No-Action Letter to the Investment Company Institute (Interpretation)
Investment Company Institute No-Action Letter
September 12, 2011
The SEC Division of Investment Management granted no-action relief, under Advisers Act Rule 204-2(a)(18)(i)(B), for advisers to registered investment companies. The rule generally requires a registered adviser to keep a list of all government entities who invest in a registered investment company advised by the adviser . The letter provides no-action relief with respect to investments by government entities that may come through omnibus accounts in a way such that the government entity is unknown to the adviser, the relevant investment company, or its transfer agent.
For more information about this document, you may contact one of the following Cadwalader attorneys: Maurine Bartlett; Dorothy Mehta; Andrew Lom.
Cross References
Advisers Act Rule 204-2(a)(18)