SEC Staff Issues New Guidance on Use of Hedge Clauses in Investment Advisory Contracts

On February 12, 2007, the Staff of the Division of Investment Management ("Staff") of the Securities and Exchange Commission (the "SEC") responded to a request submitted by Heitman Capital Management, LLC, et al., ("Heitman") for guidance on the use of "hedge clauses" in investment advisory contracts with certain sophisticated clients (the "Heitman Letter").

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