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[18799]
May 2, 2005
TO: CHIEF COMPLIANCE OFFICER COMMITTEE No. 37-05
CLOSED-END INVESTMENT COMPANY MEMBERS No. 23-05
COMPLIANCE ADVISORY COMMITTEE No. 33-05
INVESTMENT ADVISER ASSOCIATE MEMBERS No. 6-05
INVESTMENT ADVISER MEMBERS No. 8-05
SEC RULES MEMBERS No. 54-05
SMALL FUNDS MEMBERS No. 37-05
UNIT INVESTMENT TRUST MEMBERS No. 7-05
RE: SUMMARY OF SEC NO-ACTION LETTERS -- SERIES 91
Attached is a summary of recent no-action letters 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
Note: Not all recipients receive the attachment. To obtain a copy of the attachment, please visit our members
website (http://members.ici.org) and search for memo 18799, or call the ICI Library at (202) 326-8304 and request the
attachment for memo 18799.
Attachment (in .pdf format)