1997-07-23
Added · Updated
The staff of the Division of Investment Management will not recommend enforcement action to the Commission under Section 15(a) of the Investment Company Act of 1940 if the Franklin Templeton Group of Funds amend their investment management agreements without shareholder approval. This relief permits the removal of fund administration responsibilities from existing agreements and their transfer to separate administration agreements with affiliated administrators. The staff bases this position on representations that the total combined fees will not exceed current levels, the nature and level of services will remain unchanged, and the same personnel will perform the administration services.
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JUL 2 3 1997
Our Ref. No. 97-240
Franklin Templeton
RESPONSE OF THE OFFICE OF CHIEF COUNSEL
Group of Funds
DIVISION OF INVSTMNT MAAGEMNT File Nos. 811-730. et al.
Your letter of July 16, 1997 requests our assurance that the
staff will not recommend enforcement action to the Commission
under Section 15(a) ,of the Investment Company Act of 1940 if certain funds (the "Funds") advised by Franklin Advisers, Inc.,
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