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Skip to search field Skip to main content An official website of the United States government Here’s how you know Here’s how you know Official websites use .gov A .gov website belongs to an official government organization in the United States. Secure .gov websites use HTTPS A lock (LockA locked padlock) or https:// means you’ve safely connected to the .gov website. Share sensitive information only on official, secure websites. SEC homepage Menu Close Search SEC.gov Search * Search Filings SEARCH FILINGS * Full Text Search * Latest Filings * Mutual Fund Search * Variable Insurance Products Search * SIC Codes * CIK Lookup * Public Dissemination Service (PDS) * Search Assistance * Submit Filings SUBMIT FILINGS * EDGAR Filer Management Portal * EDGAR Filing Portal * Online Forms Management Portal * Forms Index * Technical Specifications * Filer Support & Guidance * Data & Research DATA & RESEARCH * SEC & Markets Data * Taxonomies * Data Visualizations * Rules, Enforcement, & Compliance * RULES & REGULATIONS * Rulemaking Activity * Statutes & Regulations * Staff Guidance * No-Action, Interpretive, and Exemptive Letters * Self-Regulatory Organization Rulemaking * Public Petitions for Rulemaking * ENFORCEMENT & LITIGATION * Litigation Releases * Administrative Proceedings * Administrative Law Judge Orders and Initial Decisions * Trading Suspensions * Distributions to Harmed Investors * Receiverships * COMPLIANCE * Examination Priorities * Risk Alerts * Compliance Outreach Program * * Proposed Rules * What's New * Whistleblower Program * Securities Topics SECURITIES TOPICS * Crypto Assets * Cybersecurity * Saving and Investing for Military Personnel * Market Structure * Saving and Investing for Teachers * About ABOUT * Mission * Commissioners * Divisions & Offices * Division & Office Directors * Advisory Committees * Budget & Performance * Diversity, Equity, Inclusion, and Accessibility * Reports & Publications * Commission Votes * Contact Us * Careers * Submit a Tip or Complaint * Newsroom * | * Investors * Small Businesses * Whistleblowers * Newsroom * | * Investors * Small Businesses * Whistleblowers Search SEC.gov Search MORE IN ABOUT * Rules & Regulations * Rulemaking Activity * Statutes and Regulations * Staff Guidance * No Action, Interpretive and Exemptive Letters * Division of Corporation Finance No-Action, Interpretive and Exemptive Letters * Division of Investment Management Staff No-Action and Interpretive Letters * Division of Trading and Markets No-Action, Exemptive, and Interpretive Letters * Commission Orders and Notices * Shareholder Proposals * Self-Regulatory Organization Rulemaking * Policy Statements * Petitions for Rulemaking * Public Company Accounting Oversight Board Rulemaking * Exchange Delistings * How to Submit a Comment * Rules & Regulations * Rulemaking Activity * Statutes and Regulations * Staff Guidance * No Action, Interpretive and Exemptive Letters * Division of Corporation Finance No-Action, Interpretive and Exemptive Letters * Division of Investment Management Staff No-Action and Interpretive Letters * Division of Trading and Markets No-Action, Exemptive, and Interpretive Letters * Commission Orders and Notices * Shareholder Proposals * Self-Regulatory Organization Rulemaking * Policy Statements * Petitions for Rulemaking * Public Company Accounting Oversight Board Rulemaking * Exchange Delistings * How to Submit a Comment BREADCRUMB 1. Home 2. Investment Management 3. Division of Investment Management Staff No-Action and Interpretive Letters Copy Link Copied! DIVISION OF INVESTMENT MANAGEMENT STAFF NO-ACTION AND INTERPRETIVE LETTERS June 19, 2019 Important Note: This page contains Division of Investment Management no-action letters dated on or after January 1, 1993. Division of Investment Management no-action letters issued before that date may be obtained for a copy and processing fee. Please refer to information on How to Request Public Documents. * Subject Categories * Subject Category List of No-Action Letters * Alphabetical List of No-Action Letters * Chronological List of No-Action Letters A non-exhaustive list of no-action letters and other staff statements that have been modified or withdrawn is available on our Modified or Withdrawn Staff Statements webpage. The no-action and interpretive letter web intake form and specific procedures for submitting requests can be found here: https://www.sec.gov/forms/im-no-action SUBJECT CATEGORIES * 12b-1 Fees * 12b-1 Plans * Accounting * Acquisition Trust * Acquisition of Securities in Affiliated Underwriting * Administrative Fees * Advertising - Investment Advisers * Advertising - Investment Company * Advisory Contracts * Advisory Fees * Advisory Representatives * Affiliated Persons * Affiliated Transactions - Money Market Fund Letters * Affiliated Transactions - Other * Agency Cross Transactions * Aggregated Transactions * Annual Reports * Annuity Contracts * Anti-Takeover Statutes * Asset-Backed Securities * Assignments * Attribution * Auction Rate Notes * Automatic Bar * Backward Pricing * Banks * Banks - Affiliated Mutual Funds * Banks - Collective Trust Funds * Banks - Investment Advisory Activities * Beneficial Ownership Qualified Purchaser * Borrowings * Board of Directors * Board of Directors - Retirement Plans * Brokerage Activities * Broker Dealer - Special Compensation * Broker-Dealers * Bunching * Business and Industrial Development Companies * Business Development Companies * Business Transfers * Capital Structures (BDC) * Cash Solicitation * Cash Solicitation - Solicitors * Change of Control * Charitable Exclusions * Clearing Agency * Closed-End Investment Companies * Code of Ethics * Collective Investment Trusts * Commercial Paper * Commodity Pools * Commodity Trading Advisors * Compliance Policies and Procedures Rule * Consolidation * Control * Cryptocurrency * Custodial Receipts * Custodial Requirements * Custody * Custody - Investment Advisers * Custody - Investment Companies * Defined Contribution Plans * Definitions * Derivative Securities * Director * Disclosure * Disqualification - Investment Companies * Distributions * Distribution Fees * Distribution Plans * Diversification * Eligible Foreign Custodian * Emergencies * Employee Benefit Plans * Employee Securities Companies * ERISA * ETFs * Exchange Offer * Exchange Privilege * Exchange Traded Products * Exemptive Applications and Orders * Face-Amount Certificate * Factoring * Fair Value Pricing * Family Office Exclusion * Fees & Expenses * Fidelity Bonds - Investment Companies * Fiduciary Duties * Filing - Dates * Filing Procedure - Fees * Filing Procedures * Finance Subsidiaries * Financial Statement * Floating Rate Securities * Foreign Banks * Foreign Custodian * Foreign Government Securities * Foreign Investment Advisers * Foreign Investment Companies * Form 13F * Forward Contract * Fraud * Fraud - Investment Advisers Act * Funds of Funds - Affiliated * Funds of Funds - Foreign Investment Companies * Fund Supermarkets * Generic Comment Letters * Government Agency * Government Instrumentality * Government Securities * Governmental Plans * Hedge Clauses * Hedge Funds * Hub and Spoke Funds * Illiquid Securities * Inadvertent Investment Companies * Independent Directors * Independent Legal Counsel * Independent Public Accountant * Injunctions * Inspections - Investment Advisers * Insurance Companies * Insurance Company Regulation * Insurance Products * Integration * Interested Person * Internationalization of Securities Markets * Internet * Interval Funds * Investment Advisers * Investment Advisers Act Status * Investment Advisers Act Status - Publishers * Investment Advisers Act Status - Broker-Dealers * Investment Adviser Registration * Investment Company * Investment Company Act Status * Investment Restrictions * Investment Securities * Joint Transactions * Leverage * Limited Partnership Interest * Liquidating Trusts * Mergers and Reorganizations Combinations * Mini-account Program * Mixed and Shared Funding * Model Portfolio * Money Market Funds * Money Market Liquidity * Money Market - Liquidity Puts * Money Market Portfolio Valuation * Mortgages/Real Estate/REITs * Multiple Classes * Municipal Bond * Names - Misleading * National Securities Market Improvement Act of 1996 * No-Action Request Procedures * Offshore Funds * Oil & Gas * Pay to Play * Periodic Payment Plan Certificate * Performance Allocation * Performance Fees * Personal Securities Transaction * Pre-Paid Tuition Plans * Pricing - Fair Value Pricing * Principal Transaction * Principal Underwriters * Private Investment Companies * Private Investment Companies - Attribution * Private Offering * Prospectuses - Delivery * Prospectuses - Disclosure * Proxy Statement * Proxy Voting * Public Offering * Public Utility Holding Company Act of 1935 * Qualified Purchase Definition - Investment Company Act Status Determination * Qualified Purchaser Fund * Real Estate * Real Estate Investment Trusts * Recordkeeping Requirements - Investment Advisers * Recordkeeping Requirements - Investment Adviser Separate Accounts * Recordkeeping Requirements - Investment Adviser Suitability * Recordkeeping Requirements - Investment Companies * Redeemable Securities * Redemption Fees * Redemptions * Registration * Registration - Investment Advisers * Registration - Investment Companies * Regulation S-P * Reimbursement of Proxy Expenses * Reorganization * Reporting Requirements - Investment Advisers * Reporting Requirements - Investment Companies * Repurchase Agreement * Reverse Repurchase Agreement * Safe Harbors * Sales Financing * Sales Load * Sales Load - Contingent Deferred * Sales of Fund Shares below NAV * Security - Definition * Securities Lending * Securities Related Business * Self Custody - Investment Companies * Senior Securities * Separate Accounts * Series Companies * Shareholder Meetings * Shareholder Proposals * Shareholders Votes * Short Sales or Short Selling * Soft Dollar Arrangements * Solicitors * Spin Offs Assignment * Stapled Securities * State Regulation * Status of Investment Company * Structured Financing * Student Loans * Successor registration * Subsidiaries * Taxation * Tender Offers * Territorial Exemption * Tracking Stock * Transient Investment Company * Trustee * Unit Investment Trust * Valuation * Variable Annuities Contract * Variable Rate Securities * Voting Security * Voting Trust * Warrants * Wrap Fee Arrangements SUBJECT CATEGORY LIST OF NO-ACTION LETTERS 12B-1 FEES * E*TRADE Securities, LLC, November 30, 2005 * ReFlow Fund, LLC, July 15, 2002 12B-1 PLANS * Edward Mahaffy, March 6, 2003 ACCOUNTING * American General Life Insurance Company, The Variable Annuity Life Insurance Company and The United States Life Insurance Company in the City of New York, May 28, 2024 * Pacific Life Insurance Company and Pacific Life & Annuity Company, March 1, 2024 * Eagle Life Insurance Company, September 29, 2023 * Jackson National Life Insurance Company and Jackson National Life Insurance Company of New York, September 26, 2023 * Brighthouse Life Insurance Company of NY, September 21, 2023 * Delaware Life Insurance Company and Gainbridge Life Insurance Company, April 28, 2023 * Fidelity & Guaranty Life Insurance Company and Fidelity & Guaranty Life Insurance Company of New York, March 17, 2023 * Everlake Life Insurance Company, October 21, 2022 * Protective Life Insurance Company and Protective Life and Annuity Insurance Company, October 14, 2022 * Union Security Insurance Company, January 11, 2022 * Wilton Reassurance Life Company of New York, September 30, 2021 * Midland National Life Insurance Company, August 12, 2021 * Transamerica Life Insurance Company and Transamerica Financial Life Insurance Company, February 11, 2021 * MEMBERS Life Insurance Co., November 6, 2020 * Minnesota Life Insurance Co., June 11, 2020 * Merit Life Insurance Co., April 21, 2020 * Nationwide Life Insurance Company, October 17, 2019 * Forethought Life Insurance Company, October 17, 2019 * Symetra Life Insurance Company and First Symetra National Life Insurance Company of New York, August 8, 2019 * Lincoln Benefit Life Company, March 15, 2019 * MONY Life Insurance Company of America, March 7, 2019 * Allianz Life Insurance Company of North America, September 28, 2018 * Athene Annuity and Life Company, September 28, 2018 * Great West Life & Annuity Insurance Company, September 28, 2018 * Midland National Life Insurance Company, September 28, 2018 * Fidelity Management & Research Company et al., September 22, 2017 * Great-West Life & Annuity Insurance Company, November 16, 2016 * Fidelity Management & Research Company et al., June 20, 2016 * Copley Fund, Inc., August 2, 2013 * Copley Fund, Inc., June 18, 2013 * Copley Fund, Inc., April 5, 2013 * AICPA SEC Regulations Committee, March 8, 2005 * Chief Financial Officer, November 7, 1997 * Accounting Comment Letter, November 2, 1995 * Chief Financial Officer of Investment Company Registrants, February 3, 1995 * Chief Financial Officer, November 1, 1994 ACQUISITION TRUST * PaineWebber Incorporated, January 27, 1995 ACQUISITION OF SECURITIES IN AFFILIATED UNDERWRITING * Columbia Funds, December 12, 2011 * Goldman Sachs Trust, August 19, 2008 ADMINISTRATIVE FEES * Franklin Templeton Group of Funds, July 23, 1997 ADVERTISING - INVESTMENT ADVISERS * South State Bank, May 8, 2018 * The TCW Group, Inc., November 7, 2008 * Investment Adviser Association, December 2, 2005 * Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004 * Investment Counsel Association of America, Inc., March 1, 2004 * Jennison Associates LLC, July 6, 2000 * Franklin Management, Inc., December 10, 1998 * DALBAR, Inc., March 24, 1998 * Association for Investment Management and Research, December 18, 1996 * Horizon Asset Management, LLC, September 13, 1996 * Munder Capital Management, May 17, 1996 * J.P. Morgan Investment Management, Inc., May 7, 1996 * Clover Capital Management, Inc., October 28, 1986 ADVERTISING - INVESTMENT COMPANY * Department of Labor, October 26, 2011 * Lindbergh Funds, October 30, 2002 * Salomon Brothers Asset Management Inc and Salomon Brothers Asset Management Asia Pacific Limited, July 23, 1999 * Dr. William Greene, Stern School of Business, February 3, 1997 * GE Funds, February 7, 1997 * ITT Hartford Mutual Funds, February 7, 1997 * Nicholas-Applegate Mutual Funds, February 7, 1997 * Bramwell Growth Fund, August 7, 1996 * Nicholas-Applegate Mutual Funds, August 6, 1996 * Blanchard Global Growth Fund, May 7, 1996 * MassMutual Institutional Funds, September 28, 1995 * North American Security Trust, August 5, 1994 ADVISORY CONTRACTS * The BNY Mellon Family of Funds, et al., July 9, 2019 * Community Capital Management, Inc., et al., April 15, 2019 * Nuveen Fund Advisors, LLC, June 20, 2017 * American Century Investment Management, Inc., December 20, 2016 * RS Global Natural Resources Fund, March 6, 2014 * Hatteras Alternative Mutual Funds Trust, et al., September 25, 2012 * Nationwide Mutual Funds, et al., April 5, 2011 * Claymore Advisors, LLC, April 27, 2010 * Boulder Growth and Income Fund, Inc., March 5, 2010 * Boulder Total Return Fund, Inc., March 5, 2010 * Madison Asset Management, LLC, et al., June 30, 2009 * Iridian Asset Management LLC, April 14, 2009 * Bank of Ireland Asset Management (U.S.) Ltd., April 2, 2009 * Fortis Group, et al., January 27, 2009 * First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008 * Mellon Equity Associates, LLP April 1, 2005 * Eaton Vance Special Investment Trust, et al March 30, 2004 * Gartmore Mutual Funds, March 19, 2004 * PIMCO Funds: Multi-Manager Series, August 6, 2002 * AHA Investment Funds, Inc, March 8, 2001 * Metropolitan Life Insurance Company, November 13, 1999 * American Express Financial Corporation, November 17, 1998 * Wells Fargo Bank, N.A., March 31, 1998 * Franklin Templeton Group of Funds, July 23, 1997 * Dean Witter, Discover & Co.; Morgan Stanley Group Inc., April 18, 1997 * American Odyssey Funds, Inc., October 7, 1996 * The Ayco Company L.P., December 14, 1995 * Century Shares Trust, May 4, 1994 * Shearson Lehman Brothers Inc. and Smith Barney, Harris Upham & Co. Incorporated, June 8, 1993 * Washington Mutual Investors Fund, Inc., May 14, 1993 ADVISORY FEES * Differential Advisory Fee Waivers, February 2, 2023 * Golub Capital Investment Corporation, et al., June 24, 2019 * Citigroup Global Markets Inc., August 6, 2014 * RiverNorth, July 28, 2014 * Constellation Financial Management LLC, January 9, 2003 * Seligman New Technologies Fund II, Inc., February 7, 2002 * R.O.C. Taiwan Fund, February 11, 2000 * BISYS Fund Services, Inc., September 2, 1999 * INVESCO Funds Group, Inc., August 5, 1997 * Franklin Templeton Group of Funds, July 23, 1997 * American Odyssey Funds, Inc., October 7, 1996 * Lazard Freres Asset Management, February 12, 1996 * George Colman, July 18, 1995 * Benson White & Company, June 14, 1995 ADVISORY REPRESENTATIVES * Manufacturers Adviser Corp, September 10, 2002 * W.R. Huff Asset Management Co., L.P., August 10, 1994 AFFILIATED PERSONS * Russell Investment Management, LLC, December 16, 2016 * UBS AG, July 29, 2009 * Investment Company Institute, March 12, 2009 * Auction Rate Securities, January 6, 2009 * Drinker, Biddle & Reath, December 18, 1998 * First Financial Fund, Inc., at al., June 5, 1997 * Mark A. Bush, August 8, 1995 * The One Group, May 23, 1995 * North American Security Trust and NASL Series Trust, February 2, 1993 AFFILIATED TRANSACTIONS - MONEY MARKET FUND LETTERS * Fifth Street Finance Corp., February 25, 2010 * Allianz Funds, August 3, 2009 * The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., August 3, 2009 * Mount Vernon Securities Lending Trust, August 3, 2009 * Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Fund, August 3, 2009 * SEI Daily Income Trust ? Prime Obligation Fund, April 20, 2009 * SEI Liquid Asset Trust ? Prime Obligation Fund, April 20, 2009 * Columbia Funds Series Trust - Columbia Cash Reserves, March 2, 2009 * Columbia Funds Series Trust - Columbia Money Market Reserves, March 2, 2009 * Master Portfolio Trust - Liquid Reserves Portfolio and Legg Mason Partners Money Market Trust - Western Asset Money Market Fund, March 2, 2009 * Northern Institutional Funds - Diversified Assets Portfolio, Liquid Assets Portfolio and Prime Obligations Portfolio and Northern Funds - Money Market Fund, March 2, 2009 * SEI Liquid Asset Trust - Prime Obligation Fund, March 2, 2009 * Mount Vernon Securities Lending Trust, January 8, 2009 * Master Portfolio Trust - Liquid Reserves Portfolio, December 8, 2008 * Reserve New York Municipal Money-Market Trust - New York Municipal Money-Market Fund, November 18, 2008 * SEI Daily Income Trust - Prime Obligation Fund, November 18, 2008 * Mount Vernon Securities Lending Trust, October 24, 2008 * Russell Investment Company, October 24, 2008 * Columbia Funds Series Trust, October 22, 2008 * ING Funds Trust, ING Investors Trust, and ING Series Fund, Inc., October 22, 2008 * Legg Mason Partners Institutional Trust, October 22, 2008 * Legg Mason Partners Institutional Trust, October 22, 2008 * MainStay VP Cash Management Portfolio, October 22, 2008 * Morgan Stanley Institutional Liquidity Funds, October 22, 2008 * Morgan Stanley Money Market Funds, October 22, 2008 * Mount Vernon Securities Lending Trust, October 22, 2008 * Northwestern Mutual Series Fund, Inc., October 22, 2008 * Penn Series Funds Inc., October 22, 2008 * Penn Series Funds Inc., October 22, 2008 * Phoenix Opportunities Trust, October 22, 2008 * Principal Funds, Inc. and Principal Variable Contracts Funds, Inc., October 22, 2008 * RidgeWorth Funds, October 22, 2008 * Tamarack Funds Trust, October 22, 2008 * Touchstone Variable Series Trust, October 22, 2008 * USAA Mutual Funds Trust, October 22, 2008 * The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., October 20, 2008 * Sun Capital Advisers Trust, October 20, 2008 * Advantus Series Fund, October 20, 2008 * Dreyfus Cash Management Plus, October 20, 2008 * Dreyfus Money Funds, October 20, 2008 * Dreyfus Money Funds, October 20, 2008 * Russell Investment Company, October 20, 2008 * Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 2008 * Northern Institutional Fund, July 16, 2008 * Western Asset Money Market Fund, June 27, 2008 * Western Asset Institutional Money Market Fund, June 27, 2008 * Munder Series Trust, June 23, 2008 * HSBC Investor Funds, June 25, 2008 * Allianz Dresdner Daily Asset Fund, May 5, 2008 * Institutional Liquidity Trust, April 30, 2008 * Master Portfolio Trust, April 18, 2008 * Master Portfolio Trust, April 4, 2008 * SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008 * Northern Institutional Funds, February 28, 2008 * Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008 * HSBC Investor Funds, January 18, 2008 * STI Classic Funds, January 2, 2008 * TDAM Money Market Portfolio, December 21, 2007 * First American Funds, Inc. – Prime Obligation Fund, December 3, 2007 * SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007 * SEI Daily Income Trust - Money Market Fund, November 9, 2007 * SEI Daily Income Trust - Prime Obligation Fund, November 8, 2007 * STI Classic Funds, October 26, 2007 AFFILIATED TRANSACTIONS - OTHER * Investment Company Institute and SIFMA AMG, May 27, 2020 * Investment Company Institute, March 26, 2020 * Golub Capital BDC, Inc., et al., September 7, 2018 * Morgan Stanley Institutional Fund of Hedge Funds, October 7, 2011 * Investment Company Institute, April 2, 2010 * T. Rowe Price Associates, Inc., October 8, 2009 * Regions Morgan Keegan Funds, March 30, 2009 * Columbia Funds, et al., December 23, 2008 * BNY Mellon Funds Trust, December 2, 2008 * Franklin Templeton Investments, November 21, 2008 * Highbridge Statistical Market Neutral Fund, September 29, 2008 * Dreyfus Cash Management, et al., September 25, 2008 * Investment Company Institute, September 25, 2008 * T. Rowe Price Associates, Inc., July 10, 2008 * ING Series Fund, Inc., et al., April 30, 2008 * Highbridge Statistical Market Neutral Fund, April 7, 2008 * Old Mutual Advisors Funds, November 16, 2007 * Van Kampen Funds Inc., January 31, 2007 * Gartmore Variable Insurance Trust, December 29, 2006 * GuideStone Financial, et al., December 27, 2006 * Federated