No-Action Letters

Investment Advisers Act of 1940 – Rule 204A-1 and 204-2 Prudential Insurance Company of America March 1, 2005 RESPONSE OF THE OFFICE OF CHIEF COUNSEL ...

Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc. December 6, 2004 RESPONSE OF THE OFFICE OF CHIEF COUNSEL DIVISION OF INVESTMENT ...

This is an SEC no-action letter from 2004 providing guidance on the use of past-specific recommendations in firm advertising and marketing.

This is a copy of the SEC's no-action letter related to advertising and marketing in response to a request from Jennison Associates.

This is an SEC no-action letter released in 1999 prompted by Goldman Sachs Asset Management. The letter concerns application of Advisers Act section 206(3). It ...

This is a copy of the 1998 Franklin no-action letter that relates to quarterly reports to clients.

If a fund has not adopted a rule 12b-1 plan, then it cannot use fund assets to pay for services that are primarily intended to ...

The SEC rejects a commissions-relationship by reps who aren't registered.

This is the 1997 no-action letter from the SEC's Division of Investment Management requested by Cambiar Investors. The RIA sought, and received, a determination that ...

This 1996 no-action letter helps to define what net-of-fee performance data means. The SEC, in this correspondence, held that it include all transaction costs and ...