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Division of Investment Management
Staff No-Action Letters
Important Note: This page contains Division of Investment Management no-action letters dated on or after January 1, 2001. Division of Investment Management no-action letters issued before that date may be obtained for a fee. Please call (202) 942-8090, or email publicinfo@sec.gov.
Subject Categories
Subject Category List of No-Action Letters
Alphabetical List of No-Action Letters
Chronological List of No-Action Letters
List of No-Action Letters by Subject Category
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Advertising Investment Company
Advisory Contract
Advisory Representatives
12b-1 Fees
12b-1 Plans
Advisory Fees
Affiliated Transaction
- Neuberger Berman Management Inc., et al., April 30, 2003
- AAL Mutual Funds, et al., December 12, 2002
- AIM Advisors, Inc., February 12, 2002
- Calvert Social Index Fund, September 4, 2001
- Evergreen Investment Management Company, LLC, February 13, 2002
- Longleaf Partners Funds Trust, April 9, 2001
Annual Reports
Backward Pricing
Beneficial Ownership Qualified Purchaser
Business and Industrial Development Companies
Business Transfers
Cash Solicitation
- Deutsche Bank Securities Inc., September 24, 2004
- Thomas Weisel Partners LLC, September 24, 2004
- J.P. Morgan Securities Inc., October 31, 2003
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- Goldman, Sachs & Company, October 31, 2003
- Lehman Brothers, October 31, 2003
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Bear, Stearns & Co. Inc., October 31, 2003
- Morgan Stanley & Company, October 31, 2003
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- James DeYoung, October 24, 2003
- J.P. Morgan Securities Inc., October 8, 2003
- Dougherty & Company LCC, July 3, 2003
- Fahnestock & Company Inc., April 21, 2003
- Dougherty & Company LLC, March 21, 2003
- Legg Mason Wood Walker, Inc., June 11, 2001
- National Football League Players Association, January 25, 2002
- Prudential Securities Inc., February 7, 2001
- Stephens Inc., December 27, 2001
Charitable Exclusions
Closed-End Investment Companies
Code of Ethics
Commerical Paper
Custody-Investment Company
Director
Disclosure
Employee Benefit Plans
Exchange Offer
Exemptive Applications and Orders
Face-Amount Certificate
Fees & Expenses
Fiduciary Duties
Fraud
Funds of Funds - Affiliated
Funds of Funds - Foreign Investment Companies
Government Instrumentalities
Government Securities
Hub and Spoke Funds
Independent Directors
Independent Legal Counsel
Insurance Products
- GE Life and Annuity Assurance Company, June 25, 2004
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Acacia National Life Insurance Company, December 19, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- AIG Life Insurance Company, August 16, 2001
- Manufacturers Life Insurance Company, The, December 27, 2001
- National Association for Variable Annunities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001
- Nationwide Life Insurance Company, March 16, 2001
Interested Person
Internet
Investment Advisers
Investment Advisers Act Status
Investment Company
Investment Securities
Joint Transactions
Mergers and Reorganizations Combinations
- GE Life and Annuity Assurance Company, June 25, 2004
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Acacia National Life Insurance Company, December 19, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
Money Market Funds
Money Market Liquidity
Periodic Payment Plan Certificate
Performance Fees
Pre-Paid Tuition Plans
Prospectuses Delivery
Prospectuses Disclosure
Proxy Voting
Public Offering
Public Utility Holding Companies
- Section 2(a)(3)
- Bonneville Power Administration, February 10, 2004
- RealEnergy, Inc., et al., August 12, 2003
- Dominion Equipment II, Inc., et al., March 25, 2003
- Juniper Capital L.P., June 23, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- Sections 2(a)(3) and 2(a)(7)
- Sections 2(a)(7)
- Sections 2(a)(7) and 2(a)(11)(A)
- Section 17(c) and Rule 70
