The SEC staff recently issued a no-action letter stating that registration as an investment adviser was not necessary when (i) asset management services are provided only to wholly-owned subsidiaries of a parent which also owns the adviser, (ii) the adviser does not hold itself out to the public as an investment adviser and (iii) the parent beneficially owns, directly or indirectly, 100% of the assets for which the adviser provides investment advice.

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Stinson Leonard Street LLP provides sophisticated transactional and litigation legal services to clients ranging from individuals and privately held enterprises to national and international public companies. As one of the 75 largest firms in the U.S., Stinson Leonard Street has more than 520 attorneys and offices in 14 cities, including Minneapolis, Mankato and St. Cloud, Minn.; Kansas City, St. Louis and Jefferson City, Mo.; Phoenix, Ariz.; Denver, Colo.; Washington, D.C.; Decatur, Ill.; Wichita and Overland Park, Kan.; Omaha, Neb.; and Bismarck, N.D.

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