Investment Management : Law and Regulation

by Bines, Harvey E.

• ISBN13: 9780735530485
• ISBN10: 0735530483
• Edition: 2nd
• Format: Hardcover
• Copyright: 2004-03-01
• Publisher: Aspen Pub

Summary

In its First Edition, this classic treatise called attention To The duty of reasonable care, The duty of loyalty And The public duty of fiduciaries To The marketplace. Grounded in the idea that prudent investing is to be defined by professional practices accepted as appropriate at the time of investment by the management, thereby permitting such practices to adapt to changing conditions and insights, The field of investment management law and regulation has at its center the goal of a common standard of care for investment. Now in its Second Edition, this definitive guide to investment management law and regulation helps you to profitably adapt to today's new and changing conditions and anticipate tomorrow's regulatory response. Here are just a few of the reasons why Investment Management Law and Regulation will be so valuable to you: Explains and analyzes all the ins and outs of the law, clarifies the complexities, answers your questions, points out pitfalls and helps you avoid them Covers the entire field in one volume, saves you valuable time and effort in finding information and searching through stacks of references Ensures compliance with all relevant regulations, makes sure nothing is overlooked, protects you against costly mistakes Updates you on the latest important changes, tells you what is happening now and what is likely to happen in the future Investment Management Law and Regulation is the only up-to-date volume to offer a comprehensive examination of the field of investment management law, covering everything from financial theory and legal theory To The various aspects of hands-on fund management. It's the only resource of its kind that: Identifies and explains the financial theories that control the development of investment management law across management activities Gives critical judicial, legislative, and regulatory history that makes recent law and regulation more comprehensible Covers all areas of regulation governing the activities of investment managers, including marketing, suitability, advisory contacts, fees, exculpation and indemnification, performance, fiduciary obligations, conflicts of interest, best execution Provides the practical tools that help predict more effectively how regulators will respond to new marketplace developments and products Integrates investment management law and regulation for all institutional investment managers and more Whether you are a manager, broker, banker, or legal counsel, a seasoned professional or just starting out, this treatise will quickly become your most trusted guide through the intricacies of this complex, critical, and closely scrutinized area

Table of Contents

About the Authors	v
Preface to the Second Edition	xxvii
Foreword to the First Edition	xxxiii
Preface to the First Edition	xxxv
PART I PRINCIPLES OF INVESTMENT MANAGEMENT LAW
Chapter 1 THE FUNDAMENTAL PRINCIPLES OF INVESTMENT MANAGEMENT LAW	1	(42)
§ 1.01 Evolution of the Fundamental Principles	3	(19)
[A] The Duty of Reasonable Care and the Duty of Loyalty	3	(9)
[1] The Emergence of Investment Management as a Profession	5	(1)
[2] The Expanding Influence of the Contract Approach	6	(3)
[3] The Expanded Opportunities for Abuse of Duty in Connection with Pooled Investment Vehicles	9	(1)
[4] Legislative Reinforcement of Fiduciary Principles	10	(2)
[B] The Public-Duty Principle	12	(1)
[C] The Establishment of Operative Rules: Post-1940 Developments	12	(10)
[1] Rules of Conduct Evidencing Reasonable Care	13	(3)
[2] Regulation of Practices Involving Divided Loyalties	16	(4)
[3] Extension of the Public-Duty Principle	20	(2)
