SEC Division of Investment Management staff letter: Stephen R. Kelly

The Division of Investment Management grants no-action relief to Stephen R. Kelly for operating a listing service for land contracts and mortgages without registering as an investment adviser. The relief applies provided the service lists all encumbrances with a minimum value of $50,000 regardless of interest rate, excludes disqualified persons, and presents listings alphabetically without investment advice. This modification removes the original requirement that encumbrances bear an interest rate of at least three points above the prime rate.

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MOV 2 9 1993

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RESPONSE OF THE OFFICE OF CHIEF COUNSEL Stephen R. Kelly

DIVISION OF INVESTMENT MANAGEMENT File No. 132-3

Your letter dated August 10, 1993 requests our assurance that we would not recommend enforcement action to the Commission under the Investment Advisers Act of 1940 (the "Advisers Act") if" Stephen R. Kelly operates a listing service for land contracts or mortgages ("encumbrances"), as described in your letter, without registering as an investment adviser. Mr. Kelly proposes to publish a newsletter that will list

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