Based upon the representation in your correspondence, we understand the facts to be as follows. However, fees and expenses incurred by or allocable to the Investment Vehicles, including legal and accounting fees and transaction-related fees, are generally borne by the Investment Vehicles.
Participation is entirely voluntary.
You further represent that all employees participating in the Investment Vehicles will receive full disclosures as to the nature and type of investments, and that each such employee can obtain access to the Investment Vehicles' books and records upon request. Any different, changed or omitted material facts or circumstances might render these positions void. Further, the no-action positions taken herein are solely those of the Division and do not necessarily represent the views of the Commission or those of any other division or office of the Commission. Very truly yours John C. Lawton Acting Director 1 Commission rules referred to herein are found at 17 C.F.R. Ch.