§ 1.02 Analysis of the Reasonable-Care Principle	22	(13)
[A] The Meaning of Reasonable Care	23	(1)
[B] Applying the Reasonable-Care Standard	24	(21)
[1] Reasonable Care as a Question of Fact; Professional Standards	25	(2)
[2] Reasonable Care as an Issue of Law	27	(1)
[3] When Standard-Setting Is a Matter of Fact and When a Matter of Law	28	(7)
§ 1.03 Analysis of the Loyalty Principle	35	(6)
§ 1.04 Analysis of the Public-Duty Principle	41	(2)
Chapter 2 THE GOVERNING STATUTORY AND COMMON-LAW SYSTEMS	43	(40)
§ 2.01 The Diverse Systems Regulating Investment Management Activities	45	(1)
§ 2.02 Defining the Common-Law Relationship Between Client and Manager	45	(4)
[A] Trust Relationships	45	(3)
[B] Agency Relationships	48	(1)
§ 2.03 Application of the Law by Type of Transaction: The Antifraud Provisions of the Securities Act of 1933 and the Securities Exchange Act of 1934	49	(3)
§ 2.04 Application of the Law by Type of Client	52	(18)
[A] Publicly Owned Corporate Investors: The Investment Company Act of 1940	53	(6)
[B] Employee Benefit Plans	59	(7)
[1] The Employee Retirement Income Security Act of 1974	59	(6)
[2] The Uniform Management of Public Employee Retirement Systems Act	65	(1)
[C] Charitable Endowment Funds	66	(4)
[1] Private Foundations: The Internal Revenue Code	66	(1)
[2] Charitable Organizations: The Uniform Management of Institutional Funds Act	67	(3)
[D] Holders of Debt Securities: The Trust Indenture Act of 1939	70	(1)
§ 2.05 Application of the Law by Type of Manager	70	(13)
[A] Bank Trust Departments: Regulation by the Federal Reserve Board and the Comptroller of the Currency	71	(3)
[B] Investment Advisers: The Investment Advisers Act of 1940	74	(13)
[1] Investment Counsel	76	(1)
[2] Broker-Dealers	77	(2)
[3] Other Statutory Investment Advisers	79	(4)
PART II ESTABLISHING THE CLIENT MANAGER RELATIONSHIP
Chapter 3 DEVELOPING NEW BUSINESS	83	(76)
§ 3.01 Constraints on the Investment Manager's Relationship with Prospective Clients	85	(2)
§ 3.02 Application of the Registration Provisions of the Securities Act and the Investment Company Act to Investment Management Arrangements	87	(49)
[A] The Context in Which Investment Management Arrangements Came to be Subject to the Registration Provisions of the Securities Laws	87	(2)
[B] Investment Management Arrangements as Securities	89	(31)
[1] Common Enterprise	92	(1)
[a] Horizontal Commonality	93	(1)
[b] Broad Vertical Commonality	94	(1)
[c] Narrow Vertical Commonality	97	(1)
[d] Individual Treatment and Commonality-The Limited Relevance of Common Enterprise for Investment Management	98	(6)
[2] Manager Control of Investment Decisions	104	(5)
[3] The Form of the Arrangement: The Status of Trust Relationships	109	(11)
[C] Managed Accounts as Investment Companies	120	(9)
[D] Individualized Treatment as the Key to Whether Investment Management Arrangements Are Subject to the Registration Provisions of the Securities Laws	129	(4)
[E] Reprise: The Context in Which Investment Management Arrangements Are Likely to be Subject to the Securities Laws	133	(3)
§ 3.03 Application of the Antifraud Provisions of the Federal Securities Laws to Promotional Activities	136	(23)
[A] The Broad Reach of the Provisions	136	(2)
[B] The Disclosure Rules: Advertising as the Focus of Regulatory Activity	138	(23)
[1] Testimonials	142	(1)
[2] Referrals	143	(6)
[3] Past Investment Recommendations as a Measure of Performance	149	(2)
[4] Other Measures of Performance	151	(4)
[5] Special Services	155	(1)
[6] Portfolio Appraisal and Management by Formula	156	(1)
[7] Mandatory Disclosures	157	(2)
Chapter 4 SETTING INVESTMENT OBJECTIVES	159	(62)
§ 4.01 Determining the Client's Tolerance for Risk	161	(14)
[A] Presumptive Standards of Risk	165	(2)
[B] The Suitability Doctrine	167	(8)
[1] Application of the Doctrine to Investment Managers	170	(4)
