RegAlert1994-09-15
Added · Updated
SEC Division of Investment Management staff letter: Pershing Division of Donaldson, Lufkin & Jenrette Securities Corp.
The Division of Investment Management states it would not recommend enforcement action if Pershing/DLJ includes disclosure about its PEAK II mutual fund asset allocation program in the wrap fee brochure required for its PEAK I wrap fee program. This combined brochure may be provided to clients of both programs in lieu of Part II of Form ADV. The staff's position is based on the facts that PEAK II is not defined as a wrap fee program under rule 204-3(q)(4) and that combining disclosures may be helpful to investors.
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UNITED STATES PUBLIC
SECURITIES AND EXCHANGE CO*~ q /s- /t'f WASHINGTON. D.C. 20549 DIVISION OF INVESTMENT MANAGEMENT September 15, 1994
Michael D. Udoff, Esq.
Vice President
Pershinq Division of Donaldson, Lufkin & Jenrette
Securi ties Corp.
One Pershinq Plaza
Jersey City, NJ 07399
Dear Mr. Udoff:
Your letter of Auqust 12, 1994 reqests assurance that the Division of Investant Manaqement would not recomend enforcement action to the Coaiasion if the Perahinq Division of Donaldson, Lufkin & Jenrette Securities Corpration ("Pershinq/DLJ") includes in the disclosure documnt reqired to be provided to clients and prospective clients of the wrap fee program that it sponsors (the "wrap fee brochure") information about another advisory proqram sponsored by Pershinq/DLJ, and provides the wrap fee brochure to clients of both the wrap fee program and the other program in lieu of Part II of DLJ' s Form ADV. Accordinq to your letter, Pershinq/DLJ is the sponsor of,
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