RegAlert1995-12-27
Added · Updated
SEC Division of Investment Management staff letter: The Standish Ayer & Wood Inc. Stable Value Group Trust
The staff of the Division of Investment Management will not recommend enforcement action if a participant-directed defined contribution plan is treated as the single beneficial owner of units in the Standish Ayer Wood Inc Stable Value Group Trust for purposes of Section 3(c)(1) of the Investment Company Act of 1940. This determination applies provided that the plan fiduciary, rather than participants, makes all investment decisions regarding the fund, the generic investment option holds at least 50% of its assets in securities other than the fund units, and no representations are made to participants that specific contributions will be invested in the fund. The staff's position relies on eligibility criteria ensuring the fund is not managed to facilitate individual participant investment decisions, distinguishing the arrangement from the PanAgora Group Trust precedent.
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ROPES GRAY
ONE INTERNATIONAL PLACE
ONE rRANKLIN SQUARE
BOSTON MASSACH USETTS 02110-2624 I3 STREET
30 KENNEDY PLAZA 617 951-7000 SUITE 800 EAST
PROVIDENCE RI 02903-2328 WASHINGTON DC 20005-3333 40 455-4400 FAX 617 951-7050 202 626-3900 FAX 401 455-4401 WRITERS DIRECT DIAL NUMBER 95 7400 FAx 202 626-3961 December 27 1995 Jack Murphy Esq Associate Director Chief Counsel ACT Division of Investment Management SECTION Securities and Exchange Commission 450 Fifth Street N.W RULE Washington DC 20549 AVAILABILITY_1 Re The Standish Ayer Wood Inc Stable Value Group Trust Dear Mr Murphy On behalf of our client Standish Ayer Wood Inc Standish we respectfully request that the staff of the Division of Investment Management concur with our interpretation of Section 3c1 under the Investment Company Act of 1940 as amended the 1940 Act as it applies to the proposed activities described below Facts The Standish Ayer Wood Inc Stable Value Group Trust the Trust is being established by Standish and State Street Bank and Trust Company State Street as collective investment vehicle for tax-qualified pension and profit-sharing trusts and certain governmental retirement plans The Trust which will be organized as so-called group trust will be tax exempt by virtue of satisfying the requirements of Revenue Ruling 1-100 Standish which is registered as an investment adviser under the Investment Advisers Act of 1940 as amended will serve as the Trusts investment manager and State Street will serve as the Trusts directed Trustee It is expected that pursuant to the Trusts Agreement of Trust one or more separate investment funds each with its own investment objectives and policies may be established
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