RegAlert1995-10-20
Added · Updated
SEC Division of Investment Management staff letter: Colonial Trust I et al.
The staff of the Division of Investment Management confirms that Ms. Lora Collins will not be considered an "interested person" of the Colonial Companies under Section 2(a)(19) of the Investment Company Act of 1940 if she rejoins the law firm Kramer Levin as an employee. This determination relies on the conclusion that Ms. Collins would not be an "employee" of Mr. Meyer Eisenberg, a firm counsel who previously provided legal services to the Colonial Management, because he lacks the authority to hire, dismiss, or control her work. Consequently, the staff will not recommend enforcement action against the Colonial Companies based on Ms. Collins' status under Section 2(a)(19).
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OCT 2 0 192J
Our Ref. No. 95-CC-480
RESPONSE OF THE OFFICE OF CHIEF COUNSEL Colonial Trust I et al. DIVISION OF INVESTMNT MAAGEMENT File No. 801-2019 Your letter of September 21, 1995 requests that the staff
confirm your view that Ms. Lora Collins, a trustee of several
registered investment companies advised by Colonial Management
Associates, Inc., ("Colonial Management"), i will not be
considered an "interested person" within the meaning of section
2 (a) (19) of the Investment Company Act of 1940 (the "Act") of those investment companies, Colonial Management, Colonial
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