1990-09-27
Added · Updated
The Division of Investment Management states it would not recommend enforcement action under Section 17f of the Investment Company Act of 1940 if registered investment companies utilize Delta Government Options Corp as a securities depository under Rule 17f-4. This relief covers the deposit of margin or cover for options contracts into accounts held in Delta's or its clearing bank's name at the investment company's custodian, subject to withdrawal only upon default. The Division notes that Delta issues options in uncertificated form, maintains central book-entry records, and treats options as fungible, while acknowledging that pledge procedures are being developed to comply with system integrity requirements.
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Delta Government Options Corp
127 John Street New York N.Y 10038 212 742-0270 Company Act of tion 17 and Rule Thomas Harman Esquire Chief Counsel Division of Investment Management Securities and Exchange Commission 450 Fifth Street N.W Washington D.C 20549 RE Delta Government Options Corp Supplementary NoAction Request to your Reference No 8966-CC File No 1323 Dear Mr Harman Counsel to Delta Government Options Corp Delta1 requested by letter dated February 1989 that the staff of the Division of Investment Management take four noaction positions with respect to participation by registered investment companies in Deltas over-the-counter options trading system the No-Action Request In letter dated July 21 1989 your Reference No 89-66-CC File No 132-3 you declined to take noaction position on three of the four issues presented and took noaction position on portion of the fourth issue the No-Action Reply In subsequent telephone discussion between you and certain members of your staff and our counsel you suggested that additional information might be relevant to further consideration of two of the three issues on which you declined to take noaction position Accordingly Delta hereby requests that you consider the following as supplementary submission with respect to the No-Action Request The defined terms used in this letter have the same meaning as set forth in the No-Action Request
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