RegAlert2001-11-06
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SEC Division of Investment Management staff letter: AIG Life Insurance Company - American International Life Assurance Company of New York
The staff of the Division of Investment Management will not recommend that the Commission take enforcement action under Section 26(c) of the Investment Company Act of 1940 against AIG Life Insurance Company and American International Life Assurance Company of New York for substituting Class B Alliance Portfolio shares with Class A Alliance Portfolio shares in their Separate Accounts without obtaining a Commission order. This substitution replaces shares with higher total expenses, including a 0.25% Rule 12b-1 fee, with shares of the same fund that are at least 25 basis points less expensive. The staff determined that the transaction does not involve the abuses Section 26(c) was designed to prevent, as contract owners retain the same investment adviser and objectives while benefiting from reduced costs.
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AIG Life Insurance Company - American International Life Assurance Company of New York
November 6, 2001
RESPONSE OF THE OFFICE OF INSURANCE PRODUCTS DIVISION OF INVESTMENT MANAGEMENT
AIG Life Insurance Company, et al .
By letter dated July 30, 2001, as supplemented by letter dated November 2, 2001, you request that the staff of the Division of Investment Management advise you that it will not recommend that the Commission take any enforcement action under Section 26(c) of the Investment Company Act of 1940 (the "Act") against AIG Life Insurance Company ("AIG"), with respect to its Variable Account I, or American International Life Assurance Company of New York ("American International"), with respect to its Variable Account A, if AIG and American International proceed with certain transactions without obtaining an order pursuant to Section 26(c) of the Act. The transactions involve replacing a class of fund shares with higher total expenses with a class of shares of the same fund with lower total expenses. I. Facts
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