Redeemable Securities
Redemption Fees
Redemptions
Registration
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- Thomson Financial Inc., July 10, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
Registration Investment Companies
- Shee Atika Investments, LLC, January 20, 2004
- First Data Corporation, January 13, 2004
- Mercy Investment Program, Inc., June 12, 2003
- Metropolitan Insurance and Annuity Company, June 6, 2003
Regulation S-P
Reimbursement of Proxy Expenses
Reporting Requirements Investment Advisers
Reporting Requirements Investment Companies
- Westford Technology Ventures, L.P., January 28, 2004
- Equus Capital Partners L.P., November 14, 2003
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- Manufacturers Adviser Corp, September 10, 2002
Sales of Fund Shares below NAV
Securities Definition
Securities Lending
Self Custody - Investment Companies
Separate Accounts
- GE Life and Annuity Assurance Company, June 25, 2004
- Acacia National Life Insurance Company, December 19, 2003
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- AIG Life Insurance Company, August 16, 2001
Senior Securities
Shareholder Proposals
- Medallion Financial Corp., May 11, 2004
- Tri-Continental Corporation, March 15, 2004
- Robert P. Laukat Regarding Tri-Continental Corporation , March 15, 2004
- The New Ireland Fund, Inc., March 15, 2004
- College Retirement Equities Fund - Stone, May 3, 2004
- College Retirement Equities Fund - Belth, May 3, 2004
- College Retirement Equities Fund - Fuller, May 3, 2004
- College Retirement Equities Fund - Buchman, May 3, 2004
- Tri-Continental Corporation, March 25, 2003
- MuniYield Insured Fund, Inc., March 11, 2002
- Asia Tiger Fund, Inc., The, January 31, 2002
- Pioneer Interest Shares, June 20, 2001
- Asia Pacific Fund, Inc (The), June 8, 2001
- Asia Tiger Fund, Inc., The, December 28, 2001
- Current Income Shares, Inc., July 10, 2001
- Fidelity Advisor Korea Fund, Inc, March 7, 2001
- France Growth Fund, Inc, April 6, 2001
- France Growth Fund, Inc.; Advantage Partners LP, April 6, 2001
- France Growth Fund, Inc.; Strome Hedgecap Fund, April 6, 2001
- Lincoln National Convertible Securities Fund, Inc. - Walter S. Baer, September 28, 2001
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
Shareholders Votes
Solicitors
Alphabetical List of No-Action Letters
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- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- AAL Mutual Funds, et al., December 12, 2002
- Acacia National Life Insurance Company, December 19, 2003
- AIG Life Insurance Company, August 16, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- AIM Advisors, Inc., February 12, 2002
- Allstate Life Insurance Company, December 23, 2002
- American Bible Society, June 1, 2004
- American Enterprise Life Insurance Company, April 30, 2002
- Arizona Electric Power Cooperative Inc., July 27, 2001
- Asia Pacific Fund, Inc (The), June 8, 2001
- Asia Pacific Fund, Inc (The) - Thomas A. Kornfeld, June 8, 2001
- Asia Tiger Fund, Inc., The, December 28, 2001
- Asia Tiger Fund, Inc., The, January 31, 2002
- Austraclear Limited, April 28, 2004
- Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002
- Bear, Stearns & Co. Inc., October 31, 2003
- Bonneville Power Administration, February 10, 2004
- Calvert Social Index Fund, September 24, 2001
- Cantor Fitzgerald & Company, February 17, 2004
- The Chase Manhattan Bank, July 24, 2001
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- College Retirement Equities Fund - Stone, May 3, 2004
- College Retirement Equities Fund - Belth, May 3, 2004
- College Retirement Equities Fund - Fuller, May 3, 2004
- College Retirement Equities Fund - Buchman, May 3, 2004
- Constellation Financial Management LLC, January 9, 2003
- Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003
- Current Income Shares, Inc., July 10, 2001
- Deutsche Bank Securities Inc., September 24, 2004
- Dominion Equipment II, Inc., et al., March 25, 2003
- Dougherty & Company LCC, July 3, 2003
