RegAlert2012-05-25
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SEC Division of Investment Management staff letter: Allianz of America, Inc.
The SEC Division of Investment Management staff states it will not recommend enforcement action under Section 203(a) of the Investment Advisers Act of 1940 if Allianz of America, Inc. (AZOA) does not register as an investment adviser. This assurance applies because AZOA provides investment advisory services solely to the Allianz Group and its direct and indirect wholly-owned subsidiaries, rather than to "others" as defined by the Act. The staff's position relies on AZOA not holding itself out to the public and receiving no investment directives from third parties or insureds.
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ROPES & GRAY LLP
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May 25, 2012 Brian D. McCabe
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VIA EMAIL brian.mccabe@ropesgray.com
Division oflnvestment Management
Securities and Exchange Commission
100 F Street, N .E.
Washington, D.C. 20549-0504
Attention: Douglas J. Scheidt, Esq., Associate Director and Chief Counsel Re: Request for No-Action Assurance Ladies and Gentlemen:
We are writing on behalf of Allianz of America, Lnc. ("AZOA "), a corporation organized under the laws ofthe State of Delaware. AZOA seeks assurance from the staff of the Division of Investment Management (the "Staff') that it will not recommend enforcement action to the U.S. Securities and Exchange Commission (the "Commission") under
Section 203(a) of the Investment Advisers Act of 1940, as amended (the "Advisers Act"), if AZOA does not register
with the Commission as an investment adviser under the Advisers Act.
Based on the Staffs prior positions, we do not believe that AZOA is in the business of "advising others." Factual Background AZOA is a wholly-owned subsidiary of Allianz SE, a German Societas Europaea that provides financial services,
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