Van Kampen Asset Management, et al.; Notice of Application, 28890-28892 [E6-7567]
Download as PDF
28890
Federal Register / Vol. 71, No. 96 / Thursday, May 18, 2006 / Notices
24, 2006, and with the Minnesota State
official, Ms. D. Pile of the Commerce
Department, on April 26, 2006,
regarding the environmental impact of
the proposed actions. The State officials
had no comments.
Finding of No Significant Impact
On the basis of the environmental
assessment, the NRC concludes that the
proposed actions will not have a
significant effect on the quality of the
human environment. Accordingly, the
NRC has determined not to prepare an
environmental impact statement for the
proposed actions.
For further details with respect to the
proposed actions, see the licensee’s
letter dated October 12, 2005.
Documents may be examined, and/or
copied for a fee, at the NRC’s Public
Document Room (PDR), located at One
White Flint North, Public File Area O1
F21, 11555 Rockville Pike (first floor),
Rockville, Maryland. Publicly available
records will be accessible electronically
from the Agencywide Documents
Access and Management System
(ADAMS) Public Electronic Reading
Room on the Internet at the NRC Web
site, https://www.nrc.gov/reading-rm/
adams.html. Persons who do not have
access to ADAMS or who encounter
problems in accessing the documents
located in ADAMS should contact the
NRC PDR Reference staff by telephone
at 1–800–397–4209 or 301–415–4737, or
send an e-mail to pdr@nrc.gov.
Dated at Rockville, Maryland, this 11th day
of May 2006.
For the Nuclear Regulatory Commission.
Carl F. Lyon,
Project Manager, Plant Licensing Branch III–
1, Division of Operating Reactor Licensing,
Office of Nuclear Reactor Regulation.
[FR Doc. E6–7572 Filed 5–17–06; 8:45 am]
BILLING CODE 7590–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
27317; 812–13156]
Van Kampen Asset Management, et al.;
Notice of Application
May 12, 2006.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under sections 6(c) and 23(c)(3) of
the Investment Company Act of 1940
(the ‘‘Act’’) for an exemption from rule
23c–3 under the Act.
wwhite on PROD1PC61 with NOTICES
AGENCY:
Van Kampen Asset
Management (the ‘‘VK Adviser’’), Van
APPLICANTS:
VerDate Aug<31>2005
18:14 May 17, 2006
Jkt 208001
Kampen Funds Inc. (the ‘‘VK
Distributor’’), Van Kampen Senior Loan
Fund (formerly known as Van Kampen
Prime Rate Income Trust) (the ‘‘VK
Trust’’), Morgan Stanley Investment
Advisors Inc. (the ‘‘MS Adviser’’),
Morgan Stanley Distributors Inc. (the
‘‘MS Distributor’’) and Morgan Stanley
Prime Income Trust (the ‘‘MS Trust’’,
and, together with the VK Trust, the
‘‘Trusts’’).
SUMMARY OF APPLICATION: Applicants
request an order under sections 6(c) and
23(c)(3) of the Act for an exemption
from certain provisions of rule 23c–3 to
permit certain registered closed-end
investment companies to make
repurchase offers on a monthly basis.
FILING DATES: The application was filed
on January 25, 2005 and amended on
December 29, 2005 and May 5, 2006.
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 June 6, 2006, and
should be accompanied by proof of
service on the 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, c/o Charles B. Taylor,
Esq., Skadden, Arps, Slate, Meagher &
Flom LLP, 333 West Wacker Drive,
Chicago, Illinois 60606.
FOR FURTHER INFORMATION CONTACT:
Shannon Conaty, Senior Counsel, at
(202) 551–6827, or Janet M. Grossnickle,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Office of Investment Company
Regulation).
The
following is a summary of the
application. The complete application
may be obtained for a fee at the
Commission’s Public Reference Branch,
100 F Street, NE., Washington, DC
20549–0102 (tel. (202) 551–8090).
