RegAlert1996-05-17
Added · Updated
SEC Division of Investment Management staff letter: Munder Capital Management
The Division of Investment Management states it would not recommend enforcement action against Munder Capital Management and The Munder Funds under Rule 206(4)-1 of the Investment Advisers Act of 1940 for making portfolio transaction information available via the Internet. The information, updated monthly and released at least 15 days after month-end, details all positions added or eliminated and includes commentary on the rationale for trades, accompanied by disclaimers stating it is not a recommendation to buy or sell. The Division concluded this disclosure constitutes investment company sales literature rather than an advertisement for advisory services, thereby falling outside the scope of the rule's prohibitions on selective disclosure of profitable recommendations. This response is based on the specific facts and representations provided in the February 9, 1996 letter.
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Our Ref. No. 96-77-CC'
Munder Capital
RESPONSE OF THE OFFICE OF CHIEF COUNSEL Managemen t
DIVISION OF INVESTMNT MAAGEMENT File No. 801-48394
Your letter of February 9, 1996 requests our assurance that
we would not recommend enforcement action to the Commission under
Rule 206 (4) -1 under the Investment Advisers Act of 1940 (IIAdvisers Actll) 1./ if the registered open-end management
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