SEC Division of Investment Management staff letter: Fidelity Advisor Korea Fund, Inc.

The SEC staff will not recommend enforcement action against Fidelity Advisor Series VIII if it imposes a 4% redemption fee on Reorganization Class A shares redeemed or exchanged fewer than 200 days after the fund's conversion from closed-end to open-end status. This limited exception applies because the fee is reasonably related to anticipated portfolio and administrative costs arising from expected short-term trading by arbitrageurs in an emerging market context. The fee must be paid directly to the New Fund and is restricted to the specific period following the reorganization completed on June 30, 2000.

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Fidelity Advisor Korea Fund, Inc

March 7, 2001

RESPONSE OF THE OFFICE OF CHIEF COUNSEL DIVISION OF INVESTMENT MANAGEMENT

Our Ref. No. 00-511167 File No. 811-8608

Your letter dated February 22, 2001 requests our assurance that we would not recommend enforcement action to the Commission under Section 34(b), Section l8(f)(1), or Section 11 (a) of the Investment Company Act of 1940 (the "Act") or Rule lla-3 under the Act, if, upon the reorganization of the Fidelity Advisor Korea Fund, Inc. (the "Fund"), a closed-end investment company, into an open-end series (the "New Fund") of Fidelity Advisor Series VIII, the New Fund imposes a 4% redemption fee on shares that it issues to Fund shareholders in exchange for their Fund shares and that are redeemed or exchanged out of the New Fund fewer than 200 calendar days after the reorganization (the "4% Redemption Fee"). 1

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