- Dougherty & Company LLC, March 21, 2003
- DTE Heritage, LLC, et. al., July 30, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- Eaton Vance Special Investment Trust, et al March 30, 2004
- Egan-Jones Proxy Services, May 27, 2004
- Enron Corporation, March 11, 2004
- Equus Capital Partners L.P., November 14, 2003
- Evercore METC Investment Inc., et. al., November 25, 2003
- Evergreen Investment Management Company, LLC, February 13, 2002
- Fahnestock & Company Inc., April 21, 2003
- Federal Home Loan Mortgage Corporation, July 12, 2002
- Federal National Mortgage Association, July 12, 2002
- Federated Core Trust II, L.P., February 6, 2002
- Fidelity Advisor Korea Fund, Inc, March 7, 2001
- First Data Corporation, January 13, 2004
- Fixed Income Clearing Corporation, March 13, 2003
- Fixed Income Securities, L.P., April 29, 2004
- France Growth Fund, Inc., April 6, 2001
- France Growth Fund, Inc., July 15, 2003
- France Growth Fund, Inc.; Advantage Partners LP, April 6, 2001
- France Growth Fund, Inc.; Strome Hedgecap Fund, April 6, 2001
- Frank Russell Investment Company, et al., October 18, 2002
- Gartmore Mutual Funds, March 19, 2004
- GE Life and Annuity Assurance Company, June 25, 2004
- General Electric Capital Corporation, April 26, 2002
- Goldman, Sachs & Company, October 31, 2003
- Government Securities Clearing Corporation, October 19, 2001
- Gulf Coast Venture Forum, Inc., August 21, 2002
- H.E.B. Investment and Retirement Plan (H.E. Butt Grocery Company), May 18, 2001
- Honeywell International Inc Savings Plan Trust, October 7, 2002
- ING Bank, N.V., July 8, 2002
- ING Mutual Funds Management Co. LLC; ING Funds Distributors Inc. and Reich & Tang Distributors Inc., February 9, 2001
- Institutional Shareholder Services, Inc., September 15, 2004
- Investec Ernst & Company, April 24, 2001
- Investment Company Institute, February 12, 2002
- Investment Counsel Association of America, Inc., March 1, 2004
- J.P. Morgan Securities Inc., October 8, 2003
- J.P. Morgan Securities Inc., October 31, 2003
- James DeYoung, October 24, 2003
- Juniper Capital L.P., June 23, 2003
- k1 Ventures, et. al., July 28, 2003
- Kirkpatrick & Lockhart LLP, January 28, 2004
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- Legg Mason Wood Walker, Inc., June 11, 2001
- Lehman Brothers, October 31, 2003
- Lincoln National Convertible Securities Fund, Inc. - Walter S. Baer, September 28, 2001
- Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003
- Lindbergh Funds, October 30, 2002
- Longleaf Partners Funds Trust, April 9, 2001
- Mahaffy, Edward , March 6, 2003
- Man-Glenwood Lexington TEI, LLC and Man-Glenwood Lexington TEI, LDC, April 30, 2004
- Manufacturers Adviser Corp, September 10, 2002
- Manufacturers Life Insurance Company, The, December 27, 2001
- Maxim Series Fund Inc., January 14, 2004
- Medallion Financial Corp., May 11, 2004
- Mercy Investment Program, Inc., June 12, 2003
- Merrill Lynch Investment Managers, May 10, 2002
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Metropolitan Insurance and Annuity Company, June 6, 2003
- Mexico Equity and Income Fund, The, November 15, 2001
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- MTB Group of Funds, October 21, 2003
- MuniYield Insured Fund, Inc., March 11, 2002
- Mutual Fund Directors Forum, May 9, 2002
- National Association for Variable Annunities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001
- National Football League Players Association, January 25, 2002
- Nationwide Life Insurance Company, March 16, 2001
- Neuberger Berman Management Inc., et al., April 30, 2003
- Peninsular & Oriental Steam Navigation Company, October 15, 2003
- Pioneer Interest Shares, June 20, 2001
- PIMCO Funds: Multi-Manager Series, August 6, 2002
- PIMCO Funds, July 9, 2002
- Prudential Investment Management Services LLC, April 19, 2001
- Prudential Securities Incorporated, February 7, 2001
- RealEnergy, Inc., et al., August 12, 2003
- ReFlow Fund, LLC, July 15, 2002
- Seligman New Technologies Fund II, Inc., February 7, 2002
