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No-Action Letters

No-Action Letters Listed by Date of Issuance

2008

Blue Source Investment Company, LP, Blue Source, LLC & Blue Source CO2 Company, LLC, File #B00781846, September 8, 2008

Artisan Group, File # B00720551, February 28, 2008

2007

Merrill Lynch Client Transition Program, File #B00694707, September 19, 2007

Advanta Corp., File #B00662714, May 24, 2007

Enterprise Engineering Group, File #B00657514, April 30, 2007

Education CRA Management and Education CRA Fund, LLC, File #B00646867, January 24, 2007

2006

Graybar Electric Company, Inc., File #B00628329, October 31, 2006

Sun American Bancorp Inc., File #B00587353, May 3, 2006

IDA Management Services, Inc., File # B00586482, February 17, 2006

2005

Jameson Inns, Inc., File # B00499720, January 21, 2005

2004

Allstate Bank, File # B00310193, July 12, 2004

Getty Realty Corp., File # B00449293, April 20, 2004

2003

State Farm Financial Services, F.S.B., File # B00221793, December 2, 2003

Tuition Plan Consortium, LLC, File # B00388089, July 22, 2003

People's Utah Bancorp, File # B00381602, April 17, 2003

2002

Republic Engineered Products LLC, File # B00354627, December 9, 2002

2001

CBOT Holdings, Inc., File # B00301028, December 12, 2001

Anthem Insurance Companies, Inc., File # B00268177, June 6, 2001

Collins/Bay Island Securities LLC, File # B00262834, June 5, 2001

TruServ Corporation, File # B00265525, May 24, 2001

Principal Financial Group, Inc., File # B00263159, May 10, 2001

2000

Phoenix Home Life Mutual Insurance Company, File # B00233311, December 15, 2000

Prudential Insurance Company of America, File # B00232479, December 14, 2000

VelocityHSI, Inc., File # B00207324, July 21, 2000

Zap.Com Corporation, File # B00179478, February 16, 2000

1999

Metropolitan Life Insurance Company, File # B00138255, July 22, 1999

John Hancock Mutual Life Insurance Company, File # B00136422, July 6, 1999

Canada Life Assurance Company, File # B00125606, May 18, 1999

Sun Life Assurance Company, File # B00125580, May 12, 1999

Tender Loving Care Health Care Services. Inc., File # B00122265, April 20, 1999

The Manufacturers Life Insurance Company, File # B00115570, March 22, 1999

Cattle Management Program, File # B00112437, February 25, 1999

1998

Park Place Entertainment Corporation, File # B00099827, December 31, 1998

Excel Realty Trust, Inc., File # B00086255, September 25, 1998

Internet Stock & Securities Exchange, File # B00083915, September 9, 1998

Gruntal & Co., LLC, File # B00073840, July 13, 1998

Clear Sky, File # B00047333, March 26, 1998

Equitable Financial Services, Inc., File # B00045331, February 9, 1998

Excel Legacy Corporation, File # B00042146, February 9, 1998

1997

David H. Miner, File # B00028834, November 14, 1997 (Letter not available)

Alcatel Alsthom Compagnie General d'Electricite, S.A., File # B00025974, October 30, 1997

Utah Valley Physicians Network, L.L.C., File # B00014664, September 29, 1997

Culbro Corporation, File # B00002223, June 5, 1997

Professional Veterinary Products, Inc., File # A60850-50, April 29, 1997

Capital Funding & Financial Group and kidZtime TV, File # A58753-50, April 10, 1997 - Rescinded October 8, 2004

1996

Virginia Higher Education Tuition Trust, File # A56500-47, October 10, 1996

Lloyd's, File # A56585-49, September 25, 1996

Towne Bancorp, Inc., File # A56302-47, September 24, 1996

Madison Mortgage, Inc., File # A55928-47, August 14, 1996

Firstar Trust Company, File # A55682-47, August 12, 1996

Westmed Physician Network, Inc., File # A54673-47, July 25, 1996

Lloyd's, File # A55699-47, July 18, 1996

Tupperware Corporation, File # A54804-47, May 14, 1996

Physician Management Company of Utah, L.C., File # A53093-47, March 18, 1996

1995

W.R. Grace & Co., File # A49498-36, October 26, 1995

Smith Barney Incorporated, File # A49048-34, October 19, 1995

Philadelphia Stock Exchange, Inc, File # A41129-34, July 12, 1995

Prudential Securities Incorporated, File # A42022-34, July 5, 1995

Motorola, Inc, File # A42020-34, June 27, 1995

Crabbe Huson Funds, File # A40620-35, February 7, 1995

Shoreline Financial Corporation, File # A40343-34, January 5, 1995

Commonwealth Energy System, File # A40345-34, January 4, 1995

Fleming Companies Inc, File # A40342-34, January 4, 1995

Pacificorp Dividend Reinvestment and Stock Purchase Plan, File # A40347-34, January 4, 1995

