SEC Division of Investment Management staff letter: Columbia Funds Series Trust

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
INVESTMENT MANAGEMENT
October 22,2008
Stephen A. Keen
Reed Smith LLP
435 Sixth Avenue
Pittsburg, PA 1521 9-1 886
Re: Columbia Funds Series Trust- Columbia Money Market Reserves (File No. 8 1 1-09645) Dear Mr. Keen:
Your letter of October 3,2008 requests our assurance that we would not recommend that the Commission take any enforcement action under Sections 17(a)', 1 7(d12 and 1 2(d)(313 of the Investment Company Act of 1940 (the "Act"), and the rules thereunder, if Columbia Money Market Reserves (the "Fund"), a series of the Columbia Funds Series Trust (the "Trust), and N.B. Funding Company LLC (the "Affiliate"), enter into the arrangement summarized below and more fully described in the letter. The Affiliate is a subsidiary of Bank of America Corporation (the "Parent"), that is the parent of the Fund's investment adviser and, therefore, an affiliated person of the Fund as defined in Section 2(a)(3) of the Act. The Fund is an open-end management investment company that is registered with the Commission under the Act. The Fund is a money market fund that seeks to maintain a stable net 1 Section 17(a)(l) generally makes it unlawful for any affiliated person of a registered investment company, or an affiliated person of such person, acting as principal, to knowingly sell any security or other property to the registered investment company. 2 Section 17(d) generally makes it unlawful for any affiliated person of a registered investment company, or any affiliated person of such a person, acting as principal, to effect any transaction in which the registered investment company is a joint or joint and several participant with such person in contravention of rules and regulations adopted by the Commission. 3 Section 12(d)(3) generally makes it unlawful for any registered investment company to acquire any security issued by, or any interest in the business of, any broker-dealer, any person engaged in the business of underwriting, or an investment adviser of an investment company, or an investment adviser registered under the Investment Advisers Act of 1940.