- Shee Atika Investments, LLC, January 20, 2004
- Staff Responses to Questions About Regulation S-P, January 23, 2003
- Stephens Inc., December 27, 2001
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- Swiss Helvetia Fund, Inc., March 6, 2001
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
- Thomas Weisel Partners LLC, September 24, 2004
- Thomson Financial Inc., July 10, 2002
- Tri-Continental Corporation, March 25, 2003
- Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003
- Tuition Plan Consortium, LLP, February 4, 2003
- UAM Inc., September 24, 2001
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- USB Global Asset Management (US), Inc., November 21, 2002
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- U.S. Bancorp Asset Management Inc., et al., December 11, 2001
- Westford Technology Ventures, L.P., January 28, 2004<
- Western Farmers Electric Cooperative, February 23, 2001
- Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001
Chronological List of No-Action Letters
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- Deutsche Bank Securities Inc., September 24, 2004
- Thomas Weisel Partners LLC, September 24, 2004
- Institutional Shareholder Services, Inc., September 15, 2004
- GE Life and Annuity Assurance Company, June 25, 2004
- American Bible Society, June 1, 2004
- Egan-Jones Proxy Services, May 27, 2004
- Medallion Financial Corp., May 11, 2004
- College Retirement Equities Fund - Stone, May 3, 2004
- College Retirement Equities Fund - Belth, May 3, 2004
- College Retirement Equities Fund - Fuller, May 3, 2004
- College Retirement Equities Fund - Buchman, May 3, 2004
- Man-Glenwood Lexington TEI, LLC and Man-Glenwood Lexington TEI, LDC, April 30, 2004
- Fixed Income Securities, L.P., April 29, 2004
- Austraclear Limited, April 28, 2004
- Eaton Vance Special Investment Trust, et al March 30, 2004
- Dominion Equipment II, Inc., et al., March 25, 2003
- Gartmore Mutual Funds, March 19, 2004
- Enron Corporation, March 11, 2004
- Investment Counsel Association of America, Inc., March 1, 2004
- Cantor Fitzgerald & Company, February 17, 2004
- Bonneville Power Administration, February 10, 2004
- Kirkpatrick & Lockhart LLP, January 28, 2004
- Westford Technology Ventures, L.P., January 28, 2004
- Shee Atika Investments, LLC, January 20, 2004
- Maxim Series Fund Inc., January 14, 2004
- First Data Corporation, January 13, 2004
- Acacia National Life Insurance Company, December 19, 2003
- Sun Life Assurance Company of Canada (U.S.) and Keyport Life Insurance Company, December 19, 2003
- Evercore METC Investment Inc., et. al., November 25, 2003
- Equus Capital Partners L.P., November 14, 2003
- J.P. Morgan Securities Inc., October 31, 2003
- UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003
- Goldman, Sachs & Company, October 31, 2003
- Lehman Brothers, October 31, 2003
- Merrill Lynch, Pierce, Fenner & Smith Incorporated, October 31, 2003
- Bear, Stearns & Co. Inc., October 31, 2003
- Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003
- Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003
- U.S. Bancorp Piper Jaffray Inc., October 31, 2003
- James DeYoung, October 24, 2003
- MTB Group of Funds, October 21, 2003
- Peninsular & Oriental Steam Navigation Company, October 15, 2003
- J.P. Morgan Securities Inc., October 8, 2003
- Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003
- RealEnergy, Inc., et al., August 12, 2003
- DTE Heritage, LLC, et. al., July 30, 2003
- France Growth Fund, Inc., July 15, 2003
- Duke Energy Control Area Services, LLC, July 9, 2003
- Dougherty & Company LCC, July 3, 2003
- Juniper Capital L.P., June 23, 2003
- Mercy Investment Program, Inc., June 12, 2003
- Metropolitan Insurance and Annuity Company, June 6, 2003
- Neuberger Berman Management Inc., et al., April 30, 2003
- Fahnestock & Company Inc., April 21, 2003
- Tri-Continental Corporation, March 25, 2003
- Dougherty & Company LLC, March 21, 2003
- Fixed Income Clearing Corporation, March 13, 2003
- Edward Mahaffy, March 6, 2003
