SEC Division of Investment Management staff letter: Robertson, Stephens & Company

The SEC Division of Investment Management staff states it would not recommend enforcement action against Robertson, Stephens & Company if it implements a custodial receipt program for cumulative convertible preferred stock without registering as an investment company. This no-action position applies provided that receipts represent entire ownership interests, holders can withdraw underlying shares at any time, and the custodian performs only ministerial duties. The staff's conclusion relies on specific representations regarding holder rights, default procedures, and the non-discretionary nature of the custodian's role.

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Our Ref. No. 92-669-CC

Robertson, Stephens &
RESPONSE OF THE OFFICE OF CHIEF COUNSEL Company DIVISION OF INVESTMENT MAAGEMENT File No. 8-23192 By letter dated January 8, 1993, you request assurance that

the staff would not recommend enforcement action to the

Commission under the Investment Company Act of 1940 (the "1940

Act") if, as more fully described in your letter, Robertson,

Stephens & Company ("Robertson Stephens") implements a custodial

receipt program involving cumulative convertible preferred stock

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Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works