RegAlert2003-07-03
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SEC Division of Investment Management staff letter: Dougherty & Company LCC
The document establishes that the SEC will not recommend enforcement action against investment advisers paying cash solicitation fees to solicitors subject to Disqualifying Orders, provided the solicitor is not barred or suspended, has complied with all order terms, and discloses the order in writing to solicited persons within ten years of the order's entry. Disclosure must occur at least 48 hours before contract execution, or at execution if a five-day penalty-free termination right exists. The letter also specifies that case-by-case no-action relief remains available for solicitors barred from acting, those with recent relevant felony or misdemeanor convictions, or those subject to specific orders not covered by the standard Disqualifying Order definition.
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Effective November 4, 2022, This Letter is Withdrawn. Please consult the following web page for more information: https://www.sec.gov/divisions/investment/im-modified-withdrawn-staff-statements .
Dougherty & Company LCC, Mr. Thomas Abood
July 3, 2003
Response of the Senior Counsel Division of Investment Management
Mr. Thomas J. Abood Dougherty & Company LLC 90 South Seventh Street, Suite 4400 Minneapolis, Minnesota 55402-4115
Dear Mr. Abood:
By letter dated March 21, 2003, we advised you that we would not recommend enforcement action to the Commission under section 206(4) of the Investment Advisers Act of 1940 (the "Advisers Act") and rule 206(4)-3 thereunder if any investment adviser that is required to be registered pursuant to section 203 of the Advisers Act paid Dougherty & Company LLC ("Dougherty") or any of its associated persons a cash fee, directly or indirectly, for the solicitation of advisory clients in accordance with the rule, notwithstanding two Commission administrative orders that otherwise would preclude the investment adviser from paying Dougherty such a fee (the "Dougherty letter"). 1 Our position in that letter was based upon, among other things, your representation that:
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Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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