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PIMCO Advisors Holdings L.P.
800 Newport Center Drive
Newport Beach, CA 92660
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: PIMCO Advisors Holdings L.P.
Form RW - Application for Withdrawal
File Nos. 333-09618, 333-43201, 333-47417 and 333-53055
Ladies and Gentlemen:
Pursuant to Rule 477(a) of Regulation C of the General Rules and
Regulations under the Securities Act of 1933, as amended, the undersigned on
behalf of PIMCO Advisors Holdings L.P. (the "Registrant"), respectfully requests
an order granting the immediate withdrawal of (i) its registration statement on
Form S-8, File No. 333-09618, together with all exhibits and any amendments
thereto, filed with the Securities and Exchange Commission on October 7, 1998
(the "October 1998 Form S-8"), (ii) its registration statement on Form S-8, File
No. 333-43201, together with all exhibits and any amendments thereto, filed with
the Securities and Exchange Commission on December 24, 1997 (the "December 1997
Form S-8") (iii) its registration statement on Form S-3, File No. 333-47417,
together with all exhibits thereto, filed with the Securities and Exchange
Commission on March 6, 1998 (the "Form S-3") and (iv) its registration statement
on Form S-4, File No. 333-53055, together with all exhibits thereto, originally
filed with the Securities and Exchange Commission on May 19, 1998, as amended
(the "Form S-4", and together with the October 1998 Form S-8, the December 1997
Form S-8 and the Form S-3, the "Registration Statements"). The Form S-3 and the
Form S-4 were filed with the Securities and Exchange Commission pursuant to Rule
415 of the Securities Act of 1933, as amended.
Affiliates of Allianz AG, a German insurer, completed its acquisition of
the Registrant and a majority of the equity interests in its wholly owned
subsidiary, PIMCO Advisors L.P., on May 5, 2000. On that date, the Registrant
filed a Form 15 with the Securities and Exchange Commission to terminate the
registration of the Registrant under the Securities Exchange Act of 1934, as
amended, and its obligations to file reports thereunder. On May 9, 2000, the
New York Stock Exchange filed a notification on Form 25 with the Securities and
Exchange Commission of its intent to delist and deregister the Registrant. No
offers of sales of securities have been made pursuant to the Registration
Statements since May 5, 2000.
Should you have any questions concerning this matter, please do not
hesitate to contact David C. Flattum, Esq. at Latham & Watkins, legal counsel
for the Registrant, at (714) 540-1235. Thank you for your assistance and
cooperation in this matter.
PIMCO Advisors Holdings L.P.
By: /s/ Robert M. Fitzgerald
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Name: Robert M. Fitzgerald
Title: Chief Financial Officer