[2] Substance Questions and Enforcement Problems	174	(1)
§ 4.02 An Examination of Suitability According to Economic Theory	175	(12)
[A] The Effect of Shifts in Wealth	176	(1)
[B] The Dependency of Suitability on Shifts in Utility	177	(2)
[C] The Dependency of Suitability on Attitude Toward Risk	179	(1)
[D] Problems in Seeking to Maximize Suitability	180	(4)
[E] How Suitability Continually Changes	184	(2)
[F] The Limits on Lessons to Be Derived from Economic Theory	186	(1)
§ 4.03 An Examination of Suitability According to Legal Theory	187	(34)
[A] Factors Tending to Shift Responsibility for Suitability to the Manager	192	(23)
[1] The Level of Risk in a Proposed Investment Program or Recommended Investment	192	(1)
[a] Source of Risk	193	(1)
[b] Relationship Between Risk and Suitability Duty	195	(1)
[c] Presumptive Risk and Sophisticated Investment Techniques	196	(1)
[d] Questions of Professional Competence Masquerading as Questions of Suitability	198	(1)
[2] The Nature of the Management Relationship; Discretionary Authority	199	(1)
[a] Working Within Preset Risk-Return Constraints: The Investment Company Model	203	(1)
[b] Authority to Set Risk-Return Constraints: The Pension Fund Model I	205	(1)
[c] Investment Management Performed for Persons Having Authority to Set Risk-Return Constraints: The Pension Fund Model II	209	(1)
[d] Investment Management Performed for Beneficiaries Making Their Own Investment Decisions: The Pension Fund Model III	213	(1)
[e] The Lessons of the Models	214	(1)
[B] Factors Tending to Place Responsibility for Suitability on the Client	215	(10)
[1] Actual Notice of Risk	215	(4)
[2] Constructive Notice of Risk: The Sophisticated-Investor Doctrine	219	(2)
Chapter 5 SPECIAL PROBLEMS IN STRUCTURING INVESTMENT MANAGEMENT AGREEMENTS	221	(66)
§ 5.01 Unenforceable Provisions Generally	223	(2)
§ 5.02 Exculpatory Clauses	225	(20)
[A] Bad Faith or Reckless Disregard of Fiduciary Duties	226	(2)
[B] Negligence	228	(6)
[C] Drafting Effective Exculpatory Provisions	234	(11)
[1] Reliance on the Opinions of Experts	237	(1)
[2] Responsibility for Co-Managers	238	(1)
[3] Responsibility for Portfolio Diversification	239	(2)
[4] Indemnification Provisions	241	(4)
§ 5.03 Management Compensation Arrangements	245	(42)
[A] The Management Fee	247	(13)
[B] Performance and Incentive Fees	260	(33)
[1] The Controversy Surrounding Performance-Fee Arrangements	263	(5)
[2] Bases for Effective Performance-Fee Provisions: Risk-Sharing, Cost Control, Superior Managerial Talent	268	(2)
[3] Regulation of Performance-Fee Arrangements	270	(4)
[4] Standards for Measuring the Effectiveness of Performance-Fee Arrangements	274	(1)
[a] Comparison of Returns With an Unmanaged Portfolio	275	(1)
[b] Identity of Risk Between the Managed and Unmanaged Portfolios	277	(1)
[c] Accounting for Distributions and Other Returns	279	(1)
[d] Accounting for Receipts and Disbursements	280	(1)
[e] Symmetrical Pricing of the Performance Fee	281	(1)
[f] Relating Performance Fees to Significant Differences in Result	281	(1)
[g] Time Intervals for Evaluating Performance	282	(5)
PART III STRUCTURING THE PORTFOLIO
Chapter 6 THE IMPRECISE PARAMETERS OF THE OLD JURISPRUDENCE OF PRUDENCE AS THE MEASURE OF THE DUTY OF REASONABLE CARE	287	(26)
§ 6.01 Professional Competence as a Legal Duty	289	(4)
§ 6.02 The Second Restatement's Taxonomy of Prudent Investing	293	(20)
[A] Avoiding Speculation	295	(8)
[B] Disposing of Unsuitable Investments	303	(3)
[C] Making a Portfolio Productive	306	(2)
[D] Achieving Diversification	308	(5)
Chapter 7 MODERN PORTFOLIO THEORY AS A TOOL TO MEASURE PROFESSIONAL COMPETENCE	313	(48)
§ 7.01 The Impact of Modern Portfolio Theory on Common-Law Standards	315	(4)
§ 7.02 Theory in a Single-Investor World of Certain Values	319	(26)
[A] Measuring Possible Investments Against the Client's Objectives: Expected Return	319	(3)
