[18120]
November 5, 2004
TO: BOARD OF GOVERNORS No. 70-04
CHIEF COMPLIANCE OFFICER COMMITTEE No. 18-04
CLOSED-END INVESTMENT COMPANY MEMBERS No. 71-04
COMPLIANCE ADVISORY COMMITTEE No. 103-04
INVESTMENT ADVISER ASSOCIATE MEMBERS No. 11-04
INVESTMENT ADVISER MEMBERS No. 23-04
PRIMARY CONTACTS - MEMBER COMPLEX No. 98-04
SEC RULES MEMBERS No. 158-04
SMALL FUNDS MEMBERS No. 118-04
UNIT INVESTMENT TRUST MEMBERS No. 41-04
RE: SUMMARY OF SEC NO-ACTION AND INTERPRETIVE POSITIONS -- SERIES 90
Attached is a summary of recent no-action and interpretive positions issued by the
Securities and Exchange Commission staff relating to investment company and investment
adviser matters. The summary includes only those items that we believe are of interest or
importance to Institute members and do not necessarily include all relevant facts. In view of
these limitations, members should not rely on Institute summaries as an all-inclusive survey of
staff positions in this area. A copy of the complete text of the summarized items may be
obtained from the Institute for the use of members and counsel by contacting Monica Carter-
Johnson at (202) 326-5823. Alternatively, complete copies are available on the SEC’s website, as
noted at the end of the summary.
Jane G. Heinrichs
Assistant Counsel
Attachment (in .pdf format)
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