As here relevant, the Sudan Accountability and Divestment Act of 2007 (“SDA”) provides registered investment companies (and their related persons) a safe harbor from liability for any action “based solely upon the investment company divesting from, or avoiding investment in, securities issued by persons that the investment company determines . . . conduct or have direct investments in business operations in Sudan.”  This relief is conditioned on the fund-making disclosures regarding any such divestment in accordance with a rule adopted by the SEC for this purpose.  On April 24, 2008, the SEC issued a Release adopting amendments to Form N-CSR and Form N-SAR that allow funds to disclose to the SEC specific information regarding any securities they divest in accordance with the SDA’s safe harbor.  Release Nos. 34-57711; IC-28254; available at http://www.sec.gov/rules/final/2008/34-57711.pdf.

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