RegAlert1997-07-01
Added · Updated
SEC Division of Investment Management staff letter: ABN AMRO Bank N.V.
The staff will not recommend enforcement action against ABN AMO Bank N.V. or its unregistered affiliates if they do not register under the Investment Advisers Act of 1940, provided they share certain personnel with and provide services to ABN AMO Asset Management (USA) Inc., a registered investment adviser. This relief applies if the entities comply with specific representations regarding recordkeeping, client communications, and the treatment of shared personnel as associated persons. Additionally, the staff will not recommend enforcement against these entities for providing investment advisory services to non-U.S. residents solely in accordance with foreign law, provided such activities do not involve conduct or effects within the United States.
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. . m¡';...~ ~.'il :~¡¡;;. iii,)l:i' ~tl ,',.,,;;;1 iI ur Ref. No. 97-39-CC ~ PULIO . N AMO BanN.V.; . VAll, AliIL MN AMO Asset Management (USA) Inc.; ABN AMO Asset Management REPONSE OF TH OFFICE OF CID COUNSEL (Far East) Limted DIVSION OF INTM MANAGEM File No. 132-3 Y Ol,ir letter dated March 7, 1997 requests our assurace that we wil not recommend enforcement action to thy Commission if neither ABN AMO Ban N. V. (" ABN AMO Ban"), nor cert of its afiltes, register under the Investment Advisers Act of 1940 (the
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