Robert E. Mannion, Esq.
Arnold & Porter
Thurman Arnold Building
555 Twelfth Street, N.W.
Washington, D.C. 20004-1202

Dear Mr. Mannion:

This will respond to your correspondence, on behalf of Firstar Corporation, Milwaukee, Wisconsin ("Firstar"), requesting that the Board concur in your interpretation of the name restriction in the Board's interpretive rule on investment adviser activities.¹ The interpretive rule prohibits a bank holding company from acting as investment adviser to an investment company that has either the same name as the name of the holding company or any of its subsidiary banks, or a name that contains the word "bank".² You have requested that the Board concur that this restriction would not prevent a nonbank subsidiary of Firstar from acting as investment adviser to a series of investment companies called "The Firstar Funds."

After considering your request, the Board has concluded that it will not object if Firstar or its nonbank subsidiaries acts as investment adviser to investment companies called "The Firstar Funds." The Board expects that, in performing investment advisory activities, Firstar and its subsidiaries will comply with the disclosure and other requirements in the Board's interpretive rule as well as with the requirements of the Interagency Statement on the Retail Sale of Nondeposit Investment Products and all applicable regulations of the Securities and Exchange Commission.

Very truly yours,

(Signed) Jennifer J. Johnson

Jennifer J. Johnson

cc: Federal Reserve Bank of Chicago

1. 12 CFR 225.125. Return to text

2. 12 CFR 225.125(f).Return to text