwood Lexington TEI, LLC and Man-Glenwood Lexington TEI, LDC, April 30, 2004
- Fixed Income Securities, L.P., April 29, 2004
- Austraclear Limited, April 28, 2004
- Eaton Vance Special Investment Trust, et al March 30, 2004
- Dominion Equipment II, Inc., et al., March 25, 2003
- Gartmore Mutual Funds, March 19, 2004
- Enron Corporation, March 11, 2004
- Investment Counsel Association of America, Inc., March 1, 2004
- Cantor Fitzgerald & Company, February 17, 2004
- Bonneville Power Administration, February 10, 2004
- Kirkpatrick & Lockhart LLP, January 28, 2004
- Westford Technology Ventures, L.P., January 28, 2004
- Shee Atika Investments, LLC, January 20, 2004
- Maxim Series Fund Inc., January 14, 2004
- First Data Corporation, January 13, 2004
- Acacia National Life Insurance Company, December 19, 2003
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Evercore METC Investment Inc., et. al., November 25, 2003
- Equus Capital Partners L.P., November 14, 2003
- J.P. Morgan Securities Inc., October 31, 2003
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- Goldman, Sachs & Company, October 31, 2003
- Lehman Brothers, October 31, 2003
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Bear, Stearns & Co. Inc., October 31, 2003
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- James DeYoung, October 24, 2003
- MTB Group of Funds, October 21, 2003
- Peninsular & Oriental Steam Navigation Company, October 15, 2003
- J.P. Morgan Securities Inc., October 8, 2003
- Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003
- RealEnergy, Inc., et al., August 12, 2003
- DTE Heritage, LLC, et. al., July 30, 2003
- France Growth Fund, Inc., July 15, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- Dougherty & Company LCC, July 3, 2003
- Juniper Capital L.P., June 23, 2003
- Mercy Investment Program, Inc., June 12, 2003
- Metropolitan Insurance and Annuity Company, June 6, 2003
- Neuberger Berman Management Inc., et al., April 30, 2003
- Fahnestock & Company Inc., April 21, 2003
- Tri-Continental Corporation, March 25, 2003
- Dougherty & Company LLC, March 21, 2003
- Fixed Income Clearing Corporation, March 13, 2003
- Edward Mahaffy, March 6, 2003
- 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
- Staff Responses to Questions About Regulation S-P, January 23, 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
- k1 Ventures, et. al., July 28, 2003
- 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
- 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
- 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
- Comdisco, Inc., October 25, 2000
- Willkie Farr & Gallagher, October 23, 2000
- Mackenzie Investment Managment et al., August 8, 2000
- Jennison Associates LLC, July 6, 2000
- Massachusetts Mutual Life, June 7, 2000
- Brown & Wood, February 24, 2000
- General Motors Investment Management, February 20, 2000
- R.O.C. Taiwan Fund, February 11, 2000
- Pengrowth Energy Trust, January 27, 2000
- Signature Financial Group, Inc., December 28, 1999
- Investment Company Institute, December 8, 1999
- Metropolitan Life Insurance Company, November 13, 1999
- HOLDRs, September 3, 1999
- BISYS Fund Services, Inc., September 2, 1999
- The First Australia Fund, Inc., July 29, 1999
- Salomon Brothers Asset Management Inc and Salomon Brothers Asset Management Asia Pacific Limited, July 23, 1999
- Investment Company Institute, June 15, 1999
- ING Bank N.V., et al., May 24, 1999
- Frankin Templeton Group of Funds, et al., May 21, 1999
- Select Sector SPDR Trust, May 6, 1999
- American Bar Association, April 22, 1999
- Defined Asset Funds, December 23, 1998
- Drinker, Biddle & Reath, December 18, 1998
- SSGA International Liquidity Fund, December 2, 1998
- Mutual of Omaha Insurance Company, November 27, 1998
- New Center Asset Trust, November 5, 1998
- Investment Company Institute, October 30, 1998
- MassMutual Institutional Funds, Inc., October 19, 1998
- Service Corporation International, October 6, 1998
- Goodwin, Procter & Hoar, October 5, 1998
- Wilmer, Cutler & Pickering and Davis Polk & Wardell, October 5, 1998
- Credit Suisse First Boston, September 9, 1998
- ICI Mutual Insurance Company, July 27, 1998
- Plymouth Commercial Mortgage Fund, July 13, 1998
- Nuveen Flagship Multistate Trust I, July 10, 1998
- Chase Manhattan Bank, June 12, 1998
- One Point Communications Corp, June 12, 1998
- Lamp Technologies, Inc., May 29, 1998
- New England Education Loan Marketing Corp, May 22, 1998
- Safra Republic Holdings, April 21, 1998
- Investment Company Institute, April 15, 1998
- Moscow Municipal Bank, April 8, 1998
- Daughters of Charity National Health System, Inc., April 3, 1998
- Nebraska Higher Education Loan Program, April 3, 1998
- Wells Fargo Bank, N.A., March 31, 1998
- Public Employees' Retirement Board of the State of Oregon, March 3, 1998
- Neuberger & Berman Income Funds, February 27, 1998
- Investment Company Institute and the Global Custodians, February 19, 1998
- Reserve Bank of Australia, January 30, 1998
- Societatea Nationala de Compensare, January 28, 1998
- Stock Holding Corporation of Indian Ltd., January 21, 1998
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