RegAlert2015-06-16
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SEC Division of Investment Management staff letter: Jackson National Life
Jackson National Life Insurance Company and its affiliates request assurance that the SEC Staff will not recommend enforcement action if registration fees under Rule 24f-2 are calculated by excluding the net sales price of Master Fund shares from Divisions and Feeder Funds where fees have already been paid on those shares. This relief applies to a three-tiered structure involving Separate Accounts, Divisions, and Feeder Funds investing in Master Funds, aiming to prevent triple counting of registration fees on the same aggregate proceeds. The request is conditioned on specific representations, including that Divisions invest exclusively in corresponding Feeder Funds and that Feeder Funds invest at least 95% of their assets in corresponding Master Funds. Additionally, entities avoiding fees on specific securities cannot use redemptions of those securities to offset fees for other entities, and one entity must pay the fees excluded by the others.
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Stradley Ronon Stevens & Young, LLP STRADLEY 1250 Connecticut Avenue, N.W., Suite 500 Washington, DC 20036-2652 RONON Telephone 202.822.9611 Fax 202.822 .0140 ATTORNEYS AT LAW www.stradley.com Joan E. Boros, Esq. (202) 507-6413 Jboros@Stradley.com June 16, 2015 Via Electronic Mail Division ofInvestment Management United States Securities and Exchange Commission 100 F Street, N .E. Washington, DC 20549 Attn: Douglas J. Scheidt, Esq. Re: Request for No-Action Relief under Section 6(b) ofthe Securities Act of 1933,
Section 24(f)(2) of the Investment Company Act of 1940, and Rule 24f-2 thereunder
Introduction and Relief Requested
I am writing on behalf of Jackson National Life Insurance Company and Jackson National Life Insurance Company ofNew York (collectively referred to as "Jackson") to request your assurance that the staff of the Division ofInvestment Management (the "Staff') will not recommend that the Securities and Exchange Commission (the "Commission" or "SEC") take enforcement action under Section 6(b) of the Securities Act of 1933, as amended (the "1933 Act"), Section 24(f)(2) of the Investment Company Act of 1940 ("1940 Act"), or Rule 24f-2 thereunder, against any ofthe Requestors (defined below) if Rule 24f-2 registration fees are calculated and paid in the manner described below. Philadelphia, PA • Malvern, PA • New York, NY • Harrisburg, PA • Wilmington, DE • Cherry Hill, NJ • Washington, DC A Pennl)'lvanla LlmJttd Ll•bUity Partnership lifMERITAS LAW FIRMS WORLDWIDE
1387446 v. 1
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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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SEC published 7 documents in the last 30 days. We email you each new one the day it's published.