Municipal Funds, November 20, 2006 * Merrill Lynch & Co., Inc., September 27, 2006 * Citigroup Global Markets, Inc., September 26, 2006 * Mutual of America Investment Corporation, June 2, 2006 * GE Institutional Funds, December 21, 2005 * Investment Company Institute, December 14, 2005 * Wells Fargo Alternative Asset Management, LLC, January 26, 2005 * 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 * Signature Financial Group, Inc., December 28, 1999 * Drinker, Biddle & Reath, December 18, 1998 * The Eaton Vance Group of Investment Companies, July 25, 1997 * Merrill Lynch Asset Management, April 28, 1997 * Dean Witter World Wide Investment Trust, September 17, 1996 * Morgan Grenfell Investment Trust, September 13, 1996 * Rowe Price-Fleming International Inc., April 12, 1996 * DFA Investment Trust, March 21, 1996 * DFA Investment Trust Company, October 17, 1995 * Norwest Funds - Municipal Money Market Fund, August 8, 1995 * ACM Institutional Reserves, Inc., July 14, 1995 * Alliance Municipal Trust, July 14, 1995 * Municipal Fund for California Investors, Inc., July 12, 1995 * California Municipal Cash Trust, July 11, 1995 * Lehman Brothers Daily Income Fund, July 7, 1995 * Benham California Tax-Free and Municipal Funds, June 30, 1995 * Kemper Money Market Funds, June 23, 1995 * The One Group, May 23, 1995 * Twentieth Century Mutual Funds, July 7, 1995 * Wells Fargo Money Market Funds, July 7, 1995 * Salomon Brothers Inc., April 25, 1995 * PaineWebber Managed Investments Trust, August 4, 1994 * Century Shares Trust, May 4, 1994 * The Capitol Mutual Funds and Nations Fund Trust, February 24, 1994 * North American Security Trust and NASL Series Trust, February 2, 1993 AGENCY CROSS TRANSACTIONS * Merrill Lynch Asset Management, April 28, 1997 AGGREGATED TRANSACTIONS * Massachusetts Mutual Life, July 28, 2000 * Massachusetts Mutual Life, June 7, 2000 ANNUAL REPORTS * Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003 * Lindbergh Funds, October 30, 2002 ANNUITY CONTRACTS * Mutual of America Life Insurance Company, June 17, 1993 ANTI-TAKEOVER STATUTES * Staff Statement on Control Share Acquisition Statutes, May 27, 2020 * Boulder Total Return Fund, Inc., November 15, 2010 ASSET-BACKED SECURITIES * Investment Company Institute and SIFMA AMG, May 27, 2020 * Franklin Templeton Investments, June 19, 2009 * New Center Asset Trust, November 5, 1998 * Credit Suisse First Boston, September 9, 1998 * Nebraska Higher Education Loan Program Inc., April 4, 1998 * Nebraska Higher Education Loan Program, April 3, 1998 * Federated Investors, July 8, 1997 * Citicorp Securities, April 6, 1995 * ESI S.A., February 2, 1995 * Global Exempt Certificates of Ownership in NHA MBS Securities Inc., December 30, 1994 * Donaldson, Lufkin & Jenrette Securities Corporation, May 26, 1994 * Brown & Wood, February 24, 1994 ASSIGNMENTS * lNG Investments, LLC, Directed Services LLC, and lNG Investment Management Co. LLC, March 27, 2013 * Emerging Global Advisors, LLC and EGA Emerging Global Shares Trust, February 27, 2013 * American Century Investment Management, Inc., February 2, 2012 * Fortis Group, et al., January 27, 2009 * First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008 * JP Morgan Chase-Bear Stearns Asset Management, July 14 and March 16, 2008 * Metropolitan Life Insurance Company, November 23, 1999 * Zurich Insurance Company; Scudder Kemper Investments, Inc., August 31, 1998 * Wells Fargo Bank, N.A., March 31, 1998 * American Century Companies, Inc. / J.P. Morgan & Co., December 23, 1997 * Dean Witter, Discover & Co.; Morgan Stanley Group Inc., April 18, 1997 * Pilgrim America, Inc., October 8, 1996 * Mutual Benefit Fund, et al., March 30, 1994 * Dean Witter, Discover & Co., February 8, 1993 * Mutual Benefit Fund, et al., August 23, 1991 * Value Line, Inc., April 18, 1990 ATTRIBUTION * Cornish & Carey Commercial Inc., February 26, 1996 AUCTION RATE NOTES * Auction Rate Securities, January 6, 2009 * BNY Mellon Funds Trust, December 2, 2008 * Auction Rate Securities - Global Exemptive Relief, September 22, 2008 AUTOMATIC BAR * E*Trade Capital Markets LLC, March 12, 2009 BACKWARD PRICING * ReFlow Fund, LLC, July 15, 2002 BANKS * North American Division of Seventh-Day Adventists, October 6, 2015 * General Motors Investment Management, February 20, 2000 BANKS - AFFILIATED MUTUAL FUNDS * Mutual Funds and Derivative Instruments, September 26, 1994 BANKS - COLLECTIVE TRUST FUNDS * ABA Retirement Funds Program, June 7, 2010 * Massachusetts Mutual Life Insurance Company, August 10, 1998 * State Street Bank & Trust, August 1, 1996 * Federated Investors, April 21, 1994 BANKS - INVESTMENT ADVISORY ACTIVITIES * Federated Investors, April 21, 1994 BENEFICIAL OWNERSHIP QUALIFIED PURCHASER * Invesco Advisers, Inc., April 8, 2014 * Trusts under the Will of Marion Searle, March 29, 2005 * H.E.B. Investment and Retirement Plan (H.E. Butt Grocery Company), May 18, 2001 * Caxton Corporation, December 28, 1994 * Latham & Watkins, December 28, 1994 * Wm. S. Barnickel & Company, November 1, 1994 * Owens-Illinois, Inc., June 24, 1994 * PanAgora Group Trust, April 29, 1994 BOARD OF DIRECTORS * Staff Statement on Fund Board Meetings and Unforeseen or Emergency Circumstances Related to Coronavirus Disease 2019 (COVID-19), March 4, 2020 * Independent Directors Council, February 28, 2019 * Independent Directors Council, October 12, 2018 * Independent Directors Council and Mutual Fund Directors Forum, November 2, 2010 BOARD OF DIRECTORS - RETIREMENT PLANS * Investment Company Institute, April 15, 1998 BORROWINGS * Alliance Funds, April 25, 1997 * Bear, Stearns & Co. Inc., September 16, 1997 * The T. Rowe Price Funds, July 31, 1995 * Alliance Capital Management L.P., April 7, 1993 BROKER DEALER - SPECIAL COMPENSATION * Townsend and Associates, Inc., September 21, 1994 BROKER-DEALERS * Capital Group, January 11, 2017 * InTouch Global, LLC, November 14, 1995 * Letter to Investment Advisers, October 25, 1994 * R. Bryan Stoker, May 13, 1994 * Charles Schwab & Co., May 28, 1992 BROKERAGE ACTIVITIES * Letter to Investment Advisers, October 25, 1994 BUNCHING * Investment Company Institute, October 26, 2017 * Pretzel & Stouffer, December 1, 1995 * SMC Capital, Inc., September 5, 1995 BUSINESS DEVELOPMENT COMPANIES * Carey Credit Income Fund et al., July 15, 2015 * New Mountain Finance Corporation, December 18, 2014 * Main Street Capital Corporation, November 7, 2013 * New Mountain Finance Corporation, November 4, 2013 * MCG Capital Corporation, September 27, 2013 * Main Street Capital Corporation, June 20, 2011 * New Mountain Finance Corporation, April 27, 2011 * Fifth Street Finance Corp., February 25, 2010 * Philadelphia Ventures Liberty Fund, L.P., February 14, 1995 BUSINESS AND INDUSTRIAL DEVELOPMENT COMPANIES * American Capital, Ltd, June 30, 2009 * Kohlberg Capital Corporation, March 12, 2009 * NGP Capital Resources Company (Corrected), December 28, 2007 * Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001 * Plymouth Commercial Mortgage Fund, July 13, 1998 * Plymouth Commercial Mortgage Fund, December 3, 1996 BUSINESS TRANSFERS * Investec Ernst & Company, April 24, 2001 * Prudential Investment Management Services LLC, April 19, 2001 * ING Mutual Funds Management Co. LLC, ING Funds Distributor Inc. and Reich & Tang Distributors, Inc, February 9, 2001 CAPITAL STRUCTURES (BDC) * American Capital, Ltd, June 30, 2009 CASH SOLICITATION * Wells Fargo Securities, LLC, et al., March 21, 2019 * Charles Schwab & Co., Inc., August 7, 2018 * Macquarie Capital (USA) Inc., June 1, 2017 * Stifel, Nicolaus & Company, Inc., December 6, 2016 * F. Porter Stansberry, September 30, 2015 * UBS AG, May 20, 2015 * JPMorgan Chase & Co., May 20, 2015 * Royal Bank of Canada, December 19, 2014 * Bank of America, N.A., November 25, 2014 * Credit Suisse, May 20, 2014 * Stephanie Hibler, January 24, 2014 * RBS Securities, Inc., November 26, 2013 * Wells Fargo Bank, N.A., July 15, 2013 * J.P. Morgan Securities LLC, January 9, 2013 * Wells Fargo Bank, N.A., September 21, 2012 * J.P. Turner & Company, L.L.C., et al, September 10, 2012 * GE Funding Capital Market Services, Inc., January 25, 2012 * Wells Fargo Bank, N.A., December 12, 2011 * J.P. Morgan Securities LLC, July 11, 2011 * J.P. Morgan Securities LLC, June 29, 2011 * BAC Home Loans Servicing, LP (formerly Countrywide Home Loans Servicing LP), June 2, 2011 * UBS Financial Services Inc., May 9, 2011 * Citigroup Inc., October 22, 2010 * General Electric Company, August 2, 2010 * Goldman, Sachs & Co., July 22, 2010 * General Electric Company, August 12, 2009 * Banc of America Securities LLC, June 10, 2009 * RBC Capital Markets Corporation, June 10, 2009 * Deutsche Bank Securities Inc., June 9, 2009 * UBS AG, March 20, 2009 * Automated Trading Desk Specialists, LLC, March 13, 2009 * E*Trade Capital Markets LLC, March 12, 2009 * Wachovia Securities LLC, February 18, 2009 * Citigroup Global Markets, Inc., December 23, 2008 * UBS Securities LLC/UBS Financial Services Inc., December 23, 2008 * Prudential Financial, Inc., September 5, 2008 * Mayer Brown LLP, July 28, 2008 * Barclays Bank PLC, June 6, 2007 * Emanuel J. Friedman and EJF Capital LLC, January 16, 2007 * Ameriprise Financial Services Inc., April 5, 2006 * Millennium Partners, L.P., et al, March 9, 2006 * American International Group, Inc., February 21, 2006 * ING Bank N.V., August 31, 2005 * CIBC Mellon Trust Company, February 24, 2005 * Goldman, Sachs & Co., February 23, 2005 * Morgan Stanley & Co., Inc., February 4, 2005 * American International Group, Inc., December 8, 2004 * 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 * Ramius Capital Management, LLC, April 5, 1996 CASH SOLICITATION - SOLICITORS * Dana Investment Advisors, Inc., October 12, 1994 CHANGE OF CONTROL * JPMorgan Chase; Bear Stearns Asset Management I,, July 14, 2008 * JPMorgan Chase; Bear Stearns Asset Management II, March 16, 2008 CHARITABLE EXCLUSIONS * Deutsche Bank Microcredit Development Fund, Inc., April 8, 2011 * Goldman Sachs Asset Management, L.P., March 13, 2007 * American Bible Society, June 1, 2004 * Mercy Investment Program, Inc., June 12, 2003 * Daughters of Charity National Health System, Inc., April 3, 1998 CLEARING AGENCY * National Securities Clearing Corp., May 24, 1996 CLOSED-END INVESTMENT COMPANIES * Staff Statement on Control Share Acquisition Statutes, May 27, 2020 * BlackRock Science and Technology Trust and BlackRock Utilities, Infrastructure & Power Opportunities Trust, March 3, 2020 * Eaton Vance Tax-Advantaged Dividend Income Fund, et al., December 16, 2019 * Gladstone Investment Corporation, December 5, 2019 * XAI Octagon Floating Rate & Alternative Income Term Trust, August 6, 2019 * Cushing MLP & Infrastructure Total Return Fund and Cushing Renaissance Fund, August 6, 2019 * Nuveen S&P 500 Dynamic Overwrite Fund, et al., April 26, 2019 * Voya Prime Rate Trust, April 8, 2019 * PIMCO Income Strategy Fund and PIMCO Income Strategy Fund II, January 30, 2019 * Eaton Vance Tax-Managed Buy-Write Opportunities Fund, et al., October 29, 2018 * DNP Select Income Fund Inc., October 4, 2018 * PIMCO Corporate & Income Opportunity Fund and PIMCO Income Opportunity Fund, September 13, 2018 * Eagle Point Credit Company Inc., February 14, 2018 * PIMCO Dynamic Income Fund, December 12, 2017 * Nuveen California Select Tax-Free Income Portfolio, November 21, 2017 * Nuveen Municipal Income Fund, Inc. et al., July 27, 2017 * Guggenheim Credit Allocation Fund, April 5, 2017 * Invesco Senior Income Trust, et al., January 25, 2017 * Dechert, January 25, 2017 * The Herzfeld Caribbean Basin Fund, Inc., September 21, 2016 * BlackRock Health Sciences Trust, February 25, 2016 * Fiduciary/Claymore MLP Opportunity Fund, January 7, 2016 * BlackRock Limited Duration Trust, et al., October 19, 2015 * Nuveen Credit Strategies Income Fund, et al., November 7, 2014 * Guggenheim Strategic Opportunities Fund, October 2, 2014 * The Gabelli Convertible & Income Securities Fund, Inc., et al., April 18, 2014 * The Mexico Fund, Inc., December 31, 2013 * Aberdeen Asia-Pacific Income Fund, Inc., June 26, 2013 * Credit Suisse High Yield Bond Fund and Credit Suisse Asset Management Income Fund, Inc., June 26, 2013 * Eaton Vance, et al., June 26, 2013 * First Trust, et al., June 26, 2013 * John Hancock Investors Trust and John Hancock Tax-Advantaged Global Shareholder Yield Fund, June 26, 2013 * NexPoint Credit Strategies Fund, June 26, 2013 * Nuveen, et al., June 26, 2013 * Aberdeen Australia Equity Fund, Inc., Aberdeen Chile Fund, Inc. and Aberdeen Global Income Fund, Inc., April 12, 2012 * Bank of America Corporation and Affiliates ("BAC"), April 29, 2011 * Calamos Convertible Opportunities and Income Fund, Calamos Convertible and High Income Fund, and Calamos Global Total Return Fund, February 14, 2011 * Boulder Total Return Fund, Inc., November 15, 2010 * Nuveen Municipal High Income Opportunity Fund, Nuveen Municipal High Income Opportunity Fund 2, Nuveen Floating Rate Income Opportunity Fund, Nuveen Senior Income Fund, Nuveen Floating Rate Income Fund, and Nuveen Municipal Value Fund, Inc., November 9, 2010 * Energy Income and Growth Fund and First Trust Active Dividend Income Fund, July 27, 2010 * Tortoise Energy Infrastructure Corporation and Tortoise Energy Capital Corporation, April 23, 2010 * Investment Company Institute, March 12, 2009 * BlackRock Advisers LLC and Affiliates, November 4, 2008 * Nuveen Virginia Premium Income Municipal Fund, October 6, 2006 * Investment Company Institute, November 10, 2004 * Frank Russell Investment Company, et al., October 18, 2002 * R.O.C. Taiwan Fund, February 11, 2000 CODE OF ETHICS * WilmerHale, LLP, July 28, 2010 * M&G Investment Management Ltd., March 1, 2007 * National Compliance Service, November 30, 2005 * Prudential Insurance Company of America, March 1, 2005 * Manufacturers Adviser Corp, September 10, 2002 COLLECTIVE INVESTMENT TRUSTS * North American Division of Seventh-Day Adventists, October 6, 2015 * ABA Retirement Funds, November 25, 2013 * General Motors Investment Management, February 20, 2000 COMMERCIAL PAPER * ING Bank, N.V., July 8, 2002 COMMODITY POOLS * Managed Futures Association, July 11, 1996 * Philadelphia Stock Exchange, Inc., October 18, 1994 COMMODITY TRADING ADVISORS * Philadelphia Stock Exchange, Inc., October 18, 1994 COMPLIANCE POLICIES AND PROCEDURES RULE * Investment Company Institute, November 10, 2004 CONSOLIDATION * Fidelity Select Portfolio, April 29, 2008 CONTROL * Iridian Asset Management LLC, April 14, 2009 * Bank of Ireland Asset Management (U.S.) Ltd., April 2, 2009 * Investment Company Institute, March 12, 2009 * Auction Rate Securities, January 6, 2009 CRYPTOCURRENCY * Staff Statement on Funds Registered Under the Investment Company Act Investing in the Bitcoin Futures Market, May 11, 2021 * Staff Letter to ICI and SIFMA AMG: Engaging on Fund Innovation and Cryptocurrency-related Holdings, January 18, 2018 CUSTODIAL RECEIPTS * HOLDRs, September 3, 1999 * Bear, Stearns & Co. Inc., January 28, 1992 CUSTODIAL REQUIREMENTS * Bancafe/Juan Vico, May 22, 1996 CUSTODY * Macedonian Stock Exchange, July 10, 1997 * Bancafe/Juan Vico, May 22, 1996 * Robertson, Stephens & Company, January 12, 1993 CUSTODY - INVESTMENT ADVISERS * Robert Van Grover Esq., Seward & Kissel LLP, December 11, 2019 * Engaging on Non-DVP Custodial Practices and Digital Assets, March 12, 2019 * Madison Capital Funding LLC, December 20, 2018 * Investment Adviser Association, February 21, 2017 * Robert Van Grover, Esq., Seward & Kissel LLP, October 4, 2016 * Investment Adviser Association, April 25, 2016 * 16th Amendment Advisors LLC, March 23, 2015 * Robert Van Grover, Esq., Seward & Kissel LLP, November 5, 2013 * Investment Company Institute, September 5, 2012 * Seward & Kissel LLP, July 21, 2011 * American Institute of Certified Public Accountants, December 23, 2010 * Seward & Kissell, October 12, 2010 * Investment Adviser Association, September 20, 2007 * Deloitte & Touche LLP, August 28, 2006 * ABA Subcommittee on Private Investment Entities, August 10, 2006 * American Skandia Life Assurance Corporation, May 16, 2005 CUSTODY - INVESTMENT COMPANIES * K&L Gates LLP, January 13, 2021 * Chicago Mercantile Exchange, December 19, 2017 * ICE Clear Credit LLC, December 19, 2017 * LCH Limited and LCH.Clearnet LLC, December 19, 2017 * Depository Trust Company of Delaware, LLC dba Delaware Depository, September 12, 2016 * Chicago Mercantile Exchange, December 29, 2015 * ICE Clear Credit LLC, December 29, 2015 * LCH.Clearnet Limited and LCH.Clearnet LLC, December 29, 2015 * LCH.Clearnet Limited and LCH.Clearnet LLC, December 19, 2014 * ICE Clear Credit LLC, December 19, 2014 * Chicago Mercantile Exchange, December 19, 2014 * The Brink’s Company, February 11, 2014 * Chicago Mercantile Exchange, December 26, 2013 * ICE Clear Credit LLC, December 26, 2013 * LCH.Clearnet Limited and LCH.Clearnet LLC, December 26, 2013 * Chicago Mercantile Exchange, July 10, 2013 * Chicago Mercantile Exchange, September 27, 2012 * Chicago Mercantile Exchange, September 27, 2012 * ICE Clear Credit LLC, September 27, 2012 * LCH.Clearnet Limited, September 27, 2012 * ICE Clear Credit LLC, July 29, 2011 * Chicago Mercantile Exchange, July 29, 2011 * Chicago Mercantile Exchange, July 29, 2011 * Chicago Mercantile Exchange, March 24, 2011 * LCH.Clearnet Limited, March 16, 2011 * ICE Trust U.S. LLC, March 1, 2011 * CME Group, Inc., December 3, 2010 * CME Group, Inc., July 16, 2010 * Franklin Templeton Investments, June 19, 2009 * Highbridge Statistical Market Neutral Fund, April 7, 2008 * Austraclear Limited, April 28, 2004 * Fixed Income Clearing Corporation, March 13, 2003 * Government Securities Clearing Corporation, October 19, 2001 * Investment Company Institute, June 15, 1999 * ING Bank N.V., et al., May 24, 1999 * Investment Company Institute, October 3, 1997 * AmSouth Mutual Funds, July 8, 1997 * ASX Settlement & Transfer Corporation, August 13, 1996 * National Securities Clearing Corp., May 24, 1996 * Kavilco, Inc., April 4, 1996 * Morgan Guaranty Trust Company of New York, November 17, 1995 * The Riverfront Funds, Inc., November 8, 1995 * Hongkong Securities Clearing Company Limited, July 13, 1995 * The Canadian Depository for Securities Limited, August 4, 1994 * ASX Settlement and Transfer Corporation, April 19, 1994 * David S. Butterworth, January 27, 1994 * Delta Government Options Corp., Sept. 27, 1990 * Delta Government Options Corp., July 21, 1989 DEFINED CONTRIBUTION PLANS * The Standish Ayer & Wood Inc. Stable Value Group Trust, December 28, 1995 DEFINITIONS * Comdisco, Inc., October 25, 2000 DERIVATIVE SECURITIES * Mutual Funds and Derivative Instruments, September 26, 1994 DIRECTOR * Boulder Growth and Income Fund, Inc., March 5, 2010 * Boulder Total Return Fund, Inc., March 5, 2010 * Federated Core Trust II, L.P., February 6, 2002 * Mexico Equity and Income Fund, The, November 15, 2001 DISCLOSURE * Department of Labor, October 26, 2011 * Kirkpatrick & Lockhart LLP, January 28, 2004 * Janus Adviser Series, August 28, 2000 * Eaton Vance Master Portfolio, December 11, 1996 * National Association for Variable Annuities, June 4, 1996 * Investment Company Registrant General Letter, February 15, 1996 * Letter to Investment Company Registrants, February 3, 1995 * Mutual Funds and Derivative Instruments, September 26, 1994 * Pershing Division of Donaldson, Lufkin & Jenrette Securities Corp., September 15, 1994 DISQUALIFICATION - INVESTMENT COMPANIES * American International Group, Inc., July 18, 1997 DISTRIBUTIONS * Aberdeen Australia Equity Fund, Inc., July 13, 2006 DISTRIBUTION FEES * Citigroup Inc., July 26, 2006 * Investment Company Institute, October 30, 1998 DISTRIBUTION PLANS * E*TRADE Securities, LLC, November 30, 2005 * Investment Company Institute, October 30, 1998 * Gary E. Hughes, American Council of Life Insurance, May 26, 1996 DIVERSIFICATION * Stradley Ronon Stevens & Young, LLP, June 24, 2019 * Frankin Templeton Group of Funds, et al., May 21, 1999 ELIGIBLE FOREIGN CUSTODIAN * Moscow Municipal Bank, April 8, 1998 * Stock Holding Corporation of Indian Ltd., January 21, 1998 * K. K. Rajendran, November 21, 1997 * Bucharest Stock Exchange, June 3, 1997 * Depository Clearing Company, December 19, 1997 * Russia Growth Fund, Inc., May 20, 1997 * National Securities Depository Ltd., February 25, 1997 * ASX Settlement & Transfer Corporation, August 13, 1996 * Financial Services Board, April 24, 1996 * Templeton Russia Fund, Inc., April 18, 1995 * State Street Bank & Trust Company, February 28, 1995 * Warsaw Stock Exchange, October 20, 1994 * Japan Securities Depository Center, August 31, 1993 * Stock Exchange of Thailand, August 26, 1993 * Malaysian Central Depository Sdn. Bhd., May 19, 1993 * Korea Securities Depository Corporation, May 14, 1993 * Austraclear Limited, April 6, 1993 * Reserve Bank of New Zealand, May 24, 1993 * Custody of B Shares Trading on the Shenzhen and Shanghai Securities Exchanges, April 26, 1993 EMERGENCIES * Investment Company Institute, December 8, 1999 EMPLOYEE BENEFIT PLANS * Investment Company Institute, et al., November 16, 2015 * American Retirement Association, February 18, 2015 * ABA Retirement Funds, November 25, 2013 * ING Life Insurance and Annuity Company, August 30, 2012 * Emeriti Consortium for Retirement Health Solutions, June 16, 2008 * Lear Corporation Retirement Savings Plan Trusts, March 16, 2007 * Emeriti Consortium for Retirement Health Solutions, April 7, 2005 * Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003 * Honeywell International Inc Savings Plan Trust, October 7, 2002 * World Financial Network National Bank, May 28, 1996 * U.S. Department of Labor, February 22, 1996 * Total, January 26, 1996 * Department of Labor, December 5, 1995 * Caxton Corporation, December 28, 1994 * Latham & Watkins, December 28, 1994 * Edward H. Fleischman, June 30, 1994 * Owens-Illinois, Inc., June 24, 1994 * PanAgora Group Trust, April 29, 1994 * County of Los Angeles, January 27, 1993 EMPLOYEE SECURITIES COMPANIES * Tudor Employee Investment Fund LLC and Tudor Investment Corporation, April 28, 2015 * BSC Employee Fund, L.P. October 14, 1997 ERISA * Department of Labor, October 26, 2011 * Department of Labor, December 5, 1995 EXCHANGE-TRADED