1994

Dean Witter Reynolds Inc., File # A30721-35, September 27, 1994

Grubb & Ellis Company, File # B00114673, September 13, 1994

O&G Clearinghouse, Inc., File # A23830-35, May 13, 1994

1993

Atlantic Shores, File # A21247-35, December 15, 1993

Nissan Motor Corporation, File # A21150-35, November 30, 1993

Dean Witter Financial Services Group, Inc., File # A20244-21, October 8, 1993

Donaldson, Lufkin & Jenrette Securities Corporation, File # A18276-21, July 21, 1993

1992

Collision Automotive Repair Services, Inc. ("CARS" Tm), File # A15779-21, October 28, 1992

Home Shopping Network, Inc., File # A15441-21, September 22, 1992

Leasing Technology, File # A13964-21, July 2, 1992

Geological Society of America Foundation, File # A14167-21, June 8, 1992

Ebco U.S.A., Incorporated, File # A13099-21, May 20, 1992

Stonegate Village Metropolitan District, File # A13319-31, May 20, 1992

1990

American National Petroleum Company, File # A08543-21, December 26, 1990

American First Financial Fund 1987-A LP, File # A08355-21, December 6, 1990

America First Participating/Preferred Equity Mortgage Fund LP, File # A06978-21, July 16, 1990 (Letter not available)

America First Prep Fund 2 LP, File # A06976-21, July 16, 1990

Pharmics, Inc., File # A05803-21, February 9, 1990

Pep Boys - Manny, Moe & Jack, The, File # A05634-21, January 16, 1990

Vipont Pharmaceutical, Inc., File # A05474-21, January 4, 1990 (Letter not available)

1989

Sun Bancorp, Inc., File # A02797-17, September 7, 1989 (Letter not available)


No-Action Letters Listed Alphabetically

Advanta Corp., File #B00662714, May 24, 2007

Alcatel Alsthom Compagnie General d'Electricite, S.A., File # B00025974, October 30, 1997

Allstate Bank, File # B00310193, July 12, 2004

America First Participating/Preferred Equity Mortgage Fund LP, File # A06978-21, July 16, 1990 (Letter not available)

America First Prep Fund 2 LP, File # A06976-21, July 16, 1990

American First Financial Fund 1987-A LP, File # A08355-21, December 6, 1990

American National Petroleum Company, File # A08543-21, December 26, 1990

Anthem Insurance Companies, Inc., File # B00268177, June 6, 2001

Artisan Group, File # B00720551, February 28, 2008

Atlantic Shores, File # A21247-35, December 15, 1993

Blue Source Investment Company, LP, Blue Source, LLC & Blue Source CO2 Company, LLC, File #B00781846, September 8, 2008

Canada Life Assurance Company, File # B00125606, May 18, 1999

Capital Funding & Financial Group and kidZtime TV, File # A58753-50, April 10, 1997

Cattle Management Program, File # B00112437, February 25, 1999

Clear Sky, File # B00047333, March 26, 1998

Collins/Bay Island Securities LLC, File # B00262834, June 5, 2001

Collision Automotive Repair Services, Inc. ("CARS" Tm), File # A15779-21, October 28, 1992

Commonwealth Energy System, File # A40345-34, January 4, 1995

Crabbe Huson Funds, File # A40620-35, February 7, 1995

Culbro Corporation, File # B00002223, June 5, 1997

David H. Miner, File # B00028834, November 14, 1997 (Letter not available)

Dean Witter Financial Services Group, Inc., File # A20244-21, October 8, 1993

Dean Witter Reynolds Inc., File # A30721-35, September 27, 1994

Donaldson, Lufkin & Jenrette Securities Corporation, File # A18276-21, July 21, 1993

