Investment Management

Dechert LLP: No-Action letter dated August 4, 2009 Investment Company Act of 1940 — Section 12(d)(1) Dechert LLP August 4, 2009 RESPONSE OF THE OFFICE ...

No-Action Letter: Maxim Series Fund, Inc., et al. (July 31, 2009) Investment Company Act of 1940 — Sections 9(a), 13(a), 15(a) and 15(b) Maxim Series ...

No-Action Letter: Straight-A Funding, LLC (July 28, 2009) Investment Company Act of 1940 — Sections 34(b), 35(d) and Rules 2a-7 and 35d-1 Straight-A Funding, LLC ...

Madison Asset Management, LLC, et al.: No-Action letter dated June 30, 2009 Investment Company Act of 1940 — Section 12(d)(1)(A), 12(d)(1)(B) and 15(a) Madison Asset ...

American Capital, Ltd: No-Action letter dated June 30, 2009 Investment company Act of 1940 — Sections 18(a)(1)(B) and 61(a)(1) American Capital, Ltd June 30, 2009 ...

Franklin Templeton Investments: No-Action letter dated June 19, 2009 Investment Company Act of 1940 — Sections 18(a)(1), 18(c) and 18(f)(1) Franklin Templeton Investments June 19, ...

RBC Capital Markets Corporation: No-Action letter dated June 10, 2009 Investment Advisers Act of 1940 — Rule 206(4)-3 RBC Capital Markets Corporation June 10, 2009 ...

Banc of America Securities LLC: No-Action letter dated June 10, 2009 Investment Advisers Act of 1940 — Section 206 and Rule 206(4)-3 Banc of America ...

Deutsche Bank Securities Inc.: No-Action letter dated June 9, 2009 Investment Advisers Act of 1940 — Section 206(4) Deutsche Bank Securities Inc. June 9, 2009 ...