SEC Division of Investment Management staff letter: Welsh, Carson, Anderson & Stowe

The staff of the Division of Investment Management will not recommend enforcement action to the Commission if Welsh, Carson, Anderson & Stowe organizes and manages three new investment limited partnerships without registering them under the Investment Company Act of 1940, provided the aggregate number of limited partners across all funds exceeds one hundred. This no-action position applies provided the Institutional Fund, Healthcare Fund, and Information Fund are structured as separate entities with distinct investment strategies, investor bases, and operational constraints, such that a reasonable investor would regard the interests as materially different. The staff's conclusion is based on the specific facts and representations regarding the funds' segregation, including separate books, records, audits, and creditor protections, and does not constitute a legal opinion on the applicability of Section 3(c)(1) of the 1940 Act.

SEC published 7 documents in the last 30 days — get each new one by email the day it lands.

JUN1.~1~
Our -Ref-. No. 93-118-CC l'" ! Welsh, Carson,
RESPONSE OF THE OFFICE OF CHIEF COUNSEL Anderson & stowe DIVISION OF INVESTMENT MAAGEMENT File No. 132-3 Your letter of March 8, 1993, requests our assurance that we

not recommend enforcement action to the Commission if Welsh,

Carson, Anderson & Stowe ("WCAS") organizes and manages three new

investment limited partnerships (the "Funds") without registering

the Funds under the Investment Company Act of 1940 (the "1940

Actll) in reliance on section 3(c) (1) of the 1940 ~ct, if the

Read the rest free, and get an email when SEC publishes again

Email me when SEC publishes something newOne email per publication, same day. Sign in below to keep reading.

Lineage: In force

amendssupersedesissued underrefers toproposed or not in RegAlertarrows run from the older text to the one that changes it

Source: Securities and Exchange Commission — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works