RegAlert2008-10-20
Added · Updated
SEC Division of Investment Management staff letter: Sun Capital Advisers Trust
The Division of Investment Management will not recommend enforcement action under Sections 17(a), 17(d), and 12(d)(3) of the Investment Company Act of 1940 if Sun Capital Money Market Fund and Sun Life Assurance Company of Canada (US) enter into a capital support agreement. The agreement allows Sun Life to make cash contributions to the Fund, up to $4.7 million, to offset losses on commercial paper from American General Finance Corporation, thereby maintaining the Fund's net asset value at $1.00 per share. Sun Life must fund these contributions via a segregated account with a qualified custodian, and the Fund must sell the affected securities promptly before the agreement's expiration. This relief applies exclusively to the entities named in the letter and does not constitute a general legal conclusion or allow reliance by other funds.
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UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
INVESTMENT MANAGEMENT
October 20, 2008
Christopher P. Harvey
WilmerHale
60 State Street
Boston, MA 02019
Re: Sun Capital Advisers Trust-Sun Capital Money Market Fund (File No. 811-08879) Dear Mr. Harvey:
Your letter of September 17, 2008 requests our assurance that we would not recommend that the Commission take any enforcement action under Sections 17(a)1 , 17(di and 12(d)(3)3 of the Investment Company Act of 1940 (the "Act"), and the rules thereunder, if Sun Capital Money Market Fund (the "Fund"), a separate series of Sun Capital Advisers Trust (the "Trust"), and Sun Life Assurance Company ofCanada (US) ("Sun Life") enter into the arrangement summarized below and more fully described in the letter. Sun Life is under common control with the Fund's investment adviser, Sun Capital Advisers LLC ("Sun Capital") and, therefore, is an affiliated person of an affiliated person ofthe Fund as defined in Section 2(a)(3) ofthe Act. The Trust 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 2
Section 17(a)(l) generally makes it unlawful for any affiliated person of a registered investment
company, or an affiliated person ofsuch person, acting as principal, to knowingly sell any security or other property to the registered investment company.
Section 17(d) generally makes it unlawful for any affiliated person of a registered investment
company, or any affiliated person ofsuch 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 ofrules and regulations adopted by the Commission.
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 ofunderwriting, or an investment adviser of an investment company, or an investment adviser registered under the Investment Advisers Act of 1940.
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