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