No-Action Letters

You state that each Fund’s board of trustees (the “Board”),[2] including a majority of independent trustees, has concluded that a continuously effective equity shelf registration ...

Investment Company Act of 1940 — Section 57(a) and Rule 17d-1 Golub Capital BDC, Inc., et al. September 7, 2018 Response of the Chief Counsel's ...

    Securities Exchange Act of 1934 – Rule 14a-8 Asia Pacific Fund-Omission of Shareholder Proposal Submitted by Matisse Capital Management, L.P. July 20, 2018 ...

You represent that financial exploitation of seniors and other vulnerable adults is a serious problem, with substantial amounts lost annually to senior financial abuse.

We are unable to concur in your view that the Fund may exclude the Proposal from the Proxy Materials under Rule 14a-8(i)(3). We do not ...

You argue that, so long as appropriate disclosure is provided, it would not be misleading for the Minis Division to continue to use the Minis ...