[B] Determining Relative Risk as a Deviation from Expected Value: Variance	322	(4)
[C] Measuring the Effects of Combinations of Securities on Risk and Return: Covariance	326	(10)
[1] Covariance Analysis of a Two-Security Portfolio	329	(5)
[2] Implications of the Covariance Analysis	334	(2)
[D] The Traditional Principles Revisited	336	(9)
[1] Speculation	336	(2)
[2] Disposing of Unsuitable Investments	338	(4)
[3] Making a Portfolio Productive	342	(1)
[a] Securities Having a Return at the Expected Value Level Indicated by the Client's Investment Objectives	342	(1)
[b] Securities Having Expected Values Lower Than That Indicated by the Client's Investment Objectives	343	(1)
[c] Securities Having a Higher Expected Value Than That Indicated by the Client's Investment Objectives	343	(1)
[4] Diversification	344	(1)
§ 7.03 Theory in a Many-Investor World of Certain Values	345	(8)
[A] Volatility	346	(1)
[B] Capital Asset Pricing	347	(3)
[C] The Traditional Principles	350	(3)
[1] Speculation	350	(1)
[2] Disposing of Unsuitable Investments	351	(1)
[3] Making a Portfolio Productive	352	(1)
[4] Diversification	352	(1)
§ 7.04 Theory in a Many-Investor World of Uncertain Values	353	(8)
[A] Assumptions Underlying the Capital Asset Pricing Model	354	(2)
[B] The Capital Asset Pricing Model Tested	356	(5)
Chapter 8 PRUDENT INVESTING AS A CONTEMPORARY ISSUE	361	(136)
§ 8.01 Background	363	(2)
§ 8.02 Harvard College Renewed	365	(33)
[A] The Developing Jurisprudence	365	(11)
[1] Rejection of Per Se Rules	367	(2)
[2] Marginalizing the Evidentiary Value of Securities Ratings	369	(2)
[3] Diversification	371	(2)
[4] Combinations of Investments	373	(3)
[B] ERISA and Other Federal Statutes	376	(21)
[1] Section 404(a)(1) of ERISA	377	(8)
[2] Other Federal Statutes	385	(1)
[a] Trust Powers of National Banks	385	(1)
[b] Antifraud Provisions of the Federal Securities Laws	389	(1)
[c] Investment Company Act and Investment Advisers Act	394	(1)
[d] Taxation Under the Internal Revenue Code of Private Foundations for Making Investments Jeopardizing Their Charitable Purposes	396	(1)
[C] Uniform Management of Institutional Funds Act	397	(1)
§ 8.03 The Prudent-Investor Rule of the Restatement (Third) of Trusts	398	(25)
[A] The Third Restatement's Prudent Investor Rule	401	(16)
[1] Investment Objectives	402	(4)
[2] Selection of Investments and Diversification	406	(11)
[B] The Uniform Acts	417	(6)
[1] The Uniform Prudent Investor Act	418	(3)
[2] The Uniform Management of Public Employee Retirement Systems Act	421	(2)
§ 8.04 Application of Modern Portfolio Theory to the Reasonable-Care Standard	423	(39)
[A] The Efficient Market Hypothesis	426	(28)
[1] Capital Asset Pricing and the Productive Portfolio: Legal Standards	436	(3)
[2] Active Investment Strategies	439	(1)
[a] Conventional Strategies	440	(1)
[b] Unconventional Strategies	441	(1)
[c] Fundamental Analysis	443	(1)
[d] Technical Analysis	448	(6)
[B] Diversification	454	(4)
[C] Disposing of Unsuitable Investments	458	(4)
§ 8.05 Investments and Investment Strategies in Contemporary Markets	462	(29)
[A] Consideration of the Entire Portfolio	462	(4)
[B] The New Perspective on Speculation	466	(20)
[1] High-Volatility Securities	466	(1)
[2] Leveraging	467	(2)
[3] Options and Other Derivatives	469	(7)
[4] Securities Lending; Repurchase Agreements	476	(4)
[5] Guaranteed Investment Contracts	480	(1)
[6] Private Equity Funds	481	(4)
[7] Other Traditional Speculations	485	(1)
[C] Socially Responsible Investing	486	(2)
[D] Use of Employee Benefit Plan Assets in Corporate Control Disputes; Proxy Voting	488	(3)
[1] Corporate Control	488	(2)
[2] Voting	490	(1)
§ 8.06 Important Client Relationship Factors in Managing Risk	491	(6)
[A] Asset Class Investment Management	491	(1)
[B] Proving Management of Risk	492	(1)
[C] Obtaining Contractual Protection	493	(4)
