RegAlert1994-08-10
Added · Updated
SEC Division of Investment Management staff letter: W.R. Huff Asset Management Co., L.P.
The Office of the Chief Counsel, Division of Investment Management, will not recommend enforcement action to the Commission under Rule 204-2(a)(12) of the Investment Advisers Act of 1940 if W.R. Huff Asset Management Co., L.P. does not maintain records of securities transactions for its Outside Limited Partners. This relief applies to limited partners who own, hold, or control less than five percent of the partnership interests and do not participate in formulating investment decisions or receive advance information regarding investment decisions or trading activities. The Division determined that treating these passive investors as advisory representatives would not further the rule's purpose of preventing scalping, aligning their treatment with that of non-controlling shareholders under the Investment Company Act of 1940.
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10 AUG 1994
P "B l' Our Ref. No. 93-172-CC
W.R. Huff Asset
RESPONSE OF THE OFFICE OF CHIEF COUNSEL Management Co., L. P. DIVI SION OF INVESTMENT MANAGEMENT File No. 801-32541 Your letter of May 26, 1994 requests our assurance that we
would not recommend enforcement action to the Commission under
the Investment Advisers Act of 1940 ("Advisers Act") if W.R. Huff
Asset Management Co., L. P. ( "WRH"), a registered investment
adviser, does not treat certain of its limited partners as
advisory representatives for purposes of the recordkeeping
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