WNC Housing Tax Credit Fund VI, L.P., Series 13 and Series 14, and WNC National Partners, LLC; Notice of Application, 46894-46896 [E5-4353]
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46894
Federal Register / Vol. 70, No. 154 / Thursday, August 11, 2005 / Notices
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Rockville Pike (first floor), Rockville,
Maryland. Publicly available records
will be accessible electronically from
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of August 2005.
For The Nuclear Regulatory Commission.
Robert E. Martin,
Senior Project Manager, Section 1, Project
Directorate II, Division of Licensing Project
Management, Office of Nuclear Reactor
Regulation.
[FR Doc. E5–4351 Filed 8–10–05; 8:45 am]
BILLING CODE 7590–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
27026 ; 812–13183]
WNC Housing Tax Credit Fund VI, L.P.,
Series 13 and Series 14, and WNC
National Partners, LLC; Notice of
Application
issued unless the Commission orders a
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on August 29, 2005, and
should be accompanied by proof of
service on applicants in the form of an
affidavit or, for lawyers, a certificate of
service. Hearing requests should state
the nature of the writer’s interest, the
reason for the request, and the issues
contested. Persons may request
notification by writing to the
Commission’s Secretary.
ADDRESSES: Secretary, Commission, 100
F Street, NE., Washington, DC 20549–
9303. Applicants, 17782 Sky Park
Circle, Irvine, California 92614.
FOR FURTHER INFORMATION CONTACT:
Bruce R. MacNeil, Senior Counsel, (202)
551–6817, or Mary Kay Frech, Branch
Chief, (202) 551–6821 (Division of
Investment Management, Office of
Investment Company Regulation).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained for a fee from the
Commission’s Public Reference Branch,
100 F Street, NE., Washington, DC
20549–0102 (telephone (202) 551–5850).
Applicants’ Representations
1. Each Series was formed in 2005 as
a California limited partnership. Each
August 4, 2005.
Series will operate as a ‘‘two-tier’’
AGENCY: Securities and Exchange
partnership, i.e., each Series will invest
Commission (‘‘Commission’’).
as a limited partner in other limited
partnerships (‘‘Local Limited
ACTION: Notice of an application for an
order under sections 6(c) and 6(e) of the Partnerships’’). The Local Limited
Partnerships in turn will engage in the
Investment Company Act of 1940 (the
ownership and operation of apartment
‘‘Act’’) granting relief from all
provisions of the Act, except sections 37 complexes expected to be qualified for
low income housing tax credit under the
through 53 of the Act and the rules and
Internal Revenue Code of 1986, as
regulations under those sections, other
amended. The General Partner is a
than rule 38a–1.
California limited liability company
Applicants: WNC Housing Tax Credit whose sole member is WNC &
Fund VI, L.P., Series 13 and WNC
Associates, Inc. (‘‘WNC & Associates’’),
Housing Tax Credit Fund VI, L.P., Series a California corporation.
14 (each a ‘‘Series,’’ and collectively, the
2. The objectives of each Series are (a)
‘‘Fund’’), and WNC National Partners,
to provide current tax benefits primarily
LLC (the ‘‘General Partner’’).
in the form of low income housing
Summary of the Application:
credits which investors may use to
Applicants request an order to permit
offset their Federal income tax
each Series to invest in limited
liabilities, (b) to preserve and protect
partnerships that engage in the
capital, and (c) to provide cash
ownership and operation of apartment
distributions from sale or refinancing
complexes for low and moderate income transactions.
persons.
3. On April 18, 2005, the Fund filed
a registration statement under the
DATES: The application was filed on
April 18, 2005, and amended on July 22, Securities Act of 1933, pursuant to
which the Fund intends to offer
2005.
Hearing or Notification of Hearing: An publicly, in two series of offerings,
25,000 units of limited partnership
order granting the application will be
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interest (‘‘Units’’) at $1,000 per Unit.
