RegAlert2002-09-10
Added · Updated
SEC Division of Investment Management staff letter: Manufacturers Adviser Corp
The Division of Investment Management will not recommend enforcement action against Manufacturers Adviser Corp, Manufacturers Investment Trust, Manufacturers Securities Services LLC, and Manulife Financial Securities LLC if their access persons do not report personal trading transactions in or holdings of certain Canadian mutual funds, or if Manufacturers Adviser Corp and Manufacturers Securities Services LLC do not maintain records of advisory representatives' transactions in those funds. This relief applies to Subject Canadian Mutual Funds that operate with operational similarities to U.S. open-end funds, specifically by issuing redeemable shares, calculating net asset value daily, and using forward-pricing principles consistent with Rule 22c-1 under the 1940 Act. The position relies on representations that there is no secondary market for these funds and that their pricing structure prevents the improper trading practices targeted by Section 17(j) of the 1940 Act and Section 204 of the Advisers Act.
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Manufacturers Adviser Corp
IM Ref. No. 2002991523 September 10, 2002
RESPONSE OF THE OFFICE OF CHIEF COUNSEL DIVISION OF INVESTMENT MANAGEMENT
Manufacturers Adviser Corp. File No. 801-21276 ____
By letter dated September 9, 2002, you seek our assurance that we would not recommend enforcement action to the Commission under Section 17(j) of the Investment Company Act of 1940 ("1940 Act") and Rule 17j-1 thereunder if, for purposes of the reporting requirements of Rule 17j-1, access persons, as defined in that rule, 1 of Manufacturers Adviser Corporation ("MAC"), Manufacturers Investment Trust ("Trust"), Manufacturers Securities Services, LLC ("MSS"), and Manulife Financial Securities LLC ("MFS") (collectively, the "Companies") do not report their personal trading transactions in and holdings of shares of certain Canadian mutual funds. 2 Similarly, you seek our assurance that we would not recommend enforcement action to the Commission under Section 204 of the Investment Advisers Act of 1940 ("Advisers Act") and Rule 204-2(a)(12) thereunder if, for purposes of the record-keeping requirements of Rule 204-2(a)(12), MAC and MSS do not make and keep records of the personal trading transactions involving shares of Subject Canadian Mutual Funds of their advisory representatives, as defined in that rule. 3
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