SEC Division of Investment Management staff letter: SEI Daily Income Trust - Prime Obligation Fund

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
INVESTMENT MANAGEMENT
November 18,2008
Timothy W. Levin
Morgan, Lewis & Bockius LLP

1701 Market Street

Philadelphia, PA 191 03-2921
Re: SEI Daily Income Trust- Prime Obligation Fund (File No. 8 1 1-0345 1) Dear Mr. Levin:
Your letter of November 5,2008 requests our assurance that we would not recommend that the Commission take any enforcement action under Sections 17(a)', 17(d12 and 12(d)(3)~ of the Investment Company Act of 1940 (the "Act"), and the rules thereunder, if the Prime Obligation Fund (the "Fund'), a series of SEI Daily Income Trust (the "Trust), and SEI Investments Company ("SEI"), enter into the arrangement summarized below and more fully described in the letter. SEI is the parent of the Trust's investment adviser, SEI Investments Management Corporation (the "Adviser") and, thus, is an affiliated person of the Fund as defined in Section 2(a)(3) of the Act. The Fund is an open-end management investment company that is registered with the Commission under the Act. The Fund is a money market fund that seeks to maintain a stable net 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.