The minimum investment will be five
Units for most investors, although
employees of the General Partner and/
or its affiliates and/or investors in
syndications previously sponsored by
the General Partner and/or its affiliates
may purchase a minimum of two Units.
Purchasers of the Units will become
limited partners (‘‘Limited Partners’’) of
the Series offering the Units.
4. A Series will not accept any
subscriptions for Units until the
requested exemptive order is granted or
the Series receives an opinion of
counsel that it is exempt from
registration under the Act.
Subscriptions for Units must be
approved by the General Partner. Such
approval will be conditioned upon
representations as to suitability of the
investment for each subscriber. The
suitability standards provide, among
other things, that investment in a Series
is suitable only for an investor who
either (a) has a net worth (exclusive of
home, furnishings, and automobiles), of
at least $35,000 and an annual gross
income of at least $35,000, or (b)
irrespective of annual income, has a net
worth (exclusive of home, furnishings,
and automobiles) of at least $75,000.
Units will be sold only to investors who
meet these suitability standards, or such
more restrictive suitability standards as
may be established by certain states for
purchasers of Units within their
respective jurisdictions. In addition,
transfers of Units will be permitted only
if the transferee meets the same
suitability standards as had been
imposed on the transferor Limited
Partner.
5. Although a Series’ direct control
over the management of each apartment
complex will be limited, the Series’
ownership of interests in Local Limited
Partnerships will, in an economic sense,
be tantamount to direct ownership of
the apartment complexes themselves. A
Series normally will acquire at least a
90% interest in the profits, losses, and
tax credits of the Local Limited
Partnerships. However, in certain cases,
the Series may acquire a lesser interest
in such partnerships. Each Local
Limited Partnership’s partnership
agreement will provide that
distributions of proceeds from a sale or
refinancing of an apartment complex
will be paid to a Series in the range of
from 10% to 50%.
6. Each Series will have certain voting
rights with respect to each Local
Limited Partnership. The voting rights
will include the right to dismiss and
replace the local general partner on the
basis of performance, to approve or
disapprove a sale or refinancing of the
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11AUN1
Federal Register / Vol. 70, No. 154 / Thursday, August 11, 2005 / Notices
apartment complex owned by such
Local Limited Partnership, to approve or
disapprove the dissolution of the Local
Limited Partnership, and to approve or
disapprove amendments to the Local
Limited Partnership agreement
materially and adversely affecting the
Series’ investment.
7. Each Series will be controlled by
the General Partner, pursuant to a
partnership agreement (the ‘‘Partnership
Agreement’’). The Limited Partners,
consistent with their limited liability
status, will not be entitled to participate
in the control of the business of the
Series. However, a majority-in-interest
of the Limited Partners will have the
right to amend the Partnership
Agreement (subject to certain
limitations), to remove any General
Partner and elect a replacement, and to
dissolve the Series. In addition, under
the Partnership Agreement, each
Limited Partner is entitled to review all
books and records of the Series.
8. Applicants state that the
Partnership Agreement and prospectus
of the Series contain provisions
designed to ensure fair dealing by the
General Partner with the Limited
Partners. Applicants also state that all
compensation to be paid to the General
Partner and its affiliates is specified in
the Partnership Agreement and
prospectus. Applicants believe that the
fees and other forms of compensation
that will be paid to the General Partner
and its affiliates are fair and on terms no
less favorable to the Series than would
be the case if such arrangements had
been made with independent third
parties.
9. During the offering and
organizational phase, WNC Capital
Corporation, an affiliate of the General
Partner, will receive a dealer-manager
fee and a nonaccountable underwriting
expense allowance in amounts equal to
2% and 1%, respectively, of capital
contributions. The General Partner or an
affiliate will receive a nonaccountable
organizational and offering expense
reimbursement in an amount equal to
3% of capital contributions. The
General Partner has agreed to pay all
organizational and offering expenses
(excluding selling commissions, the
dealer-manager fee, the nonaccountable
underwriting expense allowance and
the nonaccountable expense
reimbursement).