FUNDS (ETFS) * SPDR Series Trust, et al., (June 24 , 2015) * Derivatives Use by Actively-Managed ETFs, December 6, 2012 * FQF Trust, et al., December 13, 2011 * Barclays Global Fund Advisors et al., March 12, 2009 * iShares Trust, et al., October 22, 2008 EXCHANGE-TRADED PRODUCTS * SPDR S&P Dividend ETF, March 28, 2016 * Market Vectors ETF Trust, et al., March 26, 2012 * Select Sector SPDR Fund and Diamonds Trust, July 6, 2000 EXCHANGE OFFER * National Association for Variable Annuities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001 * Bradley A. Veld, August 15, 1997 EXCHANGE PRIVILEGE * New Mountain Finance Corporation, December 18, 2014 * New Mountain Finance Corporation, April 27, 2011 EXEMPTIVE APPLICATIONS AND ORDERS * Innovator Capital Management, LLC, et al., October 6, 2017 * Neuberger Berman Investment Advisers LLC, September 28, 2016 * Maxim Series Fund, Inc., et al., July 31, 2009 * Fixed Income Securities, L.P., April 29, 2004 * MTB Group of Funds, October 21, 2003 * Chase Manhattan Bank, June 12, 1998 FACE-AMOUNT CERTIFICATE * Peninsular & Oriental Steam Navigation Company, October 15, 2003 FACTORING * Municipality Finance Ltd., April 28, 1994 FAIR VALUE PRICING * Letter to the Investment Company Institute Regarding Valuation Issues, April 2001 * Investment Company Institute, December 8, 1999 FAMILY OFFICE EXCLUSION * Peter Adamson III, April 3, 2012 FEES & EXPENSES * AIG Life Insurance Company, August 16, 2001 FIDELITY BONDS - INVESTMENT COMPANIES * ICI Mutual Insurance Company, February 28, 1994 FIDUCIARY DUTIES * BNY ConvergEx Group, September 21, 2010 * Boulder Growth and Income Fund, Inc., March 5, 2010 * Boulder Total Return Fund, Inc., March 5, 2010 * Constellation Financial Management LLC, January 9, 2003 FILING - DATES * Scudder Investment Trust, March 23, 1994 FILING PROCEDURE - FEES * Ironwood Multi-Strategy Fund LLC and Ironwood Institutional Multi-Strategy Fund LLC (April 19, 2017) * Jackson National Life (July 9, 2015) * GMO Trust, May 24, 2012 * AXA Equitable Life Insurance Company, February 27, 2009 * Nuveen Flagship Multistate Trust I, July 10, 1998 * American Council of Life Insurance, June 20, 1995 * The Victory Funds and The Victory Portfolios, April 24, 1995 * Kemper Total Return Fund, February 6, 1995 FILING PROCEDURES * Investment Company Registrant General Letter, February 15, 1996 * Letter to Investment Company Registrants, February 3, 1995 FINANCE SUBSIDIARIES * Brown & Wood, February 24, 2000 * KDSM, Inc. and Sinclair Capital, February 21, 1997 * Hewlett-Packard Finance Company, July 17, 1996 * Queensland Treasury Corporation, September 26, 1995 * Goldman Sachs & Co., April 27, 1995 * Andrews & Kurth L.L.P., April 5, 1994 * Lehman Brothers Inc., March 8, 1994 FINANCIAL STATEMENT * Fidelity Management & Research Company et al., September 22, 2017 * Great-West Life & Annuity Insurance Company, November 16, 2016 * Franklin Limited Duration Income Trust, July 27, 2016 * Fidelity Management & Research Company et al., June 20, 2016 * Copley Fund, Inc., April 5, 2013 * TIAA Real Estate Account, May 1, 1996 FLOATING RATE SECURITIES * Investment Company Institute (Corrected), August 10, 2010 * Investment Company Institute, June 16, 1993 * Investment Company Institute, November 2, 1992 FOREIGN BANKS * Seward & Kissel, October 12, 2005 * Safra Republic Holdings, April 21, 1998 * Interbolsa, August 5, 1996 * Alliance Capital Management L.P., April 7, 1993 FOREIGN CUSTODIAN * Chase Manhattan Bank, June 12, 1998 * Investment Company Institute and the Global Custodians, February 19, 1998 * Reserve Bank of Australia, January 30, 1998 * Societatea Nationala de Compensare, January 28, 1998 * K. K. Rajendran, November 21, 1997 * The Canadian Depository for Securities Limited, August 4, 1994 * ASX Settlement and Transfer Corporation, April 19, 1994 FOREIGN GOVERNMENT SECURITIES * SSGA International Liquidity Fund, December 2, 1998 * Five Arrows Short-Term Investment Trust, September 26, 1997 FOREIGN INVESTMENT ADVISERS * Alliance Trust Company of Nevada, March 5, 2021 * Royal Bank of Canada, et al., June 3, 1998 * ABN AMRO Bank N.V., July 1, 1997 * Murray Johnstone Holdings Limited; Murray Johnstone Limited; Murray Johnstone International Limited, July 21, 1994 * Mercury Asset Management plc, April 16, 1993 * Uniao de Bancos de Brasileiros S.A., July 28, 1992 * Richard Ellis, Inc., March 19, 1981 FOREIGN INVESTMENT COMPANIES * Dechert LLP, March 8, 2017 * Red Rocks Capital, LLC, June 3, 2011 * Dechert LLP, August 24, 2009 * Mike Krichew, November 5, 1997 * Bradley A. Veld, August 15, 1997 * Eaton Vance South Asia Portfolio, March 12, 1997 * Goodwin, Procter & Hoar, February 28, 1997 * Indosuez Asset Management Asia Limited, February 14, 1997 * Templeton Vietnam Opportunities Fund, Inc., September 6, 1996 * Investment Funds Institute of Canada, February 6, 1996 * Fiduciary Trust Global Fund, August 2, 1995 * The South America Fund N.V., September 2, 1993 * Pasadena Investment Trust, January 22, 1993 * American Funds Distributors, October 16, 1989 FORM 13F * Morgan Stanley Smith Barney LLC, May 29, 2009 FORWARD CONTRACT * Drinker, Biddle & Reath, December 18, 1998 FRAUD * GE Funding Capital Market Services, Inc., January 25, 2012 * J.P. Morgan Securities LLC, July 11, 2011 * Constellation Financial Management LLC, January 9, 2003 FRAUD - INVESTMENT ADVISERS ACT * Heitman Capital Management, LLC, February 12, 2007 FUNDS OF FUNDS - AFFILIATED * Dechert LLP, March 8, 2017 * Dechert, January 25, 2017 * Thrivent Financial for Lutherans and Thrivent Asset Management, LLC, September 27, 2016 * Northern Lights Fund Trust, June 29 , 2015 * Franklin Templeton Investments, April 3, 2015 * New Mountain Finance Corporation, December 18, 2014 * John Hancock Trust, et al, April 12, 2012 * FQF Trust, et al., December 13, 2011 * New Mountain Finance Corporation, April 27, 2011 * Madison Asset Management, LLC, et al., June 30, 2009 * iShares Trust, et al., October 22, 2008 * Merrill Lynch & Co., Inc., September 27, 2006 * Principal Investors Fund Inc., May 13, 2005 * Neuberger Berman Management Inc., et al., April 30, 2003 * MassMutual Institutional Funds, Inc., October 19, 1998 * Eaton Vance South Asia Portfolio, March 12, 1997 * Lazard Freres Asset Management, January 10, 1997 * Mutual Series Fund Inc., November 7, 1995 FUNDS OF FUNDS - FOREIGN INVESTMENT COMPANIES * Dechert LLP, March 8, 2017 * Red Rocks Capital, LLC, June 3, 2011 * Dechert LLP, August 24, 2009 * ASA (Bermuda) Limited, December 13, 2006 * Alternative Investment Partners Absolute Return Fund STS, July 10, 2006 * France Growth Fund, Inc., July 15, 2003 * Man-Glenwood Lexington TEI, LLC and Man-Glenwood Lexington TEI, LDC, April 30, 2004 * Templeton Vietnam Opportunities Fund, Inc., September 6, 1996 FUND SUPERMARKETS * Investment Company Institute, October 30, 1998 GENERIC COMMENT LETTE>CHIEF FINANCIAL OFFICER, NOVEMBER 1, 1994 GOVERNMENT AGENCY * Missouri Family Trust Fund, September 22, 1992 GOVERNMENT INSTRUMENTALITIES * Federal National Mortgage Association, July 12, 2002 * Federal Home Loan Mortgage Corporation, July 12, 2002 GOVERNMENT SECURITIES * Straight-A Funding, LLC, July 28, 2009 * Federal National Mortgage Association, July 12, 2002 * Federal Home Loan Mortgage Corporation, July 12, 2002 * J.P. Morgan Structured Obligations Corporation, July 27, 1994 * T. Rowe Price Tax-Free Funds, June 24, 1993 GOVERNMENTAL PLANS * Massachusetts Mutual Life Insurance Company, August 10, 1998 * State Street Bank & Trust, August 1, 1996 HEDGE CLAUSES * Heitman Capital Management, LLC, February 12, 2007 HEDGE FUNDS * The Townsend Group, Inc., July 9, 2008 * ABA Subcommittee on Private Investment Entities, August 10, 2006 * ABA Subcommittee on Private Investment Entities, December 8, 2005 * The Goldman Sachs Group, Inc., March 8, 2005 HUB AND SPOKE FUNDS * Dechert LLP, March 8, 2017 * PIMCO Funds, July 9, 2002 * Signature Financial Group, Inc., December 28, 1999 * Neuberger & Berman Income Funds, February 27, 1998 * The Eaton Vance Group of Investment Companies, July 25, 1997 * Principle Preservation Portfolios, Inc., December 6, 1995 ILLIQUID SECURITIES * Investment Company Institute and SIFMA AMG, May 27, 2020 * Franklin Templeton Investments, June 19, 2009 * Investment Company Institute, May 26, 1995 INADVERTENT INVESTMENT COMPANIES * Missouri Bankers Association, August 18, 2008 * One Point Communications Corp, June 12, 1998 INDEPENDENT DIRECTORS * Pioneer Funds, December 20, 2005 * Mutual Fund Directors Forum, May 9, 2002 INDEPENDENT LEGAL COUNSEL * Investment Company Institute, February 12, 2002 INDEPENDENT PUBLIC ACCOUNTANT * Main Street Capital Corporation, June 20, 2011 INJUNCTIONS * Goldman, Sachs & Co., July 22, 2010 * E*Trade Capital Markets LLC, March 12, 2009 INSPECTIONS - INVESTMENT ADVISERS * Jennison Associates LLC, July 6, 2000 INSURANCE COMPANIES * Mutual of Omaha Insurance Company, November 27, 1998 * American Mutual Life Insurance, June 13, 1996 * Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, November 8, 1989 INSURANCE COMPANY REGULATION * Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, January 24, 1989 INSURANCE PRODUCTS * Integrity Life Insurance Co., National Integrity Life Insurance Co., Western-Southern Life Assurance Co., Touchtone Securities, Inc., December 21, 2011 * IDS Life Insurance Company, et al., December 14, 2006 * American Home Assurance Company, et al., October 17, 2005 * AICPA SEC Regulations Committee, March 8, 2005 * 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 Annuities; Insurance Marketplace Standards Assn; American Council of Life Insurers, June 19, 2001 * Nationwide Life Insurance Company, March 16, 2001 INTEGRATION * Mark A. Bush, August 8, 1995 * Shoreline Fund, L.P., November 14, 1994 * Shoreline Fund, L.P., April 11, 1994 * Welsh, Carson, Anderson & Stowe, June 18, 1993 INTERESTED PERSON * Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002 * First Financial Fund, Inc., at al., June 5, 1997 * G.T. Global Growth Series et al., February 2, 1996 * Colonial Trust I et al., October 20, 1995 * Founders Funds, Inc., August 4, 1992 INTERNATIONALIZATION OF SECURITIES MARKETS * Goodwin, Procter & Hoar, February 28, 1997 * Indosuez Asset Management Asia Limited, February 14, 1997 INTERNET * Thomson Financial Inc., July 10, 2002 * ReFlow Fund, LLC, July 15, 2002 INTERVAL FUNDS * The Swiss Helvetia Fund, Inc., May 5, 2010 INVESTMENT ADVISERS * Golub Capital Investment Corporation, et al., June 24, 2019 * DJZ Associates, Nov. 19, 1975 * Goldman, Sachs & Co., June 20, 2013 * Tuition Plan Consortium, LLP, February 4, 2003 * Thomson Financial Inc., July 10, 2002 * National Football League Players Association, January 25, 2002 * Goldman, Sachs & Co., February 22 , 1999 INVESTMENT ADVISERS ACT STATUS * Sisters of Mercy of the Americas, Inc., October 1, 2009 * Credit Agricole Asset Management Alternative Investments, Inc., August 7, 2006 * Morgan, Lewis & Bockius LLP, November 17, 2005 * UBS Financial Services, Inc., September 29, 2005 * Ark Therapeutics Group plc, April 15, 2005 * Emeriti Consortium for Retirement Health Solutions, April 7, 2005 * The Goldman Sachs Group, Inc., March 8, 2005 * Gulf Coast Venture Forum, Inc., August 21, 2002 * Thomson Financial Inc., July 10, 2002 * BISYS Fund Services, Inc., September 2, 1999 * Sacha Stawski, August 9, 1996 * PerfectData Corporation, August 5, 1996 * Mr. Frank Mason, July 3, 1996 * Real Goods Trading Corporation, June 24, 1996 * Russell H. Smith, May 2, 1996 * RDM Infodustries, Inc., March 25, 1996 * U.S. Department of Labor, February 22, 1996 * Department of Labor, December 5, 1995 * InTouch Global, LLC, November 14, 1995 * Datastream International Inc., March 15, 1993 INVESTMENT ADVISERS ACT STATUS - BROKER-DEALERS * Securities Industry and Financial Markets Association, November 4, 2019 * Securities Industry and Financial Markets Association, October 26, 2017 * BNY ConvergEx Group, September 21, 2010 INVESTMENT ADVISERS ACT STATUS - PUBLISHERS * Jonathon Hendricks, January 26, 2015 * Missouri Innovation Center, Inc., October 17, 1995 * Alfred A. Zurl, August 7, 1995 * Venture Search Technology Inc., July 11, 1995 * Louis Russo, June 16, 1994 * Stephen R. Kelly, July 28, 1994 INVESTMENT ADVISER REGISTRATION * Industrial Alliance, Investment Management Inc. , November 5, 2018 * CenturyLink Investment Management Company, December 8, 2016 * Willkie Farr & Gallagher, September 21, 2015 * TACT Asset Management Inc., October 24, 2012 * Allianz of America, Inc., May 25, 2012 * Peter Adamson III, April 3, 2012 * Industrial Alliance, Investment Management Inc., March 14, 2012 * American Bar Association, Business Law Section, January 18, 2012 * Zenkyoren Asset Management of America Inc., June 30, 2011 * Lockheed Martin Investment Management Company, June 6, 2006 * Royal Bank of Canada, et al., June 3, 1998 * ABN AMRO Bank N.V., July 1, 1997 * David Parkinson, October 19, 1995 * Thomson Advisory Group L.P., September 26, 1995 * Mark A. Bush, August 8, 1995 * Gilbert G. Beezley, July 17, 1995 * Venture Search Technology Inc., July 11, 1995 * Dana Investment Advisors, Inc., October 12, 1994 * Arthur Andersen & Co., July 8, 1994 INVESTMENT COMPANY * Washington Capital Joint Master Trust, September 25, 2006 * Royal Dutch Shell plc, May 17, 2005 * Cantor Fitzgerald & Company, February 17, 2004 * Peninsular & Oriental Steam Navigation Company, October 15, 2003 INVESTMENT COMPANY ACT STATUS * John Hancock Stable Value Fund, March 25, 2019 * Hannon Armstrong Sustainable Infrastructure Capital, Inc., September 29, 2016 * North American Division of Seventh-Day Adventists, October 6, 2015 * Royal Dutch Shell plc, August 7, 2015 * Erste Abwicklungsanstalt, October 10, 2012 * Linn Energy, LLC, August 30, 2012 * Xplornet Communications Inc., January 11, 2012 * Royalty Pharma, August 13, 2010 * Accor Services, June 7, 2010 * Sisters of Mercy of the Americas, Inc., October 1, 2009 * Emeriti Consortium for Retirement Health Solutions, September 3, 2009 * Emeriti Consortium for Retirement Health Solutions, June 16, 2008 * Dexia Municipal Agency, December 26, 2007 * Exelon Corporation, September 13, 2007 * Cooley Godward & Kronish, July 12, 2007 * MACRO Securities Depositor, LLC, December 1, 2006 * Willkie Farr & Gallagher, October 23, 2000 * Pengrowth Energy Trust, January 27, 2000 * HOLDRs, September 3, 1999 * Mutual of Omaha Insurance Company, November 27, 1998 * Credit Suisse First Boston, September 9, 1998 * Puerto Rico Balanced Fund, Inc., April 29, 1997 * Managed Futures Association, July 11, 1996 * Mr. Frank Mason, July 3, 1996 * American Mutual Life Insurance, June 13, 1996 * World Financial Network National Bank, May 28, 1996 * Total, January 26, 1996 * Maxine Harry, December 6, 1995 * Kake Tribal Corporation, May 25, 1994 INVESTMENT RESTRICTIONS * BlackRock Multi-Sector Income Trust, July 9, 2013 * Morgan Stanley Mortgage Securities Trust, July 9, 2013 * The First Australia Fund, Inc., July 29, 1999 INVESTMENT SECURITIES * PIMCO Funds, July 9, 2002 JOINT TRANSACTIONS * Carlyle Global Credit Investment Management, L.L.C., October 19, 2023 * Investment Company Institute and SIFMA AMG, May 27, 2020 * Mutual of America Capital Management LLC, October 26, 2017 * Nuveen Asset Management, Inc., et al., December 30, 2010 * Investment Company Institute, April 2, 2010 * Highbridge Statistical Market Neutral Fund, September 29, 2008 * Highbridge Statistical Market Neutral Fund, April 7, 2008 * Neuberger Berman Management Inc., et al., April 30, 2003 * The Chase Manhattan Bank, July 24, 2001 * Investment Company Institute, April 15, 1998 * PNC Bank N.A., June 10, 1997 * Alliance Funds, April 25, 1997 * The T. Rowe Price Funds, July 31, 1995 LEVERAGE * Investment Company Institute and SIFMA AMG, May 27, 2020 * T. Rowe Price Associates, Inc., October 8, 2009 * Franklin Templeton Investments, June 19, 2009 LIQUIDATING TRUSTS * Lehman Brothers Holdings Inc., August 12, 2019 * Life Partners Position Holder Trust and Life Partners IRA Partnership, LLC, December 2, 2016 * I.C.H. Corporation, February 26, 1997 * Integrated Resources, Inc., August 5, 1994 * First Coastal Corporation, July 28, 1994 * MPC Liquidating Trust, March 10, 1994 * Oppenheimer Landmrk Properties, March 9, 1993 * Celina Financial Corporation, February 19, 1993 LIMITED PARTNERSHIP INTEREST * W.R. Huff Asset Management Co., L.P., August 10, 1994 * Andrews & Kurth L.L.P., April 5, 1994 * Michael Tannenbaum, January 5, 1993 MERGERS AND REORGANIZATIONS COMBINATIONS * Integrity Life Insurance Co., National Integrity Life Insurance Co., Western-Southern Life Assurance Co., Touchtone Securities, Inc., December 21, 2011 * Janus Aspen Series, April 10, 2008 * CUNA Mutual Life Insurance Company, et al., December 27, 2007 * Ameritas Life Insurance Corp., April 5, 2007 * Mutual of America Investment Corporation, June 2, 2006 * 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 * Nuveen Flagship Multistate Trust I, July 10, 1998 * Neuberger & Berman Income Funds, February 27, 1998 * Equitable Life Assurance Society, December 18, 1996 * Dreyfus Asset Allocation Fund, Inc., June 14, 1996 * Massachusetts Mutual Life, February 15, 1996 * The Capitol Mutual Funds and Nations Fund Trust, February 24, 1994 MINI-ACCOUNT PROGRAM * United Missouri Bank of Kansas City, January 23, 1995 * Wall Street Preferred Money Managers, Inc., April 10, 1992 MONEY MARKET FUNDS * Investment Company Institute, March 19, 2020 * Investment Company Institute Designated NRSROs, August 19, 2010 * Investment Company Institute (Corrected), August 10, 2010 * The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., August 3, 2009 * Mount Vernon Securities Lending Trust, August 3, 2009 * Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Fund, August 3, 2009 * Straight-A Funding, LLC, July 28, 2009 * Citigroup Global Markets, Inc, May 28, 2009 * SEI Daily Income Trust ? Prime Obligation Fund, April 20, 2009 * SEI Liquid Asset Trust ? Prime Obligation Fund, April 20, 2009 * College Retirement Equities Fund (CREF), April 13, 2009 * Columbia Funds Series Trust - Columbia Cash Reserves, March 2, 2009 * Columbia Funds Series Trust - Columbia Money Market Reserves, March 2, 2009 * Master Portfolio Trust - Liquid Reserves Portfolio and Legg Mason Partners Money Market Trust - Western Asset Money Market Fund, March 2, 2009 * Northern Institutional Funds - Diversified Assets Portfolio, Liquid Assets Portfolio and Prime Obligations Portfolio and Northern Funds - Money Market Fund, March 2, 2009 * SEI Liquid Asset Trust - Prime Obligation Fund, March 2, 2009 * Mount Vernon Securities Lending Trust, January 8, 2009 * Master Portfolio Trust - Liquid Reserves Portfolio, December 8, 2008 * Reserve New York Municipal Money-Market Trust - New York Municipal Money-Market Fund, November 18, 2008 * SEI Daily Income Trust - Prime Obligation Fund, November 18, 2008 * Mount Vernon Securities Lending Trust, October 24, 2008 * Russell Investment Company, October 24, 2008 * Columbia Funds Series Trust, October 22, 2008 * ING Funds Trust, ING Investors Trust, and ING Series Fund, Inc., October 22, 2008 * J.P. Morgan Securities Inc., October 22, 2008 * Legg Mason Partners Institutional Trust, October 22, 2008 * Legg Mason Partners Institutional Trust, October 22, 2008 * MainStay VP Cash Management Portfolio, October 22, 2008 * Morgan Stanley Money Market Funds, October 22, 2008 * Mount Vernon Securities Lending Trust, October 22, 2008 * Northwestern Mutual Series Fund, Inc., October 22, 2008 * Penn Series Funds Inc., October 22, 2008 * Penn Series Funds Inc., October 22, 2008 * Phoenix Opportunities Trust, October 22, 2008 * Principal Funds, Inc. and Principal Variable Contracts Funds, Inc., October 22, 2008 * RidgeWorth Funds, October 22, 2008 * Tamarack Funds Trust, October 22, 2008 * Touchstone Variable Series Trust, October 22, 2008 * USAA Mutual Funds Trust, October 22, 2008 * The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., October 20, 2008 * Sun Capital Advisers Trust, October 20, 2008 * Advantus Series Fund, October 20, 2008 * Dreyfus Cash Management Plus, October 20, 2008 * Dreyfus Money Funds, October 20, 2008 * Dreyfus Money Funds, October 20, 2008 * Russell Investment Company, October 20, 2008 * Investment Company Institute, October 10, 2008 * Investment Company Institute, October 8, 2008 * Investment Company Institute, September 25, 2008 * Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 2008 * Northern Institutional Fund, July 16, 2008 * Western Asset Money Market Fund, June 27, 2008 * Western Asset Institutional Money Market Fund, June 27, 2008 * HSBC Investor Funds, June 25, 2008 * Munder Series Trust, June 23, 2008 * Eaton Vance Management, June 13, 2008 * Allianz Dresdner Daily Asset Fund, May 5, 2008 * Master Portfolio Trust, April 18, 2008 * Master Portfolio Trust, April 4, 2008 * SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008 * Northern Institutional Funds, February 28, 2008 * Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008 * HSBC Investor Funds, January 18, 2008 * STI Classic Funds, January 2, 2008 * TDAM Money Market Portfolio, December 21, 2007 * First American Funds, Inc. – Prime Obligation Fund, December 3, 2007 * SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007 * SEI Daily Income Trust - Money Market Fund, November 9, 2007 * SEI Daily Income Trust - Prime Obligation Fund, November 8, 2007 * STI Classic Funds, October 26, 2007 * Evergreen Investment Management Company LLC, October 11, 2005 * Merrill Lynch Investment Managers, May 10, 2002 * AIM Advisors, Inc., February 12, 2002 * SSGA International Liquidity Fund, December 2, 1998 * ICI Mutual Insurance Company, July 27, 1998 * Investment Company Institute, April 15, 1998 * Investment Company Institute, May 9, 1996 * Norwest Funds - Municipal Money Market Fund, August 8, 1995 * California Municipal Cash Trust, July 11, 1995 * Lehman Brothers Daily Income Fund, July 7, 1995 * Twentieth Century Mutual Funds, July 7, 1995 * Wells Fargo Money Market Funds, July 7, 1995 * Benham California Tax-Free and Municipal Funds, June 30, 1995 * J.P. Morgan Structured Obligations Corporation, July 27, 1994 * Adam W. Glass, July 20, 1994 * CBA Money Fund, et al., June 