PART IV ONGOING MANAGEMENT: EXECUTIONS
Chapter 9 EXECUTING INVESTMENT DECISIONS AS A LEGAL DUTY	497	(82)
§ 9.01 The Duty of Best Execution	499	(10)
[A] Best Execution as Best Net Price: The Analytic Base for Professional Competence	502	(6)
[B] The Analytic Structure for Departures from Best Net Price: The Interplay Between the Legal Duties of Reasonable Care and Loyalty	508	(1)
§ 9.02 The Effect of Commission Rate Structure on Best-Execution Standards	509	(40)
[A] Securities Transactions Before 1960: The Fixed-Rate System	509	(1)
[B] 1960 Through 1970: Identification of Conflict-of-Interest Problems and Public-Policy Considerations	510	(8)
[1] Reciprocal Practices	513	(3)
[2] Commission Recapture	516	(2)
[C] Through April 30, 1975: The Move Toward Abolition of the Fixed-Rate System	518	(5)
[D] The Impact of Negotiated Commission Rates on the Structure of the Securities Industry	523	(5)
[E] Developments Following the Introduction of Negotiated Rates Through the Market Break of 1987 and the Brady Report	528	(9)
[F] The Market 2000 Report, The Fragmentation Release, and Related Developments	537	(46)
[1] Transparency	539	(1)
[2] Fair Treatment for Investors	539	(1)
[3] Fair Market Competition	540	(1)
[4] Open Market Access	540	(9)
§ 9.03 The Duty of Best Execution: General Observations	549	(7)
§ 9.04 Inadvertent Sacrifice of Best Execution: Standards of Reasonable Care	556	(9)
Appendix: AIMR Trade Management Guidelines (2002)	565	(14)
Chapter 10 USE OF COMMISSIONS TO PURCHASE SUPPLEMENTARY SERVICES	579	(116)
§ 10.01 Conflicts of Interest Surrounding the Intentional Sacrifice of Best Net Price in Order to Purchase Supplementary Services	581	(2)
§ 10.02 The Development of Best-Execution Standards During the Fixed-Rate Era	583	(11)
[A] Best Net Price and the Duty to Recapture Excess Commissions	583	(4)
[B] The Manager's Discretion to Incur Supplementary Product and Service Costs	587	(3)
[C] Congressional Attempts to Clarify the Rules: S. 470 and H.R. 5050	590	(4)
§ 10.03 Federally Legislated Standards	594	(21)
[A] The Employee Retirement Income Security Act of 1974: Commission-Purchased Supplementary Products and Services as a Prohibited Transaction	594	(2)
[B] The Securities Acts Amendments of 1975: Protections Provided by Section 28(e) of the Securities Exchange Act	596	(19)
[1] Good Faith and Reasonableness as a Defense to Challenged Conduct: Section 28(e)(1)	598	(2)
[2] Disclosure Requirements: Section 28(e)(2)	600	(3)
[3] Definition of Brokerage and Research Services: Section 28(e)(3)	603	(3)
[4] SEC Administration of Section 28(e)	606	(1)
[a] Directed Brokerage	606	(1)
[b] Principal Transactions	610	(5)
§ 10.04 Determining the Limits of an Investment Manager's Discretion to Purchase Supplementary Services with Commissions	615	(9)
[A] Deciding Which Services to Purchase	616	(4)
[B] Allocating the Benefits of Purchased Services Between Manager and Client	620	(4)
§ 10.05 Conflict-of-Interest Problems in the Use of Excess Commissions to Purchase Brokerage Services	624	(11)
[A] Proving Pure Execution	628	(4)
[B] Allocating Execution Costs Among Multiple Accounts	632	(3)
§ 10.06 Conflict-of-Interest Problems in the Use of Excess Commissions to Purchase Research Services	635	(34)
[A] Identifying Breaches of Fiduciary Duty	635	(1)
[B] The Limited Protection Afforded by Section 28(e) of the Securities Exchange Act	636	(7)
[C] Fixed-Rate Underwriting Commissions	643	(4)
[D] Allocating Benefits Between Client and Manager: The Relevant Factors	647	(19)
[1] Congressional Purpose Behind Enactment of Section 28(e)	647	(4)
[2] The Value of the Service Purchased	651	(2)
[3] The Execution Price	653	(3)
[4] Portfolio Performance	656	(1)
[5] Published Price (Unbundled Pricing)	657	(5)
[6] Management Fee	662	(3)
[7] Quality of Execution	665	(1)
[E] Allocating Costs Among Multiple Accounts	666	(3)
