Van Eck Associates Corporation, et al.; Notice of Application, 19214-19221 [E6-5483]
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Federal Register / Vol. 71, No. 71 / Thursday, April 13, 2006 / Notices
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[FR Doc. E6–5524 Filed 4–12–06; 8:45 am]
BILLING CODE 3110–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
27283; 812–12947]
Van Eck Associates Corporation, et al.;
Notice of Application
April 7, 2006.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 6(c) of the
Investment Company Act of 1940 (the
‘‘Act’’) for an exemption from sections
2(a)(32), 5(a)(1), 22(d), and 24(d) of the
Act and rule 22c–1 under the Act, under
section 12(d)(1)(J) for an exemption
from sections 12(d)(1)(A) and (B) of the
Act, and under sections 6(c) and 17(b)
of the Act for an exemption from
sections 17(a)(1) and (a)(2) of the Act.
AGENCY:
Summary of Application: Applicants
request an order that would permit (a)
series of open-end management
investment companies, to issue shares
(‘‘Shares’’) that can be redeemed only in
large aggregations (‘‘Creation Units’’); (b)
secondary market transactions in Shares
to occur at negotiated prices; (c) dealers
to sell Shares to purchasers in the
secondary market unaccompanied by a
prospectus when prospectus delivery is
not required by the Securities Act of
1933 (‘‘Securities Act’’); (d) certain
affiliated persons of the series to deposit
securities into, and receive securities
from, the series in connection with the
purchase and redemption of Creation
Units; and (e) certain registered
management investment companies and
unit investment trusts outside of the
same group of investment companies as
the series to acquire Shares.
Applicants: Van Eck Associates
Corporation (the ‘‘Adviser’’); Market
Vectors—Gold Miners ETF (the
‘‘Trust’’); and Van Eck Securities
Corporation (the ‘‘Distributor’’).
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Filing Dates: The application was
filed on March 25, 2003, and amended
on February 3, 2006. Applicants have
agreed to file an amendment during the
notice period, the substance of which is
reflected in the notice.
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 May 1, 2006, 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 who wish to be
notified of a hearing may request
notification by writing to the
Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F
Street, NE., Washington, DC 20549–
1090; Applicants, 99 Park Avenue, 8th
Floor, New York, NY 10016.
FOR FURTHER INFORMATION CONTACT:
Deepak T. Pai, Senior Counsel at (202)
551–6876, or Michael W. Mundt, Senior
Special Counsel, at (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 at the Public
Reference Desk, U.S. Securities and
Exchange Commission, 100 F Street,
NE., Washington DC 20549–0102,
telephone (202) 551–5850.
Applicants’ Representations
1. The Trust is registered as an openend management investment company
and is organized as a Delaware trust
authorized to issue multiple series. The
Trust intends to offer and sell shares of
one or more series (each an ‘‘Index
Fund’’), including the Market Vectors—
Gold Miners ETF (‘‘Initial Index Fund’’).
The Adviser is registered as an
investment adviser under the
Investment Advisers Act of 1940, as
amended (the ‘‘Advisers Act’’) and will
serve as the investment adviser to each
Index Fund. In the future, the Adviser
may enter into sub-advisory agreements
with other investment advisers to act as
‘‘sub-advisers’’ with respect to
particular Index Funds. Any sub-adviser
will be registered under the Advisers
Act or exempt from registration. The
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Distributor, a broker-dealer registered
under the Securities Exchange Act of
1934 (the ‘‘Exchange Act’’), will serve as
the principal underwriter and
distributor for the Index Funds.
2. Each Index Fund will hold certain
securities (‘‘Portfolio Securities’’)
selected to correspond generally to the
price and yield performance, before fees
and expenses, of a specified equity
securities index (each an ‘‘Underlying
Index’’). No entity that creates,
compiles, sponsors or maintains an
Underlying Index is or will be an
affiliated person, as defined in section
2(a)(3) of the Act, or an affiliated person
of an affiliated person, of the Trust, the
Adviser, the Distributor, promoter or
any sub-adviser to an Index Fund. The
Underlying Index for the Initial Index
Fund is the Amex Gold Miners Index,
a modified market capitalization
weighted index comprised of publiclytraded companies involved primarily in
mining for gold and silver. The Trust
may offer additional Index Funds in the
future based on other Underlying
Indexes (‘‘Future Index Funds’’). Any
Future Index Funds will (a) comply
with the terms and conditions of any
order granted pursuant to the
application and (b) be advised by the
Adviser.
3. The investment objective of each
Index Fund will be to provide
investment results that correspond
generally to the price and yield
performance, before fees and expenses,
of its Underlying Index. Intra-day values
of the Underlying Index will be
disseminated every 15 seconds
throughout the trading day. An Index
Fund will utilize either a ‘‘replication’’
or ‘‘representative sampling’’ strategy.1
An Index Fund using a ‘‘replication’’
strategy will invest in substantially all
of the Component Securities in its
Underlying Index in approximately the
same weightings as in the Underlying
Index. In certain circumstances, such as
when there are practical difficulties or
substantial costs involved in holding
every security in an Underlying Index or
when a Component Security is illiquid,
an Index Fund may use a
‘‘representative sampling’’ strategy
pursuant to which it will invest in
1 Applicants represent that the Index Fund will
normally invest at least 95% of its total assets in
the component securities that comprise its
Underlying Index (‘‘Component Securities’’). Each
Index Fund also may invest up to 5% of its assets
in money market instruments or money market
funds that comply with rule 2(a)(7) under the Act,
in futures contracts, options, options on futures
contracts, swap contracts, cash and cash
equivalents, as well as in stocks not included in its
Underlying Index, but which the Adviser believes
will help the Index Fund track its Underlying
Index.
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some, but not all of the relevant
Component Securities.2 Applicants
anticipate that an Index Fund that
utilizes a ‘‘representative sampling’’
strategy will not track the performance
of its Underlying Index with the same
degree of accuracy as an investment
vehicle that invests in every Component
Security of the Underlying Index in the
same weighting as the Underlying
Index. Applicants expect that each
Index Fund will have a tracking error
relative to the performance of its
Underlying Index of less than 5 percent.
4. Shares of the Index Funds will be
sold at a price of between $40 and $50
per Share in Creation Units of 50,000
Shares. All orders to purchase Creation
Units must be placed with the
Distributor by or through a party that
has entered into an agreement with the
Trust and Distributor (‘‘Authorized
Participant’’). An Authorized
Participant must be either: (a) A brokerdealer or other participant in the
continuous net settlement system of the
National Securities Clearing Corporation
(‘‘NSCC’’), a clearing agency registered
with the Commission, or (b) a
participant in the Depository Trust
Company (‘‘DTC’’, and such participant,
‘‘DTC Participant’’). Shares of each
Index Fund generally will be sold in
Creation Units in exchange for an inkind deposit by the purchaser of a
portfolio of securities designated by the
Adviser to correspond generally to the
price and yield performance, before fees
and expenses, of the relevant
Underlying Index (the ‘‘Deposit
Securities’’), together with the deposit of
a relatively small specified cash
payment (‘‘Cash Component’’). The
Cash Component is generally an amount
equal to the difference between (a) the
net asset value (‘‘NAV’’) (per Creation
Unit) of the Index Fund and (b) the total
aggregate market value (per Creation
Unit) of the Deposit Securities.3
2 Under the ‘‘representative sampling’’ strategy,
the Adviser will seek to construct an Index Fund’s
portfolio so that its market capitalization, industry
weightings, fundamental investment characteristics
(such as return variability, earnings valuation and
yield) and liquidity measures perform like those of
the Underlying Index.
3 The Trust will sell Creation Units of each Index
Fund on any day that an Index Fund is open for
business, including as required by section 22(e) of
the Act (a ‘‘Business Day’’). In addition to the list
of names and amount of each security constituting
the current Deposit Securities, it is intended that,
on each Business Day, the Cash Component
effective as of the previous Business Day, per
outstanding Share of each Index Fund, will be made
available. The Exchanges intend to disseminate,
every 15 seconds, during their respective regular
trading hours, through the facilities of the
Consolidated Tape Association (‘‘CTA’’), an
approximate amount per Share representing the
sum of the estimated Cash Component effective
through and including the previous Business Day,
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Applicants state that in some
circumstances it may not be practicable
or convenient for an Index Fund to
operate exclusively on an ‘‘in-kind’’
basis. The Trust reserves the right to
permit, under certain circumstances, a
purchaser of Creation Units to substitute
cash in lieu of depositing some or all of
the requisite Deposit Securities. An
investor purchasing a Creation Unit
from an Index Fund will be charged a
fee (‘‘Transaction Fee’’) to prevent the
dilution of the interests of the remaining
shareholders resulting from costs in
connection with the purchase of
Creation Units.4 The maximum
Transaction Fees relevant to each Index
Fund will be fully disclosed in the
prospectus (‘‘Prospectus’’) of such Index
Fund or statement of additional
information (‘‘SAI’’). All orders to
purchase Creation Units will be placed
with the Distributor by or through an
Authorized Participant and it will be the
Distributor’s responsibility to transmit
such orders to the Trust. The Distributor
also will be responsible for delivering
the Prospectus to those persons
purchasing Creation Units, and for
maintaining records of both the orders
placed with it and the confirmations of
acceptance furnished by it. In addition,
the Distributor will maintain a record of
the instructions given to the Trust to
implement the delivery of Shares.
5. Purchasers of Shares in Creation
Units may hold such Shares or may sell
such Shares into the secondary market.
Shares will be listed and traded on the
American Stock Exchange, LLC,
(‘‘Amex’’), another U.S. national
securities exchange as defined in
section 2(a)(26) of the Act, and Nasdaq
Stock Market (‘‘Nasdaq’’) (each, an
‘‘Exchange’’). It is expected that one or
more member firms of a listing
Exchange will be designated to act as a
specialist and maintain a market for
Shares on the Exchange (the ‘‘Exchange
Specialist’’), or if Nasdaq is the listing
Exchange, one or more member firms of
Nasdaq will act as a market maker
(‘‘Market Maker’’) and maintain a
market for Shares.5 Prices of Shares
plus the current value of the Deposit Securities, on
a per Share basis.
4 Where an Index Fund permits a purchaser to
substitute cash in lieu of depositing a portion of the
requisite Deposit Securities, the purchaser may be
assessed a higher Transaction Fee to cover the cost
of purchasing such Deposit Securities, including
brokerage costs, and part or all of the spread
between the expected bid and the offer side of the
market relating to such Deposit Securities.
5 If Shares are listed on the Nasdaq, no particular
Market Maker will be contractually obligated to
make a market in Shares, although Nasdaq’s listing
requirements stipulate that at least two Market
Makers must be registered as Market Makers in
Shares to maintain the listing. Registered Market
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trading on an Exchange will be based on
the current bid/offer market. Shares sold
in the secondary market will be subject
to customary brokerage commissions
and charges.
6. Applicants expect that purchasers
of Creation Units will include
institutional investors and arbitrageurs
(which could include institutional
investors). The Exchange Specialist, or
Market Maker, in providing a fair and
orderly secondary market for the Shares,
also may purchase Creation Units for
use in its market-making activities.