9, 1994 * Donaldson, Lufkin & Jenrette Securities Corporation, May 26, 1994 * Sean J. Egan, May 10, 1994 * Investment Company Institute, June 16, 1993 * Investment Company Institute, November 2, 1992 * Morgan Keegan & Company, Inc., July 24, 1992 MIXED AND SHARED FUNDING * Maxim Series Fund, Inc., et al., July 31, 2009 MODEL PORTFOLIO * Clover Capital Management, Inc., October 28, 1986 MONEY MARKET LIQUIDITY * J.P. Morgan Securities Inc., October 22, 2008 * Eaton Vance Management, June 13, 2008 * Merrill Lynch Investment Managers, May 10, 2002 MONEY MARKET - LIQUIDITY PUTS * UBS AG, July 29, 2009 MONEY MARKET PORTFOLIO VALUATION * College Retirement Equities Fund (CREF), April 13, 2009 MORTGAGES/REAL ESTATE/REITS * Redwood Trust, Inc., August 15, 2019 * Great Ajax Funding LLC , February 12, 2018 * Redwood Trust, Inc. , October 16, 2017 * Greenwich Capital Acceptance Inc., August 8, 1991 * NAB Asset Corp., June 20, 1991 * Citytrust, December 19, 1990 * United States Property Investment N.V., May 1, 1989 * United Bankers, March 23, 1988 * M.D.C. Holdings, May 5, 1987 * The State Street Mortgage Co., November 18, 1986 * First National Bank of Fremont, November 18, 1985 * Salomon Brothers, Inc., June 17, 1985 * Health Facility Credit Corp., February 6, 1985 * Baton Rouge Building and Construction Industry Foundation, August 31, 1984 * Northwestern Ohio Building and Construction Trades Foundation, April 20, 1984 * Nottingham Realty Securities, April 19, 1984 * Realex Capital Corporation, April 19, 1984 * American Home Finance Corp., April 9, 1981 * MGIC Mortgage Corp., August 1, 1974 * MGIC Mortgage Corp., October 6, 1972 * Urban Land Investments, November 4, 1971 MULTIPLE CLASSES * Differential Advisory Fee Waivers, February 2, 2023 * PaineWebber Incorporated, January 27, 1995 * Investment Company Institute, June 15, 1993 * PNC Fund, et al., April 2, 1993 MUNICIPAL BOND * United Municipal Bond Fund, January 27, 1995 NAMES - MISLEADING * Straight-A Funding, LLC, July 28, 2009 NATIONAL SECURITIES MARKET IMPROVEMENT ACT OF 1996 * BSC Employee Fund, L.P., October 14, 1997 * Davis, Polk & Wardwell, April 24, 1997 NO-ACTION REQUEST PROCEDURES * The Swiss Helvetia Fund, Inc., May 5, 2010 OFFSHORE FUNDS * Dechert LLP, March 8, 2017 * Wilmer, Cutler & Pickering and Davis Polk & Wardell, October 5, 1998 * Goodwin, Procter & Hoar, October 5, 1998 * Pasadena Investment Trust, January 22, 1993 OIL & GAS * Linn Energy, LLC, August 30, 2012 PAY TO PLAY * Investment Company Institute, September 12, 2011 PERIODIC PAYMENT PLAN CERTIFICATE * Peninsular & Oriental Steam Navigation Company, October 15, 2003 PERFORMANCE ALLOCATION * Summit Advisors, Inc., March 1, 1994 PERFORMANCE FEES * Golub Capital Investment Corporation, et al., June 24, 2019 * Amerivest Investment Management, LLC, August 19, 2014 * Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004 * Pacific Select Fund, et al., December 23, 2004 * Seligman New Technologies Fund II, Inc., February 7, 2002 * John W. Henry Co. Inc., September 20, 1996 * Lazard Freres Asset Management, February 12, 1996 * James R. Waters, June 1, 1995 * George Colman, July 18, 1995 * Gerald Zuckerman, February 1, 1994 PERSONAL SECURITIES TRANSACTION * National Compliance Service, November 30, 2005 * Mackenzie Investment Managment et al., August 8, 2000 * Pretzel & Stouffer, December 1, 1995 * W.R. Huff Asset Management Co., L.P., August 10, 1994 PRE-PAID TUITION PLANS * Tuition Plan Consortium, LLP, February 4, 2003 * University of Alaska Advance College Tuition Payment, March 2, 1992 PRICING - FAIR VALUE PRICING * Investment Company Institute, April 30, 2001 * Investment Company Institute, April 30, 2001 * Investment Company Institute, December 8, 1999 * Charles Schwab & Co., Inc., July 7, 1997 * M.S.B. Fund, Inc., February 10, 1995 * United Municipal Bond Fund, January 27, 1995 PRINCIPAL TRANSACTION * J.P. Morgan Securities LLC, April 14, 2016 * BNY ConvergEx Group, September 21, 2010 * Auction Rate Securities, January 6, 2009 * Barclays Capital Inc., September 19, 2008 * JPMorgan Chase; Bear Stearns Asset Management II, March 16, 2008 * Gardner Russo & Gardner, June 7, 2006 * Credit Suisse First Boston, LLC, August 31, 2005 PRINCIPAL UNDERWRITERS * Investment Company Institute, November 10, 2004 PRIVATE INVESTMENT COMPANIES * Managed Funds Association, February 6, 2014 * Frankin Templeton Group of Funds, et al., May 21, 1999 * American Bar Association, April 22, 1999 * Service Corporation International, October 6, 1998 * Lamp Technologies, Inc., May 29, 1998 * Wilkie Farr & Gallagher, June 11, 1996 * Cornish & Carey Commercial Inc., February 26, 1996 * Maxine Harry, December 6, 1995 * Caxton Corporation, December 28, 1994 * Latham & Watkins, December 28, 1994 * Glenwood Investment Corp., August 10, 1994 * Edward H. Fleischman, June 30, 1994 * PanAgora Group Trust, April 29, 1994 * Long-Term Capital Management, L.P., April 28, 1994 PRIVATE INVESTMENT COMPANIES - ATTRIBUTION * Michael Tannenbaum, January 5, 1993 PRIVATE OFFERING * Lamp Technologies, Inc., May 29, 1998 * Goodwin, Procter & Hoar, February 28, 1997 * Merrill Lynch Asset Management, April 28, 1997 * Indosuez Asset Management Asia Limited, February 14, 1997 * Investment Funds Institute of Canada, February 6, 1996 PROSPECTUSES - DELIVERY * Lincoln National Life Insurance & Lincoln Financial Advisors, January 30, 2003 * Metropolitan Life Insurance Company, April 26, 1995 PROSPECTUSES - DISCLOSURE * Lindbergh Funds, October 30, 2002 * Nationwide Life Insurance Company, March 16, 2001 * Investment Company Institute, July 29, 1996 * John Hancock Fund, Inc., June 25, 1996 * Australian Securities Commission, October 23, 1996 * Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, November 8, 1989 * Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, January 24, 1989 * Frank Russell Investment Management Company, August 30, 1993 PROXY STATEMENT * Transamerica Series, Inc., November 7, 1994 * Alameda Contra Costa Medical Association Collective Investment Trust for Retirement Plans, August 26, 1993 PROXY VOTING * Templeton Emerging Markets Income Fund - Omission of Shareholder Proposal Submitted by The McGowan Group Asset Management Retirement Plan, FBO Spencer McGowan, February 5, 2021 * Swiss Helvetia Fund, April 6, 2017 * JP Morgan Municipal Money Market Fund, April 15, 2014 * First Trust Dividend and Income Fund, January 30, 2014 * Firsthand Technology Value Fund, Inc., February 11, 2014 * College Retirement Equities Fund ("Fund") Shareholder Proposal of Aaron Levitt, May 6, 2011 PUBLIC OFFERING * ING Bank, N.V., July 8, 2002 * Wilmer, Cutler & Pickering and Davis Polk & Wardell, October 5, 1998 * Goodwin, Procter & Hoar, October 5, 1998 * Lamp Technologies, Inc., May 29, 1997 * Dean Witter, Discover & Co., February 8, 1993 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) * EIF Neptune, LLC Starwood Energy Investors, LLC & Atlantic Energy Parts, July 29, 2005 * DTE Heritage, LLC, et. al., July 30, 2003 * Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003 * Sections 2(a)(7) * Old Dominion Electric Cooperative, et al., October 13, 2004 * Arizona Electric Power Cooperative, Inc., July 27, 2001 * Western Farmers Electric Cooperative, February 23, 2001 * Sections 2(a)(7) and 2(a)(11)(A) * k1 Ventures, et. al., July 28, 2003 * Evercore METC Investment Inc., et. al., November 25, 2003 * General Electric Capital Corporation, April 26, 2002 * Section 17(c) and Rule 70 * Enron Corporation, March 11, 2004 QUALIFIED PURCHASE DEFINITION - INVESTMENT COMPANY ACT STATUS DETERMINATION * Cabot Wellington, LLC, June 17, 2008 * McDermott, Will & Emery, July 26, 2007 * Goldman Sachs Asset Management, L.P., March 13, 2007 * SCP Private Equity Partners II, L.P., June 6, 2006 * American Bar Association, April 22, 1999 * Sullivan and Cromwell, December 29, 1997 QUALIFIED PURCHASER FUND * The Townsend Group, Inc., July 9, 2008 * Cabot Wellington, LLC, June 17, 2008 * Goldman Sachs Asset Management, L.P., March 13, 2007 * Service Corporation International, October 6, 1998 * BSC Employee Fund, L.P., October 14, 1997 * Redwood Investment Fund, LLC, October 14, 1997 * Davis, Polk & Wardwell, April 24, 1997 REAL ESTATE * Capital Trust, Inc., February 3, 2009 * Capital Trust, Inc., May 24, 2007 * Stephen R. Kelly, July 28, 1994 REAL ESTATE INVESTMENT TRUSTS * College Retirement Equities Fund Real Estate Account, July 22, 1993 RECORDKEEPING REQUIREMENTS - INVESTMENT ADVISERS * Investment Company Institute, September 12, 2011 * Omgeo LLC, August 14, 2009 * Jennison Associates LLC, July 6, 2000 * Salomon Brothers Asset Management Inc and Salomon Brothers Asset Management Asia Pacific Limited, July 23, 1999 * John Bowen Investment Management, May 13, 1997 * Horizon Asset Management, LLC, September 13, 1996 * First Call Corporation, September 6, 1995 RECORDKEEPING REQUIREMENTS - INVESTMENT ADVISER SEPARATE ACCOUNTS * LNC Equity Sales Corporation, August 8, 1997 RECORDKEEPING REQUIREMENTS - INVESTMENT ADVISER SUITABILITY * MLC Limited, July 21, 1997 RECORDKEEPING REQUIREMENTS - INVESTMENT COMPANIES * First Call Corporation, September 6, 1995 REDEEMABLE SECURITIES * ING Life Insurance and Annuity Company, August 30, 2012 * Eaton Vance Management, June 13, 2008 * Nationwide Life Insurance Company, March 16, 2001 * Credit Suisse First Boston, September 9, 1998 * Nebraska Higher Education Loan Program, April 3, 1998 * Donaldson, Lufkin & Jenrette Securities Corporation, May 26, 1994 * Brown & Wood, February 24, 1994 REDEMPTION FEES * Investment Company Institute, February 1, 2007 * Fidelity Advisor Korea Fund, Inc., March 7, 2001 REDEMPTIONS * Committee of Annuity Insurers, April 11, 2024 * Investment Company Institute, June 1, 2018 * ReFlow Fund, LLC, July 15, 2002 * Signature Financial Group, Inc., December 28, 1999 * Investment Company Institute, December 8, 1999 * M.S.B. Fund, Inc., February 10, 1995 * CBA Money Fund, et al., June 9, 1994 * Travelers Insurance Company et al., September 3, 1993 REGISTRATION * ABA Retirement Funds, November 25, 2013 * IDS Life Insurance Company, et al., December 14, 2006 * 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 ADVISERS * Willkie Farr & Gallagher, September 21, 2015 * MEAG MUNICH ERGO., February 14, 2014 * TACT Asset Management Inc., October 24, 2012 * Allianz of America, Inc., May 25, 2012 * Peter Adamson III, April 3, 2012 * Industrial Alliance, Investment Management Inc., March 14, 2012 * American Bar Association, Business Law Section, January 18, 2012 * Zenkyoren Asset Management of America Inc., June 30, 2011 * Lockheed Martin Investment Management Company, June 6, 2006 * Royal Bank of Canada, et al., June 3, 1998 * ABN AMRO Bank N.V., July 1, 1997 * David Parkinson, October 19, 1995 * Thomson Advisory Group L.P., September 26, 1995 * Mark A. Bush, August 8, 1995 * Gilbert G. Beezley, July 17, 1995 * Venture Search Technology Inc., July 11, 1995 * Dana Investment Advisors, Inc., October 12, 1994 * Arthur Andersen & Co., July 8, 1994 REGISTRATION - INVESTMENT COMPANIES * Linn Energy, LLC, August 30, 2012 * ABA Retirement Funds Program, June 7, 2010 * Seward & Kissel LLP, April 15, 2009 * Exelon Corporation, September 13, 2007 * MACRO Securities Depositor, LLC, December 1, 2006 * 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 * Brown & Wood, February 24, 2000 * Richard L. Mertz, April 1, 1993 REGULATION S-P * Staff Responses to Questions About Regulation S-P, January 23, 2003 REIMBURSEMENT OF PROXY EXPENSES * Mexico Equity and Income Fund, The, November 15, 2001 REORGANIZATION * IDS Life Insurance Company, et al., December 14, 2006 * The Eaton Vance Group of Investment Companies, July 25, 1997 * Dreyfus Asset Allocation Fund, Inc., June 14, 1996 * Principle Preservation Portfolios, Inc., December 6, 1995 * The Capitol Mutual Funds and Nations Fund Trust, February 24, 1994 REPORTING REQUIREMENTS - INVESTMENT ADVISERS * Manufacturers Adviser Corp, September 10, 2002 REPORTING REQUIREMENTS - INVESTMENT COMPANIES * Bank of America Corporation and Affiliates ("BAC"), April 29, 2011 * Berthel Growth & Income Trust I, May 5, 2009 * BlackRock Advisers LLC and Affiliates, November 4, 2008 * NGP Capital Resources Company (Corrected), December 28, 2007 * American Home Assurance Company, et. al., October 17, 2005 * College and University Facility Loan Trust One, et al., November 29, 2004 * 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 * Select Sector SPDR Trust, May 6, 1999 REPURCHASE AGREEMENT * Investment Company Institute, June 15, 1999 REVERSE REPURCHASE AGREEMENT * Dreyfus Cash Management, et al., September 25, 2008 SAFE HARBORS * Citigroup Inc., July 26, 2006 SALES FINANCING * Royalty Pharma, August 13, 2010 SALES LOAD * Capital Group, January 11, 2017 * Linsco/Private Ledger Corp., November 1, 1994 * Sedgwick Consulting Group, May 17, 1993 * Charles Schwab & Co., May 28, 1992 SALES LOAD - CONTINGENT DEFERRED * Thomson Fund Group, et al., January 28, 1993 SALES OF FUND SHARES BELOW NAV * Kohlberg Capital Corporation, March 12, 2009 * ReFlow Fund, LLC, July 15, 2002 SECURITY - DEFINITION * PIMCO Funds, July 9, 2002 * Willkie Farr & Gallagher, October 23, 2000 * Mutual of Omaha Insurance Company, November 27, 1998 * American Mutual Life Insurance, June 13, 1996 SECURITIES LENDING * Nuveen Investment Funds, February 13, 2014 * Securities Lending by U.S. Open-End and Closed-End Investment Companies, November 6, 2012 * Nuveen Asset Management, Inc., et al., December 30, 2010 * USB Global Asset Management (US), Inc., November 21, 2002 * UAM Funds Inc., September 24, 2001 * U.S. Bancorp Asset Management Inc., et al., December 11, 2001 * Brinson Funds, et al., November 25, 1997 * Bear, Stearns & Co. Inc., September 16, 1997 * Morgan Guaranty Trust Company of New York, November 17, 1995 * Norwest Bank Minnesota, N.A. and Society National Bank, May 25, 1995 * United Services Funds, April 23, 1993 SECURITIES RELATED BUSINESS * SPDR S&P Dividend ETF, March 28, 2016 * Vanguard Group, Inc., May 22, 2009 * Select Sector SPDR Fund and Diamonds Trust, July 6, 2000 * Victory Stock Index Fund, February 7, 1995 * The Royce Fund, January 24, 1995 * Kidder Peabody Investment Trust, May 14, 1993 SELF CUSTODY - INVESTMENT COMPANIES * Maxim Series Fund Inc., January 14, 2004 SENIOR SECURITIES * Registered Investment Company Use of Senior Securities - Select Bibliography, February 12, 2013 (Last Modified) * American Capital, Ltd, June 30, 2009 * Investment Company Institute, October 8, 2008 * ReFlow Fund, LLC, July 15, 2002 * New America High Income Fund, Inc., July 29, 1993 SEPARATE ACCOUNTS * Integrity Life Insurance Co., National Integrity Life Insurance Co., Western-Southern Life Assurance Co., Touchtone Securities, Inc., December 21, 2011 * First Great-West Life & Annuity Insurance Company & Canada Life Insurance Company of New York, December 22, 2005 * 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 * Massachusetts Mutual Life Insurance Company, August 10, 1998 * Gary E. Hughes, American Council of Life Insurance, May 26, 1996 * Metropolitan Life Insurance Company, New England Mutual Life Insurance Company, and New England Variable Life Insurance Company, May 17, 1996 * The Equitable Life Assurance Society of the United States, December 22, 1995 SERIES COMPANIES * Mutual Series Fund Inc., November 7, 1995 * Scudder Investment Trust, March 23, 1994 SHAREHOLDER MEETINGS * Kohlberg Capital Corporation, March 12, 2009 * Calvert Group, January 7, 1993 SHAREHOLDER PROPOSALS * Nuveen Funds (Nuveen AMT-Free Quality Municipal Income Fund and Nuveen New York AMT-Free Quality Municipal Income Fund) – Omission of Shareholder Proposal Submitted by Karpus Investment Management, May 14, 2024 * Highland Opportunities and Income Fund – Omission of Shareholder Proposal Submitted by Allan Hausman, April 5, 2024 * BNY Mellon Municipal Income, Inc. – Omission of Shareholder Proposal Submitted by Saba Capital Management, L.P., on behalf of Saba Capital Master Fund, Ltd., Pursuant to Rule 14a-8, March 8, 2024 * Nuveen Funds (Nuveen Real Asset Income and Growth Fund; Nuveen Multi-Asset Income Fund, Nuveen Core Plus Impact Fund) – Omission of Shareholder Proposal Submitted by Saba Capital Management, L.P., on behalf of Saba Capital Master Fund, Ltd., February 16, 2024 * Puerto Rico Residents Tax-Free Fund, Inc. – Omission of Shareholder Proposal Submitted by Ocean Capital LLC Pursuant to Rule 14a-8, November 30, 2023 * Japan Smaller Capitalization Fund , October 4, 2022 * Japan Smaller Capitalization Fund, August 26, 2022 * ClearBridge Energy Midstream Opportunity Fund Inc. -- Omission of Shareholder Proposal Submitted by Spencer McGowan Pursuant to Rule 14a-8, February 10, 2021 * ClearBridge MLP and Midstream Fund Inc.-- Omission of Shareholder Proposal Submitted by Spencer McGowan Pursuant to Rule 14a-8 , February 10, 2021 * Vanguard Funds (Vanguard U.S. Value Fund, Vanguard Health Care Fund, Vanguard Energy Fund) - Omission of Shareholder Proposal Submitted by Kani Ilangovan and Mary Lou Rosczyk September 11, 2020 * Prospect Capital Corporation - Omission of Shareholder Proposal Submitted by Michelle Bronsted, August 10, 2020 * Prospect Capital Corporation - Omission of Shareholder Proposal Submitted by Camilla Cane, August 10, 2020 * Prospect Capital Corporation - Omission of Shareholder Proposal Submitted by Camilla Cane, August 10, 2020 * Reconsideration Request, August 24, 2020 * Supplemental Submission, August 27, 2020 * Outgoing Letter, September 16. 2020 * Prospect Capital Corporation - Omission of Shareholder Proposal Submitted by Mark Cane, August 10, 2020 * First Trust Senior Floating Rate Income Fund II - Omission of Shareholder Proposal Submitted by Saba Capital Management, L.P., on behalf of Saba Capital Master Fund, Ltd., June 17, 2020 * Dividend and Income Fund - Omission of Shareholder Proposal Submitted by Alison Pampinella, April 10, 2020 * Dividend and Income Fund - Omission of Shareholder Proposal Submitted by Matisse Discounted Closed-End Fund Strategy, April 10, 2020 * RMR Real Estate Income Fund - Omission of Shareholder Proposal Submitted by Matisse Discounted Closed-End Fund Strategy, April 1, 2020 * Fidelity Blue Chip Value Fund, January 30, 2020 * Fidelity Canada Fund, January 30, 2020 * Fidelity Growth Discovery Fund, January 30, 2020 * Fidelity Mid-Cap Stock Fund, January 30, 2020 * Fidelity Magellan Fund, January 30, 2020 * Fidelity Puritan Fund, January 30, 2020 * Fidelity Stock Selector Small Cap Fund, January 30, 2020 * Fidelity Value Fund, January 30, 2020 * First Trust High Income Long/Short Fund - Omission of Shareholder Proposal Submitted by Dolphin Limited Partnership I, L.P., February 27, 2019 * Tekla Life Sciences Investors - Omission of Shareholder Proposal Submitted by Kenneth Steiner, February 27, 2019 * RMR Real Estate Income Fund - Omission of Shareholder Proposal Submitted by Matisse Discounted Closed-End Fund Strategy, February 20, 2019 * Asia Pacific Fund-Omission of Shareholder Proposal Submitted by Matisse Capital Management, L.P., July 20, 2018 * Delaware Enhanced Global Dividend and Income Fund-Omission of Shareholder Proposal Submitted by Saba Capital Management L.P., May 11, 2018 * Dividend and Income Fund— Omission of Shareholder Proposal Submitted by Matisse Capital , March 27, 2018 * Tekla Life Sciences Investors — Omission of Shareholder Proposal Submitted by Kenneth Steiner, March 8, 2018 * First Trust Mortgage Income Fund, January 25, 2018 * Franklin Limited Duration Income Trust, July 27, 2016 * Deutsche Multi-Market Income Trust (Omission of Shareholder Proposal), June 24, 2016 * Deutsche Strategic Income Trust (Omission of Shareholder Proposal), June 24, 2016 * Omission of Shareholder Proposal (Fidelity Freedom 2020 Fund, Fidelity Freedom 2025 Fund, and Fidelity Advisor Municipal Income Fund), August 12, 2015 * Omission of Shareholder Proposal Submitted by Steven N. Harris (Liberty All-Star Equity Fund), May 6, 2015 * Opportunity Partners L.P. Shareholder Proposal (Clough Global Equity Fund), April 16, 2015 * Harris & Harris Group, Inc., April 3, 2015 * Tom DeWard Shareholder Proposal (LMP Real Estate Income Fund, Inc.), March 25, 2015 * Fidelity Inflation-Protected Bond Fund (Omission of Shareholder Proposal), February 24, 2015 * Karpus Management, Inc. Shareholder Proposal (Alliance Bernstein Income Fund, Inc.), February 18, 2015 * Ellsworth Fund Ltd, November 6, 2014 * First Trust Dividend and Income Fund, January 30, 2014 * Firsthand Technology Value Fund, Inc., February 11, 2014 * Request for Consideration of the Steve Tamari Shareholder Proposal (College Retirement Equities Fund), May 23, 2013 * Sandra M. Fox Shareholder Proposal (College Retirement Equities Fund), May 10, 2013 * Steve Tamari Shareholder Proposal (College Retirement Equities Fund), May 10, 2013 * Fidelity Select Portfolios, March 15, 2013 * Pacholder High Yield Fund, Inc., January 18, 2013 * Foxby Corp., September 17, 2012 * Liberty All-star Growth Fund, Inc., May 10, 2012 * ING Emerging Countries Fund, May 7, 2012 * Guggenheim Enhanced Equity Strategy Fund, March 21, 2012 * College Retirement Equities Fund ("Fund") Shareholder Proposal of Aaron Levitt, May 6, 2011 * Omission of Shareholder Proposal Pursuant to Rule 14a-8 for H&Q Life Sciences Investors, March 24, 2011 * Lazard Global Total Return and Income Fund, Inc. and Lazard World Dividend & Income Fund, Inc., February 15, 2011 * H & Q Life Sciences Investors, February 4, 2011 * Adams Express Company, January 26, 2011 * The Ibero-America Fund, Inc., September 9, 2010 * The Swiss Helvetia Fund, Inc., May 5, 2010 * TS&W/Claymore Tax-Advantaged Balanced Fund, April 27, 2009 * U.S. Government Reserves and Fidelity Cash Reserves, April 27, 2009 * American Capital, Ltd., February 5, 2009 * College Retirement Equities Fund, May 19, 2008 * Fidelity Funds, January 22, 2008 * Franklin Universal Trust, December 18, 2007 * Alliance World Dollar Government Fund, Inc., October 19, 2006 * Putnam Premier Income Trust, March 14, 2006 * Putnam High Income Securities Fund, March 14, 2006 * Putnam Tax-Free Health Care Fund, August 8, 2005 * Fidelity Magellan Fund, March 15, 2005 * 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 * AHA Investment Funds, Inc, March 