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Archive | SEC Letters

Gartmore Mutual Funds (Mar. 19, 2004) (Advisory Contracts)

Friday, 19 March 2004 08:00 Investment Company Act of 1940 – Section 15(a)Gartmore Mutual Funds March 19, 2004 Our Ref. No. 20039291130 RESPONSE OF THE OFFICE OF CHIEF COUNSEL DIVISION OF INVESTMENT MANAGEMENT Gartmore Mutual Funds, et al. File No. 811-08495 Your letter dated March 18, 2004 requests our assurance that we would not recommend […]

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Goldman, Sachs & Company (Oct. 31, 2003) (Cash Solicitation)

Friday, 31 October 2003 08:00 Investment Advisers Act of 1940 Section 206(4) and Rule 206(4)-3 Goldman, Sachs & Company October 31, 2003 RESPONSE OF THE OFFICE OF CHIEF COUNSEL IM Ref. No. 2003428912 Goldman, Sachs & Company DIVISION OF INVESTMENT MANAGEMENT File No. 8-129 We would not recommend enforcement action to the Commission under Section […]

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Goldman Sachs Group, Inc. (Mar. 8, 2005) (Hedge Funds)

Tuesday, 08 March 2005 08:00 Investment Company Act of 1940 – Section 3(c)(1) and 3(c ) (7) The Goldman Sachs Group, Inc. March 8, 2005 RESPONSE OF THE OFFICE OF CHIEF COUNSEL DIVISION OF INVESTMENT MANAGEMENT Our Ref. No. 200264850 The Goldman Sachs Group Inc. File No. 132-3 Your letter dated March 2, 2005 requests […]

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Investment Adviser Association (Dec. 2, 2005) (Advertising)

Friday, 02 December 2005 08:00 Investment Advisers Act of 1940 Rule 206(4)-1(a)(1) Investment Adviser Association December 2, 2005 Karen L. Barr General Counsel Investment Adviser Association 1050 17th Street, NW Suite 725 Washington, DC 20036-5503 Dear Ms. Barr: We request that you share with your members the following guidance concerning investment advisers’ advertisements of their […]

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Investment Company Institute (Nov. 10, 2004) (Closed-end Investment Companies)

Wednesday, 10 November 2004 08:00 Investment Company Act of 1940 – Rule 38a-1 Application of Rule 38a-1 to a Closed-End Investment Company’s Principal Underwriters November 10, 2004 By Facsimile and U.S. Mail Elizabeth R. Krentzman, Esq. General Counsel Investment Company Institute 1401 H Street, NW Washington, DC 20005 Re: Application of Rule 38a-1 to a […]

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ING Bank (Jul. 8, 2002) (Public Offering)

Monday, 08 July 2002 08:00 Investment Company Act of 1940 – Section 3(c)(1) ING Bank, N.V. July 8, 2002 RESPONSE OF THE OFFICE OF CHIEF COUNSEL DIVISION OF INVESTMENT MANAGEMENT Our Ref. No. 20019191717 ING Bank, N.V. File No. 132-3 Your letter dated June 18, 2002, requests our assurance that we would not recommend enforcement […]

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