Applicants expect that secondary
market purchasers of Shares will
include both institutional investors and
retail investors.6 Applicants expect that
the price at which the Shares trade will
be disciplined by arbitrage
opportunities created by the ability to
continually purchase or redeem
Creation Units at their NAV, which
should ensure that the Shares will not
trade at a material discount or premium
in relation to their NAV.
7. Shares will not be individually
redeemable, and owners of Shares may
acquire those Shares from the Index
Fund, or tender such Shares for
redemption to the Index Fund, in
Creation Units only. To redeem, an
investor will have to accumulate enough
Shares to constitute a Creation Unit.
Redemption orders must be placed by or
through an Authorized Participant. An
investor redeeming a Creation Unit
generally will receive (a) a portfolio of
securities designated to be delivered for
Creation Unit redemptions on the date
that the request for redemption is
submitted (‘‘Fund Securities’’), which
may not be identical to the Deposit
Securities required to purchase Creation
Units on that date, and (b) a ‘‘Cash
Redemption Payment,’’ consisting of an
amount calculated in the same manner
as the Cash Component, although the
actual amount of the Cash Redemption
Payment may differ from the Cash
Component if the Fund Securities are
not identical to the Deposit Securities
on that day. An investor may receive the
cash equivalent of a Fund Security in
certain circumstances, such as if the
investor is constrained from effecting
transactions in the security by
regulation or policy. A redeeming
investor may pay a Transaction Fee,
calculated in the same manner as a
Makers are required to make a continuous, twosided market at all times or be subject to regulatory
sanctions.
6 Shares will be registered in book-entry form
only. DTC or its nominee will be the registered
owner of all outstanding Shares. DTC or DTC
Participants will maintain records reflecting
beneficial owners of Shares.
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Transaction Fee payable in connection
with purchases of Creation Units.
8. Neither the Trust nor any
individual Index Fund will be marketed
or otherwise held out as an ‘‘open-end
investment company’’ or a ‘‘mutual
fund.’’ Instead, each Fund will be
marketed as an ‘‘exchange-traded fund,’’
an ‘‘investment company,’’ a ‘‘fund,’’ or
a ‘‘trust.’’ All marketing materials that
describe the method of obtaining,
buying or selling Shares, or refer to
redeemability, will prominently
disclose that Shares are not individually
redeemable and that the owners of
Shares may purchase or redeem Shares
from the Index Fund in Creation Units
only. The same approach will be
followed in the SAI, shareholder reports
and investor educational materials
issued or circulated in connection with
the Shares. The Funds will provide
copies of their annual and semi-annual
shareholder reports to DTC Participants
for distribution to beneficial owners of
Shares.
Applicants’ Legal Analysis
1. Applicants request an order under
section 6(c) of the Act for an exemption
from sections 2(a)(32), 5(a)(1), 22(d) and
24(d) of the Act and rule 22c–1 under
the Act, under section 12(d)(1)(J) for an
exemption from sections 12(d)(1)(A) and
(B) of the Act, and under sections 6(c)
and 17(b) of the Act for an exemption
from sections 17(a)(1) and 17(a)(2) of the
Act.
2. Section 6(c) of the Act provides that
the Commission may exempt any
person, security or transaction, or any
class of persons, securities or
transactions, from any provision of the
Act, 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 17(b)
of the Act authorizes the Commission to
exempt a proposed transaction from
section 17(a) of the Act if evidence
establishes that the terms of the
transaction, including the consideration
to be paid or received, are reasonable
and fair and do not involve
overreaching on the part of any person
concerned, and the proposed
transaction is consistent with the
policies of the registered investment
company and the general provisions of
the Act. Section 12(d)(1)(J) of the Act
provides that the Commission may
exempt any person, security, or
transaction, or any class or classes of
persons, securities or transactions, from
any provisions of section 12(d)(1) if the
exemption is consistent with the public
interest and the protection of investors.
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Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an
‘‘open-end company’’ as a management
investment company that is offering for
sale or has outstanding any redeemable
security of which it is the issuer.
Section 2(a)(32) of the Act defines a
redeemable security as any security,
other than short-term paper, under the
terms of which the owner, upon its
presentation to the issuer, is entitled to
receive approximately his proportionate
share of the issuer’s current net assets,
or the cash equivalent. Because Shares
will not be individually redeemable,
applicants request an order that would
permit the Trust to register as an openend management investment company
and issue Shares that are redeemable in
Creation Units only. Applicants state
that investors may purchase Shares in
Creation Units and redeem Creation
Units from each Fund. Applicants
further state that because the market
price of Shares will be disciplined by
arbitrage opportunities, investors should
be able to sell Shares in the secondary
market at prices that do not vary
substantially from their NAV.
Section 22(d) of the Act and Rule
22c–1 Under the Act
4. Section 22(d) of the Act, among
other things, prohibits a dealer from
selling a redeemable security, which is
currently being offered to the public by
or through a principal underwriter,
except at a current public offering price
described in the prospectus. Rule 22c–
1 under the Act generally requires that
a dealer selling, redeeming or
repurchasing a redeemable security do
so only at a price based on its NAV.
Applicants state that secondary market
trading in Shares will take place at
negotiated prices, not at a current
offering price described in the
Prospectus, and not at a price based on
NAV. Thus, purchases and sales of
Shares in the secondary market will not
comply with section 22(d) of the Act
and rule 22c–1 under the Act.
Applicants request an exemption under
section 6(c) from these provisions.
5. Applicants assert that the concerns
sought to be addressed by section 22(d)
of the Act and rule 22c–1 under the Act
with respect to pricing are equally
satisfied by the proposed method of
pricing Shares. Applicants maintain that
while there is little legislative history
regarding section 22(d), its provisions,
as well as those of rule 22c–1, appear to
have been designed to (a) prevent
dilution caused by certain risklesstrading schemes by principal
underwriters and contract dealers, (b)
prevent unjust discrimination or
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preferential treatment among buyers,
and (c) ensure an orderly distribution of
investment company shares by
eliminating price competition from
dealers offering shares at less than the
published sales price and repurchasing
shares at more than the published
redemption price.
6. Applicants believe that none of
these purposes will be thwarted by
permitting Shares to trade in the
secondary market at negotiated prices.
Applicants state that (a) secondary
market trading in Shares does not
involve the Index Funds as parties and
cannot result in dilution of an
investment in Shares, and (b) to the
extent different prices exist during a
given trading day, or from day to day,
such variances occur as a result of thirdparty market forces, such as supply and
demand. Therefore, applicants assert
that secondary market transactions in
Shares will not lead to discrimination or
preferential treatment among
purchasers. Finally, applicants contend
that the proposed distribution system
will be orderly because arbitrage activity
will ensure that the difference between
the market price of Shares and their
NAV remains narrow.
HSRObinson on PROD1PC61 with NOTICES
Section 24(d) of the Act
7. Section 24(d) of the Act provides,
in relevant part, that the prospectus
delivery exemption provided to dealer
transactions by section 4(3) of the
Securities Act does not apply to any
transaction in a redeemable security
issued by an open-end investment
company. Applicants seek relief from
section 24(d) to permit dealers selling
Shares to rely on the prospectus
delivery exemption provided by section
4(3) of the Securities Act.7
7 Applicants state that they are not seeking relief
from the prospectus delivery requirement for nonsecondary market transactions, such as transactions
in which an investor purchases Shares from the
Trust or an underwriter. Applicants further state
that the Prospectus will caution broker-dealers and
others that some activities on their part, depending
on the circumstances, may result in their being
deemed statutory underwriters and subject them to
the Prospectus delivery and liability provisions of
the Securities Act. For example, a broker-dealer
firm and/or its client may be deemed a statutory
underwriter if it purchases Creation Units from an
Index Fund, breaks them down into the constituent
Shares, and sells those Shares directly to customers,
or if it chooses to couple the creation of a supply
of new Shares with an active selling effort involving
solicitation of secondary market demand for Shares.
Each Index Fund’s Prospectus will state that
whether a person is an underwriter depends upon
all of the facts and circumstances pertaining to that
person’s activities. Each Index Fund’s Prospectus
will caution dealers who are not ‘‘underwriters’’ but
are participating in a distribution (as contrasted to
ordinary secondary trading transactions), and thus
dealing with Shares that are part of an ‘‘unsold
allotment’’ within the meaning of section 4(3)(C) of
the Securities Act, that they would be unable to
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8. Applicants state that Shares are
bought and sold in the secondary
market in the same manner as closedend fund shares. Applicants note that
transactions in closed-end fund shares
are not subject to section 24(d), and thus
closed-end fund shares are sold in the
secondary market without a prospectus.
Applicants contend that Shares likewise
merit a reduction in the unnecessary
compliance costs and regulatory
burdens resulting from the imposition of
the prospectus delivery obligations in
the secondary market. Because Shares
will be listed on an Exchange,
prospective investors will have access to
information about the product over and
above what is normally available about
an open-end security. Applicants state
that information regarding market price
and volume will be continually
available on a real time basis throughout
the day on brokers’ computer screens
and other electronic services. The
previous day’s price and volume
information will be published daily in
the financial section of newspapers. In
addition, the Trust also intends to
maintain a Web site that will include
the Prospectus and SAI, the relevant
Underlying Index for each Index Fund
and additional quantitative information
that is updated on a daily basis,
including daily trading volume, closing
price, the NAV for each Index Fund and
information about the premiums and
discounts at which the Index Fund’s
Shares have traded.
9. Applicants will arrange for brokerdealers selling Shares in the secondary
market to provide purchasers with a
product description (‘‘Product
Description’’) that describes, in plain
English, the relevant Index Fund and
the Shares it issues. Applicants state
that a Product Description is not
intended to substitute for a full
Prospectus. Applicants state that the
Product Description will be tailored to
meet the information needs of investors
purchasing Shares in the secondary
market.
Section 12(d)(1)
10. Section 12(d)(1)(A) of the Act
prohibits a registered investment
company from acquiring securities of an
investment company if such securities
represent more than 3% of the total
outstanding voting stock of the acquired
company, more than 5% of the total
assets of the acquiring company, or,
together with the securities of any other
investment companies, more than 10%
of the total assets of the acquiring
take advantage of the prospectus delivery
exemption provided by section 4(3) of the
Securities Act.
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company. Section 12(d)(1)(B) of the Act
prohibits a registered open-end
investment company, its principal
underwriter and any other broker-dealer
from selling the investment company’s
shares to another investment company if
the sale will cause the acquiring
company to own more than 3% of the
acquired company’s voting stock, or if
the sale will cause more than 10% of the
acquired company’s voting stock to be
owned by investment companies
generally.
11. Applicants request an exemption
to permit management investment
companies (‘‘Investing Management
Companies’’) and unit investment trusts
(‘‘Investing Trusts’’) registered under the
Act that are not part of the same ‘‘group
of investment companies,’’ as defined in
section 12(d)(1)(G)(ii) of the Act, as the
Trust to acquire shares of an Index Fund
beyond the limits of section 12(d)(1)(A)
and (B), (Investing Management
Companies and Investing Trusts
collectively, ‘‘Investing Funds’’).