- ML-Lee Acquisition Fund II, L.P. and ML-Lee Acquisition Fund (Retirement Accounts) II, L.P, March 4, 2003
- Tuition Plan Consortium, LLP, February 4, 2003
- Staff Responses to Questions About Regulation S-P, January 23, 2003
- Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003
- Constellation Financial Management LLC, January 9, 2003
- Allstate Life Insurance Company, December 23, 2002
- Sun Life Insurance and Annuity Company of New York, et al., December 20, 2002
- AAL Mutual Funds, et al., December 12, 2002
- USB Global Asset Management (US), Inc., November 21, 2002
- Lindbergh Funds, October 30, 2002
- Frank Russell Investment Company, et al., October 18, 2002
- Honeywell International Inc Savings Plan Trust, October 7, 2002
- Manufacturers Adviser Corp, September 10, 2002
- Gulf Coast Venture Forum, Inc., August 21, 2002
- PIMCO Funds: Multi-Manager Series, August 6, 2002
- ReFlow Fund, LLC, July 15, 2002
- Federal National Mortgage Association, July 12, 2002
- Federal Home Loan Mortgage Corporation, July 12, 2002
- Thomson Financial Inc., July 10, 2002
- PIMCO Funds, July 9, 2002
- ING Bank, N.V., July 8, 2002
- Merrill Lynch Investment Managers, May 10, 2002
- Mutual Fund Directors Forum, May 9, 2002
- American Enterprise Life Insurance Company, April 30, 2002
- General Electric Capital Corporation, April 26, 2002
- Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002
- MuniYield Insured Fund, Inc., March 11, 2002
- Evergreen Investment Management Company, LLC, February 13, 2002
- AIM Advisors, Inc., February 12, 2002
- Investment Company Institute, February 12, 2002
- Seligman New Technologies Fund II, Inc., February 7, 2002
- Federated Core Trust II, L.P., February 6, 2002
- National Football League Players Association, January 25, 2002
- Asia Tiger Fund, Inc., The, January 31, 2002
- Asia Tiger Fund, Inc., The, December 28, 2001
- Manufacturers Life Insurance Company, The, December 27, 2001
- Stephens Inc., December 27, 2001
- Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001
- U.S. Bancorp Asset Management Inc., et al., December 11, 2001
- Mexico Equity and Income Fund, The, November 15, 2001
- AIG Life Insurance Company - American International Life Assurance Company of New York, November 6, 2001
- Government Securities Clearing Corporation, October 19, 2001
- Lincoln National Convertible Securities Fund, Inc. - Walter S. Baer, September 28, 2001
- Templeton Vietnam and Southeast Asia Fund, September 28, 2001
- UAM Inc., September 24, 2001
- Calvert Social Index Fund, September 24, 2001
- Large Scale Distributed Generation II Statutory Trust, September 5, 2001
- AIG Life Insurance Company, August 16, 2001
- k1 Ventures, et. al., July 28, 2003
- Arizona Electric Power Cooperative Inc., July 27, 2001
- The Chase Manhattan Bank, July 24, 2001
- Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001
- Current Income Shares, Inc., July 10, 2001
- Pioneer Interest Shares, June 20, 2001
- National Association for Variable Annunities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001
- Asia Pacific Fund, Inc (The), June 8, 2001
- Asia Pacific Fund, Inc (The) - Thomas A. Kornfeld, June 8, 2001
- Legg Mason Wood Walker, Inc., June 11, 2001
- H.E.B. Investment and Retirement Plan (H.E. Butt Grocery Company), May 18, 2001
- Investec Ernst & Company, April 24, 2001
- Prudential Investment Management Services LLC, April 19, 2001
- Longleaf Partners Funds Trust, April 9, 2001
- France Growth Fund, Inc, April 6, 2001
- France Growth Fund, Inc.; Advantage Partners LP, April 6, 2001
- France Growth Fund, Inc.; Strome Hedgecap Fund, April 6, 2001
- Nationwide Life Insurance Company, March 16, 2001
- Fidelity Advisor Korea Fund, Inc, March 7, 2001
- Swiss Helvetia Fund, Inc., March 6, 2001
- Western Farmers Electric Cooperative, February 23, 2001
- ING Mutual Funds Management Co. LLC; ING Funds Distributors Inc. and Reich & Tang Distributors Inc., February 9, 2001
- Prudential Securities Incorporated, February 7, 2001
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