SEC Division of Investment Management staff letter: CenturyLink Investment Management Company

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David J. Baum
VIA EMAIL
The Atlantic Building
950 F Street, NW
Washington, OC 20004-1404
202-239-3300
Fax: 202-654-4946 www.alston.com
Direct Dial: 202-239-3346
Division of Investment Management
I 00 F Street, N.E.
Washington, D.C. 20549-0504
Email: david.baum@alston.com
Attention: Douglas J. Scheidt, Esq., Associate Director and Chief Counsel Re: Request for No-Action Assurance Dear Mr. Scheidt:
We are writing on behalf of CenturyLink Investment Management Company ("Adviser"), a corporation organized under the laws of the State of Colorado. Adviser 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 Adviser withdraws its registration with the Commission as an investment adviser under the Advisers Act. Based on the Staffs prior positions, we do not believe that Adviser is in the business of "advising others." Facts Adviser is an indirect wholly-owned subsidiary of CenturyLink, Inc. ("CenturyLink"), a large telecommunications firm. Adviser is currently registered as an investment adviser with the Commission, however, it would like to withdraw its registration. We believe that Adviser would comply with the representations of the Lockheed Martin Investment Management Co. no action letter ("Lockheed Letter"), 1 described below, permitting registration withdrawal except for the fact that Adviser also advises a charitable foundation. Adviser, incorporated in 1995, is the named fiduciary for the management and investment of assets held in trust under the employee benefit plans sponsored by 1 See Lockheed Martin Investment Management Co., SEC Staff No-Action Letter (Jun. 5, 2006). Atlanta• Beijing• Brussels• Charlotte• Dallas• Los Angeles • New York• Research Triangle• Silicon Valley• Washington, D.C.