RegAlert1995-02-28
Added · Updated
SEC Division of Investment Management staff letter: State Street Bank & Trust Company
The SEC staff confirms that omnibus account arrangements are permissible under Rule 17f-5 of the Investment Company Act of 1940. This interpretation applies to State Street Bank and Trust Company, which proposes to maintain customer securities in single accounts at foreign custodians rather than individual accounts. The staff concludes that such arrangements satisfy the rule's requirement for adequate records identifying assets as belonging to the investment company, provided the foreign custodian identifies assets on its books as held for the primary custodian and the primary custodian identifies specific customer ownership.
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FEB 2 8 1995
! PUBLLC Our Ref. No. 95-35-CC
State Street Bank &
"~ESPONSE OF THE OFFICE OF CHIEF COUNSEL Trus t Company
~IVISION OF INVESTMENT MAAGEMENT File No. 132-3
By letter dated January 16, 1995, you request that the staff
confirm that the use of "omnibus accounts" is permissible under
Rule 17f-5 under the Investment Company Act of 1940 (the
"Investment Company Act") .
State Street Bank and Trust Company ("State Street") is a
provider of custody services to the investment company industry.
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