10. During the acquisition phase, each
Series will pay WNC & Associates a fee
equal to 7% of capital contributions for
analyzing and evaluating potential
investments in Local Limited
Partnerships and for various other
services. WNC & Associates will receive
a nonaccountable acquisition expense
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16:14 Aug 10, 2005
Jkt 205001
reimbursement equal to 2% of capital
contributions in consideration of which
WNC & Associates will pay all
acquisition expenses of each Series.
Aggregate fees and expenses paid in
connection with the organization of
each Series, the offering of Units, and
the acquisition of Local Limited
Partnership interests by each Series will
be limited by the Partnership Agreement
and will comply with guidelines
published by the North American
Securities Administrators Association.
These guidelines require that a specified
percentage (generally 80%, but subject
to reduction) of the aggregate Limited
Partners’ capital contributions to the
Fund be committed to Local Limited
Partnership interests.
11. During the operating phase, the
General Partner will receive 0.1% of any
cash available for distribution, and each
Series may pay certain fees and
reimbursements to the General Partner
or its affiliates. An asset management
fee will be payable for services related
to the administration of the affairs of
each Series and ongoing management of
each Series. Other fees may be paid in
consideration of property management
services provided by the General Partner
or its affiliates as the management and
leasing agents for some of the apartment
complexes. In addition, the General
Partner and its affiliates generally will
be allocated 0.1% of profits and losses
of each Series for tax purposes and tax
credits.
12. During the liquidation phase, and
subject to certain prior payments to the
Limited Partners, each Series will pay
the General Partner or its affiliates a fee
equal to 1% of the sales price of the
apartment complexes sold in which the
General Partner or its affiliates have
provided a substantial amount of
services. The General Partner also will
receive 10% of any additional sale or
refinancing proceeds.
13. All proceeds from a Series’ public
offering of Units initially will be placed
in an escrow account with USbank
(‘‘Escrow Agent’’). Pending release of
offering proceeds to the Series, the
Escrow Agent will deposit escrowed
funds in short-term United States
Government securities, securities issued
or guaranteed by the United States
Government, and certificates of deposit
or time or demand deposits in
commercial banks. Upon receipt of a
prescribed minimum amount of capital
contributions for a Series, funds in
escrow will be released to the Series and
held by it pending investment in Local
Limited Partnerships.
14. If more than one entity that the
General Partner or its affiliates advises
or manages may invest in a particular
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46895
investment opportunity, the decision as
to the entity that will be allocated the
investment will be based upon such
factors as the effect of the acquisition on
diversification of each entity’s portfolio,
the estimated income tax effects of the
purchase on each entity, the amount of
funds of each entity available for
investment, and the length of time such
funds have been available for
investment. Priority generally will be
given to the entity having uninvested
funds for the longest period of time.
However, any entity that was formed to
invest primarily in apartment
complexes eligible for state low income
housing tax credits (‘‘state tax credits’’)
as well as for Federal low income
housing tax credits will be given
priority with respect to any investment
that is eligible for state tax credits over
entities which are not seeking to
provide state tax credits.
Applicants’ Legal Analysis
1. Applicants believe that the Fund
and its Series will not be ‘‘investment
companies’’ under sections 3(a)(1)(A) or
3(a)(1)(C) of the Act. If the Fund and its
Series are deemed to be investment
companies, however, applicants request
an exemption under sections 6(c) and
6(e) of the Act from all provisions of the
Act, except sections 37 through 53 of
the Act and the rules and regulations
under those sections, other than rule
38a–1.
2. Section 3(a)(1)(A) of the Act
provides that an issuer is an
‘‘investment company’’ if it is or holds
itself out as being engaged primarily, or
proposes to engage primarily, in the
business of investing, reinvesting, or
trading in securities. Applicants believe
that the Fund will not be an investment
company under section 3(a)(1)(A)
because the Fund will be in the business
of investing in and being beneficial
owner of apartment complexes, not
securities.