SUPPLEMENTARY INFORMATION:
Applicants’ Representations
1. Each of the Trusts is a closed-end
management investment company
registered under the Act and organized
PO 00000
Frm 00041
Fmt 4703
Sfmt 4703
as a Massachusetts business trust. The
VK Adviser and the MS Adviser, both
investment advisers registered under the
Investment Advisers Act of 1940 (the
‘‘Advisers Act’’), serve as investment
adviser to the VK Trust and the MS
Trust, respectively. The VK Distributor,
a broker-dealer registered under the
Securities Exchange Act of 1934 (the
‘‘Exchange Act’’), distributes the VK
Trust’s shares and serves as the VK
Trust’s administrator. The MS
Distributor, a broker-dealer registered
under the Exchange Act, distributes the
MS Trust’s shares. The VK Adviser, the
VK Distributor, the MS Adviser and the
MS Distributor are all direct or indirect
wholly-owned subsidiaries of Morgan
Stanley. Applicants request that any
relief granted also apply to any
registered closed-end management
investment company that operates as an
interval fund pursuant to rule 23c–3 for
which the VK Adviser, the VK
Distributor, the MS Adviser, the MS
Distributor or any entity controlling,
controlled by or under common control
(within the meaning of section 2(a)(9) of
the Act) with the VK Adviser, the VK
Distributor, the MS Adviser or the MS
Distributor acts as investment adviser,
principal underwriter or administrator
(collectively, the ‘‘Other Trusts’’).1
2. The VK Trust’s investment
objective is to provide a high level of
current income, consistent with the
preservation of capital. The VK Trust
invests primarily in adjustable rate
senior loans made to corporations and
other borrowers. Under normal market
conditions, the VK Trust invests at least
80% of its net assets (plus any
borrowings for investment purposes) in
adjustable rate senior loans. The VK
Trust may also invest up to 20% of its
total assets in senior loans that are not
secured by any specific collateral, senior
loans made to borrowers located outside
the U.S. (provided no more than 5% of
these loans or other assets are non-U.S.
dollar denominated), and in any
combination of warrants and equity
securities incidental to investment in
senior loans, junior debt securities, high
quality short-term debt securities,
credit-linked deposits and Treasury
Inflation Protected Securities (or other
inflation-indexed bonds issued by the
U.S. government, its agencies or
instrumentalities).
3. The MS Trust’s investment
objective is to provide a high level of
current income, consistent with the
preservation of capital. The MS Trust
1 All entities currently intending to rely on the
requested relief have been named as applicants.
Any entity that relies on the requested order in the
future will do so only in accordance with the terms
and conditions of the application.
E:\FR\FM\18MYN1.SGM
18MYN1
Federal Register / Vol. 71, No. 96 / Thursday, May 18, 2006 / Notices
wwhite on PROD1PC61 with NOTICES
invests primarily in collateralized senior
loans made to corporations,
partnerships or other entities. Under
normal market conditions, the MS Trust
invests at least 80% of its total assets in
collateralized senior loans. The MS
Trust may also invest up to 20% of its
total assets in cash or short-term high
quality money market instruments,
credit-linked deposits, junior debt
securities or securities with a lien on
collateral that is lower than a senior
claim on collateral, and in loans that
hold the most senior position in a
borrower’s capital structure, but are
unsecured.
4. The VK Trust continuously offers
three classes of shares to the public at
net asset value. The VK Trust currently
operates as an ‘‘interval fund’’ pursuant
to rule 23c–3 under the Act, and makes
quarterly tender offers to repurchase its
shares.2 The MS Trust continuously
offers one class of shares to the public
at net asset value, but it intends to add
multiple classes of shares. The MS Trust
also intends to operate as an ‘‘interval
fund’’ pursuant to rule 23c–3 under the
Act, and make quarterly tender offers to
repurchase its shares.3 Applicants
request an order to permit each of the
VK Trust and the MS Trust (and any
Other Trust) to offer to repurchase a
portion of its common shares at one–
month intervals, rather than the three,
six, or twelve–month intervals specified
by rule 23c–3. Shares of the VK Trust
and the MS Trust are offered with initial
or deferred sales charges and certain
classes of the VK Trust’s shares also
carry asset-based distribution and
service fees.4 The Trusts or any Other
Trust may in the future offer additional
2 From its inception in 1989 until February 2005,
the VK Trust considered each quarter to offer to
repurchase a portion of its outstanding shares at
their then-current net asset value pursuant to rule
13e–4 of the Exchange Act. In February 2005, the
VK Trust began operating as an interval fund
making quarterly repurchases pursuant to Rule
23c–3.