Ebco U.S.A., Incorporated, File # A13099-21, May 20, 1992

Education CRA Management and Education CRA Fund, LLC, File #B00646867, January 24, 2007

Enterprise Engineering Group, File #B00657514, April 30, 2007

Equitable Financial Services, Inc., File # B00045331, February 9, 1998

Excel Legacy Corporation, File # B00042146, February 9, 1998

Excel Realty Trust, Inc., File # B00086255, September 25, 1998

Firstar Trust Company, File # A55682-47, August 12, 1996

Fleming Companies Inc, File # A40342-34, January 4, 1995

Geological Society of America Foundation, File # A14167-21, June 8, 1992

Getty Realty Corp., File # B00449293, April 20, 2004

Graybar Electric Company, Inc., File #B00628329, October 31, 2006

Grubb & Ellis Company, File # B00114673, September 13, 1994

Gruntal & Co., LLC, File # B00073840, July 13, 1998

Home Shopping Network, Inc., File # A15441-21, September 22, 1992

Internet Stock & Securities Exchange, File # B00083915, September 9, 1998

Jameson Inns, Inc., File # B00499720, January 21, 2005

John Hancock Mutual Life Insurance Company, File # B00136422, July 6, 1999

Leasing Technology, File # A13964-21, July 2, 1992

Lloyd's, File # A56585-49, September 25, 1996

Lloyd's, File # A55699-47, July 18, 1996

Madison Mortgage, Inc., File # A55928-47, August 14, 1996

The Manufacturers Life Insurance Company, File # B00115570, March 22, 1999

Merrill Lynch Client Transition Program, File #B00694707, September 19, 2007

Metropolitan Life Insurance Company, File # B00138255, July 22, 1999

Motorola, Inc, File # A42020-34, June 27, 1995

Nissan Motor Corporation, File # A21150-35, November 30, 1993

O&G Clearinghouse, Inc., File # A23830-35, May 13, 1994

Pacificorp Dividend Reinvestment and Stock Purchase Plan, File # A40347-34, January 4, 1995

Park Place Entertainment Corporation, File # B00099827, December 31, 1998

People's Utah Bancorp, File # B00381602, April 17, 2003

Pep Boys - Manny, Moe & Jack, The, File # A05634-21, January 16, 1990

Pharmics, Inc., File # A05803-21, February 9, 1990

Philadelphia Stock Exchange, Inc, File # A41129-34, July 12, 1995

Phoenix Home Life Mutual Insurance Company, File # B00233311, December 15, 2000

Physician Management Company of Utah, L.C., File # A53093-47, March 18, 1996

Principal Financial Group, Inc., File # B00263159, May 10, 2001

Professional Veterinary Products, Inc., File # A60850-50, April 29, 1997

Prudential Insurance Company of America, File # B00232479, December 14, 2000

Prudential Securities Incorporated, File # A42022-34, July 5, 1995

Republic Engineered Products LLC, File # B00354627, December 9, 2002

Shoreline Financial Corporation, File # A40343-34, January 5, 1995

Smith Barney Incorporated, File # A49048-34, October 19, 1995

State Farm Financial Services, F.S.B, File # B00221793, December 2, 2003

Stonegate Village Metropolitan District, File # A13319-31, May 20, 1992

Sun American Bancorp Inc., File #B00587353, May 3, 2006

Sun Bancorp, Inc., File # A02797-17, September 7, 1989 (Letter not available)

Sun Life Assurance Company, File # B00125580, May 12, 1999

Tender Loving Care Health Care Services. Inc., File # B00122265, April 20, 1999

Towne Bancorp, Inc., File # A56302-47, September 24, 1996

TruServ Corporation, File # B00265525, May 24, 2001

Tuition Plan Consortium, LLC, File # B00388089, July 22, 2003

Tupperware Corporation, File # A54804-47, May 14, 1996

Utah Valley Physicians Network, L.L.C., File # B00014664, September 29, 1997

VelocityHSI, Inc., File # B00207324, July 21, 2000

Vipont Pharmaceutical, Inc., File # A05474-21, January 4, 1990 (Letter not available)

Virginia Higher Education Tuition Trust, File # A56500-47, October 10, 1996

W.R. Grace & Co., File # A49498-36, October 26, 1995

Westmed Physician Network, Inc., File # A54673-47, July 25, 1996

Zap.Com Corporation, File # B00179478, February 16, 2000

 

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