Investing Funds exclude registered
investment companies that are, or in the
future may be, part of the same group
of investment companies within the
meaning of section 12(d)(1)(G)(ii) of the
Act as the Index Funds. In addition,
applicants seek relief to permit an Index
Fund and the Distributor or any broker
or dealer (‘‘Broker’’) that is registered
under the Exchange Act to knowingly
sell shares of the Index Fund to an
Investing Fund in excess of the limits of
section 12(d)(1)(B). Applicants request
that the relief sought apply to (a) Index
Funds that are advised by the Adviser
and in the same group of investment
companies as the Trust, (b) each
Investing Fund that enters into a
participation agreement with the Index
Fund (‘‘Participation Agreement’’), and
(c) any Broker.8
12. Each Investing Management
Company will be advised by an
investment adviser within the meaning
of section 2(a)(20)(A) of the Act (the
‘‘Investing Fund Advisor’’) and may be
advised by one or more investment
advisers within the meaning of section
2(a)(20)(B) of the Act (each a
‘‘Subadviser’’). Any investment adviser
to an Investing Fund will be registered
under the Advisers Act or exempt from
registration. Each Investing Trust will be
sponsored by a sponsor (‘‘Sponsor’’).
8 All parties that currently intend to rely on the
requested relief from section 12(d)(1) are named as
applicants. Any other party that relies on this relief
in the future will comply with the terms and
conditions of the application. An Investing Fund
may rely on the requested order only to invest in
the Index Funds and not in any other registered
investment company.
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13. Applicants submit that the
proposed conditions to the relief
requested adequately address the
concerns underlying the limits in
section 12(d)(1)(A) and (B), which
include concerns about undue
influence, excessive layering of fees and
overly complex structures. Applicants
believe that the requested exemption is
consistent with the public interest and
the protection of investors.
14. Applicants believe that neither the
Investing Funds nor an Investing Fund
Affiliate would be able to exert undue
influence over the Index Funds.9 To
limit the control that an Investing Fund
may have over an Index Fund,
applicants propose a condition
prohibiting an Investing Fund Advisor
or a Sponsor, any person controlling,
controlled by, or under common control
with an Investing Fund Advisor or
Sponsor, and any investment company
and any issuer that would be an
investment company but for sections
3(c)(1) or 3(c)(7) of the Act that is
advised or sponsored by an Investing
Fund Advisor or Sponsor, or any person
controlling, controlled by, or under
common control with an Investing Fund
Advisor or Sponsor (‘‘Investing Fund
Advisor/Sponsor Group’’) from
controlling (individually or in the
aggregate) an Index Fund within the
meaning of section 2(a)(9) of the Act.
The same prohibition would apply to
any Subadviser, any person controlling,
controlled by or under common control
with the Subadviser, and any
investment company or issuer that
would be an investment company but
for sections 3(c)(1) or 3(c)(7) of the Act
(or portion of such investment company
or issuer) advised or sponsored by the
Subadviser or any person controlling,
controlled by or under common control
with the Subadviser (‘‘Subadviser
Group’’). Applicants propose other
conditions to limit the potential for
undue influence over the Index Funds,
including that no Investing Fund or
Investing Fund Affiliate (except to the
extent it is acting in its capacity as an
investment adviser to an Index Fund)
will cause an Index Fund to purchase a
security in any offering of securities
during the existence of any
underwriting or selling syndicate of
which a principal underwriter is an
Underwriting Affiliate (‘‘Affiliated
Underwriting’’). An ‘‘Underwriting
Affiliate’’ is a principal underwriter in
any underwriting or selling syndicate
9 An ‘‘Investing Fund Affiliate’’ is an Investing
Fund Advisor, Subadviser, Sponsor, promoter, and
principal underwriter of an Investing Fund, and any
person controlling, controlled by, or under common
control with any of those entities.
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that is an officer, director, member of an
advisory board, Investing Fund Advisor,
Subadviser, employee or Sponsor of an
Investing Fund, or a person which any
such officer, director, member of an
advisory board, Investing Fund Advisor,
Subadviser, employee, or Sponsor is an
affiliated person (except any person
whose relationship to the Index Fund is
covered by section 10(f) of the Act is not
an Underwriting Affiliate.)
15. Applicants do not believe the
proposed arrangement will involve
excessive layering of fees. The board of
directors or trustees of any Investing
Management Company, including a
majority of the disinterested directors or
trustees, will find that the advisory fees
charged to the Investing Management
Company are based on services
provided that will be in addition to,
rather than duplicative of, services
provided under the advisory contract(s)
of any Index Fund in which the
Investing Management Company may
invest. In addition, an Investing Fund
Advisor or a trustee or Sponsor of an
Investing Trust will waive fees
otherwise payable to it by the Investing
Management Company or Investing
Trust in an amount at least equal to any
compensation (including fees received
pursuant to any plan adopted by an
Index Fund under rule 12b–1 under the
Act) received by the Investing Fund
Advisor or trustee or Sponsor to the
Investing Trust or an affiliated person of
the Investing Fund Advisor, trustee or
Sponsor, from the Index Funds in
connection with the investment by the
Investing Management Company or
Investing Trust in the Index Fund.
Applicants state that any sales loads or
service fees charged with respect to
shares of an Investing Fund will not
exceed the limits applicable to a fund of
funds set forth in Conduct Rule 2830 of
the NASD.
16. Applicants submit that the
proposed arrangement will not create an
overly complex fund structure.
Applicants note that no Index Fund may
acquire securities of any investment
company or company relying on
sections 3(c)(1) or 3(c)(7) of the Act in
excess of the limits contained in section
12(d)(1)(A) of the Act, except to the
extent permitted by an exemptive order
that allows the Index Fund to purchase
shares of an affiliated money market
fund for short-term cash management
purposes. Applicants also represent that
to ensure that Investing Funds comply
with the terms and conditions of the
requested relief from section 12(d)(1),
any Investing Fund that intends to
invest in an Index Fund in reliance on
the requested order will be required to
enter into a Participation Agreement
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between the Index Fund and the
Investing Fund. The Participation
Agreement will require the Investing
Fund to adhere to the terms and
conditions of the requested order and
participate in the proposed transactions
in a manner that addresses concerns
regarding the requested relief. The
Participation Agreement also will
include an acknowledgement from the
Investing Fund that it may rely on the
order only to invest in the Index Funds
and not in any other investment
company. The Participation Agreement
will further require any Investing Fund
that exceeds the 5% or 10% limitations
in section 12(d)(1)(A)(ii) and (iii) to
disclose in its prospectus that it may
invest in Index Funds, and to disclose,
in ‘‘plain English,’’ in its prospectus the
unique characteristics of the Investing
Funds investing in Index Funds,
including but not limited to the expense
structure and any additional expenses of
investing in Index Funds.
Section 17(a)(1) and (2) of the Act
17. Section 17(a) of the Act generally
prohibits sales or purchases of securities
between a registered investment
company and any affiliated person of
such company. Section 2(a)(3) of the Act
defines an affiliated person to include
(a) any person directly or indirectly
owning, controlling, or holding with
power to vote, 5% or more of the
outstanding voting securities of the
other person; (b) any person 5% or more
of whose outstanding voting securities
are directly or indirectly owned,
controlled or held with power to vote,
by the other person and (c) any person
directly or indirectly controlling,
controlled by, or under common control
with, the other person. Section 2(a)(9) of
the Act provides that a control
relationship will be presumed where
one person owns more than 25% of
another person’s voting securities.
Applicants state that if Creation Units of
an Index Fund are held by twenty or
fewer investors, including an Exchange
Specialist or Market Maker, some or all
of such investors will be 5% owners of
the Index Fund, and one or more
investors may hold in excess of 25% of
the Index Fund. Such investors would
be deemed to be affiliates of the Index
Fund.
18. Applicants request an exemption
from section 17(a) of the Act pursuant
to sections 17(b) and 6(c) of the Act to
permit any persons that are affiliated
persons of the Index Funds solely by
virtue of (a) holding 5% or more, or in
excess of 25% of the outstanding Shares
of the Trust or one or more Index Funds
(and affiliated persons of such persons
so long as they are not otherwise
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affiliated with the Trust or the Index
Funds) or (b) holding 5% or more of one
or more other registered investment
companies (or series thereof) advised by
the Adviser, or holding in excess of 25%
of the outstanding shares of such
registered investment company (or
series thereof), to effectuate purchases
and redemptions in-kind.
19. Applicants assert that no useful
purpose would be served by prohibiting
these types of affiliated persons from
purchasing or redeeming Creation Units
through ‘‘in-kind’’ transactions. The
deposit procedures for both in-kind
purchases and in-kind redemptions of
Creation Units will be the same for all
purchases and redemptions. Deposit
Securities and Fund Securities will be
valued in the same manner as Portfolio
Securities. Therefore, applicants state
that in-kind purchases and redemptions
will afford no opportunity for the
affiliated persons of an Index Fund, or
the affiliated persons of such affiliated
persons, described above, to effect a
transaction detrimental to other holders
of Shares. Applicants also believe that
in-kind purchases and redemptions will
not result in self-dealing or overreaching
of the Index Fund.
20. Applicants also seek relief from
section 17(a) to permit an Index Fund
that is an affiliated person of an
Investing Fund because the Investing
Fund holds 5% or more of the Index
Fund’s Shares to sell it’s Shares to and
redeem its Shares from an Investing
Fund.10 Applicants believe that any
proposed transactions directly between
Index Funds and Investing Funds will
be consistent with the policies of each
Investing Fund. The purchase of
Creation Units by an Investing Fund
directly from an Index Fund will be
accomplished in accordance with the
investment restrictions of any such
Investing Fund and will be consistent
with the investment policies set forth in
the Investing Fund’s registration
statement. The Participation Agreement
will require any Investing Fund that
purchases Creation Units directly from
an Index Fund to represent that the
purchase of Creation Units from an
Index Fund by an Investing Fund will
be accomplished in compliance with the
investment restrictions of the Investing
Fund and will be consistent with the
10 Applicants believe that an Investing Fund will
purchase Shares in the secondary market and will
not purchase or redeem Creation Units directly
from an Index Fund. Nonetheless, an Investing
Fund that owns 5% or more of an Index Fund could
seek to transact in Creation Units directly with an
Index Fund pursuant to the section 17(a) relief
requested.
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investment policies set forth in the
Investing Fund’s registration statement.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief to permit
the operations of the Index Funds will
be subject to the following conditions:
1. Applicants will not register a
Future Index Fund of the Trust by
means of filing a post-effective
amendment to the Trust’s registration
statement or by any other means, unless:
(a) applicants have requested and
received with respect to such Future
Index Fund, either exemptive relief
from the Commission or a no-action
letter from the Division of Investment
Management of the Commission; or (b)
the Future Index Fund will be listed on
an Exchange without the need for a
filing pursuant to rule 19b–4 under the
Exchange Act.
2. Each Index Fund’s Prospectus and
Product Description will clearly
disclose that, for purposes of the Act,
Shares are issued by the Index Fund and
that the acquisition of Shares by
investment companies is subject to the
restrictions of section 12(d)(1) of the
Act, except as permitted by an
exemptive order that permits registered
investment companies to invest in an
Index Fund beyond the limits of section
12(d)(1), subject to certain terms and
conditions, including that the registered
investment company enter into a
Participation Agreement with the Trust
regarding the terms of the investment.
3. As long as a Trust operates in
reliance on the requested order, the
Shares will be listed on an Exchange.
4. Neither the Trust nor any Index
Fund will be advertised or marketed as
an open-end fund or a mutual fund.