3. Section 3(a)(1)(C) of the Act
provides that an issuer is an
‘‘investment company’’ if it is engaged
or proposes to engage in the business of
investing, reinvesting, owning, holding,
or trading in securities, and owns or
proposes to acquire ‘‘investment
securities’’ having a value exceeding
40% of the value of such issuer’s total
assets (exclusive of Government
securities and cash items). Applicants
state that although the Local Limited
Partnership interests may be deemed
‘‘investment securities,’’ they are not
readily marketable, cannot be sold
without severe adverse tax
consequences, and have no value apart
from the value of the apartment
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11AUN1
46896
Federal Register / Vol. 70, No. 154 / Thursday, August 11, 2005 / Notices
complexes owned by the Local Limited
Partnerships.
4. Applicants believe that the two-tier
structure is consistent with the purposes
and criteria set forth in the
Commission’s release concerning twotier real estate partnerships (the
‘‘Release’’).1 The Release states that
investment companies that are two-tier
real estate partnerships that invest in
limited partnerships engaged in the
development and operation of housing
for low and moderate income persons
may qualify for an exemption from the
Act pursuant to section 6(c). Section
6(c) provides that the Commission may
exempt any person from any provision
of the Act and any rule thereunder, if,
and to the extent that, such exemption
is necessary or appropriate in the public
interest and consistent with the
protection of investors and the purposes
fairly intended by the policy and
provisions of the Act. Section 6(e)
permits the Commission to require
companies exempted from the
registration requirements of the Act to
comply with certain specified
provisions of the Act as though the
company were a registered investment
company.
5. The Release lists two conditions,
designed for the protection of investors,
which must be satisfied by two-tier
partnerships to qualify for the
exemption under section 6(c). First,
interests in the issuer should be sold
only to persons for whom investments
in limited profit, essentially tax-shelter,
investments would not be unsuitable.
Second, requirements for fair dealing by
the general partner of the issuer with the
limited partners of the issuer should be
included in the basic organizational
documents of the company.
6. Applicants assert, among other
things, that the suitability standards set
forth in the application, the
requirements for fair dealing provided
by the Partnership Agreement, and
pertinent governmental regulations
imposed on each Local Limited
Partnership by various Federal, state,
and local agencies provide protection to
investors in Units. In addition,
applicants assert that the requested
exemption is both necessary and
appropriate in the public interest.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
J. Lynn Taylor,
Assistant Secretary.
[FR Doc. E5–4353 Filed 8–10–05; 8:45 am]
BILLING CODE 8010–01–P
16:14 Aug 10, 2005
[Release No. 34–52216; File No. SR–Amex–
2005–024]
Self-Regulatory Organizations;
American Stock Exchange LLC; Notice
of Filing of Proposed Rule Change and
Amendment No. 1 Thereto to Establish
a Process for the Waiver, Deferral, or
Rebate of Listing Fees for Certain
Closed-End Funds
August 5, 2005.
Pursuant to section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on February
17, 2005, the American Stock Exchange
LLC (‘‘Amex’’ or ‘‘Exchange’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
items I, II, and III below, which items
have been prepared by the Exchange.
On July 27, 2005, the Exchange filed
Amendment No. 1 to the proposed rule
change.3 The Commission is publishing
this notice to solicit comments on the
proposed rule change, as amended, from
interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Amex proposes to amend Section
140 of the Amex Company Guide to
provide a process for the waiver,
deferral, or rebate of listing fees for
certain closed-end funds. The text of the
proposed rule change is available on the
Amex’s Web site, https://
www.amex.com, at the Amex’s principal
office, and at the Commission’s Public
Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Amex included statements concerning
the purpose of and basis for the
proposed rule change and discussed any
comments it received on the proposal.
The text of these statements may be
examined at the places specified in item
IV below. The Exchange has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of such statements.