8, 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 * Fidelity Advisor Korea Fund, Inc, March 7, 2001 SHAREHOLDERS VOTES * Main Street Capital Corporation, June 20, 2011 * First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008 * AHA Investment Funds, Inc., March 8, 2001 * Swiss Helvetia Fund, Inc., March 6, 2001 * R.O.C. Taiwan Fund, February 11, 2000 * Wells Fargo Bank, N.A., March 31, 1998 * Dessauer Global Equity Fund, April 3, 1997 SHORT SALES OR SHORT SELLING * Highbridge Statistical Market Neutral Fund, September 29, 2008 * Highbridge Statistical Market Neutral Fund, April 7, 2008 SOFT DOLLAR ARRANGEMENTS * BNY ConvergEx Group, September 21, 2010 SOLICITORS * Dougherty & Company LCC, July 3, 2003 * Fahnestock & Company Inc., April 21, 2003 * Dougherty & Company LLC, March 21, 2003 * National Football League Players Association, January 25, 2002 SPIN OFFS ASSIGNMENT * Dean Witter, Discover & Co., February 8, 1993 STAPLED SECURITIES * Robertson, Stephens & Company, January 12, 1993 STATE REGULATION * Public Employees' Retirement Board of the State of Oregon, March 3, 1998 STATUS OF INVESTMENT COMPANY * Continental of Illinois (Delaware), Ltd., March 14, 1973 STRUCTURED FINANCING * Franklin Templeton Investments, June 19, 2009 * Credit Suisse First Boston, September 9, 1998 * Nebraska Higher Education Loan Program Inc., April 4, 1998 * Federated Investors, July 8, 1997 * ESI S.A., February 2, 1995 * Global Exempt Certificates of Ownership in NHA MBS Securities Inc., December 30, 1994 * Donaldson, Lufkin & Jenrette Securities Corporation, May 26, 1994 * Brown & Wood, February 24, 1994 STUDENT LOANS * New England Education Loan Marketing Corp, May 22, 1998 SUBSIDIARIES * Hercules Capital, Inc., May 11, 2020 * AFL-CIO Housing Investment Trust, Aug. 5, 2016 * Adams Diversified Equity Fund Inc., April 30, 2015 * ASA Limited, July 23, 2010 * Pengrowth Energy Trust, January 27, 2000 SUCCESSOR REGISTRATION * Barclays Capital Inc., September 19, 2008 TAXATION * Copley Fund, Inc., April 5, 2013 * Wilmer, Cutler & Pickering and Davis Polk & Wardell, October 5, 1998 * Goodwin, Procter & Hoar, October 5, 1998 TENDER OFFERS * UBS AG, July 29, 2009 * Eaton Vance Management, June 13, 2008 TERRITORIAL EXEMPTION * Puerto Rico Balanced Fund, Inc., April 29, 1997 TRACKING STOCK * Comdisco, Inc., October 25, 2000 TRANSIENT INVESTMENT COMPANY * One Point Communications Corp, June 12, 1998 * Keene Corporation, June 2, 1993 TRUSTEE * Global Exempt Certificates of Ownership in NHA MBS Securities Inc., December 30, 1994 UNIT INVESTMENT TRUST * Unit Investment Trust Organizational Expenses, May 9, 1995 * Travelers Insurance Company et al., September 3, 1993 * PaineWebber Equity Trusts, July 19, 1993 * Defined Asset Funds - Equity Income Fund - Select Ten Series, May 5, 1993 VALUATION * Valuation of Portfolio Securities and other Assets Held by Registered Investment Companies - Select Bibliography of the Division of Investment Management, March 20, 2009 * Letter to the Investment Company Institute Regarding Valuation Issues, April 2001 * Investment Company Institute, December 8, 1999 VARIABLE ANNUITIES CONTRACT * AICPA SEC Regulations Committee, March 8, 2005 * National Association for Variable Annuities, June 4, 1996 * Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, November 8, 1989 * Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, January 24, 1989 VARIABLE RATE SECURITIES * Bank of America Corporation and Affiliates ("BAC"), April 29, 2011 * BlackRock Advisers LLC and Affiliates, November 4, 2008 VOTING SECURITY * Staff Statement on Control Share Acquisition Statutes, May 27, 2020 * Boulder Total Return Fund, Inc., November 15, 2010 * Wells Fargo Alternative Asset Management, LLC, January 26, 2005 * Wilkie Farr & Gallagher, June 11, 1996 * Philadelphia Ventures Liberty Fund, L.P., February 14, 1995 VOTING TRUST * Metropolitan Life Insurance Company, November 13, 1999 WARRANTS * The South America Fund N.V., September 2, 1993 WRAP FEE ARRANGEMENTS * BISYS Fund Services, Inc., September 2, 1999 * Pershing Division of Donaldson, Lufkin & Jenrette Securities Corp., September 15, 1994 ALPHABETICAL LIST OF NO-ACTION LETTERS * 16th Amendment Advisors LLC, March 23, 2015 * AAL Mutual Funds, et al., December 12, 2002 * ABA Retirement Funds, November 25, 2013 * ABA Retirement Funds Program, June 7, 2010 * ABA Subcommittee on Private Investment Entities, August 10, 2006 * ABA Subcommittee on Private Investment Entities, December 8, 2005 * Aberdeen Asia-Pacific Income Fund, Inc., June 26, 2013 * Aberdeen Australia Equity Fund, Inc., July 13, 2006 * Aberdeen Australia Equity Fund, Inc., Aberdeen Chile Fund, Inc. and Aberdeen Global Income Fund, Inc., April 12, 2012 * Accor Services, June 7, 2010 * AHA Investment Funds, Inc, March 8, 2001 * ABN AMRO Bank N.V., July 1, 1997 * Acacia National Life Insurance Company, December 19, 2003 * Accounting Comment Letter, November 2, 1995 * ACM Institutional Reserves, Inc., July 14, 1995 * The Adams Company, November 26, 1982 * Adams Diversified Equity Fund Inc., April 30, 2015 * Adams Express Company, January 26, 2011 * Adams Express Company, September 7, 1984 * Adams Express Company, September 20, 1979 * Adams Express Company, September 9, 1974 * Peter Adamson III, April 3, 2012 * Advantus Series Fund, October 20, 2008 * AFL-CIO Housing Investment Trust, Aug. 5, 2016 * AICPA SEC Regulations Committee, March 8, 2005 * Aid Association for Lutherans/Lutheran Brotherhood, December 21, 2001 * 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 * Alameda Contra Costa Medical Association Collective Investment Trust for Retirement Plans, August 26, 1993 * Allianz of America, Inc., May 25, 2012 * Alliance Capital Management L.P., April 7, 1993 * Alliance Funds, April 25, 1997 * Alliance Municipal Trust, July 14, 1995 * Alliance Trust Company of Nevada, March 5, 2021 * Alliance World Dollar Government Fund, Inc., October 19, 2006 * Allianz Dresdner Daily Asset Fund, May 5, 2008 * Allianz Funds, August 3, 2009 * Allianz Life Insurance Company of North America, September 28, 2018 * Allstate Life Insurance Company, December 23, 2002 * Alternative Investment Partners Absolute Return Fund STS, July 10, 2006 * American Bar Association, Business Law Section, January 18, 2012 * American Bar Association, April 22, 1999 * American Bible Society, June 1, 2004 * American Capital, Ltd, June 30, 2009 * American Capital, Ltd., February 5, 2009 * American Century Companies, Inc. / J.P. Morgan & Co., December 23, 1997 * American Century Investment Management, Inc., December 20, 2016 * American Century Investment Management, Inc., February 2, 2012 * American Council of Life Insurance, June 20, 1995 * American Enterprise Life Insurance Company, April 30, 2002 * American Express Financial Corporation, November 17, 1998 * American Funds Distributors, October 16, 1989 * American General Life Insurance Company, The Variable Annuity Life Insurance Company and The United States Life Insurance Company in the City of New York, May 28, 2024 * American Home Assurance Company, et. al., October 17, 2005 * American Home Finance Corp., April 9, 1981 * American Institute of Certified Public Accountants, December 23, 2010 * American International Group, Inc., February 21, 2006 * American International Group, Inc., December 8, 2004 * American International Group, Inc., July 18, 1997 * American Mutual Life Insurance, June 13, 1996 * American Odyssey Funds, Inc., October 7, 1996 * American Retirement Association, February 18, 2015 * American Skandia Life Assurance Corporation, May 16, 2005 * Ameriprise Financial Services Inc., April 5, 2006 * Ameritas Life Insurance Corp., April 5, 2007 * Amerivest Investment Management, LLC, August 19, 2014 * AmSouth Mutual Funds, July 8, 1997 * Andrews & Kurth L.L.P., April 5, 1994 * Arizona Electric Power Cooperative Inc., July 27, 2001 * Ark Therapeutics Group plc, April 15, 2005 * Arthur Andersen & Co., July 8, 1994 * ASA Limited, July 23, 2010 * ASA (Bermuda) Limited, December 13, 2006 * Asia Pacific Fund-Omission of Shareholder Proposal Submitted by Matisse Capital Management, L.P., July 20, 2018 * 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 * Association for Investment Management and Research, December 18, 1996 * ASX Settlement & Transfer Corporation, August 13, 1996 * ASX Settlement and Transfer Corporation, April 19, 1994 * Athene Annuity and Life Company, September 28, 2018 * Auction Rate Securities, January 6, 2009 * Auction Rate Securities - Global Exemptive Relief, September 22, 2008 * Austraclear Limited, April 28, 2004 * Austraclear Limited, April 6, 1993 * Australian Securities Commission, October 23, 1996 * Automated Trading Desk Specialists, LLC, March 13, 2009 * AXA Equitable Life Insurance Company, February 27, 2009 * The Ayco Company L.P., December 14, 1995 * BAC Home Loans Servicing, LP (formerly Countrywide Home Loans Servicing LP), June 2, 2011 * Ballard Spahr Andrews & Ingersoll, LLP, April 3, 2002 * Bancafe/Juan Vico, May 22, 1996 * Banc of America Securities LLC, June 10, 2009 * Bank of America Corporation and Affiliates ("BAC"), April 29, 2011 * Bank of America, N.A., November 25, 2014 * Bank of Ireland Asset Management (U.S.) Ltd., April 2, 2009 * Barclays Capital Inc., September 19, 2008 * Barclays Global Fund Advisors et al., March 12, 2009 * Wm. S. Barnickel & Company, November 1, 1994 * Baton Rouge Building and Construction Industry Foundation, August 31, 1984 * Bear, Stearns & Co. Inc., October 31, 2003 * Bear, Stearns & Co. Inc., September 16, 1997 * Bear, Stearns & Co. Inc., January 28, 1992 * Benham California Tax-Free and Municipal Funds, June 30, 1995 * Benson White & Company, June 14, 1995 * Berthel Growth & Income Trust I, May 5, 2009 * Gilbert G. Beezley, July 17, 1995 * BISYS Fund Services, Inc., September 2, 1999 * BlackRock Advisers LLC and Affiliates, November 4, 2008 * BlackRock Health Sciences Trust, February 25, 2016 * BlackRock Limited Duration Trust, et al. , October 19, 2015 * BlackRock Multi-Sector Income Trust, July 9, 2013 * BlackRock Science and Technology Trust and BlackRock Utilities, Infrastructure & Power Opportunities Trust, March 3, 2020 * Blanchard Global Growth Fund, May 7, 1996 * BNY ConvergEx Group, September 21, 2010 * The BNY Mellon Family of Funds, et al., July 9, 2019 * BNY Mellon Municipal Income, Inc. – Omission of Shareholder Proposal Submitted by Saba Capital Management, L.P., on behalf of Saba Capital Master Fund, Ltd., Pursuant to Rule 14a-8, March 8, 2024 * BNY Mellon Funds Trust, December 2, 2008 * Bonneville Power Administration, February 10, 2004 * Boulder Total Return Fund, Inc., November 15, 2010 * Boulder Growth and Income Fund, Inc., March 5, 2010 * Boulder Total Return Fund, Inc., March 5, 2010 * Bradley A. Veld, August 15, 1997 * Bramwell Growth Fund, August 7, 1996 * Brighthouse Life Insurance Company of NY, September 21, 2023 * The Brink’s Company, February 11, 2014 * Brinson Funds, et al., November 25, 1997 * Brown & Wood, February 24, 2000 * Brown & Wood, February 24, 1994 * BSC Employee Fund, L.P., October 14, 1997 * Bucharest Stock Exchange, June 3, 1997 * Mark A. Bush, August 8, 1995 * David S. Butterworth, January 27, 1994 * Cabot Wellington, LLC, June 17, 2008 * Calamos Convertible Opportunities and Income Fund, Calamos Convertible and High Income Fund, and Calamos Global Total Return Fund, February 14, 2011 * California Municipal Cash Trust, July 11, 1995 * Calvert Group, January 7, 1993 * Calvert Social Index Fund, September 24, 2001 * The Canadian Depository for Securities Limited, August 4, 1994 * Cantor Fitzgerald & Company, February 17, 2004 * Capital Group, January 11, 2017 * Capital Trust, Inc., February 3, 2009 * Capital Trust, Inc., May 24, 2007 * The Capitol Mutual Funds and Nations Fund Trust, February 24, 1994 * Carey Credit Income Fund et al., July 15, 2015 * Carlyle Global Credit Investment Management, L.L.C., October 19, 2023 * Caxton Corporation, December 28, 1994 * CBA Money Fund, et al., June 9, 1994 * Celina Financial Corporation, February 19, 1993 * CenturyLink Investment Management Company, December 8, 2016 * Century Shares Trust, May 4, 1994 * Charles Schwab & Co., Inc., August 7, 2018 * Charles Schwab & Co., Inc., July 7, 1997 * Charles Schwab & Co., May 28, 1992 * The Chase Manhattan Bank, July 24, 2001 * Chase Manhattan Bank, June 12, 1998 * Chicago Mercantile Exchange, December 19, 2017 * Chicago Mercantile Exchange, December 29, 2015 * Chicago Mercantile Exchange, December 19, 2014 * Chicago Mercantile Exchange, December 26, 2013 * Chicago Mercantile Exchange, July 10, 2013 * Chicago Mercantile Exchange, September 27, 2012 * Chicago Mercantile Exchange, September 27, 2012 * Chicago Mercantile Exchange, July 29, 2011 * Chicago Mercantile Exchange, July 29, 2011 * Chicago Mercantile Exchange, March 24, 2011 * Chief Financial Officer, November>Chief Financial Officer, November 1, 1994 * Chief Financial Officer of Investment Company Registrants, February 3, 1995 * CIBC Mellon Trust Company, February 24, 2005 * Citicorp Securities, April 6, 1995 * Citigroup Global Markets Inc., August 6, 2014 * Citigroup Global Markets, Inc., May 28, 2009 * Citigroup Global Markets, Inc., December 23, 2008 * Citigroup Global Markets, Inc., September 26, 2006 * Citigroup Global Markets Inc. f/k/a Salomon Smith Barney Inc., October 31, 2003 * Citigroup Inc., October 22, 2010 * Citigroup Inc., July 26, 2006 * Citytrust, Inc., December 19, 1990 * Claymore Advisors, LLC, April 27, 2010 * ClearBridge Energy Midstream Opportunity Fund Inc. -- Omission of Shareholder Proposal Submitted by Spencer McGowan Pursuant to Rule 14a-8, February 10, 2021 * ClearBridge MLP and Midstream Fund Inc.-- Omission of Shareholder Proposal Submitted by Spencer McGowan Pursuant to Rule 14a-8 , February 10, 2021 * Clover Capital Management, Inc., October 28, 1986 * CME Group, Inc., December 3, 2010 * CME Group, Inc., July 16, 2010 * George Colman, July 18, 1995 * College and University Facility Loan Trust One, et al., November 29, 2004 * College Retirement Equities Fund, May 19, 2008 * College Retirement Equities Fund (CREF), April 13, 2009 * College Retirement Equities Fund ("Fund") Shareholder Proposal of Aaron Levitt, May 6, 2011 * 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 * College Retirement Equities Fund Real Estate Account, July 22, 1993 * Colonial Trust I et al., October 20, 1995 * Columbia Funds, December 12, 2011 * Columbia Funds, et al., December 23, 2008 * Columbia Funds Series Trust - Columbia Cash Reserves, March 2, 2009 * Columbia Funds Series Trust - Columbia Money Market Reserves, March 2, 2009 * Columbia Funds Series Trust, October 22, 2008 * Comdisco, Inc., October 25, 2000 * Committee of Annuity Insurers, April 11, 2024 * Community Capital Management, Inc., et al., April 15, 2019 * Continental of Illinois (Delaware), Ltd., March 14, 1973 * Constellation Financial Management LLC, January 9, 2003 * Cooley Godward & Kronish, July 12, 2007 * Copley Fund, Inc., August 2, 2013 * Copley Fund, Inc., June 18, 2013 * Copley Fund, Inc., April 5, 2013 * Cornish & Carey Commercial Inc., February 26, 1996 * County of Los Angeles, January 27, 1993 * Credit Agricole Asset Management Alternative Investments, Inc., August 7, 2006 * Credit Suisse, May 20, 2014 * Credit Suisse First Boston, LLC, August 31, 2005 * Credit Suisse First Boston LLC f/k/a Credit Suisse First Boston Corporation, October 31, 2003 * Credit Suisse First Boston, September 9, 1998 * Credit Suisse High Yield Bond Fund and Credit Suisse Asset Management Income Fund, Inc., June 26, 2013 * Staff Letter to ICI and SIFMA AMG: Engaging on Fund Innovation and Cryptocurrency-related Holdings, January 18, 2018 * CUNA Mutual Life Insurance Company, et al., December 27, 2007 * Current Income Shares, Inc., July 10, 2001 * Cushing MLP & Infrastructure Total Return Fund and Cushing Renaissance Fund, August 6, 2019 * Custody of B Shares Trading on the Shenzhen and Shanghai Securities Exchanges, April 26, 1993 * DALBAR, Inc., March 24, 1998 * Dana Investment Advisors, Inc., October 12, 1994 * Datastream International Inc., March 15, 1993 * Davis, Polk & Wardwell, April 24, 1997 * Daughters of Charity National Health System, Inc., April 3, 1998 * Dean Witter, Discover & Co.; Morgan Stanley Group Inc., April 18, 1997 * Dean Witter, Discover & Co., February 8, 1993 * Dean Witter World Wide Investment Trust, September 17, 1996 * Dechert, January 25, 2017 * Dechert LLP, March 8, 2017 * Dechert LLP, August 24, 2009 * Defined Asset Funds, December 23, 1998 * Defined Asset Funds - Equity Income Fund - Select Ten Series, May 5, 1993 * Delaware Enhanced Global Dividend and Income Fund-Omission of Shareholder Proposal Submitted by Saba Capital Management L.P., May 11, 2018 * Delaware Life Insurance Company and Gainbridge Life Insurance Company, April 28, 2023 * Deloitte & Touche LLP, August 28, 2006 * Delta Government Options Corp., Sept. 27, 1990 * Delta Government Options Corp., July 21, 1989 * Department of Labor, October 26, 2011 * Department of Labor, December 5, 1995 * Depository Clearing Company, December 19, 1997 * Depository Trust Company of Delaware, LLC dba Delaware Depository, September 12, 2016 * Derivatives Use by Actively-Managed ETFs, December 6, 2012 * Dessauer Global Equity Fund, April 3, 1997 * Deutsche Bank Microcredit Development Fund, Inc., April 8, 2011 * Deutsche Bank Securities Inc., June 9, 2009 * Deutsche Bank Securities Inc., September 24, 2004 * Deutsche Multi-Market Income Trust (Omission of Shareholder Proposal), June 24, 2016 * Deutsche Strategic Income Trust (Omission of Shareholder Proposal), June 24, 2016 * Dexia Municipal Agency, December 26, 2007 * DFA Investment Trust, March 21, 1996 * DFA Investment Trust Company, October 17, 1995 * Differential Advisory Fee Waivers, February 2, 2023 * Dividend and Income Fund - 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Swanton Associates, September 12, 1973 * North American Division of Seventh-Day Adventists, October 6, 2015 * North American Security Trust, August 5, 1994 * North American Security Trust and NASL Series Trust, February 2, 1993 * Northern Institutional Fund, July 16, 2008 * Northern Institutional Funds, February 28, 2008 * Northern Institutional Funds - Diversified Assets Portfolio, Liquid Assets Portfolio and Prime Obligations Portfolio and Northern Funds - Money Market Fund, March 2, 2009 * Northern Lights Fund Trust, June 29 , 2015 * Northwestern Mutual Series Fund, Inc., October 22, 2008 * Northwestern Ohio Building and Construction Trades Foundation, April 20, 1984 * Norwest Bank Minnesota, N.A. and Society National Bank, May 25, 1995 * Norwest Funds - Municipal Money Market Fund, August 8, 1995 * Nuveen Funds (Nuveen AMT-Free Quality Municipal Income Fund and Nuveen New York AMT-Free Quality Municipal Income Fund) – Omission of Shareholder Proposal Submitted by Karpus Investment Management, May 14, 2024 * Nottingham Realty Securities, April 19, 1984 * Nuveen, et al., June 26, 2013 * Nuveen Asset Management, Inc., et al., December 30, 2010 * Nuveen California Select Tax-Free Income Portfolio, November 21, 2017 * Nuveen Credit Strategies Income Fund, et al., November 7, 2014 * Nuveen Flagship Multistate Trust I, July 10, 1998 * Nuveen Fund Advisors, LLC, June 20, 2017 * Nuveen Funds (Nuveen Real Asset Income and Growth Fund; Nuveen Multi-Asset Income Fund, Nuveen Core Plus Impact Fund) – Omission of Shareholder Proposal Submitted by Saba Capital Management, L.P., on behalf of Saba Capital Master Fund, Ltd., February 16, 2024 * Nuveen Investment Funds, February 13, 2014 * Nuveen Municipal High Income Opportunity Fund, Nuveen Municipal High Income Opportunity Fund 2, Nuveen Floating Rate Income Opportunity Fund, Nuveen Senior Income Fund, Nuveen Floating Rate Income Fund, and Nuveen Municipal Value Fund, Inc., November 9, 2010 * Nuveen Municipal Income Fund, Inc. et al., July 27, 2017 * Nuveen S&P 500 Dynamic Overwrite Fund, et al., April 26, 2019 * Nuveen Virginia Premium Income Municipal Fund, October 6, 2006 * Old Dominion Electric Cooperative, et al., October 13, 2004 * Old Mutual Advisors Funds, November 16, 2007 * Omgeo LLC, August 14, 2009 * Omission of Shareholder Proposal (Fidelity Freedom 2020 Fund, Fidelity Freedom 2025 Fund, and Fidelity Advisor Municipal Income Fund), August 12, 2015 * Omission of Shareholder Proposal Pursuant to Rule 14a-8 for H&Q Life Sciences Investors, March 24, 2011 * Omission of Shareholder Proposal Submitted by Steven N. Harris (Liberty All-Star Equity Fund), May 6, 2015 * The One Group, May 23, 1995 * One Point Communications Corp, June 12, 1998 * Oppenheimer Landmrk Properties, March 9, 1993 * Opportunity Partners L.P. Shareholder Proposal (Clough Global Equity Fund), April 16, 2015 * Owens-Illinois, Inc., June 24, 1994 * Pacholder High Yield Fund, Inc., January 18, 2013 * Pacific Life Insurance Company and Pacific Life & Annuity Company, March 1, 2024 * Pacific Select Fund, et al., December 23, 2004 * PaineWebber Equity Trusts, July 19, 1993 * PaineWebber Incorporated, January 27, 1995 * PaineWebber Managed Investments Trust, August 4, 1994 * PanAgora Group Trust, April 29, 1994 * David Parkinson, October 19, 1995 * Pasadena Investment Trust, January 22, 1993 * Pengrowth Energy Trust, January 27, 2000 * Peninsular & Oriental Steam Navigation Company, October 15, 2003 * Penn Series Funds Inc., October 22, 2008 * Penn Series Funds Inc., October 22, 2008 * PerfectData Corporation, August 5, 1996 * Pershing Division of Donaldson, Lufkin & Jenrette Securities Corp., September 15, 1994 * Philadelphia Stock Exchange, Inc., October 18, 1994 * Philadelphia Ventures Liberty Fund, L.P., February 14, 1995 * Phoenix Opportunities Trust, October 22, 2008 * Pilgrim America, Inc., October 8, 1996 * PIMCO Corporate & Income Opportunity Fund and PIMCO Income Opportunity Fund, September 13, 2018 * PIMCO Dynamic Income Fund, December 12, 2017 * PIMCO Funds: Multi-Manager Series, August 6, 2002 * PIMCO Funds, July 9, 2002 * PIMCO Income Strategy Fund and PIMCO Income Strategy Fund II, January 30, 2019 * Pioneer Funds, December 20, 2005 * Pioneer Interest Shares, June 20, 2001 * Plymouth Commercial Mortgage Fund, July 13, 1998 * Plymouth Commercial Mortgage Fund, December 3, 1996 * PNC Bank N.A., June 10, 1997 * PNC Fund, et al., April 2, 1993 * Pretzel & Stouffer, December 1, 1995 * Principal Funds, Inc. and Principal Variable Contracts Funds, Inc., October 22, 2008 * Principal Investors Fund Inc., May 13, 2005 * Principle Preservation Portfolios, Inc., December 6, 1995 * Prospect Capital Corporation - Omission of Shareholder Proposal Submitted by Michelle Bronsted, August 10, 2020 * Prospect Capital Corporation - Omission of Shareholder Proposal Submitted by Camilla Cane, August 10, 2020 * Prospect Capital Corporation - Omission of Shareholder Proposal Submitted by Camilla Cane, August 10, 2020 * Reconsideration Request, August 24, 2020 * Supplemental Submission, August 27, 2020 * Outgoing Letter, September 16. 