Each Index Fund’s Prospectus will
prominently disclose that Shares are not
individually redeemable shares and will
disclose that the owners of Shares may
acquire those Shares from the Index
Fund and tender those shares for
redemption to the Index Fund in
Creation Units only. Any advertising
material that describes the purchase or
sale of Creation Units or refers to
redeemability will prominently disclose
that Shares are not individually
redeemable, and that owners of Shares
may purchase those Shares from the
Index Fund and tender those Shares for
redemption to the Index Fund in
Creation Units only.
5. The Web site for the Trust, which
will be publicly accessible at no charge,
will contain the following information,
on a per Share basis, for each Index
Fund: (a) The prior business day’s NAV
and the reported closing price, and a
calculation of the premium or discount
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19219
of such price against such NAV; and (b)
data in chart format displaying the
frequency distribution of discounts and
premiums of the daily closing price
against the NAV, within appropriate
ranges, for each of the four previous
calendar quarters. In addition the
Product Description for the Index Fund
will state that the website for the Trust
has information about the premiums
and discounts at which Shares have
traded.
6. The Prospectus and annual report
for each Index Fund also will include:
(a) The information listed in condition
5(b), (i) in the case of the Prospectus, for
the most recently completed year (and
the most recently completed quarter or
quarters, as applicable) and (ii) in the
case of the annual report, for the
immediately preceding five years, as
applicable; and (b) the following data,
calculated on a per Share basis for one,
five and ten year periods (or life of the
Index Fund): (i) the cumulative total
return and the average annual total
return based on NAV and closing price,
and (ii) the cumulative total return of
the relevant Underlying Index.
7. Before an Index Fund may rely on
the order, the Commission will have
approved, pursuant to rule 19b–4 under
the Exchange Act, an Exchange rule
requiring Exchange members and
member organizations effecting
transactions in Shares to deliver a
Product Description to purchasers of
Shares.
The Applicants agree that any order of
the Commission granting the requested
relief from section 12(d)(1) will be
subject to the following conditions:
8. The members of an Investing Fund
Advisor/Sponsor Group will not control
(individually or in the aggregate) an
Index Fund within the meaning of
section 2(a)(9) of the Act. The members
of the Subadviser Group will not control
(individually or in the aggregate) an
Index Fund within the meaning of
section 2(a)(9) of the Act. If, as a result
of a decrease in the outstanding voting
securities of an Index Fund, an
Investing Fund Advisor/Sponsor Group
or Subadviser Group, each in the
aggregate, becomes a holder of more
than 25% of the outstanding voting
securities of an Index Fund, it will vote
its shares of the Index Fund in the same
proportion as the vote of all other
holders of the Index Fund’s shares. This
condition does not apply to the
Subadviser Group with respect to an
Index Fund for which the Subadviser or
a person controlling, controlled by, or
under common control with the
Subadviser acts as the investment
adviser within the meaning of section
2(a)(20)(A) of the Act.
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9. No Investing Fund or Investing
Fund Affiliate will cause any existing or
potential investment by the Investing
Fund in an Index Fund to influence the
terms of any services or transactions
between the Investing Fund or Investing
Fund Affiliate and the Index Fund or
Index Fund Affiliate.
10. The board of directors or trustees
of an Investing Management Company,
including a majority of the disinterested
directors or trustees, will adopt
procedures reasonably designed to
assure that the Investing Fund Advisor
and Subadviser are conducting the
investment program of the Investing
Management Company without taking
into account any consideration received
by the Investing Management Company
or an Investing Fund Affiliate from an
Index Fund or an Index Fund Affiliate
in connection with any services or
transactions.
11. Once an investment by an
Investing Fund in the securities of an
Index Fund exceeds the limit in section
12(d)(1)(A)(i) of the Act, the board of
directors/trustees of the Index Fund
(‘‘Board’’), including a majority of the
disinterested Board members, will
determine that any consideration paid
by the Index Fund to the Investing Fund
or an Investing Fund Affiliate in
connection with any services or
transactions: (a) Is fair and reasonable in
relation to the nature and quality of the
services and benefits received by the
Index Fund; (b) is within the range of
consideration that the Index Fund
would be required to pay to another
unaffiliated entity in connection with
the same services or transactions; and
(c) does not involve overreaching on the
part of any person concerned. This
condition does not apply with respect to
any services or transactions between an
Index Fund and its investment
adviser(s), or any person controlling,
controlled by, or under common control
with such investment adviser(s).
12. An Investing Fund Advisor or a
trustee or Sponsor of an Investing Trust
will waive fees otherwise payable to it
by the Investing Management Company
or Investing Trust in an amount at least
equal to any compensation (including
fees received pursuant to any plan
adopted by an Index Fund under rule
12b–1 under the Act) received from an
Index Fund by the Investing Fund
Advisor or trustee or Sponsor to the
Investing Trust or an affiliated person of
the Investing Fund Adviser, trustee or
Sponsor, other than any advisory fees
paid to the Investing Fund Advisor or
trustee or Sponsor, or an affiliated
person of the Investing Fund Advisor,
trustee or Sponsor by the Index Fund in
connection with the investment by the
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Investing Management Company or
Investing Trust in the Index Fund. Any
Subadviser will waive fees otherwise
payable to the Subadviser, directly or
indirectly, by the Investing Management
Company in an amount at least equal to
any compensation received from an
Index Fund by the Subadviser, or an
affiliated person of the Subadviser,
other than any advisory fees paid to the
Subadviser or its affiliated person by the
Index Fund, in connection with the
investment by the Investing
Management Company in the Index
Fund made at the direction of the
Subadviser. In the event that the
Subadviser waives fees, the benefit of
the waiver will be passed through to the
Investing Management Company.
13. No Investing Fund or Investing
Fund Affiliate (except to the extent it is
acting in its capacity as an investment
adviser to an Index Fund) will cause an
Index Fund to purchase a security in
any Affiliated Underwriting.
14. The Board, including a majority of
the disinterested Board members, will
adopt procedures reasonably designed
to monitor any purchases of securities
by an Index Fund in an Affiliated
Underwriting once an investment by the
Investing Fund in the securities of the
Index Fund exceeds the limit of section
12(d)(1)(A)(i) of the Act, including any
purchases made directly from an
Underwriting Affiliate. The Board will
review these purchases periodically, but
no less frequently than annually, to
determine whether the purchases were
influenced by the investment by the
Investing Fund in the Index Fund. The
Board will consider, among other
things: (a) Whether the purchases were
consistent with the investment
objectives and policies of the Index
Fund; (b) how the performance of
securities purchased in an Affiliated
Underwriting compares to the
performances of comparable securities
purchased during a comparable period
of time in underwritings other than
Affiliated Underwritings or to a
benchmark such as a comparable market
index; and (c) whether the amount of
securities purchased by the Index Fund
in Affiliated Underwritings and the
amount purchased directly from an
Underwriting Affiliate have changed
significantly from prior years. The
Board will take any appropriate actions
based on its review, including, if
appropriate, the institution of
procedures designed to assure that
purchases of securities in Affiliated
Underwritings are in the best interests
of shareholders.
15. The Index Fund will maintain and
preserve permanently in an easily
accessible place a written copy of the
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procedures described in the preceding
condition, and any modifications to
such procedures, and will maintain and
preserve for a period not less than six
years from the end of the fiscal year in
which any purchase in an Affiliated
Underwriting occurred, the first two
years in an easily accessible place, a
written record of each purchase of
securities in Affiliated Underwritings
once an investment by an Investing
Fund in securities of the Index Fund
exceeds the limits of section
12(d)(1)(A)(i) of the Act, setting forth
from whom the securities were
acquired, the identity of the
underwriting syndicate’s members, the
terms of the purchase, and the
information or materials upon which
the Board’s determinations were made.
16. Before investing in an Index Fund
in excess of the limits in section
12(d)(1)(A), the Investing Fund and the
Index Fund will execute a Participation
Agreement stating, without limitation,
that their boards of directors or trustees
and their investment advisers, and the
trustee and Sponsor of an Investing
Trust, as applicable, understand the
terms and conditions of the order, and
agree to fulfill their responsibilities
under the order. At the time of its
investment in shares of an Index Fund
in excess of the limit in section
12(d)(1)(A)(i), an Investing Fund will
notify the Index Fund of the investment.
At such time, the Investing Fund will
also transmit to the Index Fund a list of
names of each Investing Fund Affiliate
and Underwriting Affiliate. The
Investing Fund will notify the Index
Fund of any changes to the list of names
as soon as reasonably practicable after a
change occurs. The Index Fund and the
Investing Fund will maintain and
preserve a copy of the order, the
agreement, and the list with any
updated information for the duration of
the investment and for a period of not
less than six years thereafter, the first
two years in an easily accessible place.
17. Before approving any advisory
contract under section 15 of the Act, the
board of directors or trustees of each
Investing Management Company,
including a majority of the disinterested
directors or trustees, will find that the
advisory fees charged under such
advisory contract are based on services
provided that will be in addition to,
rather than duplicative of, the services
provided under the advisory contract(s)
of any Index Fund in which the
Investing Management Company may
invest. These findings and their basis
will be recorded fully in the minute
books of the appropriate Investing
Management Company.
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18. Any sales charges and/or service
fees charged with respect to shares of an
Investing Fund will not exceed the
limits applicable to a fund of funds as
set forth in Conduct Rule 2830 of the
NASD.
19. No Index Fund will acquire
securities of any investment company or
company relying on sections 3(c)(1) or
3(c)(7) of the Act in excess of the limits
contained in section 12(d)(1)(A) of the
Act, except to the extent permitted by
an exemptive order that allows the
Index Fund to purchase shares of an
affiliated money market fund for shortterm cash management purposes.
20. The board of directors or trustees
of any Investing Management Company
and any Index Fund will satisfy the
fund governance standards as defined in
rule 0–1(a)(7) under the Act by the later
of (a) the compliance date of the rule or
(b) the date on which the Investing
Management Company and Index Fund
execute a Participation Agreement.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Nancy M. Morris,
Secretary.
[FR Doc. E6–5483 Filed 4–12–06; 8:45 am]
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–53607; File No. SR–BSE–
2006–05]
Self-Regulatory Organizations; Boston
Stock Exchange, Inc.; Notice of Filing
of Proposed Rule Change To Modify
the Boston Options Exchange’s Fee
Schedule To Impose Surcharge Fees
for Transactions in Options on ETFs
on a Retroactive Basis
April 6, 2006.
Pursuant to section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on March 15,
2006, the Boston Stock Exchange, Inc.
(‘‘BSE’’ 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 BSE. The Commission
is publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The BSE is proposing to retroactively
establish certain Boston Options
Exchange (‘‘BOX’’) licensing fee
surcharges applicable to broker-dealer
proprietary accounts and market maker
accounts for trades in options on certain
exchange traded funds (‘‘ETFs’’). The
Exchange is proposing to apply these
surcharge fees retroactively for each
product as of the Effective Dates listed
in Table 1, below, through January 3,
2006. On January 4, 2006, the Exchange
filed an identical amendment to the
BOX Fee Schedule,3 which became
immediately effective under section
19(b)(3)(A) of the Act.4 Because the
BILLING CODE 8010–01–P
Exchange seeks to apply the surcharge
fees listed in the BOX Fee Schedule on
a retroactive basis, the Exchange is
submitting this proposal to the
Commission pursuant to section 19b(2)
of the Act 5 to be published for notice
and comment. The current BOX Fee
Schedule is available on the BOX Web
site at https://www.bostonoptions.com.
