RegAlert1994-04-28
Added · Updated
SEC Division of Investment Management staff letter: Long-Term Capital Management, L.P.
The Division of Investment Management will not recommend enforcement action if Long-Term Capital Management, L.P. excludes holders of involuntary and non-contributory beneficial interests in trusts from the count of outstanding securities under Section 3(c)(1)(A) of the Investment Company Act of 1940. This exclusion applies to trusts formed by LTCM principals for estate and charitable planning that invest in Section 3(c)(1) companies, provided the beneficiaries do not elect to participate, contribute assets, or direct investment decisions. The staff bases this position on the rationale that such interests are not securities, citing precedents regarding involuntary, non-contributory pension plans.
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28 APR 1994
Our Ref. No. 94-49-CC
Long-Term capital
RESPONSE OF THE OFFICE OF CHIEF COUNSEL Management, L. P.
DIVISION OF INVESTMENT MAAGEMENT File No. 132-3 Your letter of January 24, 1994, requests our assurance that
we would not recommend enforcement action to the Commission if
Long-Term Cap i tal Management, L. P. ( "LTCM" ) does not treat
certain holders of involuntary and non-contributory beneficial
interests in trusts which are formed by LTCM' s principals and
invest in entities relying on section 3 (c) (1) as holders of
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