2020 * Prospect Capital Corporation - Omission of Shareholder Proposal Submitted by Mark Cane, August 10, 2020 * Prudential Financial, Inc., September 5, 2008 * Prudential Insurance Company of America, March 1, 2005 * Prudential Investment Management Services LLC, April 19, 2001 * Prudential Securities Incorporated, February 7, 2001 * Public Employees' Retirement Board of the State of Oregon, March 3, 1998 * Puerto Rico Balanced Fund, Inc., April 29, 1997 * Puerto Rico Residents Tax-Free Fund, Inc. – Omission of Shareholder Proposal Submitted by Ocean Capital LLC Pursuant to Rule 14a-8, November 30, 2023 * Putnam High Income Securities Fund, March 14, 2006 * Putnam Premier Income Trust, March 14, 2006 * Putnam Tax-Free Health Care Fund, August 8, 2005 * Queensland Treasury Corporation, September 26, 1995 * K. K. Rajendran, November 21, 1997 * Ramius Capital Management, LLC, April 5, 1996 * RBC Capital Markets Corporation, June 10, 2009 * RBS Securities, Inc., November 26, 2013 * RealEnergy, Inc., et al., August 12, 2003 * Realex Capital Corporation, April 19, 1984 * Real Goods Trading Corporation, June 24, 1996 * Red Rocks Capital, LLC, June 3, 2011 * Redwood Investment Fund, LLC, October 14, 1997 * Redwood Trust, Inc., August 15, 2019 * Redwood Trust, Inc. , October 16, 2017 * ReFlow Fund, LLC, July 15, 2002 * Registered Investment Company Use of Senior Securities - Select Bibliography, February 12, 2013 (Last Modified) * Regions Morgan Keegan Funds, March 30, 2009 * Reserve Bank of Australia, January 30, 1998 * Reserve Bank of New Zealand, May 24, 1993 * Reserve New York Municipal Money-Market Trust - New York Municipal Money-Market Fund, November 18, 2008 * RDM Infodustries, Inc., March 25, 1996 * Request for Consideration of the Steve Tamari Shareholder Proposal (College Retirement Equities Fund), May 23, 2013 * Richard Ellis, Inc., March 19, 1981 * RidgeWorth Funds, October 22, 2008 * The Riverfront Funds, Inc., November 8, 1995 * RiverNorth, July 28, 2014 * RMR Real Estate Income Fund - Omission of Shareholder Proposal Submitted by Matisse Discounted Closed-End Fund Strategy, April 1, 2020 * RMR Real Estate Income Fund - Omission of Shareholder Proposal Submitted by Matisse Discounted Closed-End Fund Strategy, February 20, 2019 * Robert Van Grover Esq., Seward & Kissel LLP, December 11, 2019 * Robert Van Grover, Esq., Seward & Kissel LLP, October 4, 2016 * Robert Van Grover, Esq., Seward & Kissel LLP, November 5, 2013 * Robertson, Stephens & Company, January 12, 1993 * R.O.C. Taiwan Fund, February 11, 2000 * Rowe Price-Fleming International Inc., April 12, 1996 * Royal Bank of Canada, December 19, 2014 * Royal Bank of Canada, et al., June 3, 1998 * Royal Dutch Shell plc, August 7, 2015 * Royal Dutch Shell plc, May 17, 2005 * Royalty Pharma, August 13, 2010 * The Royce Fund, January 24, 1995 * RS Global Natural Resources Fund, March 6, 2014 * Russell Investment Company, October 24, 2008 * Russell Investment Company, October 20, 2008 * Russell Investment Management, LLC, December 16, 2016 * Russia Growth Fund, Inc., May 20, 1997 * Louis Russo, June 16, 1994 * Safra Republic Holdings, April 21, 1998 * Salomon Brothers Asset Management Inc and Salomon Brothers Asset Management Asia Pacific Limited, July 23, 1999 * Salomon Brothers Inc., April 25, 1995 * Salomon Brothers, Inc., June 17, 1985 * Salomon Brothers, April 4, 1975 * Salomon Brothers, May 23, 1972 * SCP Private Equity Partners II, L.P., June 6, 2006 * Scudder Investment Trust, March 23, 1994 * Securities Industry and Financial Markets Association, November 4, 2019 * Securities Industry and Financial Markets Association, October 26, 2017 * Securities Lending by U.S. Open-End and Closed-End Investment Companies, November 6, 2012 * Sedgwick Consulting Group, May 17, 1993 * SEI Daily Income Trust ? Prime Obligation Fund, April 20, 2009 * SEI Daily Income Trust - Prime Obligation Fund, November 18, 2008 * SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008 * SEI Daily Income Trust - Money Market Fund, November 9, 2007 * SEI Daily Income Trust - Prime Obligation Fund, November 8, 2007 * SEI Liquid Asset Trust ? Prime Obligation Fund, April 20, 2009 * SEI Liquid Asset Trust - Prime Obligation Fund, March 2, 2009 * SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007 * Select Sector SPDR Fund and Diamonds Trust, July 6, 2000 * Select Sector SPDR Trust, May 6, 1999 * Seligman New Technologies Fund II, Inc., February 7, 2002 * Service Corporation International, October 6, 1998 * Seward & Kissel LLP, July 21, 2011 * Seward & Kissell, October 12, 2010 * Seward & Kissel LLP, April 15, 2009 * Seward & Kissel, October 12, 2005 * Sandra M. Fox Shareholder Proposal (College Retirement Equities Fund), May 10, 2013 * Shearson Lehman Brothers Inc. and Smith Barney, Harris Upham & Co. Incorporated, June 8, 1993 * Shee Atika Investments, LLC, January 20, 2004 * Shoreline Fund, L.P., November 14, 1994 * Shoreline Fund, L.P., April 11, 1994 * SIFE Trust Fund, January 18, 1982 * Signature Financial Group, Inc., December 28, 1999 * Sisters of Mercy of the Americas, Inc., October 1, 2009 * SMC Capital, Inc., September 5, 1995 * Russell H. Smith, May 2, 1996 * Societatea Nationala de Compensare, January 28, 1998 * The South America Fund N.V., September 2, 1993 * SSGA International Liquidity Fund, December 2, 1998 * Staff Responses to Questions About Regulation S-P, January 23, 2003 * Staff Statement on Control Share Acquisition Statutes, May 27, 2020 * Staff Statement on Fund Board Meetings and Unforeseen or Emergency Circumstances Related to Coronavirus Disease 2019 (COVID-19), March 4, 2020 * Standard Shares, Inc., July 29, 1974 * State Street Bank & Trust, August 1, 1996 * State Street Bank & Trust Company, February 28, 1995 * State Street Bank and Trust Company, May 22, 1972 * State Street Bank and Trust Company, December 27, 1971 * The State Street Mortgage Co., November 18, 1986 * Sacha Stawski, August 9, 1996 * South State Bank, May 8, 2018 * SPDR Series Trust, et al., (June 24 , 2015) * SPDR S&P Dividend ETF, March 28, 2016 * Staff Statement on Funds Registered Under the Investment Company Act Investing in the Bitcoin Futures Market, May 11, 2021 * The Standish Ayer & Wood Inc. Stable Value Group Trust, December 28, 1995 * Stephanie Hibler, January 24, 2014 * Stephens Inc., December 27, 2001 * Steve Tamari Shareholder Proposal (College Retirement Equities Fund), May 10, 2013 * Stifel, Nicolaus & Company, Inc., December 6, 2016 * STI Classic Funds, January 2, 2008 * STI Classic Funds, October 26, 2007 * Stock Exchange of Thailand, August 26, 1993 * Stock Holding Corporation of Indian Ltd., January 21, 1998 * R. Bryan Stoker, May 13, 1994 * Stradley Ronon Stevens & Young, LLP, June 24, 2019 * Straight-A Funding, LLC, July 28, 2009 * Sullivan and Cromwell, December 29, 1997 * Summit Advisors, Inc., March 1, 1994 * Sun Capital Advisers Trust, October 20, 2008 * 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, April 6, 2017 * The Swiss Helvetia Fund, Inc., May 5, 2010 * Swiss Helvetia Fund, Inc., March 6, 2001 * Symetra Life Insurance Company and First Symetra National Life Insurance Company of New York, August 8, 2019 * TACT Asset Management Inc., October 24, 2012 * Tamarack Funds Trust, October 22, 2008 * Michael Tannenbaum, January 5, 1993 * The TCW Group, Inc., November 7, 2008 * TDAM Money Market Portfolio, December 21, 2007 * Tekla Life Sciences Investors - Omission of Shareholder Proposal Submitted by Kenneth Steiner, February 27, 2019 * Tekla Life Sciences Investors — Omission of Shareholder Proposal Submitted by Kenneth Steiner, March 8, 2018 * Templeton Emerging Markets Income Fund - Omission of Shareholder Proposal Submitted by The McGowan Group Asset Management Retirement Plan, FBO Spencer McGowan, February 5, 2021 * Templeton Russia Fund, Inc., April 18, 1995 * Templeton Vietnam and Southeast Asia Fund, September 28, 2001 * Templeton Vietnam Opportunities Fund, Inc., September 6, 1996 * Thomas Weisel Partners LLC, September 24, 2004 * Thomson Advisory Group L.P., September 26, 1995 * Thomson Financial Inc., July 10, 2002 * Thomson Fund Group, et al., January 28, 1993 * Thrivent Financial for Lutherans and Thrivent Asset Management, LLC, September 27, 2016 * TIAA Real Estate Account, May 1, 1996 * Tom DeWard Shareholder Proposal (LMP Real Estate Income Fund, Inc.), March 25, 2015 * Tortoise Energy Infrastructure Corporation and Tortoise Energy Capital Corporation, April 23, 2010 * Total, January 26, 1996 * Touchstone Variable Series Trust, October 22, 2008 * The Townsend Group, Inc., July 9, 2008 * Townsend and Associates, Inc., September 21, 1994 * Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004 * Transamerica Life Insurance Company and Transamerica Financial Life Insurance Company, February 11, 2021 * Transamerica Series, Inc., November 7, 1994 * Transamerica Series, Inc., November 7, 1994 * Travelers Insurance Company et al., September 3, 1993 * Tri-Continental Corporation, March 25, 2003 * Tri-State Generation and Transmission Association, Inc., et. al., September 23, 2003 * T. Rowe Price Associates, Inc., October 8, 2009 * T. Rowe Price Associates, Inc., July 10, 2008 * The T. Rowe Price Funds, July 31, 1995 * T. Rowe Price Tax-Free Funds, June 24, 1993 * Trusts under the Will of Marion Searle, March 29, 2005 * TS&W/Claymore Tax-Advantaged Balanced Fund, April 27, 2009 * Tudor Employee Investment Fund LLC and Tudor Investment Corporation, April 28, 2015 * Tuition Plan Consortium, LLP, February 4, 2003 * Twentieth Century Mutual Funds, July 7, 1995 * Twentieth Century Investors, Inc., October 27, 1982 * UAM Inc., September 24, 2001 * UBS AG, May 20, 2015 * UBS AG, July 29, 2009 * UBS AG, March 20, 2009 * UBS Financial Services Inc., May 9, 2011 * UBS Financial Services, Inc., September 29, 2005 * UBS Securities LLC (f/k/a UBS Warburg LLC), October 31, 2003 * UBS Securities LLC/UBS Financial Services Inc., December 23, 2008 * USB Global Asset Management (US), Inc., November 21, 2002 * Uniao de Bancos de Brasileiros S.A., July 28, 1992 * Union Security Insurance Company, January 11, 2022 * United Bankers , March 23, 1988 * United Missouri Bank of Kansas City, January 23, 1995 * United Municipal Bond Fund, January 27, 1995 * United Services Funds, April 23, 1993 * United States & Foreign Securities Corporation, October 27, 1982 * United States Property Investment N.V., May 1, 1989 * Unit Investment Trust Organizational Expenses, May 9, 1995 * University of Alaska Advance College Tuition Payment, March 2, 1992 * Urban Land Investments, November 4, 1971 * USAA Mutual Funds Trust, October 22, 2008 * U.S. Bancorp Piper Jaffray Inc., October 31, 2003 * U.S. Bancorp Asset Management Inc., et al., December 11, 2001 * U.S. Department of Labor, February 22, 1996 * U.S. Government Reserves and Fidelity Cash Reserves, April 27, 2009 * Valuation of Portfolio Securities and other Assets Held by Registered Investment Companies - Select Bibliography of the Division of Investment Management, March 20, 2009 * Value Line, Inc., April 18, 1990 * Vanguard Funds (Vanguard U.S. Value Fund, Vanguard Health Care Fund, Vanguard Energy Fund) - Omission of Shareholder Proposal Submitted by Kani Ilangovan and Mary Lou Rosczyk September 11, 2020 * Vanguard Group, Inc., May 22, 2009 * Van Kampen Funds Inc., January 31, 2007 * Venture Search Technology Inc., July 11, 1995 * The Victory Funds and The Victory Portfolios, April 24, 1995 * Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Fund, August 3, 2009 * Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 2008 * Victory Stock Index Fund, February 7, 1995 * Voya Prime Rate Trust, April 8, 2019 * Wachovia Securities LLC, February 18, 2009 * Wall Street Preferred Money Managers, Inc., April 10, 1992 * Warsaw Stock Exchange, October 20, 1994 * Washington Capital Joint Master Trust, September 25, 2006 * Washington Mutual Investors Fund, Inc., May 14, 1993 * James R. Waters, June 1, 1995 * Wells Fargo Alternative Asset Management, LLC, January 26, 2005 * Wells Fargo Bank, N.A., July 15, 2013 * Wells Fargo Bank, N.A., September 21, 2012 * Wells Fargo Bank, N.A., December 12, 2011 * Wells Fargo Bank, N.A., March 31, 1998 * Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008 * Wells Fargo Money Market Funds, July 7, 1995 * Wells Fargo Securities, LLC, et al., March 21, 2019 * Welsh, Carson, Anderson & Stowe, June 18, 1993 * Westford Technology Ventures, L.P., January 28, 2004 * Western Asset Money Market Fund, June 27, 2008 * Western Asset Institutional Money Market Fund, June 27, 2008 * Western Farmers Electric Cooperative, February 23, 2001 * Willkie Farr & Gallagher, September 21, 2015 * Willkie Farr & Gallagher, October 23, 2000 * Wilkie Farr & Gallagher, June 11, 1996 * Wilmer, Cutler & Pickering and Davis Polk & Wardell, October 5, 1998 * WilmerHale, LLP, July 28, 2010 * Wilton Reassurance Life Company of New York, September 30, 2021 * Windamere Capital Ventures, L.P., Windamere Capital Ventures Company, LLC, July 23, 2001 * World Financial Network National Bank, May 28, 1996 * XAI Octagon Floating Rate & Alternative Income Term Trust, August 6, 2019 * Xplornet Communications Inc., January 11, 2012 * Zenkyoren Asset Management of America Inc., June 30, 2011 * Gerald Zuckerman, February 1, 1994 * Zurich Insurance Company; Scudder Kemper Investments, Inc., August 31, 1998 * Alfred A. Zurl, August 7, 1995 CHRONOLOGICAL LIST OF NO-ACTION LETTERS * American General Life Insurance Company, The Variable Annuity Life Insurance Company and The United States Life Insurance Company in the City of New York, May 28, 2024 * Nuveen Funds (Nuveen AMT-Free Quality Municipal Income Fund and Nuveen New York AMT-Free Quality Municipal Income Fund) – Omission of Shareholder Proposal Submitted by Karpus Investment Management, May 14, 2024 * Committee of Annuity Insurers, April 11, 2024 * Highland Opportunities and Income Fund – Omission of Shareholder Proposal Submitted by Allan Hausman, April 5, 2024 * BNY Mellon Municipal Income, Inc. – Omission of Shareholder Proposal Submitted by Saba Capital Management, L.P., on behalf of Saba Capital Master Fund, Ltd., Pursuant to Rule 14a-8, March 8, 2024 * Pacific Life Insurance Company and Pacific Life & Annuity Company, March 1, 2024 * Nuveen Funds (Nuveen Real Asset Income and Growth Fund; Nuveen Multi-Asset Income Fund, Nuveen Core Plus Impact Fund) – Omission of Shareholder Proposal Submitted by Saba Capital Management, L.P., on behalf of Saba Capital Master Fund, Ltd., February 16, 2024 * Puerto Rico Residents Tax-Free Fund, Inc. – Omission of Shareholder Proposal Submitted by Ocean Capital LLC Pursuant to Rule 14a-8, November 30, 2023 * Carlyle Global Credit Investment Management, L.L.C., October 19, 2023 * Eagle Life Insurance Company, September 29, 2023 * Jackson National Life Insurance Company and Jackson National Life Insurance Company of New York, September 26, 2023 * Brighthouse Life Insurance Company of NY, September 21, 2023 * Delaware Life Insurance Company and Gainbridge Life Insurance Company, April 28, 2023 * Fidelity & Guaranty Life Insurance Company and Fidelity & Guaranty Life Insurance Company of New York, March 17, 2023 * Differential Advisory Fee Waivers, February 2, 2023 * Everlake Life Insurance Company, October 21, 2022 * Japan Smaller Capitalization Fund , October 4, 2022 * Japan Smaller Capitalization Fund, August 26, 2022 * Union Security Insurance Company, January 11, 2022 * Wilton Reassurance Life Company of New York, September 30, 2021 * Midland National Life Insurance Company, August 12, 2021 * Staff Statement on Funds Registered Under the Investment Company Act Investing in the Bitcoin Futures Market, May 11, 2021 * Alliance Trust Company of Nevada, March 5, 2021 * ClearBridge Energy Midstream Opportunity Fund Inc. -- Omission of Shareholder Proposal Submitted by Spencer McGowan Pursuant to Rule 14a-8, February 10, 2021 * ClearBridge MLP and Midstream Fund Inc.-- Omission of Shareholder Proposal Submitted by Spencer McGowan Pursuant to Rule 14a-8 , February 10, 2021 * Templeton Emerging Markets Income Fund - Omission of Shareholder Proposal Submitted by The McGowan Group Asset Management Retirement Plan, FBO Spencer McGowan, February 5, 2021 * Transamerica Life Insurance Company and Transamerica Financial Life Insurance Company, February 11, 2021 * K&L Gates LLP, January 13, 2021 * MEMBERS Life Insurance Co., November 6, 2020 * Vanguard Funds (Vanguard U.S. Value Fund, Vanguard Health Care Fund, Vanguard Energy Fund) - Omission of Shareholder Proposal Submitted by Kani Ilangovan and Mary Lou Rosczyk September 11, 2020 * Prospect Capital Corporation - Omission of Shareholder Proposal Submitted by Michelle Bronsted, August 10, 2020 * Prospect Capital Corporation - Omission of Shareholder Proposal Submitted by Camilla Cane, August 10, 2020 * Reconsideration Request, August 24, 2020 * Supplemental Submission, August 27, 2020 * Outgoing Letter, September 16. 2020 * Prospect Capital Corporation - Omission of Shareholder Proposal Submitted by Mark Cane, August 10, 2020 * First Trust Senior Floating Rate Income Fund II - Omission of Shareholder Proposal Submitted by Saba Capital Management, L.P., on behalf of Saba Capital Master Fund, Ltd., June 17, 2020 * Minnesota Life Insurance Co., June 11, 2020 * Staff Statement on Control Share Acquisition Statutes, May 27, 2020 * Investment Company Institute and SIFMA AMG, May 27, 2020 * Hercules Capital, Inc., May 11, 2020 * Merit Life Insurance Co., April 21, 2020 * Dividend and Income Fund - Omission of Shareholder Proposal Submitted by Matisse Discounted Closed-End Fund Strategy, April 10, 2020 * Dividend and Income Fund - Omission of Shareholder Proposal Submitted by Alison Pampinella, April 10, 2020 * RMR Real Estate Income Fund - Omission of Shareholder Proposal Submitted by Matisse Discounted Closed-End Fund Strategy, April 1, 2020 * Investment Company Institute, March 26, 2020 * Investment Company Institute, March 19, 2020 * Staff Statement on Fund Board Meetings and Unforeseen or Emergency Circumstances Related to Coronavirus Disease 2019 (COVID-19), March 4, 2020 * BlackRock Science and Technology Trust and BlackRock Utilities, Infrastructure & Power Opportunities Trust, March 3, 2020 * Fidelity Blue Chip Value Fund, January 30, 2020 * Fidelity Canada Fund, January 30, 2020 * Fidelity Growth Discovery Fund, January 30, 2020 * Fidelity Magellan Fund, January 30, 2020 * Fidelity Mid-Cap Stock Fund, January 30, 2020 * Fidelity Puritan Fund, January 30, 2020 * Fidelity Stock Selector Small Cap Fund, January 30, 2020 * Fidelity Value Fund, January 30, 2020 * Eaton Vance Tax-Advantaged Dividend Income Fund, et al., December 16, 2019 * Robert Van Grover Esq., Seward & Kissel LLP, December 11, 2019 * Gladstone Investment Corporation, December 5, 2019 * Securities Industry and Financial Markets Association, November 4, 2019 * Nationwide Life Insurance Company, October 17, 2019 * Forethought Life Insurance Company, October 17, 2019 * Redwood Trust, Inc., August 15, 2019 * Lehman Brothers Holdings Inc., August 12, 2019 * Symetra Life Insurance Company and First Symetra National Life Insurance Company of New York, August 8, 2019 * XAI Octagon Floating Rate & Alternative Income Term Trust, August 6, 2019 * Cushing MLP & Infrastructure Total Return Fund and Cushing Renaissance Fund, August 6, 2019 * The BNY Mellon Family of Funds, et al., July 9, 2019 * Golub Capital Investment Corporation, et al., June 24, 2019 * Stradley Ronon Stevens & Young, LLP, June 24, 2019 * Nuveen S&P 500 Dynamic Overwrite Fund, et al., April 26, 2019 * Community Capital Management, Inc., et al., April 15, 2019 * Voya Prime Rate Trust, April 8, 2019 * John Hancock Stable Value Fund, March 25, 2019 * Wells Fargo Securities, LLC, et al., March 21, 2019 * Lincoln Benefit Life Company, March 15, 2019 * MONY Life Insurance Company of America, March 7, 2019 * Engaging on Non-DVP Custodial Practices and Digital Assets, March 12, 2019 * Independent Directors Council, February 28, 2019 * First Trust High Income Long/Short Fund - Omission of Shareholder Proposal Submitted by Dolphin Limited Partnership I, L.P., February 27, 2019 * Tekla Life Sciences Investors - Omission of Shareholder Proposal Submitted by Kenneth Steiner, February 27, 2019 * RMR Real Estate Income Fund - Omission of Shareholder Proposal Submitted by Matisse Discounted Closed-End Fund Strategy, February 20, 2019 * PIMCO Income Strategy Fund and PIMCO Income Strategy Fund II, January 30, 2019 * Madison Capital Funding LLC, December 20, 2018 * Industrial Alliance, Investment Management Inc. , November 5, 2018 * Eaton Vance Tax-Managed Buy-Write Opportunities Fund, et al., October 29, 2018 * Independent Directors Council, October 12, 2018 * DNP Select Income Fund Inc., October 4, 2018 * Allianz Life Insurance Company of North America, September 28, 2018 * Athene Annuity and Life Company, September 28, 2018 * Great West Life & Annuity Insurance Company, September 28, 2018 * Midland National Life Insurance Company, September 28, 2018 * PIMCO Corporate & Income Opportunity Fund and PIMCO Income Opportunity Fund, September 13, 2018 * Golub Capital BDC, Inc., et al., September 7, 2018 * Charles Schwab & Co., Inc., August 7, 2018 * Asia Pacific Fund-Omission of Shareholder Proposal Submitted by Matisse Capital Management, L.P., July 20, 2018 * Investment Company Institute, June 1, 2018 * Delaware Enhanced Global Dividend and