SEC Division of Investment Management staff letter: Lockheed Martin Investment Management Company

The Division of Investment Management states it will not recommend enforcement action against Lockheed Martin Investment Management Company (LMIMCo) under Section 203(a) of the Investment Advisers Act of 1940 following LMIMCo's withdrawal of its investment adviser registration. This assurance applies because LMIMCo is a wholly owned subsidiary of Lockheed Martin Corporation that provides advisory services exclusively to Lockheed's employee benefit plans, does not hold itself out to the public, and receives only ERISA-compliant reimbursements for direct costs. The decision relies on representations that LMIMCo has no separate financial operations or personnel, manages assets solely for Lockheed and its affiliates, and that none of the plans are required to register as investment companies.

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Investment Advisers Act of 1940 – Section 203(a) Lockheed Martin Investment Management Company June 5, 2006 Our Ref. No. 20052292 Lockheed Martin Investment RESPONSE OF THE OFFICE OF CHIEF COUNSEL Management Company DIVISION OF INVESTMENT MANAGEMENT File No. 801-56611

Your letter dated May 5, 2006 requests our written assurance that we would not recommend enforcement action against Lockheed Martin Investment Management Company (“LMIMCo”) under section 203(a) of the Investment Advisers Act of 1940 (“Advisers Act”) as a result of LMIMCo’s withdrawal of its registration as an investment adviser under the Advisers Act.1 LMIMCo is a wholly owned subsidiary of Lockheed Martin Corporation (“Lockheed”) whose sole purpose is to provide investment advisory services to various employee benefit plans and trusts of Lockheed and certain of its affiliates (the “LMC Plans”).2

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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