SEC Division of Investment Management staff letter: DFA Investment Trust Company

The Division of Investment Management states it will not recommend enforcement action to the Commission under Section 17(a) of the Investment Company Act of 1940 or Rule 17a-7 regarding the sale of portfolio securities by three tax-exempt group trusts to The DFA Investment Trust Company in exchange for shares of corresponding Series. The transaction involves Subtrusts selling securities to Series with identical investment objectives and policies at current net asset value, bypassing the Rule 17a-7(a) requirement that consideration be solely cash. The Division's position is based on the representations that the transaction complies with all other conditions of Rule 17a-7, including valuation methods, absence of brokerage commissions, and lack of beneficial interest by affiliated persons other than the common investment advisor. The Division further announces that it will no longer respond to requests for no-action relief in this area unless they present novel or unusual issues.

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:~ OCT I ì 1995

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Our Ref. No. 95-496-CC
The DFA Investment Trost
REPONSE OF TH OFFCE OF CHI COUNSEL Compay DIVSION OF INTM MAAGEM File No. 132-3 By letr date August 23, 1995, you reues ou assuce tht we would not remmend enforcment acon to the Comsion un seon 17(a) of the Invesent Company Act of 1940 ("Invesent ComplY Ac") or ni 17a-7 thereder 11 with

ret to the sae of portolio seti by'lh ta-exem gr tnst ("Group Trosts") '1/ to cert series of The DFA Invesent Trost Compay ("DFAIC"), a regire invesent company, in exchage for sha of thse series ("Series"), as
describe in your letr. . .....

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