Regulation S-AM Compliance Date is June 1

Funds and Advisers

As previously announced, the date to comply with Regulation S-AM is June 1, 2010. Regulation S-AM applies to all SEC-registered investment companies and advisers, transfer agents and broker-dealers who share certain consumer information with affiliates for the purpose of making marketing solicitations. The regulation controls how these registrants use consumersí information obtained from, or provided to, their affiliates. S-AM requires registrants to provide consumers notice of such potential marketing activities, and a reasonable opportunity to opt out of receiving these marketing solicitations, prior to marketing to such consumers.

Unlike Regulation S-P, Regulation S-AM does not limit a registrantís ability to share information with affiliates. Instead, it limits the registrantís and affiliateís abilities to use the consumerís information received from one another to solicit the consumer for marketing purposes.

Please contact Vista360 if you have any questions regarding your Regulation S-AM obligations.








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