RegAlert1997-04-29
Added · Updated
SEC Division of Investment Management staff letter: Puerto Rico Balanced Fund, Inc.
The Division of Investment Management agrees not to recommend enforcement action if Puerto Rico Balanced Fund, Inc. relies on Section 6(a)(1) of the Investment Company Act of 1940 to exempt itself from registration. This exemption applies despite the Fund retaining United States sub-advisers, investing in securities of non-Puerto Rico issuers, and engaging in hedging transactions with non-Puerto Rico counterparties. The Fund must ensure its securities are offered and sold only to residents of Puerto Rico, and the staff considers the totality of the Fund's contacts with Puerto Rico rather than any single factor to determine its principal place of business.
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Puerto Rico Balanced
RESPONSE OF THE OFFICE OF CHIEF COUNSEL Fund, Inc. DIVISION OF INVSTMNT MAAGEMENT File No. 132 -3
By letter dated January 10, 1997, you seek assurance that
the staff will not recommend enforcement action to the Commission
if the Puerto Rico Balanced Fund, Inc. (the "Fund") does not
register under the Investment Company Act of 1940 (the
"Investment Company Act") in reliance on Section 6 (a) (1) of the
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