3 From its inception in 1989, the MS Trust has
considered each quarter to offer to repurchase a
portion of its outstanding shares at their thencurrent net asset value pursuant to rule 13e–4 of the
Exchange Act. The MS Trust is currently in the
process of converting to an interval fund making
quarterly repurchases pursuant to Rule 23c–3.
4 The VK Trust currently offers Class A, B and C
shares. (The VK Trust also has IB shares and IC
shares which are not continuously offered.) Each
class of continuously offered shares is subject to
annual asset-based distribution and service fees.
Class B and C shares are subject to early withdrawal
charges (‘‘EWCs’’). The MS Trust’s single class of
shares is not subject to any annual asset-based
distribution and service fees, but is subject to an
EWC. The applicants previously obtained
exemptive relief from the Commission as it relates
to the imposition of EWCs. See In the Matter of Van
Kampen Investment Advisory Corp., et al.,
Investment Company Act Rel. Nos. 25924 (February
3, 2003) (notice) and 25951 (March 3, 2003) (order).
VerDate Aug<31>2005
17:06 May 17, 2006
Jkt 208001
classes of common shares with a frontend sales charge, an EWC and/or assetbased distribution or service fees. The
Trusts’ common shares are not offered
or traded in the secondary market and
are not listed on any exchange or quoted
on any quotation medium.
5. Each of the Trusts and any Other
Trust will disclose in its prospectus and
annual reports its fundamental policy to
make monthly offers to repurchase a
portion of its common shares at net
asset value, less deduction of a
repurchase fee, if any, as permitted by
rule 23c–3(b)(1), and the imposition of
EWCs as permitted pursuant to
exemptive relief previously granted by
the Commission. The fundamental
policy will be changeable only by a
majority vote of the holders of such
trust’s outstanding voting securities.
Under the fundamental policy, the
repurchase offer amount will be
determined by the board of trustees of
the relevant Trust or Other Trust
(‘‘Board’’) prior to each repurchase offer.
The Trusts and any Other Trust will
comply with rule 23c–3(b)(8)’s
requirements with respect to its trustees
who are not interested persons of the
VK Trust, the MS Trust or Other Trust,
as applicable, within the meaning of
section 2(a)(19) of the Act
(‘‘Disinterested Trustees’’) and their
legal counsel. Under its fundamental
policy, each Trust and Other Trust will
make monthly offers to repurchase not
less than 5% of its outstanding shares at
the time of the repurchase request
deadline. The repurchase offer amounts
for the then-current monthly period,
plus the repurchase offer amounts for
the two monthly periods immediately
preceding the then-current monthly
period, will not exceed 25% of the
outstanding common shares of the
relevant Trust or Other Trust.
6. The prospectus of each Trust and
Other Trust will state the means to
determine the repurchase request
deadline and the maximum number of
days between each repurchase request
deadline and the repurchase pricing
date. Each Trust’s or Other Trust’s
repurchase pricing date normally will
be the same date as the repurchase
request deadline and pricing will be
determined after close of business on
that date.
7. Pursuant to rule 23c–3(b)(1), each
Trust and any Other Trust will
repurchase shares for cash on or before
the repurchase payment deadline,
which will be no later than seven
calendar days after the repurchase
pricing date. Each Trust and Other Trust
currently intends to make payment by
the third business day following the
repurchase pricing date. Each Trust and
PO 00000
Frm 00042
Fmt 4703
Sfmt 4703
28891
Other Trust will make payment for
shares repurchased in the previous
month’s repurchase offer at least five
business days before sending
notification of the next repurchase offer.
The VK Trust has not and currently
does not intend to deduct any
repurchase fees from the repurchase
proceeds payable to tendering
shareholders, but the Trusts and Other
Trusts reserve the right to do so in
compliance with rule 23c–3(b)(1).