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 In Amendment No. 1, the Exchange made nonsubstantive changes to the text of the proposed rule
change.
2 17
1 Investment Company Act Release No. 8465
(Aug. 9, 1974).
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SECURITIES AND EXCHANGE
COMMISSION
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A. Self-Regulatory Organization’s
Statement of the Purpose of, and the
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange is proposing to amend
section 140 of the Amex Company
Guide to provide that the Amex Board
of Governors or its designee may, in its
discretion, waive, defer, or rebate all or
any part of the initial listing fee
applicable to a closed-end fund that
transfers to the Amex from another
marketplace. The Exchange currently
has the authority to waive, defer, or
rebate initial listing fees applicable to
stocks, bonds, and warrants.4 To enable
the Amex to respond to specific
competitive situations, the Exchange
believes it is appropriate to provide the
authority to waive, defer, or rebate all or
any part of the listing fees applicable to
closed-end funds that transfer to the
Amex from another marketplace. Such
authority could be exercised only by the
Amex Board of Governors or its
designee. At its November 17, 2004,
meeting, the Amex Board of Governors
delegated authority to a staff committee,
as its designee, to determine whether to
grant the listing fee waiver, deferral, or
rebate. The committee is comprised of
management representatives from the
Office of the Chairman and the ETF
Marketplace, Finance and Listing
Qualifications Departments.5 In
addition, an attorney from the Office of
the General Counsel would provide
legal counsel to the committee. It is
contemplated that fee reductions would
be granted only infrequently to attract
an important listing that is likely to
generate significant transaction fee
revenue. The committee composition is
intended to ensure that fee reduction
requests receive an appropriate degree
of scrutiny and are granted only under
circumstances in which a reduction is
warranted for competitive reasons. The
waiver, deferral, or rebate of closed-end
fund listing fees would not impact the
Exchange’s resource commitment to
regulatory oversight of the listing or
other regulatory programs.6
4 See Securities Exchange Act Release No. 50270
(August 26, 2004), 69 FR 53750 (September 2, 2004)
(SR–Amex–2004–70).
5 An affirmative vote of a majority of the
committee members attending a particular meeting
(subject to a three person quorum requirement)
would be necessary for waivers, deferrals, or
rebates.
6 The Amex believes that if it determines to
waive, defer, or rebate listing fees in a
comprehensive and/or recurring manner that would
constitute a stated policy, practice, or interpretation
of an existing rule, the Amex would file an
additional rule change pursuant to Rule 19b–4(f)(1)
with respect such policy practice or interpretation.
E:\FR\FM\11AUN1.SGM
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Agencies
[Federal Register Volume 70, Number 154 (Thursday, August 11, 2005)]
[Notices]
[Pages 46894-46896]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E5-4353]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 27026 ; 812-13183]
WNC Housing Tax Credit Fund VI, L.P., Series 13 and Series 14,
and WNC National Partners, LLC; Notice of Application
August 4, 2005.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under sections 6(c) and
6(e) of the Investment Company Act of 1940 (the ``Act'') granting
relief from all provisions of the Act, except sections 37 through 53 of
the Act and the rules and regulations under those sections, other than
rule 38a-1.
-----------------------------------------------------------------------
Applicants: WNC Housing Tax Credit Fund VI, L.P., Series 13 and WNC
Housing Tax Credit Fund VI, L.P., Series 14 (each a ``Series,'' and
collectively, the ``Fund''), and WNC National Partners, LLC (the
``General Partner'').
Summary of the Application: Applicants request an order to permit
each Series to invest in limited partnerships that engage in the
ownership and operation of apartment complexes for low and moderate
income persons.
DATES: The application was filed on April 18, 2005, and amended on July
22, 2005.
Hearing or Notification of Hearing: An order granting the
application will be issued unless the Commission orders a hearing.