The text of the proposed rule change is
available on the BOX’s Web site, at the
principal office of BOX, 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
BSE included statements concerning the
purpose of, and basis for, the proposed
rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item IV below. The BSE has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of such statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange is proposing to amend
BOX’s Fee Schedule to retroactively
establish, from the Effective Dates listed
in Table 1 below through January 3,
2006, a surcharge fee for certain
transactions in ETF options on BOX that
are affected by market makers and
broker-dealer proprietary accounts.6 The
respective surcharge fees became
effective on January 4, 2006 pursuant to
a previous proposed rule change
submitted by the Exchange.7
Symbol
Standard & Poor’s Depository Receipts .......................................................................................................
iShares Russell 2000 Index Fund ................................................................................................................
S&P Energy Select Sector SPDR Fund .......................................................................................................
iShares Russell 2000 Growth Index Fund ....................................................................................................
iShares Nasdaq Biotechnology Index Fund .................................................................................................
S&P Financial Select Sector SPDR Fund ....................................................................................................
HSRObinson on PROD1PC61 with NOTICES
Name
SPY ..........
IWM ..........
XLE ...........
IWO ..........
IBB ............
XLF ...........
The BOX Fee Schedule that was in
effect when these products started
trading (i.e., on the Effective Dates
1 15
specified in Table 1 above), stated in
section 2(c) that applicable surcharges
applied for options on ETFs that are
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 53454
(March 8, 2006), 71 FR 13439 (March 15, 2006) (SR–
BSE–2006–01).
4 15 U.S.C. 78s(b)(3)(A).
2 17
VerDate Aug<31>2005
14:20 Apr 12, 2006
Jkt 208001
5 15
U.S.C. 78s(b)(2).
surcharge fee for trading in the options
listed in Section 2(c) of the BOX Fee Schedule is
equal to the cost charged to BOX by the licensor in
the associated licensing agreement. BSE represents
these fees are only charged to BOX Participants.
6 The
PO 00000
Frm 00062
Fmt 4703
Sfmt 4703
Fee
$0.10
0.10
0.09
0.10
0.10
0.09
Effective
date
1/10/05
5/2/05
6/6/05
6/27/05
6/27/05
6/27/05
passed-through by BOX.8 However, in
an administrative oversight, the BSE did
not update the list of ETF products that
7 See
supra note 3.
2(c) of the BOX Fee Schedule then
stated, as it currently does: ‘‘Plus, where applicable,
any surcharge for options on ETFs that are passed
through by BOX.’’
8 Section
E:\FR\FM\13APN1.SGM
13APN1
Agencies
[Federal Register Volume 71, Number 71 (Thursday, April 13, 2006)]
[Notices]
[Pages 19214-19221]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E6-5483]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 27283; 812-12947]
Van Eck Associates Corporation, et al.; Notice of Application
April 7, 2006.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under section 6(c) of the
Investment Company Act of 1940 (the ``Act'') for an exemption from
sections 2(a)(32), 5(a)(1), 22(d), and 24(d) of the Act and rule 22c-1
under the Act, under section 12(d)(1)(J) for an exemption from sections
12(d)(1)(A) and (B) of the Act, and under sections 6(c) and 17(b) of
the Act for an exemption from sections 17(a)(1) and (a)(2) of the Act.
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Summary of Application: Applicants request an order that would
permit (a) series of open-end management investment companies, to issue
shares (``Shares'') that can be redeemed only in large aggregations
(``Creation Units''); (b) secondary market transactions in Shares to
occur at negotiated prices; (c) dealers to sell Shares to purchasers in
the secondary market unaccompanied by a prospectus when prospectus
delivery is not required by the Securities Act of 1933 (``Securities
Act''); (d) certain affiliated persons of the series to deposit
securities into, and receive securities from, the series in connection
with the purchase and redemption of Creation Units; and (e) certain
registered management investment companies and unit investment trusts
outside of the same group of investment companies as the series to
acquire Shares.
Applicants: Van Eck Associates Corporation (the ``Adviser'');
Market Vectors--Gold Miners ETF (the ``Trust''); and Van Eck Securities
Corporation (the ``Distributor'').
Filing Dates: The application was filed on March 25, 2003, and
amended on February 3, 2006. Applicants have agreed to file an
amendment during the notice period, the substance of which is reflected
in the notice.
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 May 1, 2006, 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 who wish to be notified of a hearing may request
notification by writing to the Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street, NE., Washington, DC 20549-1090; Applicants, 99 Park Avenue, 8th
Floor, New York, NY 10016.
FOR FURTHER INFORMATION CONTACT: Deepak T. Pai, Senior Counsel at (202)
551-6876, or Michael W. Mundt, Senior Special Counsel, at (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 at the
Public Reference Desk, U.S. Securities and Exchange Commission, 100 F
Street, NE., Washington DC 20549-0102, telephone (202) 551-5850.
Applicants' Representations
1. The Trust is registered as an open-end management investment
company and is organized as a Delaware trust authorized to issue
multiple series. The Trust intends to offer and sell shares of one or
more series (each an ``Index Fund''), including the Market Vectors--
Gold Miners ETF (``Initial Index Fund''). The Adviser is registered as
an investment adviser under the Investment Advisers Act of 1940, as
amended (the ``Advisers Act'') and will serve as the investment adviser
to each Index Fund. In the future, the Adviser may enter into sub-
advisory agreements with other investment advisers to act as ``sub-
advisers'' with respect to particular Index Funds. Any sub-adviser will
be registered under the Advisers Act or exempt from registration. The
[[Page 19215]]
Distributor, a broker-dealer registered under the Securities Exchange
Act of 1934 (the ``Exchange Act''), will serve as the principal
underwriter and distributor for the Index Funds.
2. Each Index Fund will hold certain securities (``Portfolio
Securities'') selected to correspond generally to the price and yield
performance, before fees and expenses, of a specified equity securities
index (each an ``Underlying Index''). No entity that creates, compiles,
sponsors or maintains an Underlying Index is or will be an affiliated
person, as defined in section 2(a)(3) of the Act, or an affiliated
person of an affiliated person, of the Trust, the Adviser, the
Distributor, promoter or any sub-adviser to an Index Fund. The
Underlying Index for the Initial Index Fund is the Amex Gold Miners
Index, a modified market capitalization weighted index comprised of
publicly-traded companies involved primarily in mining for gold and
silver. The Trust may offer additional Index Funds in the future based
on other Underlying Indexes (``Future Index Funds''). Any Future Index
Funds will (a) comply with the terms and conditions of any order
granted pursuant to the application and (b) be advised by the Adviser.
3. The investment objective of each Index Fund will be to provide
investment results that correspond generally to the price and yield
performance, before fees and expenses, of its Underlying Index. Intra-
day values of the Underlying Index will be disseminated every 15
seconds throughout the trading day. An Index Fund will utilize either a
``replication'' or ``representative sampling'' strategy.\1\ An Index
Fund using a ``replication'' strategy will invest in substantially all
of the Component Securities in its Underlying Index in approximately
the same weightings as in the Underlying Index. In certain
circumstances, such as when there are practical difficulties or
substantial costs involved in holding every security in an Underlying
Index or when a Component Security is illiquid, an Index Fund may use a
``representative sampling'' strategy pursuant to which it will invest
in some, but not all of the relevant Component Securities.\2\
Applicants anticipate that an Index Fund that utilizes a
``representative sampling'' strategy will not track the performance of
its Underlying Index with the same degree of accuracy as an investment
vehicle that invests in every Component Security of the Underlying
Index in the same weighting as the Underlying Index. Applicants expect
that each Index Fund will have a tracking error relative to the
performance of its Underlying Index of less than 5 percent.
---------------------------------------------------------------------------
\1\ Applicants represent that the Index Fund will normally
invest at least 95% of its total assets in the component securities
that comprise its Underlying Index (``Component Securities''). Each
Index Fund also may invest up to 5% of its assets in money market
instruments or money market funds that comply with rule 2(a)(7)
under the Act, in futures contracts, options, options on futures
contracts, swap contracts, cash and cash equivalents, as well as in
stocks not included in its Underlying Index, but which the Adviser
believes will help the Index Fund track its Underlying Index.
\2\ Under the ``representative sampling'' strategy, the Adviser
will seek to construct an Index Fund's portfolio so that its market
capitalization, industry weightings, fundamental investment
characteristics (such as return variability, earnings valuation and
yield) and liquidity measures perform like those of the Underlying
Index.
---------------------------------------------------------------------------
4. Shares of the Index Funds will be sold at a price of between $40
and $50 per Share in Creation Units of 50,000 Shares. All orders to
purchase Creation Units must be placed with the Distributor by or
through a party that has entered into an agreement with the Trust and
Distributor (``Authorized Participant''). An Authorized Participant
must be either: (a) A broker-dealer or other participant in the
continuous net settlement system of the National Securities Clearing
Corporation (``NSCC''), a clearing agency registered with the
Commission, or (b) a participant in the Depository Trust Company
(``DTC'', and such participant, ``DTC Participant''). Shares of each
Index Fund generally will be sold in Creation Units in exchange for an
in-kind deposit by the purchaser of a portfolio of securities
designated by the Adviser to correspond generally to the price and
yield performance, before fees and expenses, of the relevant Underlying
Index (the ``Deposit Securities''), together with the deposit of a
relatively small specified cash payment (``Cash Component''). The Cash
Component is generally an amount equal to the difference between (a)
the net asset value (``NAV'') (per Creation Unit) of the Index Fund and
(b) the total aggregate market value (per Creation Unit) of the Deposit
Securities.\3\ Applicants state that in some circumstances it may not
be practicable or convenient for an Index Fund to operate exclusively
on an ``in-kind'' basis. The Trust reserves the right to permit, under
certain circumstances, a purchaser of Creation Units to substitute cash
in lieu of depositing some or all of the requisite Deposit Securities.
An investor purchasing a Creation Unit from an Index Fund will be
charged a fee (``Transaction Fee'') to prevent the dilution of the
interests of the remaining shareholders resulting from costs in
connection with the purchase of Creation Units.\4\ The maximum
Transaction Fees relevant to each Index Fund will be fully disclosed in
the prospectus (``Prospectus'') of such Index Fund or statement of
additional information (``SAI''). All orders to purchase Creation Units
will be placed with the Distributor by or through an Authorized
Participant and it will be the Distributor's responsibility to transmit
such orders to the Trust. The Distributor also will be responsible for
delivering the Prospectus to those persons purchasing Creation Units,
and for maintaining records of both the orders placed with it and the
confirmations of acceptance furnished by it. In addition, the
Distributor will maintain a record of the instructions given to the
Trust to implement the delivery of Shares.
---------------------------------------------------------------------------
\3\ The Trust will sell Creation Units of each Index Fund on any
day that an Index Fund is open for business, including as required
by section 22(e) of the Act (a ``Business Day''). In addition to the
list of names and amount of each security constituting the current
Deposit Securities, it is intended that, on each Business Day, the
Cash Component effective as of the previous Business Day, per
outstanding Share of each Index Fund, will be made available. The
Exchanges intend to disseminate, every 15 seconds, during their
respective regular trading hours, through the facilities of the
Consolidated Tape Association (``CTA''), an approximate amount per
Share representing the sum of the estimated Cash Component effective
through and including the previous Business Day, plus the current
value of the Deposit Securities, on a per Share basis.
