Investment Management

Mutual of America Investment Corporation: No-Action letter dated June 2, 2006 Investment Company Act of 1940 – Section 17(a) and Rule 17a-8 Mutual of America ...

Ameriprise Financial Services, Inc.: No-Action letter dated August 31, 2005 Investment Advisers Act of 1940 – Section 206(4) and Rule 206(4)-3 Ameriprise Financial Services Inc. ...

Putnam Premier Income Trust – Frank H. Goodson: No-Action letter dated March 14, 2006 Securities Exchange Act of 1934 – Rule 14a-8(i)(3) and 14a-8(l) Putnam ...

Putnam High Income Securities Fund – Robert P. Laukat: No-Action letter dated March 14, 2006 Securities Exchange Act of 1934 – Rule 14a-8(i)(3) and 14a-8(1) ...

Millennium Partners, L.P., et al: No-Action letter dated March 9, 2006 Investment Advisers Act of 1940 – Section 206(4) and Rule 206(4)-3 Millennium Partners, L.P., ...

This SEC Division of Investment Management no-action letter deals with use of performance data from a PM's prior firm being applied to an advertisement.

First Great-West Life & Annuity Insurance Company & Canada Life Insurance Company of New York: No-Action Letter / December 22, 2005 Securities Act of 1933 ...

Investment Company Act of 1940 – Section 17(a) GE Institutional Funds December 21, 2005 RESPONSE OF THE OFFICE OF CHIEF COUNSEL GE Institutional Funds DIVISION ...

No-Action Letter under Securities Exchange Act of 1934 – Rule 10A-3 and Form N-SAR and N-CSR The Pioneer Funds December 20, 2005 RESPONSE OF THE ...