Interested persons may request a hearing by writing to the Commission's
Secretary and serving applicants with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 p.m. on August 29, 2005, and should be accompanied by proof of
service on applicants in the form of an affidavit or, for lawyers, a
certificate of service. Hearing requests should state the nature of the
writer's interest, the reason for the request, and the issues
contested. Persons may request notification by writing to the
Commission's Secretary.
ADDRESSES: Secretary, Commission, 100 F Street, NE., Washington, DC
20549-9303. Applicants, 17782 Sky Park Circle, Irvine, California
92614.
FOR FURTHER INFORMATION CONTACT: Bruce R. MacNeil, Senior Counsel,
(202) 551-6817, or Mary Kay Frech, Branch Chief, (202) 551-6821
(Division of Investment Management, Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained for a fee from
the Commission's Public Reference Branch, 100 F Street, NE.,
Washington, DC 20549-0102 (telephone (202) 551-5850).
Applicants' Representations
1. Each Series was formed in 2005 as a California limited
partnership. Each Series will operate as a ``two-tier'' partnership,
i.e., each Series will invest as a limited partner in other limited
partnerships (``Local Limited Partnerships''). The Local Limited
Partnerships in turn will engage in the ownership and operation of
apartment complexes expected to be qualified for low income housing tax
credit under the Internal Revenue Code of 1986, as amended. The General
Partner is a California limited liability company whose sole member is
WNC & Associates, Inc. (``WNC & Associates''), a California
corporation.
2. The objectives of each Series are (a) to provide current tax
benefits primarily in the form of low income housing credits which
investors may use to offset their Federal income tax liabilities, (b)
to preserve and protect capital, and (c) to provide cash distributions
from sale or refinancing transactions.
3. On April 18, 2005, the Fund filed a registration statement under
the Securities Act of 1933, pursuant to which the Fund intends to offer
publicly, in two series of offerings, 25,000 units of limited
partnership interest (``Units'') at $1,000 per Unit. The minimum
investment will be five Units for most investors, although employees of
the General Partner and/or its affiliates and/or investors in
syndications previously sponsored by the General Partner and/or its
affiliates may purchase a minimum of two Units. Purchasers of the Units
will become limited partners (``Limited Partners'') of the Series
offering the Units.
4. A Series will not accept any subscriptions for Units until the
requested exemptive order is granted or the Series receives an opinion
of counsel that it is exempt from registration under the Act.
Subscriptions for Units must be approved by the General Partner. Such
approval will be conditioned upon representations as to suitability of
the investment for each subscriber. The suitability standards provide,
among other things, that investment in a Series is suitable only for an
investor who either (a) has a net worth (exclusive of home,
furnishings, and automobiles), of at least $35,000 and an annual gross
income of at least $35,000, or (b) irrespective of annual income, has a
net worth (exclusive of home, furnishings, and automobiles) of at least
$75,000. Units will be sold only to investors who meet these
suitability standards, or such more restrictive suitability standards
as may be established by certain states for purchasers of Units within
their respective jurisdictions. In addition, transfers of Units will be
permitted only if the transferee meets the same suitability standards
as had been imposed on the transferor Limited Partner.
5. Although a Series' direct control over the management of each
apartment complex will be limited, the Series' ownership of interests
in Local Limited Partnerships will, in an economic sense, be tantamount
to direct ownership of the apartment complexes themselves. A Series
normally will acquire at least a 90% interest in the profits, losses,
and tax credits of the Local Limited Partnerships. However, in certain
cases, the Series may acquire a lesser interest in such partnerships.
Each Local Limited Partnership's partnership agreement will provide
that distributions of proceeds from a sale or refinancing of an
apartment complex will be paid to a Series in the range of from 10% to
50%.
6. Each Series will have certain voting rights with respect to each
Local Limited Partnership. The voting rights will include the right to
dismiss and replace the local general partner on the basis of
performance, to approve or disapprove a sale or refinancing of the
[[Page 46895]]
apartment complex owned by such Local Limited Partnership, to approve
or disapprove the dissolution of the Local Limited Partnership, and to
approve or disapprove amendments to the Local Limited Partnership
agreement materially and adversely affecting the Series' investment.