§ 10.07 Disclosure and Informed Consent: Resolving Conflicts of Interest Arising from Use of Commissions to Purchase Supplementary Services	669	(26)
[A] The Informed-Consent Principle	671	(2)
[B] Disclosure Obligations	673	(24)
[1] Principles of Disclosure Developed in Litigation Concerning Commissions Used to Obtain Supplementary Services	675	(7)
[2] SEC Consideration of Disclosure Concerning Commissions Used to Obtain Supplementary Services	682	(10)
[3] The Limits and Content of Disclosure as a Shield for Investment Managers' Use of Commissions to Acquire Supplementary Services	692	(3)
Chapter 11 EXECUTION CONFLICTS OF INTEREST	695	(128)
§ 11.01 Background	697	(1)
§ 11.02 Conflicts of Interest When Brokers Control or Influence Investment Decisions	697	(109)
[A] The Securities Acts Amendments of 1975: Restrictions on Broker-Money Manager Combinations Under Section 11(a) of the Securities Exchange Act	701	(37)
[1] Conditions Leading to the Decision to Separate Brokerage and Management	701	(1)
[a] Congress's Conflict-of-Interest Rationale	703	(1)
[b] The Brokerage Community's Public-Business Argument for Exclusion of Institutions from the Brokerage Business	706	(1)
[c] Eliminating the Broker-Manager's Competitive Edge: The Public-Interest Rationale	709	(1)
[i] Timing of the Conflict-of-Interest Theory	711	(1)
[ii] Support for Separation of Brokerage and Management	718	(1)
[iii] Client Interests Protected by the Separation of Brokerage and Management	723	(2)
[2] Analysis of the 1975 Amendments to Section 11(a): Prohibitions and Exemptions	725	(4)
[3] SEC Implementation of Section 11(a)	729	(4)
[4] The "Repeal" of the Managed-Account Provisions of Section 11(a)	733	(5)
[B] Restrictions on Broker-Money Manager Combinations Under the Employee Retirement Income Security Act of 1974	738	(36)
[1] The Prohibited-Transaction Provisions	738	(5)
[2] Definition of a Statutory Fiduciary	743	(1)
[a] Rendering Investment Advice for Compensation	744	(1)
[b] Executing Securities Transactions	746	(1)
[3] Prohibited Transaction Exemptions	747	(1)
[a] Agency Transactions	748	(1)
[i] Brokerage and Management Generally	748	(1)
[ii] Agency-Cross Transactions	752	(1)
[b] Principal Transactions	753	(1)
[c] Underwritings	754	(1)
[d] Market-Making	757	(1)
[e] Extension of Credit	758	(1)
[4] Certain ERISA Definitions and Prohibited Transaction Provisions	759	(1)
[a] Investment Advice: Labor Regulation § 2510.3-2(c) and I.R.C. Regulation § 4975-9(c)	759	(1)
[b] Execution of Securities Transactions: Labor Regulation § 2510.3-21(d); I.R.C. Regulation § 4975-9(d)	760	(1)
[c] Prohibited Transaction Exemption 75-1	761	(1)
[d] Prohibited Transaction Exemption 86-128, as Amended	768	(6)
[C] Framework for Analysis of Conflicts of Interest When Brokers Control or Influence Investment Decisions	774	(2)
[D] Broker-Manager Conflicts of Interest	776	(30)
[1] Overtrading (Churning)	776	(6)
[2] Acting as Principal or Agent for Another (Dumping)	782	(1)
[a] Isolation of Activities	788	(1)
[b] Disclosure and Informed Consent	791	(1)
[c] Established Procedures	797	(1)
[3] Negotiated Commissions and In-House Executions	798	(2)
[4] Certain Investment Company Act and Investment Advisers Act Rules	800	(1)
[a] Rule 10f-3	800	(1)
[b] Rule 206(3)-1	804	(1)
[c] Rule 206(3)-2	805	(1)
§ 11.03 Execution Conflicts of Interest Affecting Investment Managers Generally	806	(17)
[A] Benefiting by Manipulation of Short-Term Market Activity (Scalping and Front-Running)	806	(12)
[1] 17 C.F.R. § 270.17j-1 - Personal Investment Activities of Investment Company Personnel	812	(6)
[B] Preferential Treatment	818	(3)
[C] Reciprocal Dealing	821	(2)
Bibliography	823	(36)
Table of Statutes	859	(8)
Table of Rules and Regulations	867	(4)
Table of Releases	871	(4)
Table of No-Action Letters	875	(4)
Table of Cases	879	(12)
Index	891