Securities Act of 1933
Regulation D - Rule 501(a)
Rule 144A(a)(1)

July 14, 2011

Response of the Division of Corporation Finance

Re: Alaska Permanent Fund
Incoming letter dated July 12, 2011

You have requested interpretive advice as to the status of the Alaska Permanent Fund (the "Fund") as an "accredited investor" as defined in Rule 501(a)(3) of Regulation D under the Securities Act of 1933 (the "Securities Act") and as a "qualified institutional buyer" as defined in Rule 144A(a)(1)(i)(H) under the Securities Act. In your letter, you note that the Fund is a large sovereign wealth investment fund with a unique form of organization established by name in the constitution of the State of Alaska.

Based on the facts presented, the Division is of the view that the Fund, although it is not organized as an entity specifically listed in Rule 501(a)(3) of Regulation D, may be treated as an "accredited investor" as defined in that rule if it satisfies the other requirements of that definition. In addition, the Division is of the view that the Fund, although it is not organized as an entity specifically listed in Rule 144A(a)(1)(i)(H), may be treated as a "qualified institutional buyer" as defined in that rule if it satisfies the other requirements of that definition.

This position is based on the representations made to the Division in your letter. Any different facts might require the Division to reach a different conclusion.

Incoming Letter:

The Incoming Letter is in Acrobat format.

http://www.sec.gov/divisions/corpfin/cf-noaction/2011/alaskapermanentfund-071411-501a.htm