SEC Division of Corporation Finance no-action letter: Emeriti Consortium for Retirement Health Solutions

The Divisions of Corporation Finance and Investment Management will not recommend enforcement action if an Employee-Contribution VEBA offers and sells Participation Interests without registration under the Securities Act of 1933 or the Securities Exchange Act of 1934, and if the VEBA does not register as an investment company under the Investment Company Act of 1940. This relief applies to the Emeriti Consortium for Retirement Health Solutions based on the specific representations regarding the Program's structure, funding, and administrative arrangements. The response is limited to enforcement positions and does not constitute a legal conclusion on the questions presented.

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Securities Exchange Act of 1934 — Section 12(g) Investment Company Act of 1940 — Section 7

April 7, 2005

Response of the Office of Chief Counsel Division of Corporation Finance

Response of the Office of Chief Counsel Division of Investment Management

Re:

Emeriti Consortium for Retirement Health Solutions Incoming letter dated April 5, 2005

Based on the facts presented, the views of the Division of Corporation Finance and the Division of Investment Management (the "Divisions") are set forth below. Capitalized terms have the same meanings set forth in your letter.

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Lineage: In force

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Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works