\4\ Where an Index Fund permits a purchaser to substitute cash
in lieu of depositing a portion of the requisite Deposit Securities,
the purchaser may be assessed a higher Transaction Fee to cover the
cost of purchasing such Deposit Securities, including brokerage
costs, and part or all of the spread between the expected bid and
the offer side of the market relating to such Deposit Securities.
---------------------------------------------------------------------------
5. Purchasers of Shares in Creation Units may hold such Shares or
may sell such Shares into the secondary market. Shares will be listed
and traded on the American Stock Exchange, LLC, (``Amex''), another
U.S. national securities exchange as defined in section 2(a)(26) of the
Act, and Nasdaq Stock Market (``Nasdaq'') (each, an ``Exchange''). It
is expected that one or more member firms of a listing Exchange will be
designated to act as a specialist and maintain a market for Shares on
the Exchange (the ``Exchange Specialist''), or if Nasdaq is the listing
Exchange, one or more member firms of Nasdaq will act as a market maker
(``Market Maker'') and maintain a market for Shares.\5\ Prices of
Shares
[[Page 19216]]
trading on an Exchange will be based on the current bid/offer market.
Shares sold in the secondary market will be subject to customary
brokerage commissions and charges.
---------------------------------------------------------------------------
\5\ If Shares are listed on the Nasdaq, no particular Market
Maker will be contractually obligated to make a market in Shares,
although Nasdaq's listing requirements stipulate that at least two
Market Makers must be registered as Market Makers in Shares to
maintain the listing. Registered Market Makers are required to make
a continuous, two-sided market at all times or be subject to
regulatory sanctions.
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6. Applicants expect that purchasers of Creation Units will include
institutional investors and arbitrageurs (which could include
institutional investors). The Exchange Specialist, or Market Maker, in
providing a fair and orderly secondary market for the Shares, also may
purchase Creation Units for use in its market-making activities.
Applicants expect that secondary market purchasers of Shares will
include both institutional investors and retail investors.\6\
Applicants expect that the price at which the Shares trade will be
disciplined by arbitrage opportunities created by the ability to
continually purchase or redeem Creation Units at their NAV, which
should ensure that the Shares will not trade at a material discount or
premium in relation to their NAV.
---------------------------------------------------------------------------
\6\ Shares will be registered in book-entry form only. DTC or
its nominee will be the registered owner of all outstanding Shares.
DTC or DTC Participants will maintain records reflecting beneficial
owners of Shares.
---------------------------------------------------------------------------
7. Shares will not be individually redeemable, and owners of Shares
may acquire those Shares from the Index Fund, or tender such Shares for
redemption to the Index Fund, in Creation Units only. To redeem, an
investor will have to accumulate enough Shares to constitute a Creation
Unit. Redemption orders must be placed by or through an Authorized
Participant. An investor redeeming a Creation Unit generally will
receive (a) a portfolio of securities designated to be delivered for
Creation Unit redemptions on the date that the request for redemption
is submitted (``Fund Securities''), which may not be identical to the
Deposit Securities required to purchase Creation Units on that date,
and (b) a ``Cash Redemption Payment,'' consisting of an amount
calculated in the same manner as the Cash Component, although the
actual amount of the Cash Redemption Payment may differ from the Cash
Component if the Fund Securities are not identical to the Deposit
Securities on that day. An investor may receive the cash equivalent of
a Fund Security in certain circumstances, such as if the investor is
constrained from effecting transactions in the security by regulation
or policy. A redeeming investor may pay a Transaction Fee, calculated
in the same manner as a Transaction Fee payable in connection with
purchases of Creation Units.
8. Neither the Trust nor any individual Index Fund will be marketed
or otherwise held out as an ``open-end investment company'' or a
``mutual fund.'' Instead, each Fund will be marketed as an ``exchange-
traded fund,'' an ``investment company,'' a ``fund,'' or a ``trust.''
All marketing materials that describe the method of obtaining, buying
or selling Shares, or refer to redeemability, will prominently disclose
that Shares are not individually redeemable and that the owners of
Shares may purchase or redeem Shares from the Index Fund in Creation
Units only. The same approach will be followed in the SAI, shareholder
reports and investor educational materials issued or circulated in
connection with the Shares. The Funds will provide copies of their
annual and semi-annual shareholder reports to DTC Participants for
distribution to beneficial owners of Shares.
Applicants' Legal Analysis
1. Applicants request an order under section 6(c) of the Act for an
exemption from sections 2(a)(32), 5(a)(1), 22(d) and 24(d) of the Act
and rule 22c-1 under the Act, under section 12(d)(1)(J) for an
exemption from sections 12(d)(1)(A) and (B) of the Act, and under
sections 6(c) and 17(b) of the Act for an exemption from sections
17(a)(1) and 17(a)(2) of the Act.
2. Section 6(c) of the Act provides that the Commission may exempt
any person, security or transaction, or any class of persons,
securities or transactions, from any provision of the Act, 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 17(b) of the Act authorizes the Commission to exempt a proposed
transaction from section 17(a) of the Act if evidence establishes that
the terms of the transaction, including the consideration to be paid or
received, are reasonable and fair and do not involve overreaching on
the part of any person concerned, and the proposed transaction is
consistent with the policies of the registered investment company and
the general provisions of the Act. Section 12(d)(1)(J) of the Act
provides that the Commission may exempt any person, security, or
transaction, or any class or classes of persons, securities or
transactions, from any provisions of section 12(d)(1) if the exemption
is consistent with the public interest and the protection of investors.
Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an ``open-end company'' as a
management investment company that is offering for sale or has
outstanding any redeemable security of which it is the issuer. Section
2(a)(32) of the Act defines a redeemable security as any security,
other than short-term paper, under the terms of which the owner, upon
its presentation to the issuer, is entitled to receive approximately
his proportionate share of the issuer's current net assets, or the cash
equivalent. Because Shares will not be individually redeemable,
applicants request an order that would permit the Trust to register as
an open-end management investment company and issue Shares that are
redeemable in Creation Units only. Applicants state that investors may
purchase Shares in Creation Units and redeem Creation Units from each
Fund. Applicants further state that because the market price of Shares
will be disciplined by arbitrage opportunities, investors should be
able to sell Shares in the secondary market at prices that do not vary
substantially from their NAV.
Section 22(d) of the Act and Rule 22c-1 Under the Act
4. Section 22(d) of the Act, among other things, prohibits a dealer
from selling a redeemable security, which is currently being offered to
the public by or through a principal underwriter, except at a current
public offering price described in the prospectus. Rule 22c-1 under the
Act generally requires that a dealer selling, redeeming or repurchasing
a redeemable security do so only at a price based on its NAV.
Applicants state that secondary market trading in Shares will take
place at negotiated prices, not at a current offering price described
in the Prospectus, and not at a price based on NAV. Thus, purchases and
sales of Shares in the secondary market will not comply with section
22(d) of the Act and rule 22c-1 under the Act. Applicants request an
exemption under section 6(c) from these provisions.
5. Applicants assert that the concerns sought to be addressed by
section 22(d) of the Act and rule 22c-1 under the Act with respect to
pricing are equally satisfied by the proposed method of pricing Shares.
Applicants maintain that while there is little legislative history
regarding section 22(d), its provisions, as well as those of rule 22c-
1, appear to have been designed to (a) prevent dilution caused by
certain riskless-trading schemes by principal underwriters and contract
dealers, (b) prevent unjust discrimination or
[[Page 19217]]
preferential treatment among buyers, and (c) ensure an orderly
distribution of investment company shares by eliminating price
competition from dealers offering shares at less than the published
sales price and repurchasing shares at more than the published
redemption price.
6. Applicants believe that none of these purposes will be thwarted
by permitting Shares to trade in the secondary market at negotiated
prices. Applicants state that (a) secondary market trading in Shares
does not involve the Index Funds as parties and cannot result in
dilution of an investment in Shares, and (b) to the extent different
prices exist during a given trading day, or from day to day, such
variances occur as a result of third-party market forces, such as
supply and demand. Therefore, applicants assert that secondary market
transactions in Shares will not lead to discrimination or preferential
treatment among purchasers. Finally, applicants contend that the
proposed distribution system will be orderly because arbitrage activity
will ensure that the difference between the market price of Shares and
their NAV remains narrow.
Section 24(d) of the Act
7. Section 24(d) of the Act provides, in relevant part, that the
prospectus delivery exemption provided to dealer transactions by
section 4(3) of the Securities Act does not apply to any transaction in
a redeemable security issued by an open-end investment company.
Applicants seek relief from section 24(d) to permit dealers selling
Shares to rely on the prospectus delivery exemption provided by section
4(3) of the Securities Act.\7\
---------------------------------------------------------------------------
\7\ Applicants state that they are not seeking relief from the
prospectus delivery requirement for non-secondary market
transactions, such as transactions in which an investor purchases
Shares from the Trust or an underwriter. Applicants further state
that the Prospectus will caution broker-dealers and others that some
activities on their part, depending on the circumstances, may result
in their being deemed statutory underwriters and subject them to the
Prospectus delivery and liability provisions of the Securities Act.
For example, a broker-dealer firm and/or its client may be deemed a
statutory underwriter if it purchases Creation Units from an Index
Fund, breaks them down into the constituent Shares, and sells those
Shares directly to customers, or if it chooses to couple the
creation of a supply of new Shares with an active selling effort
involving solicitation of secondary market demand for Shares. Each
Index Fund's Prospectus will state that whether a person is an
underwriter depends upon all of the facts and circumstances
pertaining to that person's activities. Each Index Fund's Prospectus
will caution dealers who are not ``underwriters'' but are
participating in a distribution (as contrasted to ordinary secondary
trading transactions), and thus dealing with Shares that are part of
an ``unsold allotment'' within the meaning of section 4(3)(C) of the
Securities Act, that they would be unable to take advantage of the
prospectus delivery exemption provided by section 4(3) of the
Securities Act.
---------------------------------------------------------------------------
8. Applicants state that Shares are bought and sold in the
secondary market in the same manner as closed-end fund shares.
Applicants note that transactions in closed-end fund shares are not
subject to section 24(d), and thus closed-end fund shares are sold in
the secondary market without a prospectus. Applicants contend that
Shares likewise merit a reduction in the unnecessary compliance costs
and regulatory burdens resulting from the imposition of the prospectus
delivery obligations in the secondary market. Because Shares will be
listed on an Exchange, prospective investors will have access to
information about the product over and above what is normally available
about an open-end security. Applicants state that information regarding
market price and volume will be continually available on a real time
basis throughout the day on brokers' computer screens and other
electronic services. The previous day's price and volume information
will be published daily in the financial section of newspapers. In
addition, the Trust also intends to maintain a Web site that will
include the Prospectus and SAI, the relevant Underlying Index for each
Index Fund and additional quantitative information that is updated on a
daily basis, including daily trading volume, closing price, the NAV for
each Index Fund and information about the premiums and discounts at
which the Index Fund's Shares have traded.
