| | American Bible Society: No-Action letter dated June 1, 2004 |
 | | Because the General Fund is excluded from the definition of investment company under Section 3(c)(10)(B) of the Investment Company Act, however, you state that ABS and the Committee Members currently are exempted from registration as investment advisers under the Advisers Act. |
 | | The proposed investment by Eligible FBSs in the General Fund may cause the General Fund to fall within the definition of investment company under the Investment Company Act because the General Fund may no longer be deemed to be "maintained by a charitable organization exclusively for the collective investment and reinvestment of. |
 | | Section 203(a) of the Advisers Act generally prohibits any investment adviser, unless registered under the Advisers Act, or prohibited from registering or exempted from the requirement to register under that Act, from engaging in interstate commerce in connection with its business as an investment adviser. |
| www.sec.gov /divisions/investment/noaction/abs060104.htm (2660 words) |