SEC Division of Investment Management staff letter: Mark A. Bush

The SEC staff declined to provide a no-action position regarding Mark A. Bush's plan to establish three affiliated entities for investment-related businesses because the submission lacked sufficient information and legal analysis. The staff highlighted that Section 208(d) of the Investment Advisers Act prohibits indirect violations and warned that an unregistered adviser affiliated with a registered adviser may be integrated for registration purposes if not operated separately. The letter enclosed no-action responses applying this integration concept to different facts and releases on general procedures for requesting no-action letters.

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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON. D.C. 20549

DIVISION OF
INVESTMENT MANAGEMENT

August 8, 1995

Mark A. Bush
5443 Redwood Road
Columbus, OH 43229

Dear Mr. Bush:

I am writing in response to your letter dated June 5, 1995, in which you request a no-action position concerning your plan to set up three affiliated entities to engage in investment related businesses. One of these entities would register as an investment adviser under the Investment Advisers Act of 1940 ("Advisers Act"). The other two entities would remain unregistered.

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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