SEC Division of Investment Management staff letter: Industrial Alliance, Investment Management Inc.

Industrial Alliance, Investment Management Inc. requests assurance that the SEC staff will not recommend enforcement action if it does not register as an investment adviser under the Investment Advisers Act of 1940. The firm argues it should be exempt because its only U.S. clients are insurance companies, which are exempt under Section 203(b)(2), and its foreign clients should not trigger registration requirements for a foreign adviser with no U.S. place of business. The letter asserts that the costs of registration and compliance would substantially outweigh the benefits given the lack of U.S. regulatory interest in the firm's foreign activities.

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EDWARDS WIlDMAN PALMER UP
111 HUNTINGTON AVENUE
BOSTON, MA 02199
+16172390100 moin +1617227.:1420 fox
EDWARDS
WILDMAN edwordswildmon.com
Matthew C, Dallett
617.239.0303 fax 866.955,8690
mdallett@cdwardswildman.com
Investment Advisers Act §§203(a), 203(b)(2)
VIA EMAIL AND OVERNIGHT COURIER
Securities and Exchange Commission
Division ofInvestment Management
Attn: Douglas 1. Scheidt, Esq" Associate Director and Chief Counsel 1 00 F Street, N,E, Washington, D,C, 20549-0504 Re: Industrial Alliance, Investment Management Inc,

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