RegAlert1993-07-29
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SEC Division of Investment Management staff letter: New America High Income Fund, Inc.
The Office of Chief Counsel states it will not recommend enforcement action to the Commission if New America High Income Fund, Inc. issues $100 million of Auction Term Preferred Stock in a single transaction to redeem $80 million of existing senior securities and increase leverage by $20 million. This non-enforcement assurance applies despite the Fund's temporary noncompliance with Section 18 asset coverage and senior security class limits during the simultaneous issuance and redemption process. The Fund must ensure its capital structure complies with all Section 18 requirements both before the offering and immediately after the redemption of the outstanding $80 million in senior securities is completed.
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JUL 29 1993
P 'BLJ -....# Our Ref. No. 93-408-CC The New America High RESPONSE OF THE OFFICE OF CHIEF COUNSEL Income Fund, Inc. DIVISION OF INVSTMENT MAAGEMENT File No. 811-5399 By letter dated July 7, 1993, you request our assurance that
we would not recommend that the Commission take any enforcement
action under Section 18 of the Investment Company Act of 1940
(the 111940 Actll) if the New America High Income Fund, Inc. (the IIFundll) issues $100 million of Auction Term Preferred Stock ("ATpii), $80 million of which will be used to redeem the Fund's outstanding senior securities. The Fund will use the additional
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