2001-05-14

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SEC Division of Investment Management staff letter: Current Income Shares, Inc.

Current Income Shares, Inc. requests no-action relief to omit a shareholder proposal from its proxy materials under Rule 14a-8(i)(10), asserting the proposal has been substantially implemented. The proposal recommended merging the closed-end fund into the open-end HighMark Bond Fund to allow share redemption at net asset value. The fund argues it substantially implemented the proposal by having its Board request a merger from investment adviser HighMark Capital Management, which subsequently declined to pursue the transaction. Shareholder Walter Baer opposes the omission, arguing the adviser's refusal was based on its own financial interests rather than shareholder value and that a shareholder vote could persuade the adviser to reconsider.

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Securities Exchange Act of 19341934Investment Company Act of 19401940SEC Division of InvestmentManagement staff letter: Curr…2001-05-14 · this document
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