9. Applicants will arrange for broker-dealers selling Shares in the
secondary market to provide purchasers with a product description
(``Product Description'') that describes, in plain English, the
relevant Index Fund and the Shares it issues. Applicants state that a
Product Description is not intended to substitute for a full
Prospectus. Applicants state that the Product Description will be
tailored to meet the information needs of investors purchasing Shares
in the secondary market.
Section 12(d)(1)
10. Section 12(d)(1)(A) of the Act prohibits a registered
investment company from acquiring securities of an investment company
if such securities represent more than 3% of the total outstanding
voting stock of the acquired company, more than 5% of the total assets
of the acquiring company, or, together with the securities of any other
investment companies, more than 10% of the total assets of the
acquiring company. Section 12(d)(1)(B) of the Act prohibits a
registered open-end investment company, its principal underwriter and
any other broker-dealer from selling the investment company's shares to
another investment company if the sale will cause the acquiring company
to own more than 3% of the acquired company's voting stock, or if the
sale will cause more than 10% of the acquired company's voting stock to
be owned by investment companies generally.
11. Applicants request an exemption to permit management investment
companies (``Investing Management Companies'') and unit investment
trusts (``Investing Trusts'') registered under the Act that are not
part of the same ``group of investment companies,'' as defined in
section 12(d)(1)(G)(ii) of the Act, as the Trust to acquire shares of
an Index Fund beyond the limits of section 12(d)(1)(A) and (B),
(Investing Management Companies and Investing Trusts collectively,
``Investing Funds''). Investing Funds exclude registered investment
companies that are, or in the future may be, part of the same group of
investment companies within the meaning of section 12(d)(1)(G)(ii) of
the Act as the Index Funds. In addition, applicants seek relief to
permit an Index Fund and the Distributor or any broker or dealer
(``Broker'') that is registered under the Exchange Act to knowingly
sell shares of the Index Fund to an Investing Fund in excess of the
limits of section 12(d)(1)(B). Applicants request that the relief
sought apply to (a) Index Funds that are advised by the Adviser and in
the same group of investment companies as the Trust, (b) each Investing
Fund that enters into a participation agreement with the Index Fund
(``Participation Agreement''), and (c) any Broker.\8\
---------------------------------------------------------------------------
\8\ All parties that currently intend to rely on the requested
relief from section 12(d)(1) are named as applicants. Any other
party that relies on this relief in the future will comply with the
terms and conditions of the application. An Investing Fund may rely
on the requested order only to invest in the Index Funds and not in
any other registered investment company.
---------------------------------------------------------------------------
12. Each Investing Management Company will be advised by an
investment adviser within the meaning of section 2(a)(20)(A) of the Act
(the ``Investing Fund Advisor'') and may be advised by one or more
investment advisers within the meaning of section 2(a)(20)(B) of the
Act (each a ``Subadviser''). Any investment adviser to an Investing
Fund will be registered under the Advisers Act or exempt from
registration. Each Investing Trust will be sponsored by a sponsor
(``Sponsor'').
[[Page 19218]]
13. Applicants submit that the proposed conditions to the relief
requested adequately address the concerns underlying the limits in
section 12(d)(1)(A) and (B), which include concerns about undue
influence, excessive layering of fees and overly complex structures.
Applicants believe that the requested exemption is consistent with the
public interest and the protection of investors.
14. Applicants believe that neither the Investing Funds nor an
Investing Fund Affiliate would be able to exert undue influence over
the Index Funds.\9\ To limit the control that an Investing Fund may
have over an Index Fund, applicants propose a condition prohibiting an
Investing Fund Advisor or a Sponsor, any person controlling, controlled
by, or under common control with an Investing Fund Advisor or Sponsor,
and any investment company and any issuer that would be an investment
company but for sections 3(c)(1) or 3(c)(7) of the Act that is advised
or sponsored by an Investing Fund Advisor or Sponsor, or any person
controlling, controlled by, or under common control with an Investing
Fund Advisor or Sponsor (``Investing Fund Advisor/Sponsor Group'') from
controlling (individually or in the aggregate) an Index Fund within the
meaning of section 2(a)(9) of the Act. The same prohibition would apply
to any Subadviser, any person controlling, controlled by or under
common control with the Subadviser, and any investment company or
issuer that would be an investment company but for sections 3(c)(1) or
3(c)(7) of the Act (or portion of such investment company or issuer)
advised or sponsored by the Subadviser or any person controlling,
controlled by or under common control with the Subadviser (``Subadviser
Group''). Applicants propose other conditions to limit the potential
for undue influence over the Index Funds, including that no Investing
Fund or Investing Fund Affiliate (except to the extent it is acting in
its capacity as an investment adviser to an Index Fund) will cause an
Index Fund to purchase a security in any offering of securities during
the existence of any underwriting or selling syndicate of which a
principal underwriter is an Underwriting Affiliate (``Affiliated
Underwriting''). An ``Underwriting Affiliate'' is a principal
underwriter in any underwriting or selling syndicate that is an
officer, director, member of an advisory board, Investing Fund Advisor,
Subadviser, employee or Sponsor of an Investing Fund, or a person which
any such officer, director, member of an advisory board, Investing Fund
Advisor, Subadviser, employee, or Sponsor is an affiliated person
(except any person whose relationship to the Index Fund is covered by
section 10(f) of the Act is not an Underwriting Affiliate.)
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\9\ An ``Investing Fund Affiliate'' is an Investing Fund
Advisor, Subadviser, Sponsor, promoter, and principal underwriter of
an Investing Fund, and any person controlling, controlled by, or
under common control with any of those entities.
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15. Applicants do not believe the proposed arrangement will involve
excessive layering of fees. The board of directors or trustees of any
Investing Management Company, including a majority of the disinterested
directors or trustees, will find that the advisory fees charged to the
Investing Management Company are based on services provided that will
be in addition to, rather than duplicative of, services provided under
the advisory contract(s) of any Index Fund in which the Investing
Management Company may invest. In addition, an Investing Fund Advisor
or a trustee or Sponsor of an Investing Trust will waive fees otherwise
payable to it by the Investing Management Company or Investing Trust in
an amount at least equal to any compensation (including fees received
pursuant to any plan adopted by an Index Fund under rule 12b-1 under
the Act) received by the Investing Fund Advisor or trustee or Sponsor
to the Investing Trust or an affiliated person of the Investing Fund
Advisor, trustee or Sponsor, from the Index Funds in connection with
the investment by the Investing Management Company or Investing Trust
in the Index Fund. Applicants state that any sales loads or service
fees charged with respect to shares of an Investing Fund will not
exceed the limits applicable to a fund of funds set forth in Conduct
Rule 2830 of the NASD.
16. Applicants submit that the proposed arrangement will not create
an overly complex fund structure. Applicants note that no Index Fund
may acquire securities of any investment company or company relying on
sections 3(c)(1) or 3(c)(7) of the Act in excess of the limits
contained in section 12(d)(1)(A) of the Act, except to the extent
permitted by an exemptive order that allows the Index Fund to purchase
shares of an affiliated money market fund for short-term cash
management purposes. Applicants also represent that to ensure that
Investing Funds comply with the terms and conditions of the requested
relief from section 12(d)(1), any Investing Fund that intends to invest
in an Index Fund in reliance on the requested order will be required to
enter into a Participation Agreement between the Index Fund and the
Investing Fund. The Participation Agreement will require the Investing
Fund to adhere to the terms and conditions of the requested order and
participate in the proposed transactions in a manner that addresses
concerns regarding the requested relief. The Participation Agreement
also will include an acknowledgement from the Investing Fund that it
may rely on the order only to invest in the Index Funds and not in any
other investment company. The Participation Agreement will further
require any Investing Fund that exceeds the 5% or 10% limitations in
section 12(d)(1)(A)(ii) and (iii) to disclose in its prospectus that it
may invest in Index Funds, and to disclose, in ``plain English,'' in
its prospectus the unique characteristics of the Investing Funds
investing in Index Funds, including but not limited to the expense
structure and any additional expenses of investing in Index Funds.
Section 17(a)(1) and (2) of the Act
17. Section 17(a) of the Act generally prohibits sales or purchases
of securities between a registered investment company and any
affiliated person of such company. Section 2(a)(3) of the Act defines
an affiliated person to include (a) any person directly or indirectly
owning, controlling, or holding with power to vote, 5% or more of the
outstanding voting securities of the other person; (b) any person 5% or
more of whose outstanding voting securities are directly or indirectly
owned, controlled or held with power to vote, by the other person and
(c) any person directly or indirectly controlling, controlled by, or
under common control with, the other person. Section 2(a)(9) of the Act
provides that a control relationship will be presumed where one person
owns more than 25% of another person's voting securities. Applicants
state that if Creation Units of an Index Fund are held by twenty or
fewer investors, including an Exchange Specialist or Market Maker, some
or all of such investors will be 5% owners of the Index Fund, and one
or more investors may hold in excess of 25% of the Index Fund. Such
investors would be deemed to be affiliates of the Index Fund.
18. Applicants request an exemption from section 17(a) of the Act
pursuant to sections 17(b) and 6(c) of the Act to permit any persons
that are affiliated persons of the Index Funds solely by virtue of (a)
holding 5% or more, or in excess of 25% of the outstanding Shares of
the Trust or one or more Index Funds (and affiliated persons of such
persons so long as they are not otherwise
[[Page 19219]]
affiliated with the Trust or the Index Funds) or (b) holding 5% or more
of one or more other registered investment companies (or series
thereof) advised by the Adviser, or holding in excess of 25% of the
outstanding shares of such registered investment company (or series
thereof), to effectuate purchases and redemptions in-kind.
19. Applicants assert that no useful purpose would be served by
prohibiting these types of affiliated persons from purchasing or
redeeming Creation Units through ``in-kind'' transactions. The deposit
procedures for both in-kind purchases and in-kind redemptions of
Creation Units will be the same for all purchases and redemptions.
Deposit Securities and Fund Securities will be valued in the same
manner as Portfolio Securities. Therefore, applicants state that in-
kind purchases and redemptions will afford no opportunity for the
affiliated persons of an Index Fund, or the affiliated persons of such
affiliated persons, described above, to effect a transaction
detrimental to other holders of Shares. Applicants also believe that
in-kind purchases and redemptions will not result in self-dealing or
overreaching of the Index Fund.
20. Applicants also seek relief from section 17(a) to permit an
Index Fund that is an affiliated person of an Investing Fund because
the Investing Fund holds 5% or more of the Index Fund's Shares to sell
it's Shares to and redeem its Shares from an Investing Fund.\10\
Applicants believe that any proposed transactions directly between
Index Funds and Investing Funds will be consistent with the policies of
each Investing Fund. The purchase of Creation Units by an Investing
Fund directly from an Index Fund will be accomplished in accordance
with the investment restrictions of any such Investing Fund and will be
consistent with the investment policies set forth in the Investing
Fund's registration statement. The Participation Agreement will require
any Investing Fund that purchases Creation Units directly from an Index
Fund to represent that the purchase of Creation Units from an Index
Fund by an Investing Fund will be accomplished in compliance with the
investment restrictions of the Investing Fund and will be consistent
with the investment policies set forth in the Investing Fund's
registration statement.