7. Each Series will be controlled by the General Partner, pursuant
to a partnership agreement (the ``Partnership Agreement''). The Limited
Partners, consistent with their limited liability status, will not be
entitled to participate in the control of the business of the Series.
However, a majority-in-interest of the Limited Partners will have the
right to amend the Partnership Agreement (subject to certain
limitations), to remove any General Partner and elect a replacement,
and to dissolve the Series. In addition, under the Partnership
Agreement, each Limited Partner is entitled to review all books and
records of the Series.
8. Applicants state that the Partnership Agreement and prospectus
of the Series contain provisions designed to ensure fair dealing by the
General Partner with the Limited Partners. Applicants also state that
all compensation to be paid to the General Partner and its affiliates
is specified in the Partnership Agreement and prospectus. Applicants
believe that the fees and other forms of compensation that will be paid
to the General Partner and its affiliates are fair and on terms no less
favorable to the Series than would be the case if such arrangements had
been made with independent third parties.
9. During the offering and organizational phase, WNC Capital
Corporation, an affiliate of the General Partner, will receive a
dealer-manager fee and a nonaccountable underwriting expense allowance
in amounts equal to 2% and 1%, respectively, of capital contributions.
The General Partner or an affiliate will receive a nonaccountable
organizational and offering expense reimbursement in an amount equal to
3% of capital contributions. The General Partner has agreed to pay all
organizational and offering expenses (excluding selling commissions,
the dealer-manager fee, the nonaccountable underwriting expense
allowance and the nonaccountable expense reimbursement).
10. During the acquisition phase, each Series will pay WNC &
Associates a fee equal to 7% of capital contributions for analyzing and
evaluating potential investments in Local Limited Partnerships and for
various other services. WNC & Associates will receive a nonaccountable
acquisition expense reimbursement equal to 2% of capital contributions
in consideration of which WNC & Associates will pay all acquisition
expenses of each Series. Aggregate fees and expenses paid in connection
with the organization of each Series, the offering of Units, and the
acquisition of Local Limited Partnership interests by each Series will
be limited by the Partnership Agreement and will comply with guidelines
published by the North American Securities Administrators Association.
These guidelines require that a specified percentage (generally 80%,
but subject to reduction) of the aggregate Limited Partners' capital
contributions to the Fund be committed to Local Limited Partnership
interests.
11. During the operating phase, the General Partner will receive
0.1% of any cash available for distribution, and each Series may pay
certain fees and reimbursements to the General Partner or its
affiliates. An asset management fee will be payable for services
related to the administration of the affairs of each Series and ongoing
management of each Series. Other fees may be paid in consideration of
property management services provided by the General Partner or its
affiliates as the management and leasing agents for some of the
apartment complexes. In addition, the General Partner and its
affiliates generally will be allocated 0.1% of profits and losses of
each Series for tax purposes and tax credits.
12. During the liquidation phase, and subject to certain prior
payments to the Limited Partners, each Series will pay the General
Partner or its affiliates a fee equal to 1% of the sales price of the
apartment complexes sold in which the General Partner or its affiliates
have provided a substantial amount of services. The General Partner
also will receive 10% of any additional sale or refinancing proceeds.
13. All proceeds from a Series' public offering of Units initially
will be placed in an escrow account with USbank (``Escrow Agent'').
Pending release of offering proceeds to the Series, the Escrow Agent
will deposit escrowed funds in short-term United States Government
securities, securities issued or guaranteed by the United States
Government, and certificates of deposit or time or demand deposits in
commercial banks. Upon receipt of a prescribed minimum amount of
capital contributions for a Series, funds in escrow will be released to
the Series and held by it pending investment in Local Limited
Partnerships.
