SEC Company Response from COHEN & STEERS PREMIUM INCOME REALTY FUND INC (CIK 0001170895) — Nov 9, 2004
COHEN & STEERS PREMIUM INCOME REALTY FUND INC (CIK 0001170895)
Date: Nov. 9, 2004 · CIK: 0001170895 · Accession: 0000950117-04-003855
AI Filing Summary & Sentiment
File numbers found in text: 333-119283, 811-21074
Letter
OVERNIGHT DELIVERY AND EDGAR ---------------------------- Securities & Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Attention: Mr. Keith O'Connell
Re: Cohen & Steers Premium Income Realty, Inc. Registration Statement on Form N-2 Filed on November 8, 2004 File Nos.: 333-119283 and 811-21074
Dear Mr. O'Connell:
Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended, Cohen & Steers Premium Income Realty Fund, Inc. (the "Fund") hereby requests that the effective date of the Registration Statement on Form N-2 (File Nos.: 333-119283 and 811-21074) (the "Registration Statement") be accelerated so that it will be declared effective as soon as practicable on Wednesday, November 10, 2004.
We have also been advised that the National Association of Securities Dealers, Inc. has no objection to the underwriting arrangements.
In addition, as you requested in a telephone conversation held on November 4, 2004 with Jon R. Gray of Simpson Thacher & Bartlett LLP, the Fund hereby acknowledges that:
o in declaring the Registration Statement effective, neither the Securities and Exchange Commission (the "Commission") nor the staff of the Commission (the "Staff") forecloses itself from taking any action with respect to the Registration Statement;
o the action of the Commission or the Staff in declaring the filing effective does not relieve the Fund from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and
o the Fund may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
COHEN & STEERS PREMIUM INCOME REALTY FUND, Inc.
By: /s/ Lawrence B. Stoller ---------------------------- Name: Lawrence B. Stoller
<PAGE>
Global Markets & Investment Banking
4 World Financial Center - 5th Floor [MERRILL LYNCH LOGO] New York, New York 10080
212-449-6500
November 8, 2004
Mr. Keith O'Connell Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549
Re: Cohen & Steers Premium Income Realty Fund, Inc. (the "Fund") Form N-2 Registration Statement No. 333-119283 Investment Company Act File No. 811-21074
Dear Mr. O'Connell:
Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, as amended (the "Securities Act"), we on behalf of the several underwriters, wish to advise you that the amended Registration Statement, Form N-2 as filed on November 8, 2004, and Preliminary Prospectus dated November 8, 2004, will be electronically distributed during the period November 8, 2004 through pricing on November 10, 2004 as follows: approximately 350 copies of the Preliminary Prospectus and a limited number of Registration Statements will be sent to underwriters, dealers and institutions.
In accordance with Rule 461 of the General Rules and Regulations under the Securities Act, the undersigned, on behalf of the underwriters of the offering of up to 3,400 preferred shares of beneficial interest of the Fund, Series W28, hereby joins in the request of the Fund for acceleration of the effective date of the above-named Registration Statement so that it becomes effective on November 10, 2004, or as soon as possible thereafter.
Very truly yours,
MERRILL LYNCH & CO.
MERRILL LYNCH, PIERCE, FENNER & SMITH
INCORPORATED
Show Raw Text
<DOCUMENT>
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<SEQUENCE>1
<FILENAME>corresp.txt
<DESCRIPTION>COHEN & STEERS PREMIUM INCOME REALTY FUND
<TEXT>
<PAGE>
[Letterhead of Cohen & Steers Premium Income Realty Fund, Inc.]
November 8, 2004
OVERNIGHT DELIVERY AND EDGAR
----------------------------
Securities & Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attention: Mr. Keith O'Connell
Re: Cohen & Steers Premium Income Realty, Inc.
Registration Statement on Form N-2
Filed on November 8, 2004
File Nos.: 333-119283 and 811-21074
Dear Mr. O'Connell:
Pursuant to Rule 461 of the General Rules and Regulations under the
Securities Act of 1933, as amended, Cohen & Steers Premium Income Realty Fund,
Inc. (the "Fund") hereby requests that the effective date of the Registration
Statement on Form N-2 (File Nos.: 333-119283 and 811-21074) (the "Registration
Statement") be accelerated so that it will be declared effective as soon as
practicable on Wednesday, November 10, 2004.
We have also been advised that the National Association of Securities
Dealers, Inc. has no objection to the underwriting arrangements.
In addition, as you requested in a telephone conversation held on November
4, 2004 with Jon R. Gray of Simpson Thacher & Bartlett LLP, the Fund hereby
acknowledges that:
o in declaring the Registration Statement effective, neither the
Securities and Exchange Commission (the "Commission") nor the staff of
the Commission (the "Staff") forecloses itself from taking any action
with respect to the Registration Statement;
o the action of the Commission or the Staff in declaring the filing
effective does not relieve the Fund from its full responsibility for
the adequacy and accuracy of the disclosure in the Registration
Statement; and
o the Fund may not assert Staff comments as a defense in any proceeding
initiated by the Commission or any person under the federal securities
laws of the United States.
Very truly yours,
COHEN & STEERS PREMIUM INCOME
REALTY FUND, Inc.
By: /s/ Lawrence B. Stoller
----------------------------
Name: Lawrence B. Stoller
<PAGE>
Global Markets & Investment Banking
4 World Financial Center - 5th Floor
[MERRILL LYNCH LOGO] New York, New York 10080
212-449-6500
November 8, 2004
Mr. Keith O'Connell
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Cohen & Steers Premium Income Realty Fund, Inc. (the "Fund")
Form N-2 Registration Statement No. 333-119283
Investment Company Act File No. 811-21074
Dear Mr. O'Connell:
Pursuant to Rule 460 of the General Rules and Regulations under the
Securities Act of 1933, as amended (the "Securities Act"), we on behalf of the
several underwriters, wish to advise you that the amended Registration
Statement, Form N-2 as filed on November 8, 2004, and Preliminary Prospectus
dated November 8, 2004, will be electronically distributed during the period
November 8, 2004 through pricing on November 10, 2004 as follows: approximately
350 copies of the Preliminary Prospectus and a limited number of Registration
Statements will be sent to underwriters, dealers and institutions.
In accordance with Rule 461 of the General Rules and Regulations under the
Securities Act, the undersigned, on behalf of the underwriters of the offering
of up to 3,400 preferred shares of beneficial interest of the Fund, Series W28,
hereby joins in the request of the Fund for acceleration of the effective date
of the above-named Registration Statement so that it becomes effective on
November 10, 2004, or as soon as possible thereafter.
Very truly yours,
MERRILL LYNCH & CO.
MERRILL LYNCH, PIERCE, FENNER & SMITH
INCORPORATED
On behalf of the several Underwriters
By: MERRILL LYNCH, PIERCE, FENNER & SMITH
INCORPORATED
/s/ Michele Allong
-------------------------
Name: Michele Allong
Authorized Signatory
</TEXT>
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