RegAlert2005-05-13
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SEC Division of Investment Management staff letter: Principal Investors Fund Inc.
The Office of Chief Counsel of the Division of Investment Management states it would not recommend enforcement action to the Commission under Sections 12(d)(1)(A)(i) and (iii) of the Investment Company Act of 1940 against Chilean Pension Plans if they invest in any series of the Principal Investors Fund in excess of the statutory limits. Additionally, the staff would not recommend enforcement action under Section 12(d)(1)(B) against the Principal Investors Fund or Princor Financial Services Corporation if they sell Fund shares to these plans in excess of the limitations imposed by that section. The staff agrees that each series of the series investment company is a separate investment company for purposes of the limitations set forth in Section 12(d)(1)(B).
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May 13, 2005
RESPONSE OF THE OFFICE OF CHIEF COUNSEL DIVISION OF INVESTMENT MANAGEMENT
Our Ref. No. 20051191521 Principal Investors Fund Inc. Princor Financial Svcs. Corp. File Nos. 811-07572 8-13975
In your letter dated December 17, 2004, 1 you request our assurance that we would not recommend enforcement action to the Commission under Sections 12(d)(1)(A)(i) and (iii) of the Investment Company Act of 1940 (the "1940 Act") against Chilean Pension Plans, as defined below, if they invest in any series (each a "Fund") of the Principal Investors Fund, Inc. (the "Principal Investors Fund") in excess of the limits imposed by those sections. In addition, you request our assurance that we would not recommend enforcement action to the Commission under Section 12(d)(1)(B) of the 1940 Act against the Principal Investors Fund, or Princor Financial Services Corporation ("Princor"), if a Fund, or Princor, sells Fund shares to the Chilean Pension Plans in excess of the limitations imposed by that section.
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