RegAlert2008-02-28
Added · Updated
SEC Division of Investment Management staff letter: Northern Institutional Funds
The SEC Division of Investment Management will not recommend enforcement action under Sections 17(a)(1), 17(d), and 12(d)(3) of the Investment Company Act of 1940 if Northern Trust Corporation enters into Capital Support Agreements with Northern Institutional Funds and Northern Funds. These agreements obligate Northern Trust Corporation to make cash contributions to restore the net asset value of specific money market funds to a minimum permissible level if holdings in downgraded structured investment vehicles cause losses. The relief applies specifically to Northern Trust Corporation and the named Trusts, with the obligation to terminate upon the earlier of the maximum contribution amount being reached, the disposal of the affected notes, or July 31, 2008.
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
INVESTMENT MANAGEMENT
February 28,2008
Veena K. Jain
Drinker Biddle & Reath LLP
191 North Wacker Drive
Suite 3700
Chicago, IL 60606-1698
Re: Northern Institutional Funds- Diversified Assets Portfolio, Liquid Assets Portfolio and Prime Obligations Portfolio (File No. 8 1 1-03605) and Northern Funds- Money Market Fund (File No. 8 1 1-08236) Dear Ms. Jain:
Your letter of February 21,2008 requests our assurance that we would not recommend that the Commission take any enforcement action under Sections 17(a)(l)l, 17(d)~ and 12(d)(313 of the Investment Company Act of 1940 (the "Act") if Northern Institutional Funds and Northern Funds (each a "Trust" and together, the "Trusts") and Northern Trust Corporation ( "NTC") enter into the arrangement summarized below and more fully described in the letter. NTC is the indirect parent of the Trusts' investment adviser, Northern Trust Investments, N.A. (the "Adviser"). 1 Section 17(a)(l) generally makes it unlawful for any affiliated person of a registered investment company, or an affiliated person of such person, acting as principal, to knowingly sell any security or other property to the registered investment company. 2 Section 17(d) generally makes it unlawful for any affiliated person of a registered investment company, or any affiliated person of such a person, acting as principal to effect any transaction in which the registered investment company is a joint or joint and several participant with such person in contravention of rules and regulations adopted by the Commission. 3 Section 12(d)(3) generally makes it unlawful for any registered investment company to acquire any security issued by, or any interest in the business of, any broker-dealer, any person engaged in the business of underwriting, or an investment adviser of an investment company, or an investment adviser registered under the Investment Advisers Act of 1940.
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