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\10\ Applicants believe that an Investing Fund will purchase
Shares in the secondary market and will not purchase or redeem
Creation Units directly from an Index Fund. Nonetheless, an
Investing Fund that owns 5% or more of an Index Fund could seek to
transact in Creation Units directly with an Index Fund pursuant to
the section 17(a) relief requested.
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Applicants' Conditions
Applicants agree that any order granting the requested relief to
permit the operations of the Index Funds will be subject to the
following conditions:
1. Applicants will not register a Future Index Fund of the Trust by
means of filing a post-effective amendment to the Trust's registration
statement or by any other means, unless: (a) applicants have requested
and received with respect to such Future Index Fund, either exemptive
relief from the Commission or a no-action letter from the Division of
Investment Management of the Commission; or (b) the Future Index Fund
will be listed on an Exchange without the need for a filing pursuant to
rule 19b-4 under the Exchange Act.
2. Each Index Fund's Prospectus and Product Description will
clearly disclose that, for purposes of the Act, Shares are issued by
the Index Fund and that the acquisition of Shares by investment
companies is subject to the restrictions of section 12(d)(1) of the
Act, except as permitted by an exemptive order that permits registered
investment companies to invest in an Index Fund beyond the limits of
section 12(d)(1), subject to certain terms and conditions, including
that the registered investment company enter into a Participation
Agreement with the Trust regarding the terms of the investment.
3. As long as a Trust operates in reliance on the requested order,
the Shares will be listed on an Exchange.
4. Neither the Trust nor any Index Fund will be advertised or
marketed as an open-end fund or a mutual fund. Each Index Fund's
Prospectus will prominently disclose that Shares are not individually
redeemable shares and will disclose that the owners of Shares may
acquire those Shares from the Index Fund and tender those shares for
redemption to the Index Fund in Creation Units only. Any advertising
material that describes the purchase or sale of Creation Units or
refers to redeemability will prominently disclose that Shares are not
individually redeemable, and that owners of Shares may purchase those
Shares from the Index Fund and tender those Shares for redemption to
the Index Fund in Creation Units only.
5. The Web site for the Trust, which will be publicly accessible at
no charge, will contain the following information, on a per Share
basis, for each Index Fund: (a) The prior business day's NAV and the
reported closing price, and a calculation of the premium or discount of
such price against such NAV; and (b) data in chart format displaying
the frequency distribution of discounts and premiums of the daily
closing price against the NAV, within appropriate ranges, for each of
the four previous calendar quarters. In addition the Product
Description for the Index Fund will state that the website for the
Trust has information about the premiums and discounts at which Shares
have traded.
6. The Prospectus and annual report for each Index Fund also will
include: (a) The information listed in condition 5(b), (i) in the case
of the Prospectus, for the most recently completed year (and the most
recently completed quarter or quarters, as applicable) and (ii) in the
case of the annual report, for the immediately preceding five years, as
applicable; and (b) the following data, calculated on a per Share basis
for one, five and ten year periods (or life of the Index Fund): (i) the
cumulative total return and the average annual total return based on
NAV and closing price, and (ii) the cumulative total return of the
relevant Underlying Index.
7. Before an Index Fund may rely on the order, the Commission will
have approved, pursuant to rule 19b-4 under the Exchange Act, an
Exchange rule requiring Exchange members and member organizations
effecting transactions in Shares to deliver a Product Description to
purchasers of Shares.
The Applicants agree that any order of the Commission granting the
requested relief from section 12(d)(1) will be subject to the following
conditions:
8. The members of an Investing Fund Advisor/Sponsor Group will not
control (individually or in the aggregate) an Index Fund within the
meaning of section 2(a)(9) of the Act. The members of the Subadviser
Group will not control (individually or in the aggregate) an Index Fund
within the meaning of section 2(a)(9) of the Act. If, as a result of a
decrease in the outstanding voting securities of an Index Fund, an
Investing Fund Advisor/Sponsor Group or Subadviser Group, each in the
aggregate, becomes a holder of more than 25% of the outstanding voting
securities of an Index Fund, it will vote its shares of the Index Fund
in the same proportion as the vote of all other holders of the Index
Fund's shares. This condition does not apply to the Subadviser Group
with respect to an Index Fund for which the Subadviser or a person
controlling, controlled by, or under common control with the Subadviser
acts as the investment adviser within the meaning of section
2(a)(20)(A) of the Act.
[[Page 19220]]
9. No Investing Fund or Investing Fund Affiliate will cause any
existing or potential investment by the Investing Fund in an Index Fund
to influence the terms of any services or transactions between the
Investing Fund or Investing Fund Affiliate and the Index Fund or Index
Fund Affiliate.
10. The board of directors or trustees of an Investing Management
Company, including a majority of the disinterested directors or
trustees, will adopt procedures reasonably designed to assure that the
Investing Fund Advisor and Subadviser are conducting the investment
program of the Investing Management Company without taking into account
any consideration received by the Investing Management Company or an
Investing Fund Affiliate from an Index Fund or an Index Fund Affiliate
in connection with any services or transactions.
11. Once an investment by an Investing Fund in the securities of an
Index Fund exceeds the limit in section 12(d)(1)(A)(i) of the Act, the
board of directors/trustees of the Index Fund (``Board''), including a
majority of the disinterested Board members, will determine that any
consideration paid by the Index Fund to the Investing Fund or an
Investing Fund Affiliate in connection with any services or
transactions: (a) Is fair and reasonable in relation to the nature and
quality of the services and benefits received by the Index Fund; (b) is
within the range of consideration that the Index Fund would be required
to pay to another unaffiliated entity in connection with the same
services or transactions; and (c) does not involve overreaching on the
part of any person concerned. This condition does not apply with
respect to any services or transactions between an Index Fund and its
investment adviser(s), or any person controlling, controlled by, or
under common control with such investment adviser(s).
12. An Investing Fund Advisor or a trustee or Sponsor of an
Investing Trust will waive fees otherwise payable to it by the
Investing Management Company or Investing Trust in an amount at least
equal to any compensation (including fees received pursuant to any plan
adopted by an Index Fund under rule 12b-1 under the Act) received from
an Index Fund by the Investing Fund Advisor or trustee or Sponsor to
the Investing Trust or an affiliated person of the Investing Fund
Adviser, trustee or Sponsor, other than any advisory fees paid to the
Investing Fund Advisor or trustee or Sponsor, or an affiliated person
of the Investing Fund Advisor, trustee or Sponsor by the Index Fund in
connection with the investment by the Investing Management Company or
Investing Trust in the Index Fund. Any Subadviser will waive fees
otherwise payable to the Subadviser, directly or indirectly, by the
Investing Management Company in an amount at least equal to any
compensation received from an Index Fund by the Subadviser, or an
affiliated person of the Subadviser, other than any advisory fees paid
to the Subadviser or its affiliated person by the Index Fund, in
connection with the investment by the Investing Management Company in
the Index Fund made at the direction of the Subadviser. In the event
that the Subadviser waives fees, the benefit of the waiver will be
passed through to the Investing Management Company.
13. No Investing Fund or Investing Fund Affiliate (except to the
extent it is acting in its capacity as an investment adviser to an
Index Fund) will cause an Index Fund to purchase a security in any
Affiliated Underwriting.
14. The Board, including a majority of the disinterested Board
members, will adopt procedures reasonably designed to monitor any
purchases of securities by an Index Fund in an Affiliated Underwriting
once an investment by the Investing Fund in the securities of the Index
Fund exceeds the limit of section 12(d)(1)(A)(i) of the Act, including
any purchases made directly from an Underwriting Affiliate. The Board
will review these purchases periodically, but no less frequently than
annually, to determine whether the purchases were influenced by the
investment by the Investing Fund in the Index Fund. The Board will
consider, among other things: (a) Whether the purchases were consistent
with the investment objectives and policies of the Index Fund; (b) how
the performance of securities purchased in an Affiliated Underwriting
compares to the performances of comparable securities purchased during
a comparable period of time in underwritings other than Affiliated
Underwritings or to a benchmark such as a comparable market index; and
(c) whether the amount of securities purchased by the Index Fund in
Affiliated Underwritings and the amount purchased directly from an
Underwriting Affiliate have changed significantly from prior years. The
Board will take any appropriate actions based on its review, including,
if appropriate, the institution of procedures designed to assure that
purchases of securities in Affiliated Underwritings are in the best
interests of shareholders.
15. The Index Fund will maintain and preserve permanently in an
easily accessible place a written copy of the procedures described in
the preceding condition, and any modifications to such procedures, and
will maintain and preserve for a period not less than six years from
the end of the fiscal year in which any purchase in an Affiliated
Underwriting occurred, the first two years in an easily accessible
place, a written record of each purchase of securities in Affiliated
Underwritings once an investment by an Investing Fund in securities of
the Index Fund exceeds the limits of section 12(d)(1)(A)(i) of the Act,
setting forth from whom the securities were acquired, the identity of
the underwriting syndicate's members, the terms of the purchase, and
the information or materials upon which the Board's determinations were
made.
16. Before investing in an Index Fund in excess of the limits in
section 12(d)(1)(A), the Investing Fund and the Index Fund will execute
a Participation Agreement stating, without limitation, that their
boards of directors or trustees and their investment advisers, and the
trustee and Sponsor of an Investing Trust, as applicable, understand
the terms and conditions of the order, and agree to fulfill their
responsibilities under the order. At the time of its investment in
shares of an Index Fund in excess of the limit in section
12(d)(1)(A)(i), an Investing Fund will notify the Index Fund of the
investment. At such time, the Investing Fund will also transmit to the
Index Fund a list of names of each Investing Fund Affiliate and
Underwriting Affiliate. The Investing Fund will notify the Index Fund
of any changes to the list of names as soon as reasonably practicable
after a change occurs. The Index Fund and the Investing Fund will
maintain and preserve a copy of the order, the agreement, and the list
with any updated information for the duration of the investment and for
a period of not less than six years thereafter, the first two years in
an easily accessible place.
17. Before approving any advisory contract under section 15 of the
Act, the board of directors or trustees of each Investing Management
Company, including a majority of the disinterested directors or
trustees, will find that the advisory fees charged under such advisory
contract are based on services provided that will be in addition to,
rather than duplicative of, the services provided under the advisory
contract(s) of any Index Fund in which the Investing Management Company
may invest. These findings and their basis will be recorded fully in
the minute books of the appropriate Investing Management Company.
[[Page 19221]]
18. Any sales charges and/or service fees charged with respect to
shares of an Investing Fund will not exceed the limits applicable to a
fund of funds as set forth in Conduct Rule 2830 of the NASD.
19. No Index Fund will acquire securities of any investment company
or company relying on sections 3(c)(1) or 3(c)(7) of the Act in excess
of the limits contained in section 12(d)(1)(A) of the Act, except to
the extent permitted by an exemptive order that allows the Index Fund
to purchase shares of an affiliated money market fund for short-term
cash management purposes.
20. The board of directors or trustees of any Investing Management
Company and any Index Fund will satisfy the fund governance standards
as defined in rule 0-1(a)(7) under the Act by the later of (a) the
compliance date of the rule or (b) the date on which the Investing
Management Company and Index Fund execute a Participation Agreement.
For the Commission, by the Division of Investment Management,
under delegated authority.
Nancy M. Morris,
Secretary.
[FR Doc. E6-5483 Filed 4-12-06; 8:45 am]
BILLING CODE 8010-01-P