1996-02-02

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SEC Division of Investment Management staff letter: Lazard Freres Asset Management

The SEC staff will not recommend enforcement action if Lazard Freres Asset Management charges a performance fee to BPI Capital Management Corporation for services provided to the BPI Global Opportunities Fund. The staff determined that the Fund, rather than BPI Capital, is the client of Lazard Freres for purposes of Rule 205-3 under the Investment Advisers Act of 1940. This determination allows the proposed compensation structure, consisting of a base fee and a performance fee equal to 10% of net income in excess of a 10% time-weighted return, to comply with the rule's eligibility requirements.

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Investment Advisers Act of 19401940SEC Division of InvestmentManagement staff letter: Laza…1996-02-02 · this document
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