Income Fund-Omission of Shareholder Proposal Submitted by Saba Capital Management L.P., May 11, 2018 * South State Bank, May 8, 2018 * Dividend and Income Fund— Omission of Shareholder Proposal Submitted by Matisse Capital , March 27, 2018 * Tekla Life Sciences Investors — Omission of Shareholder Proposal Submitted by Kenneth Steiner, March 8, 2018 * Eagle Point Credit Company Inc., February 14, 2018 * Great Ajax Funding LLC , February 12, 2018 * First Trust Mortgage Income Fund, January 25, 2018 * Staff Letter to ICI and SIFMA AMG: Engaging on Fund Innovation and Cryptocurrency-related Holdings, January 18, 2018 * Chicago Mercantile Exchange, December 19, 2017 * ICE Clear Credit LLC, December 19, 2017 * LCH Limited and LCH.Clearnet LLC, December 19, 2017 * PIMCO Dynamic Income Fund, December 12, 2017 * Nuveen California Select Tax-Free Income Portfolio, November 21, 2017 * Mutual of America Capital Management LLC, October 26, 2017 * Investment Company Institute, October 26, 2017 * Securities Industry and Financial Markets Association, October 26, 2017 * Redwood Trust, Inc., October 16, 2017 * Innovator Capital Management, LLC, et al., October 6, 2017 * Fidelity Management & Research Company et al., September 22, 2017 * Nuveen Municipal Income Fund, Inc. et al., July 27, 2017 * Nuveen Fund Advisors, LLC, June 20, 2017 * Macquarie Capital (USA) Inc., June 1, 2017 * Ironwood Multi-Strategy Fund LLC and Ironwood Institutional Multi-Strategy Fund LLC, April 19, 2017 * Swiss Helvetia Fund, April 6, 2017 * Guggenheim Credit Allocation Fund, April 5, 2017 * Dechert LLP, March 8, 2017 * Investment Adviser Association, February 21, 2017 * Invesco Senior Income Trust, et al., January 25, 2017 * Dechert, January 25, 2017 * Capital Group, January 11, 2017 * American Century Investment Management, Inc., December 20, 2016 * Russell Investment Management, LLC, December 16, 2016 * Life Partners Position Holder Trust and Life Partners IRA Partnership, LLC, December 2, 2016 * CenturyLink Investment Management Company, December 8, 2016 * Stifel, Nicolaus & Company, Inc., December 6, 2016 * Great-West Life & Annuity Insurance Company, November 16, 2016 * Robert Van Grover, Esq., Seward & Kissel LLP, October 4, 2016 * Hannon Armstrong Sustainable Infrastructure Capital, Inc., September 29, 2016 * Neuberger Berman Investment Advisers LLC, September 28, 2016 * Thrivent Financial for Lutherans and Thrivent Asset Management, LLC, September 27, 2016 * The Herzfeld Caribbean Basin Fund, Inc., September 21, 2016 * Depository Trust Company of Delaware, LLC dba Delaware Depository, September 12, 2016 * AFL-CIO Housing Investment Trust, Aug. 5, 2016 * Franklin Limited Duration Income Trust, July 27, 2016 * Deutsche Multi-Market Income Trust (Omission of Shareholder Proposal), June 24, 2016 * Deutsche Strategic Income Trust (Omission of Shareholder Proposal), June 24, 2016 * Fidelity Management & Research Company et al., June 20, 2016 * Investment Adviser Association, April 25, 2016 * J.P. Morgan Securities LLC, April 14, 2016 * SPDR S&P Dividend ETF, March 28, 2016 * BlackRock Health Sciences Trust, February 25, 2016 * Fiduciary/Claymore MLP Opportunity Fund, January 7, 2016 * Chicago Mercantile Exchange, December 29, 2015 * ICE Clear Credit LLC, December 29, 2015 * LCH.Clearnet Limited and LCH.Clearnet LLC, December 29, 2015 * Investment Company Institute, et al., November 16, 2015 * BlackRock Limited Duration Trust, et al. , October 19, 2015 * North American Division of Seventh-Day Adventists, October 6, 2015 * F. Porter Stansberry, September 30, 2015 * Willkie Farr & Gallagher, September 21, 2015 * Omission of Shareholder Proposal (Fidelity Freedom 2020 Fund, Fidelity Freedom 2025 Fund, and Fidelity Advisor Municipal Income Fund), August 12, 2015 * Royal Dutch Shell plc, August 7, 2015 * Carey Credit Income Fund et al,. July 15, 2015 * Jackson National Life, July 9, 2015 * Northern Lights Fund Trust, June 29 , 2015 * SPDR Series Trust, et al., June 24 , 2015 * UBS AG, May 20, 2015 * JPMorgan Chase & Co., May 20, 2015 * Omission of Shareholder Proposal Submitted by Steven N. Harris (Liberty All-Star Equity Fund), May 6, 2015 * Adams Diversified Equity Fund Inc., April 30, 2015 * Tudor Employee Investment Fund LLC and Tudor Investment Corporation, April 28, 2015 * Opportunity Partners L.P. Shareholder Proposal (Clough Global Equity Fund), April 16, 2015 * Franklin Templeton Investments, April 3, 2015 * Harris & Harris Group, Inc., April 3, 2015 * Tom DeWard Shareholder Proposal (LMP Real Estate Income Fund, Inc.), March 25, 2015 * 16th Amendment Advisors LLC, March 23, 2015 * Fidelity Inflation-Protected Bond Fund (Omission of Shareholder Proposal), February 24, 2015 * Karpus Management, Inc. Shareholder Proposal (Alliance Bernstein Income Fund, Inc.), February 18, 2015 * American Retirement Association, February 18, 2015 * Jonathon Hendricks, January 26, 2015 * Royal Bank of Canada, December 19, 2014 * LCH.Clearnet Limited and LCH.Clearnet LLC, December 19, 2014 * ICE Clear Credit LLC, December 19, 2014 * Chicago Mercantile Exchange, December 19, 2014 * New Mountain Finance Corporation, December 18, 2014 * Bank of America, N.A., November 25, 2014 * Nuveen Credit Strategies Income Fund, et al., November 7, 2014 * Ellsworth Fund Ltd, November 6, 2014 * Guggenheim Strategic Opportunities Fund, October 2, 2014 * Amerivest Investment Management, LLC, August 19, 2014 * Citigroup Global Markets Inc., August 6, 2014 * RiverNorth, July 28, 2014 * Credit Suisse, May 20, 2014 * The Gabelli Convertible & Income Securities Fund, Inc., et al., April 18, 2014 * JP Morgan Municipal Money Market Fund, April 15, 2014 * Invesco Advisers, Inc., April 8, 2014 * RS Global Natural Resources Fund, March 6, 2014 * MEAG MUNICH ERGO., February 14, 2014 * Nuveen Investment Funds, February 13, 2014 * The Brink’s Company, February 11, 2014 * Firsthand Technology Value Fund, Inc., February 11, 2014 * Managed Funds Association, February 6, 2014 * First Trust Dividend and Income Fund, January 30, 2014 * Stephanie Hibler, January 24, 2014 * The Mexico Fund, Inc., December 31, 2013 * Chicago Mercantile Exchange, December 26, 2013 * ICE Clear Credit LLC, December 26, 2013 * LCH.Clearnet Limited and LCH.Clearnet LLC, December 26, 2013 * RBS Securities, Inc., November 26, 2013 * ABA Retirement Funds, November 25, 2013 * Main Street Capital Corporation, November 7, 2013 * Robert Van Grover, Esq., Seward & Kissel LLP, November 5, 2013 * New Mountain Finance Corporation, November 4, 2013 * MCG Capital Corporation, September 27, 2013 * Copley Fund, Inc., August 2, 2013 * Wells Fargo Bank, N.A., July 15, 2013 * Chicago Mercantile Exchange, July 10, 2013 * BlackRock Multi-Sector Income Trust, July 9, 2013 * Morgan Stanley Mortgage Securities Trust, July 9, 2013 * Aberdeen Asia-Pacific Income Fund, Inc., June 26, 2013 * Credit Suisse High Yield Bond Fund and Credit Suisse Asset Management Income Fund, Inc., June 26, 2013 * Eaton Vance, et al., June 26, 2013 * First Trust, et al., June 26, 2013 * John Hancock Investors Trust and John Hancock Tax-Advantaged Global Shareholder Yield Fund, June 26, 2013 * NexPoint Credit Strategies Fund, June 26, 2013 * Nuveen, et al., June 26, 2013 * Goldman, Sachs & Co., June 20, 2013 * Copley Fund, Inc., June 18, 2013 * Request for Consideration of the Steve Tamari Shareholder Proposal (College Retirement Equities Fund), May 23, 2013 * Sandra M. Fox Shareholder Proposal (College Retirement Equities Fund), May 10, 2013 * Steve Tamari Shareholder Proposal (College Retirement Equities Fund), May 10, 2013 * Copley Fund, Inc., April 5, 2013 * lNG Investments, LLC, Directed Services LLC, and lNG Investment Management Co. LLC, March 27, 2013 * Fidelity Select Portfolios, March 15, 2013 * Emerging Global Advisors, LLC and EGA Emerging Global Shares Trust, February 27, 2013 * Registered Investment Company Use of Senior Securities - Select Bibliography, February 12, 2013 (Last Modified) * Pacholder High Yield Fund, Inc., January 18, 2013 * J.P. Morgan Securities LLC, January 9, 2013 * Derivatives Use by Actively-Managed ETFs, December 6, 2012 * Securities Lending by U.S. Open-End and Closed-End Investment Companies, November 6, 2012 * TACT Asset Management Inc., October 24, 2012 * Erste Abwicklungsanstalt, October 10, 2012 * Chicago Mercantile Exchange, September 27, 2012 * Chicago Mercantile Exchange, September 27, 2012 * ICE Clear Credit LLC, September 27, 2012 * LCH.Clearnet Limited, September 27, 2012 * Hatteras Alternative Mutual Funds Trust, et al., September 25, 2012 * Wells Fargo Bank, N.A., September 21, 2012 * Foxby Corp., September 17, 2012 * J.P. Turner & Company, L.L.C., et al, September 10, 2012 * Investment Company Institute, September 5, 2012 * ING Life Insurance and Annuity Company, August 30, 2012 * Linn Energy, LLC, August 30, 2012 * Allianz of America, Inc., May 25, 2012 * GMO Trust, May 24, 2012 * Liberty All-star Growth Fund, Inc., May 10, 2012 * ING Emerging Countries Fund, May 7, 2012 * Aberdeen Australia Equity Fund, Inc., Aberdeen Chile Fund, Inc. and Aberdeen Global Income Fund, Inc., April 12, 2012 * John Hancock Trust, et al, April 12, 2012 * Peter Adamson III, April 3, 2012 * Market Vectors ETF Trust, et al., March 26, 2012 * Guggenheim Enhanced Equity Strategy Fund, March 21, 2012 * Industrial Alliance, Investment Management Inc., March 14, 2012 * American Century Investment Management, Inc., February 2, 2012 * GE Funding Capital Market Services, Inc., January 25, 2012 * American Bar Association, Business Law Section, January 18, 2012 * Xplornet Communications Inc., January 11, 2012 * Integrity Life Insurance Co., National Integrity Life Insurance Co., Western-Southern Life Assurance Co., Touchtone Securities, Inc., December 21, 2011 * FQF Trust, et al., December 13, 2011 * Columbia Funds, December 12, 2011 * Wells Fargo Bank, N.A., December 12, 2011 * Department of Labor, October 26, 2011 * Morgan Stanley Institutional Fund of Hedge Funds, October 7, 2011 * Investment Company Institute, September 12, 2011 * LCH Clearnet Limited, July 29, 2011 * ICE Clear Credit LLC, July 29, 2011 * Chicago Mercantile Exchange, July 29, 2011 * Chicago Mercantile Exchange, July 29, 2011 * Seward & Kissel LLP, July 21, 2011 * J.P. Morgan Securities LLC, July 11, 2011 * Zenkyoren Asset Management of America Inc., June 30, 2011 * J.P. Morgan Securities LLC, June 29, 2011 * Main Street Capital Corporation, June 20, 2011 * Red Rocks Capital, LLC, June 3, 2011 * BAC Home Loans Servicing, LP (formerly Countrywide Home Loans Servicing LP), June 2, 2011 * UBS Financial Services Inc., May 9, 2011 * College Retirement Equities Fund ("Fund") Shareholder Proposal of Aaron Levitt, May 6, 2011 * Bank of America Corporation and Affiliates ("BAC"), April 29, 2011 * New Mountain Finance Corporation, April 27, 2011 * Deutsche Bank Microcredit Development Fund, Inc., April 8, 2011 * Nationwide Mutual Funds, et al., April 5, 2011 * Chicago Mercantile Exchange, March 24, 2011 * Omission of Shareholder Proposal Pursuant to Rule 14a-8 for H&Q Life Sciences Investors, March 24, 2011 * LCH.Clearnet Limited, March 16, 2011 * ICE Trust U.S. LLC, March 1, 2011 * Lazard Global Total Return and Income Fund, Inc. and Lazard World Dividend & Income Fund, Inc., February 15, 2011 * Calamos Convertible Opportunities and Income Fund, Calamos Convertible and High Income Fund, and Calamos Global Total Return Fund, February 14, 2011 * H & Q Life Sciences Investors, February 4, 2011 * Adams Express Company, January 26, 2011 * Nuveen Asset Management, Inc., et al., December 30, 2010 * American Institute of Certified Public Accountants, December 23, 2010 * CME Group, Inc., December 3, 2010 * Boulder Total Return Fund, Inc., November 15, 2010 * Nuveen Municipal High Income Opportunity Fund, Nuveen Municipal High Income Opportunity Fund 2, Nuveen Floating Rate Income Opportunity Fund, Nuveen Senior Income Fund, Nuveen Floating Rate Income Fund, and Nuveen Municipal Value Fund, Inc., November 9, 2010 * Independent Directors Council and Mutual Fund Directors Forum, November 2, 2010 * Citigroup Inc., October 22, 2010 * Seward & Kissell, October 12, 2010 * BNY ConvergEx Group, September 21, 2010 * The Ibero-America Fund, Inc., September 9, 2010 * Investment Company Institute Designated NRSROs, August 19, 2010 * Royalty Pharma, August 13, 2010 * Investment Company Institute (Corrected), August 10, 2010 * General Electric Company, August 2, 2010 * WilmerHale, LLP, July 28, 2010 * Energy Income and Growth Fund and First Trust Active Dividend Income Fund, July 27, 2010 * ASA Limited, July 23, 2010 * Goldman, Sachs & Co., July 22, 2010 * CME Group, Inc., July 16, 2010 * ABA Retirement Funds Program, June 7, 2010 * Accor Services, June 7, 2010 * The Swiss Helvetia Fund, Inc., May 5, 2010 * Claymore Advisors, LLC, April 27, 2010 * Tortoise Energy Infrastructure Corporation and Tortoise Energy Capital Corporation, April 23, 2010 * Investment Company Institute, April 2, 2010 * Boulder Growth and Income Fund, Inc., March 5, 2010 * Boulder Total Return Fund, Inc., March 5, 2010 * Fifth Street Finance Corp., February 25, 2010 * T. Rowe Price Associates, Inc., October 8, 2009 * Sisters of Mercy of the Americas, Inc., October 1, 2009 * Emeriti Consortium for Retirement Health Solutions, September 3, 2009 * Dechert LLP, August 24, 2009 * Omgeo LLC, August 14, 2009 * General Electric Company, August 12, 2009 * Allianz Funds, August 3, 2009 * The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., August 3, 2009 * Mount Vernon Securities Lending Trust, August 3, 2009 * Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Fund, August 3, 2009 * Maxim Series Fund, Inc., et al., July 31, 2009 * UBS AG, July 29, 2009 * Straight-A Funding, LLC, July 28, 2009 * American Capital, Ltd, June 30, 2009 * Madison Asset Management, LLC, et al., June 30, 2009 * Franklin Templeton Investments, June 19, 2009 * Banc of America Securities LLC, June 10, 2009 * RBC Capital Markets Corporation, June 10, 2009 * Deutsche Bank Securities Inc., June 9, 2009 * Morgan Stanley Smith Barney LLC, May 29, 2009 * Citigroup Global Markets, Inc, May 28, 2009 * Vanguard Group, Inc., May 22, 2009 * Berthel Growth & Income Trust I, May 5, 2009 * TS&W/Claymore Tax-Advantaged Balanced Fund, April 27, 2009 * U.S. Government Reserves and Fidelity Cash Reserves, April 27, 2009 * SEI Daily Income Trust ? Prime Obligation Fund, April 20, 2009 * SEI Liquid Asset Trust ? Prime Obligation Fund, April 20, 2009 * Seward & Kissel LLP, April 15, 2009 * Iridian Asset Management LLC, April 14, 2009 * College Retirement Equities Fund (CREF), April 13, 2009 * Bank of Ireland Asset Management (U.S.) Ltd., April 2, 2009 * Regions Morgan Keegan Funds, March 30, 2009 * UBS AG, March 20, 2009 * Valuation of Portfolio Securities and other Assets Held by Registered Investment Companies - Select Bibliography of the Division of Investment Management, March 20, 2009 * Automated Trading Desk Specialists, LLC, March 13, 2009 * Barclays Global Fund Advisors et al., March 12, 2009 * E*Trade Capital Markets LLC, March 12, 2009 * Investment Company Institute, March 12, 2009 * Kohlberg Capital Corporation, March 12, 2009 * Columbia Funds Series Trust - Columbia Cash Reserves, March 2, 2009 * Columbia Funds Series Trust - Columbia Money Market Reserves, March 2, 2009 * Master Portfolio Trust - Liquid Reserves Portfolio and Legg Mason Partners Money Market Trust - Western Asset Money Market Fund, March 2, 2009 * Northern Institutional Funds - Diversified Assets Portfolio, Liquid Assets Portfolio and Prime Obligations Portfolio and Northern Funds - Money Market Fund, March 2, 2009 * SEI Liquid Asset Trust - Prime Obligation Fund, March 2, 2009 * AXA Equitable Life Insurance Company, February 27, 2009 * Wachovia Securities LLC, February 18, 2009 * American Capital, Ltd., February 5, 2009 * Capital Trust, Inc., February 3, 2009 * Fortis Group, et al., January 27, 2009 * Mount Vernon Securities Lending Trust, January 8, 2009 * Auction Rate Securities, January 6, 2009 * Citigroup Global Markets, Inc., December 23, 2008 * Columbia Funds, et al., December 23, 2008 * UBS Securities LLC/UBS Financial Services Inc., December 23, 2008 * Master Portfolio Trust - Liquid Reserves Portfolio, December 8, 2008 * BNY Mellon Funds Trust, December 2, 2008 * Franklin Templeton Investments, November 21, 2008 * Reserve New York Municipal Money-Market Trust - New York Municipal Money-Market Fund, November 18, 2008 * SEI Daily Income Trust - Prime Obligation Fund, November 18, 2008 * The TCW Group, Inc., November 7, 2008 * BlackRock Advisers LLC and Affiliates, November 4, 2008 * Mount Vernon Securities Lending Trust, October 24, 2008 * Russell Investment Company, October 24, 2008 * Columbia Funds Series Trust, October 22, 2008 * ING Funds Trust, ING Investors Trust, and ING Series Fund, Inc., October 22, 2008 * iShares Trust, et al., October 22, 2008 * J.P. Morgan Securities Inc., October 22, 2008 * Legg Mason Partners Institutional Trust, October 22, 2008 * Legg Mason Partners Institutional Trust, October 22, 2008 * MainStay VP Cash Management Portfolio, October 22, 2008 * Morgan Stanley Institutional Liquidity Funds, October 22, 2008 * Morgan Stanley Money Market Funds, October 22, 2008 * Mount Vernon Securities Lending Trust, October 22, 2008 * Northwestern Mutual Series Fund, Inc., October 22, 2008 * Penn Series Funds Inc., October 22, 2008 * Penn Series Funds Inc., October 22, 2008 * Phoenix Opportunities Trust, October 22, 2008 * Principal Funds, Inc. and Principal Variable Contracts Funds, Inc., October 22, 2008 * RidgeWorth Funds, October 22, 2008 * Tamarack Funds Trust, October 22, 2008 * Touchstone Variable Series Trust, October 22, 2008 * USAA Mutual Funds Trust, October 22, 2008 * Advantus Series Fund, October 20, 2008 * Dreyfus Cash Management Plus, October 20, 2008 * Dreyfus Money Funds, October 20, 2008 * Dreyfus Money Funds, October 20, 2008 * The Hartford Mutual Funds, Inc. and Hartford Series Fund, Inc., October 20, 2008 * Russell Investment Company, October 20, 2008 * Sun Capital Advisers Trust, October 20, 2008 * Investment Company Institute, October 10, 2008 * Investment Company Institute, October 8, 2008 * Highbridge Statistical Market Neutral Fund, September 29, 2008 * Dreyfus Cash Management, et al., September 25, 2008 * Investment Company Institute, September 25, 2008 * Auction Rate Securities - Global Exemptive Relief, September 22, 2008 * Barclays Capital Inc., September 19, 2008 * Prudential Financial, Inc., September 5, 2008 * Goldman Sachs Trust, August 19, 2008 * Missouri Bankers Association, August 18, 2008 * Victory Institutional Money Market Fund, Victory Financial Reserves Fund, and Victory Prime Obligations Funds, August 1, 2008 * Mayer Brown LLP, July 28, 2008 * Northern Institutional Fund, July 16, 2008 * JP Morgan Chase-Bear Stearns Asset Management, July 14 and March 16, 2008 * First Trust/Gallatin Specialty Finance and Financial Opportunities Fund, July 11, 2008 * T. Rowe Price Associates, Inc., July 10, 2008 * The Townsend Group, Inc., July 9, 2008 * Western Asset Money Market Fund, June 27, 2008 * Western Asset Institutional Money Market Fund, June 27, 2008 * HSBC Investor Funds, June 25, 2008 * Munder Series Trust, June 23, 2008 * Cabot Wellington, LLC, June 17, 2008 * Emeriti Consortium for Retirement Health Solutions, June 16, 2008 * Eaton Vance Management, June 13, 2008 * College Retirement Equities Fund, May 19, 2008 * Allianz Dresdner Daily Asset Fund, May 5, 2008 * Institutional Liquidity Trust, April 30, 2008 * ING Series Fund, Inc., et al, April 30, 2008 * Fidelity Select Portfolio, April 29, 2008 * Master Portfolio Trust, April 18, 2008 * Janus Aspen Series, April 10, 2008 * Highbridge Statistical Market Neutral Fund, April 7, 2008 * Master Portfolio Trust, April 4, 2008 * SEI Daily Income Trust – Prime Obligation Fund, February 29, 2008 * Northern Institutional Funds, February 28, 2008 * Wells Fargo Funds Trust – Prime Money Market Fund and Heritage Money Market Fund, February 13, 2008 * Fidelity Funds, January 22, 2008 * HSBC Investor Funds, January 18, 2008 * STI Classic Funds, January 2, 2008 * NGP Capital Resources Company (Corrected), December 28, 2007 * CUNA Mutual Life Insurance Company, et al., December 27, 2007 * Dexia Municipal Agency, December 26, 2007 * TDAM Money Market Portfolio, December 21, 2007 * Franklin Universal Trust, December 18, 2007 * First American Funds, Inc. – Prime Obligation Fund, December 3, 2007 * SEI Liquid Asset Trust Prime Obligation Fund, December 3, 2007 * Old Mutual Advisors Funds, November 16, 2007 * SEI Daily Income Trust - Money Market Fund, November 9, 2007 * SEI Daily Income Trust - Prime Obligation Fund, November 8, 2007 * STI Classic Funds, October 26, 2007 * Investment Adviser Association, September 20, 2007 * Exelon Corporation, September 13, 2007 * McDermott, Will & Emery, July 26, 2007 * Cooley Godward & Kronish, July 12, 2007 * Capital Trust, Inc., May 24, 2007 * Ameritas Life Insurance Corp., April 5, 2007 * Lear Corporation Retirement Savings Plan Trusts, March 16, 2007 * Goldman Sachs Asset Management, L.P., March 13, 2007 * M&G Investment Management Ltd., March 1, 2007 * Heitman Capital Management, LLC, February 12, 2007 * Investment Company Institute, February 1, 2007 * Van Kampen Funds Inc., January 31, 2007 * Emanuel J. Friedman and EJF Capital LLC, January 16, 2007 * Gartmore Variable Insurance Trust, December 29, 2006 * GuideStone Financial, et al., December 27, 2006 * IDS Life Insurance Company, et al., December 14, 2006 * ASA (Bermuda) Limited, December 13, 2006 * MACRO Securities Depositor, LLC, December 1, 2006 * Federated Municipal Funds, November 20, 2006 * Alliance World Dollar Government Fund, Inc., October 19, 2006 * Nuveen Virginia Premium Income Municipal Fund, October 6, 2006 * Merrill Lynch & Co., Inc., September 27, 2006 * Citigroup Global Markets, Inc., September 26, 2006 * Washington Capital Joint Master Trust, September 25, 2006 * Deloitte & Touche LLP, August 28, 2006 * ABA Subcommittee on Private Investment Entities, August 10, 2006 * Credit Agricole Asset Management Alternative Investments, Inc., August 7, 2006 * Citigroup Inc., July 26, 2006 * Aberdeen Australia Equity