14. If more than one entity that the General Partner or its
affiliates advises or manages may invest in a particular investment
opportunity, the decision as to the entity that will be allocated the
investment will be based upon such factors as the effect of the
acquisition on diversification of each entity's portfolio, the
estimated income tax effects of the purchase on each entity, the amount
of funds of each entity available for investment, and the length of
time such funds have been available for investment. Priority generally
will be given to the entity having uninvested funds for the longest
period of time. However, any entity that was formed to invest primarily
in apartment complexes eligible for state low income housing tax
credits (``state tax credits'') as well as for Federal low income
housing tax credits will be given priority with respect to any
investment that is eligible for state tax credits over entities which
are not seeking to provide state tax credits.
Applicants' Legal Analysis
1. Applicants believe that the Fund and its Series will not be
``investment companies'' under sections 3(a)(1)(A) or 3(a)(1)(C) of the
Act. If the Fund and its Series are deemed to be investment companies,
however, applicants request an exemption under sections 6(c) and 6(e)
of the Act from all provisions of the Act, except sections 37 through
53 of the Act and the rules and regulations under those sections, other
than rule 38a-1.
2. Section 3(a)(1)(A) of the Act provides that an issuer is an
``investment company'' if it is or holds itself out as being engaged
primarily, or proposes to engage primarily, in the business of
investing, reinvesting, or trading in securities. Applicants believe
that the Fund will not be an investment company under section
3(a)(1)(A) because the Fund will be in the business of investing in and
being beneficial owner of apartment complexes, not securities.
3. Section 3(a)(1)(C) of the Act provides that an issuer is an
``investment company'' if it is engaged or proposes to engage in the
business of investing, reinvesting, owning, holding, or trading in
securities, and owns or proposes to acquire ``investment securities''
having a value exceeding 40% of the value of such issuer's total assets
(exclusive of Government securities and cash items). Applicants state
that although the Local Limited Partnership interests may be deemed
``investment securities,'' they are not readily marketable, cannot be
sold without severe adverse tax consequences, and have no value apart
from the value of the apartment
[[Page 46896]]
complexes owned by the Local Limited Partnerships.
4. Applicants believe that the two-tier structure is consistent
with the purposes and criteria set forth in the Commission's release
concerning two-tier real estate partnerships (the ``Release'').\1\ The
Release states that investment companies that are two-tier real estate
partnerships that invest in limited partnerships engaged in the
development and operation of housing for low and moderate income
persons may qualify for an exemption from the Act pursuant to section
6(c). Section 6(c) provides that the Commission may exempt any person
from any provision of the Act and any rule thereunder, if, and to the
extent that, such exemption is necessary or appropriate in the public
interest and consistent with the protection of investors and the
purposes fairly intended by the policy and provisions of the Act.
Section 6(e) permits the Commission to require companies exempted from
the registration requirements of the Act to comply with certain
specified provisions of the Act as though the company were a registered
investment company.
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\1\ Investment Company Act Release No. 8465 (Aug. 9, 1974).
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5. The Release lists two conditions, designed for the protection of
investors, which must be satisfied by two-tier partnerships to qualify
for the exemption under section 6(c). First, interests in the issuer
should be sold only to persons for whom investments in limited profit,
essentially tax-shelter, investments would not be unsuitable. Second,
requirements for fair dealing by the general partner of the issuer with
the limited partners of the issuer should be included in the basic
organizational documents of the company.
6. Applicants assert, among other things, that the suitability
standards set forth in the application, the requirements for fair
dealing provided by the Partnership Agreement, and pertinent
governmental regulations imposed on each Local Limited Partnership by
various Federal, state, and local agencies provide protection to
investors in Units. In addition, applicants assert that the requested
exemption is both necessary and appropriate in the public interest.
For the Commission, by the Division of Investment Management,
pursuant to delegated authority.
J. Lynn Taylor,
Assistant Secretary.
[FR Doc. E5-4353 Filed 8-10-05; 8:45 am]
BILLING CODE 8010-01-P