Fund, Inc., July 13, 2006 * Alternative Investment Partners Absolute Return Fund STS, July 10, 2006 * Gardner Russo & Gardner, June 7, 2006 * SCP Private Equity Partners II, L.P., June 6, 2006 * Lockheed Martin Investment Management Company, June 6, 2006 * Mutual of America Investment Corporation, June 2, 2006 * Ameriprise Financial Services Inc., April 5, 2006 * Putnam Premier Income Trust, March 14, 2006 * Putnam High Income Securities Fund, March 14, 2006 * Millennium Partners, L.P., et al, March 9, 2006 * American International Group, Inc., February 21, 2006 * First Great-West Life & Annuity Insurance Company & Canada Life Insurance Company of New York, December 22, 2005 * GE Institutional Funds, December 21, 2005 * Pioneer Funds, December 20, 2005 * Investment Company Institute, December 14, 2005 * ABA Subcommittee on Private Investment Entities, December 8, 2005 * Investment Adviser Association, December 2, 2005 * National Compliance Service, November 30, 2005 * E*TRADE Securities, LLC, November 30, 2005 * Morgan, Lewis & Bockius LLP, November 17, 2005 * American Home Assurance Company, et. al., October 17, 2005 * Seward & Kissel, October 12, 2005 * Evergreen Investment Management Company LLC, October 11, 2005 * UBS Financial Services, Inc., September 29, 2005 * Credit Suisse First Boston, LLC, August 31, 2005 * ING Bank N.V., August 31, 2005 * Putnam Tax-Free Health Care Fund, August 8, 2005 * EIF Neptune, LLC Starwood Energy Investors, LLC & Atlantic Energy Parts, July 29, 2005 * Royal Dutch Shell plc, May 17, 2005 * American Skandia Life Assurance Corporation, May 16, 2005 * Principal Investors Fund Inc., May 13, 2005 * Ark Therapeutics Group plc, April 15, 2005 * Emeriti Consortium for Retirement Health Solutions, April 7, 2005 * Mellon Equity Associates, LLP April 1, 2005 * Trusts under the Will of Marion Searle, March 29, 2005 * Fidelity Magellan Fund, March 15, 2005 * AICPA SEC Regulations Committee, March 8, 2005 * The Goldman Sachs Group, Inc., March 8, 2005 * Prudential Insurance Company of America, March 1, 2005 * CIBC Mellon Trust Company, February 24, 2005 * Goldman, Sachs & Co., February 23, 2005 * Morgan Stanley & Co., Inc., February 4, 2005 * Wells Fargo Alternative Asset Management, LLC, January 26, 2005 * Pacific Select Fund, et al., December 23, 2004 * American International Group, Inc., December 8, 2004 * Trainer, Wortham & Co. Froley, Revy Investment Co. Starbuck, Tisdale & Assoc., December 6, 2004 * College and University Facility Loan Trust One, et al., November 29, 2004 * Investment Company Institute, November 10, 2004 * Old Dominion Electric Cooperative, et al., October 13, 2004 * Deutsche Bank Securities Inc., September 24, 2004 * Thomas Weisel Partners LLC, September 24, 2004 * GE Life and Annuity Assurance Company, June 25, 2004 * American Bible Society, June 1, 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 Annuities; 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 * Investment Company Institute, April 30, 2001 * Investment Company Institute, April 30, 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 * Letter to the Investment Company Institute Regarding Valuation Issues, April 2001 * Nationwide Life Insurance Company, March 16, 2001 * AHA Investment Funds, Inc, March 8, 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 * Comdisco, Inc., October 25, 2000 * Willkie Farr & Gallagher, October 23, 2000 * Janus Adviser Series, August 28, 2000 * Mackenzie Investment Managment et al., August 8, 2000 * Massachusetts Mutual Life, July 28, 2000 * Jennison Associates LLC, July 6, 2000 * Select Sector SPDR Fund and Diamonds Trust, July 6, 2000 * Massachusetts Mutual Life, June 7, 2000 * Brown & Wood, February 24, 2000 * General Motors Investment Management, February 20, 2000 * R.O.C. Taiwan Fund, February 11, 2000 * Pengrowth Energy Trust, January 27, 2000 * Signature Financial Group, Inc., December 28, 1999 * Investment Company Institute, December 8, 1999 * Metropolitan Life Insurance Company, November 23, 1999 * HOLDRs, September 3, 1999 * BISYS Fund Services, Inc., September 2, 1999 * The First Australia Fund, Inc., July 29, 1999 * Salomon Brothers Asset Management Inc and Salomon Brothers Asset Management Asia Pacific Limited, July 23, 1999 * Investment Company Institute, June 15, 1999 * ING Bank N.V., et al., May 24, 1999 * Frankin Templeton Group of Funds, et al., May 21, 1999 * Select Sector SPDR Trust, May 6, 1999 * American Bar Association, April 22, 1999 * Goldman, Sachs & Co., February 22 , 1999 * Defined Asset Funds, December 23, 1998 * Drinker, Biddle & Reath, December 18, 1998 * Franklin Management, Inc., December 10, 1998 * SSGA International Liquidity Fund, December 2, 1998 * Mutual of Omaha Insurance Company, November 27, 1998 * American Express Financial Corporation, November 17, 1998 * New Center Asset Trust, November 5, 1998 * Investment Company Institute, October 30, 1998 * MassMutual Institutional Funds, Inc., October 19, 1998 * Service Corporation International, October 6, 1998 * Goodwin, Procter & Hoar, October 5, 1998 * Wilmer, Cutler & Pickering and Davis Polk & Wardell, October 5, 1998 * Credit Suisse First Boston, September 9, 1998 * Zurich Insurance Company; Scudder Kemper Investments, Inc., August 31, 1998 * Massachusetts Mutual Life Insurance Company, August 10, 1998 * ICI Mutual Insurance Company, July 27, 1998 * Plymouth Commercial Mortgage Fund, July 13, 1998 * Nuveen Flagship Multistate Trust I, July 10, 1998 * Chase Manhattan Bank, June 12, 1998 * One Point Communications Corp, June 12, 1998 * Royal Bank of Canada, et al., June 3, 1998 * Lamp Technologies, Inc., May 29, 1998 * New England Education Loan Marketing Corp, May 22, 1998 * Safra Republic Holdings, April 21, 1998 * Investment Company Institute, April 15, 1998 * Moscow Municipal Bank, April 8, 1998 * Nebraska Higher Education Loan Program Inc., April 4, 1998 * Daughters of Charity National Health System, Inc., April 3, 1998 * Nebraska Higher Education Loan Program, April 3, 1998 * Wells Fargo Bank, N.A., March 31, 1998 * DALBAR, Inc., March 24, 1998 * Public Employees' Retirement Board of the State of Oregon, March 3, 1998 * Neuberger & Berman Income Funds, February 27, 1998 * Investment Company Institute and the Global Custodians, February 19, 1998 * Reserve Bank of Australia, January 30, 1998 * Societatea Nationala de Compensare, January 28, 1998 * Stock Holding Corporation of Indian Ltd., January 21, 1998 * Sullivan and Cromwell, December 29, 1997 * American Century Companies, Inc. / J.P. Morgan & Co., December 23, 1997 * Depository Clearing Company, December 19, 1997 * Brinson Funds, et al., November 25, 1997 * K. K. Rajendran, November 21, 1997 * Chief Financial Officer, November 7, 1997 * Mike Krichew, November 5, 1997 * BSC Employee Fund, L.P., October 14, 1997 * Redwood Investment Fund, LLC, October 14, 1997 * Investment Company Institute, October 3, 1997 * Five Arrows Short-Term Investment Trust, September 26, 1997 * Bear, Stearns & Co. Inc., September 16, 1997 * Bradley A. Veld, August 15, 1997 * LNC Equity Sales Corporation, August 8, 1997 * INVESCO Funds Group, Inc., August 5, 1997 * The Eaton Vance Group of Investment Companies, July 25, 1997 * Franklin Templeton Group of Funds, July 23, 1997 * MLC Limited, July 21, 1997 * American International Group, Inc., July 18, 1997 * Macedonian Stock Exchange, July 10, 1997 * AmSouth Mutual Funds, July 8, 1997 * Federated Investors, July 8, 1997 * Charles Schwab & Co., Inc., July 7, 1997 * ABN AMRO Bank N.V., July 1, 1997 * PNC Bank N.A., June 10, 1997 * First Financial Fund, Inc., at al., June 5, 1997 * Bucharest Stock Exchange, June 3, 1997 * Lamp Technologies, Inc., May 29, 1997 * Russia Growth Fund, Inc., May 20, 1997 * John Bowen Investment Management, May 13, 1997 * Puerto Rico Balanced Fund, Inc., April 29, 1997 * Merrill Lynch Asset Management, April 28, 1997 * Alliance Funds, April 25, 1997 * Davis, Polk & Wardwell, April 24, 1997 * Dean Witter, Discover & Co.; Morgan Stanley Group Inc., April 18, 1997 * Dessauer Global Equity Fund, April 3, 1997 * Eaton Vance South Asia Portfolio, March 12, 1997 * Goodwin, Procter & Hoar, February 28, 1997 * I.C.H. Corporation, February 26, 1997 * National Securities Depository Ltd., February 25, 1997 * KDSM, Inc. and Sinclair Capital, February 21, 1997 * Indosuez Asset Management Asia Limited, February 14, 1997 * GE Funds, February 7, 1997 * ITT Hartford Mutual Funds, February 7, 1997 * Nicholas-Applegate Mutual Funds, February 7, 1997 * Dr. William Greene, Stern School of Business, February 3, 1997 * Lazard Freres Asset Management, January 10, 1997 * Association for Investment Management and Research, December 18, 1996 * Equitable Life Assurance Society, December 18, 1996 * Eaton Vance Master Portfolio, December 11, 1996 * Plymouth Commercial Mortgage Fund, December 3, 1996 * Australian Securities Commission, October 23, 1996 * American Odyssey Funds, Inc., October 7, 1996 * Pilgrim America, Inc., October 8, 1996 * John W. Henry Co. Inc., September 20, 1996 * Dean Witter World Wide Investment Trust, September 17, 1996 * Horizon Asset Management, LLC, September 13, 1996 * Morgan Grenfell Investment Trust, September 13, 1996 * Templeton Vietnam Opportunities Fund, Inc., September 6, 1996 * ASX Settlement & Transfer Corporation, August 13, 1996 * Sacha Stawski, August 9, 1996 * Bramwell Growth Fund, August 7, 1996 * Nicholas-Applegate Mutual Funds, August 6, 1996 * Interbolsa, August 5, 1996 * PerfectData Corporation, August 5, 1996 * State Street Bank & Trust, August 1, 1996 * Investment Company Institute, July 29, 1996 * Hewlett-Packard Finance Company, July 17, 1996 * Managed Futures Association, July 11, 1996 * Mr. Frank Mason, July 3, 1996 * Wilkie Farr & Gallagher, June 11, 1996 * John Hancock Fund, Inc., June 25, 1996 * Real Goods Trading Corporation, June 24, 1996 * Dreyfus Asset Allocation Fund, Inc., June 14, 1996 * American Mutual Life Insurance, June 13, 1996 * National Association for Variable Annuities, June 4, 1996 * World Financial Network National Bank, May 28, 1996 * Gary E. Hughes, American Council of Life Insurance, May 26, 1996 * National Securities Clearing Corp., May 24, 1996 * Bancafe/Juan Vico, May 22, 1996 * Metropolitan Life Insurance Company, New England Mutual Life Insurance Company, and New England Variable Life Insurance Company, May 17, 1996 * Munder Capital Management, May 17, 1996 * Investment Company Institute, May 9, 1996 * Blanchard Global Growth Fund, May 7, 1996 * J.P. Morgan Investment Management, Inc., May 7, 1996 * Russell H. Smith, May 2, 1996 * TIAA Real Estate Account, May 1, 1996 * Financial Services Board, April 24, 1996 * Rowe Price-Fleming International Inc., April 12, 1996 * Ramius Capital Management, LLC, April 5, 1996 * Kavilco, Inc., April 4, 1996 * RDM Infodustries, Inc., March 25, 1996 * DFA Investment Trust, March 21, 1996 * Cornish & Carey Commercial Inc., February 26, 1996 * U.S. Department of Labor, February 22, 1996 * Investment Company Registrant General Letter, February 15, 1996 * Massachusetts Mutual Life, February 15, 1996 * Lazard Freres Asset Management, February 12, 1996 * Investment Funds Institute of Canada, February 6, 1996 * G.T. Global Growth Series et al., February 2, 1996 * Total, January 26, 1996 * The Standish Ayer & Wood Inc. Stable Value Group Trust, December 28, 1995 * The Equitable Life Assurance Society of the United States, December 22, 1995 * The Ayco Company L.P., December 14, 1995 * Maxine Harry, December 6, 1995 * Principle Preservation Portfolios, Inc., December 6, 1995 * Department of Labor, December 5, 1995 * Pretzel & Stouffer, December 1, 1995 * Morgan Guaranty Trust Company of New York, November 17, 1995 * InTouch Global, LLC, November 14, 1995 * The Riverfront Funds, Inc., November 8, 1995 * Mutual Series Fund Inc., November 7, 1995 * Accounting Comment Letter, November 2, 1995 * Colonial Trust I et al., October 20, 1995 * David Parkinson, October 19, 1995 * DFA Investment Trust Company, October 17, 1995 * Missouri Innovation Center, Inc., October 17, 1995 * MassMutual Institutional Funds, September 28, 1995 * Queensland Treasury Corporation, September 26, 1995 * Thomson Advisory Group L.P., September 26, 1995 * First Call Corporation, September 6, 1995 * SMC Capital, Inc., September 5, 1995 * Mark A. Bush, August 8, 1995 * Norwest Funds - Municipal Money Market Fund, August 8, 1995 * Alfred A. Zurl, August 7, 1995 * Fiduciary Trust Global Fund, August 2, 1995 * The T. Rowe Price Funds, July 31, 1995 * George Colman, July 18, 1995 * Gilbert G. Beezley, July 17, 1995 * ACM Institutional Reserves, Inc., July 14, 1995 * Alliance Municipal Trust, July 14, 1995 * Hongkong Securities Clearing Company Limited, July 13, 1995 * Municipal Fund for California Investors, Inc., July 12, 1995 * California Municipal Cash Trust, July 11, 1995 * Venture Search Technology Inc., July 11, 1995 * Lehman Brothers Daily Income Fund, July 7, 1995 * Twentieth Century Mutual Funds, July 7, 1995 * Wells Fargo Money Market Funds, July 7, 1995 * Benham California Tax-Free and Municipal Funds, June 30, 1995 * Kemper Money Market Funds, June 23, 1995 * American Council of Life Insurance, June 20, 1995 * Benson White & Company, June 14, 1995 * James R. Waters, June 1, 1995 * Investment Company Institute, May 26, 1995 * Norwest Bank Minnesota, N.A. and Society National Bank, May 25, 1995 * The One Group, May 23, 1995 * Unit Investment Trust Organizational Expenses, May 9, 1995 * Goldman Sachs & Co., April 27, 1995 * Metropolitan Life Insurance Company, April 26, 1995 * Salomon Brothers Inc., April 25, 1995 * The Victory Funds and The Victory Portfolios, April 24, 1995 * Templeton Russia Fund, Inc., April 18, 1995 * Citicorp Securities, April 6, 1995 * State Street Bank & Trust Company, February 28, 1995 * Philadelphia Ventures Liberty Fund, L.P., February 14, 1995 * M.S.B. Fund, Inc., February 10, 1995 * Victory Stock Index Fund, February 7, 1995 * Kemper Total Return Fund, February 6, 1995 * Chief Financial Officer of Investment Company Registrants, February 3, 1995 * Letter to Investment Company Registrants, February 3, 1995 * ESI S.A., February 2, 1995 * PaineWebber Incorporated, January 27, 1995 * United Municipal Bond Fund, January 27, 1995 * The Royce Fund, January 24, 1995 * United Missouri Bank of Kansas City, January 23, 1995 * Global Exempt Certificates of Ownership in NHA MBS Securities Inc., December 30, 1994 * Caxton Corporation, December 28, 1994 * Latham & Watkins, December 28, 1994 * Shoreline Fund, L.P., November 14, 1994 * Transamerica Series, Inc., November>Chief Financial Officer, November 1, 1994 * Linsco/Private Ledger Corp., November 1, 1994 * Wm. S. Barnickel & Company, November 1, 1994 * Letter to Investment Advisers, October 25, 1994 * Warsaw Stock Exchange, October 20, 1994 * Philadelphia Stock Exchange, Inc., October 18, 1994 * Dana Investment Advisors, Inc., October 12, 1994 * Mutual Funds and Derivative Instruments, September 26, 1994 * Townsend and Associates, Inc., September 21, 1994 * Pershing Division of Donaldson, Lufkin & Jenrette Securities Corp., September 15, 1994 * Glenwood Investment Corp., August 10, 1994 * W.R. Huff Asset Management Co., L.P., August 10, 1994 * Integrated Resources, Inc., August 5, 1994 * North American Security Trust, August 5, 1994 * PaineWebber Managed Investments Trust, August 4, 1994 * The Canadian Depository for Securities Limited, August 4, 1994 * First Coastal Corporation, July 28, 1994 * Stephen R. Kelly, July 28, 1994 * J.P. Morgan Structured Obligations Corporation, July 27, 1994 * Murray Johnstone Holdings Limited; Murray Johnstone Limited; Murray Johnstone International Limited, July 21, 1994 * Adam W. Glass, July 20, 1994 * Arthur Andersen & Co., July 8, 1994 * Edward H. Fleischman, June 30, 1994 * Owens-Illinois, Inc., June 24, 1994 * Louis Russo, June 16, 1994 * CBA Money Fund, et al., June 9, 1994 * Donaldson, Lufkin & Jenrette Securities Corporation, May 26, 1994 * Kake Tribal Corporation, May 25, 1994 * R. Bryan Stoker, May 13, 1994 * Sean J. Egan, May 10, 1994 * Century Shares Trust, May 4, 1994 * PanAgora Group Trust, April 29, 1994 * Long-Term Capital Management, L.P., April 28, 1994 * Municipality Finance Ltd., April 28, 1994 * Federated Investors, April 21, 1994 * ASX Settlement and Transfer Corporation, April 19, 1994 * Shoreline Fund, L.P., April 11, 1994 * Andrews & Kurth L.L.P., April 5, 1994 * Mutual Benefit Fund, et al., March 30, 1994 * Scudder Investment Trust, March 23, 1994 * MPC Liquidating Trust, March 10, 1994 * Lehman Brothers Inc., March 8, 1994 * Summit Advisors, Inc., March 1, 1994 * ICI Mutual Insurance Company, February 28, 1994 * The Capitol Mutual Funds and Nations Fund Trust, February 24, 1994 * Brown & Wood, February 24, 1994 * Gerald Zuckerman, February 1, 1994 * David S. Butterworth, January 27, 1994 * Travelers Insurance Company et al., September 3, 1993 * The South America Fund N.V., September 2, 1993 * Japan Securities Depository Center, August 31, 1993 * Frank Russell Investment Management Company, August 30, 1993 * Alameda Contra Costa Medical Association Collective Investment Trust for Retirement Plans, August 26, 1993 * Stock Exchange of Thailand, August 26, 1993 * New America High Income Fund, Inc., July 29, 1993 * College Retirement Equities Fund Real Estate Account, July 22, 1993 * PaineWebber Equity Trusts, July 19, 1993 * Welsh, Carson, Anderson & Stowe, June 18, 1993 * Mutual of America Life Insurance Company, June 17, 1993 * T. Rowe Price Tax-Free Funds, June 24, 1993 * Investment Company Institute, June 16, 1993 * Investment Company Institute, June 15, 1993 * Shearson Lehman Brothers Inc. and Smith Barney, Harris Upham & Co. Incorporated, June 8, 1993 * Keene Corporation, June 2, 1993 * Reserve Bank of New Zealand, May 24, 1993 * Malaysian Central Depository Sdn. Bhd., May 19, 1993 * Sedgwick Consulting Group, May 17, 1993 * Kidder Peabody Investment Trust, May 14, 1993 * Korea Securities Depository Corporation, May 14, 1993 * Washington Mutual Investors Fund, Inc., May 14, 1993 * Defined Asset Funds - Equity Income Fund - Select Ten Series, May 5, 1993 * Custody of B Shares Trading on the Shenzhen and Shanghai Securities Exchanges, April 26, 1993 * United Services Funds, April 23, 1993 * Mercury Asset Management plc, April 16, 1993 * Alliance Capital Management L.P., April 7, 1993 * Austraclear Limited, April 6, 1993 * PNC Fund, et al., April 2, 1993 * Richard L. Mertz, April 1, 1993 * Datastream International Inc., March 15, 1993 * Oppenheimer Landmrk Properties, March 9, 1993 * Celina Financial Corporation, February 19, 1993 * Dean Witter, Discover & Co., February 8, 1993 * North American Security Trust and NASL Series Trust, February 2, 1993 * Thomson Fund Group, et al., January 28, 1993 * County of Los Angeles, January 27, 1993 * Pasadena Investment Trust, January 22, 1993 * Robertson, Stephens & Company, January 12, 1993 * Calvert Group, January 7, 1993 * Michael Tannenbaum, January 5, 1993 * Investment Company Institute, November 2, 1992 * Missouri Family Trust Fund, September 22, 1992 * Founders Funds, Inc., August 4, 1992 * Uniao de Bancos de Brasileiros S.A., July 28, 1992 * Morgan Keegan & Company, Inc., July 24, 1992 * Charles Schwab & Co., May 28, 1992 * Wall Street Preferred Money Managers, Inc., April 10, 1992 * University of Alaska Advance College Tuition Payment, March 2, 1992 * Bear, Stearns & Co. Inc., January 28, 1992 * Mutual Benefit Fund, et al., August 23, 1991 * Greenwich Capital Acceptance Inc., August 8, 1991 * NAB Asset Corp., June 20, 1991 * Citytrust, Inc., December 19, 1990 * Delta Government Options Corp., Sept. 27, 1990 * Value Line, Inc., April 18, 1990 * Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, November 8, 1989 * American Funds Distributors, October 16, 1989 * Delta Government Options Corp., July 21, 1989 * United States Property Investment N.V., May 1, 1989 * Letter Providing General Guidance to Insurance Companies Filing Post-Effective Amendments in Connection with the Offering of Variable Life and Variable Annuity Contracts, January 24, 1989 * United Bankers , March 23, 1988 * M.D.C. Holdings, May 5, 1987 * The State Street Mortgage Co., November 18, 1986 * Clover Capital Management, Inc., October 28, 1986 * First National Bank of Fremont, November 18, 1985 * Salomon Brothers, Inc., June 17, 1985 * Health Facility Credit Corp. , February 6, 1985 * Adams Express Company, September 7, 1984 * Baton Rouge Building and Construction Industry Foundation, August 31, 1984 * Northwestern Ohio Building and Construction Trades Foundation, April 20, 1984 * Nottingham Realty Securities, April 19, 1984 * Realex Capital Corporation, April 19, 1984 * The Adams Company, November 26, 1982 * Twentieth Century Investors, Inc., October 27, 1982 * United States & Foreign Securities Corporation, October 27, 1982 * SIFE Trust Fund, January 18, 1982 * American Home Finance Corp., April 9, 1981 * Richard Ellis, Inc., March 19, 1981 * Adams Express Company, September 20, 1979 * Merrill Lynch Capital Fund, Inc., February 7, 1978 * DJZ Associates, Nov. 19, 1975 * Lionel D. Edie Capital Fund, Inc., April 15, 1975 * Salomon Brothers, April 4, 1975 * Adams Express Company, September 9, 1974 * Mutual of Omaha Interest Shares, Inc., September 9, 1974 * MGIC Mortgage Corp., August 1, 1974 * Standard Shares, Inc., July 29, 1974 * Norman F. Swanton Associates, September 12, 1973 * Continental of Illinois (Delaware), Ltd., March 14, 1973 * Salomon Brothers, May 23, 1972 * State Street Bank and Trust Company, May 22, 1972 * MGIC Mortgage Corp., October 6, 1972 * State Street Bank and Trust Company, December 27, 1971 * Urban Land Investments, November 4, 1971 Last Reviewed or Updated: May 28, 2024 Return to top SEC homepage * ABOUT THE SEC * Budget & Performance * Careers * Commission Votes * Contact * Contracts * TRANSPARENCY * Accessibility & Disability * Diversity, Equity, Inclusion, & Accessibility * FOIA * Inspector General * No FEAR Act & EEO Data * Ombuds * WEBSITES * Investor.gov * Related Sites * USA.gov * SITE INFORMATION * Plain Writing * Privacy & Security * Site Map STAY CONNECTED. SIGN UP FOR EMAIL UPDATES. Your email address Sign Up * X * Facebook * RSS * YouTube * Email Updates