8. Each Trust and Other Trust will
provide common shareholders with
notification of each repurchase offer no
less than seven days and no more than
fourteen days prior to the repurchase
request deadline. The notification will
include all information required by rule
23c–3(b)(4)(i). Each Trust and Other
Trust will file the notification and the
Form N–23c–3 with the Commission
within three business days after sending
the notification to its respective
common shareholders.
9. Each Trust and Other Trust will not
suspend or postpone a repurchase offer
except pursuant to the vote of a majority
of its Disinterested Trustees, and only
under the limited circumstances
specified in rule 23c–3(b)(3)(i). The
Trusts and any Other Trust will not
condition a repurchase offer upon
tender of any minimum amount of
shares. In addition, each of the Trusts
and any Other Trust will comply with
the pro ration and other allocation
requirements of rule 23c–3(b)(5) if
common shareholders tender more than
the repurchase offer amount. Further,
each Trust and any Other Trust will
permit tenders to be withdrawn or
modified at any time until the
repurchase request deadline, but will
not permit tenders to be withdrawn or
modified thereafter.
10. From the time a Trust or any
Other Trust sends its notification to
shareholders of the repurchase offer
until the repurchase pricing date, a
percentage of such trust’s assets equal to
at least 100% of the repurchase offer
amount will consist of: (a) Assets that
can be sold or disposed of in the
ordinary course of business at
approximately the price at which such
trust has valued such investment within
a period equal to the period between the
repurchase request deadline and the
repurchase payment deadline; or (b)
assets that mature by the next
repurchase payment deadline. In the
event the assets of a Trust or Other Trust
fail to comply with this requirement, the
Board will cause such trust to take such
action as it deems appropriate to ensure
compliance.
11. In compliance with the asset
coverage requirements of section 18 of
E:\FR\FM\18MYN1.SGM
18MYN1
28892
Federal Register / Vol. 71, No. 96 / Thursday, May 18, 2006 / Notices
wwhite on PROD1PC61 with NOTICES
the Act, any senior security issued by,
or other indebtedness of, each of the
Trusts and any Other Trust will either
mature by the next repurchase pricing
date or provide for such trust’s ability to
call, repay or redeem such senior
security or other indebtedness by the
next repurchase pricing date, either in
whole or in part, without penalty or
premium, as necessary to permit that
trust to complete the repurchase offer in
such amounts determined by its Board.
12. The Board of each Trust and any
Other Trust will adopt written
procedures to ensure that such trust’s
portfolio assets are sufficiently liquid so
that it can comply with its fundamental
policy on repurchases and the liquidity
requirements of rule 23c–3(b)(10)(i). The
Board will review the overall
composition of the portfolio and make
and approve such changes to the
procedures as it deems necessary.
Applicants’ Legal Analysis
1. Section 6(c) 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 provision of the
Act or rule thereunder, if and to the
extent that such exemption is necessary
or appropriate in the public interest and
consistent with the protection of
investors and the purposes fairly
intended by the policy and provisions of
the Act.
2. Section 23(c) of the Act provides in
relevant part that no registered closedend investment company shall purchase
any securities of any class of which it
is the issuer except: (a) On a securities
exchange or other open market; (b)
pursuant to tenders, after reasonable
opportunity to submit tenders given to
all holders of securities of the class to
be purchased; or (c) under such other
circumstances as the Commission may
permit by rules and regulations or
orders for the protection of investors.
3. Rule 23c–3 under the Act permits
a registered closed-end investment
company to make repurchase offers for
its common stock at net asset value at
periodic intervals pursuant to a
fundamental policy of the investment
company. ‘‘Periodic interval’’ is defined
in rule 23c–3(a)(1) as an interval of
three, six, or twelve months. Rule 23c–
3(b)(4) requires that notification of each
repurchase offer be sent to shareholders
no less than 21 calendar days and no
more than 42 calendar days before the
repurchase request deadline.
4. Applicants request an order
pursuant to sections 6(c) and 23(c) of
the Act exempting them from rule 23c–
3(a)(1) to the extent necessary to permit
the Trusts and any Other Trust to make
VerDate Aug<31>2005
17:06 May 17, 2006
Jkt 208001
monthly repurchase offers. Applicants
also request an exemption from the
notice provisions of rule 23c–3(b)(4) to
the extent necessary to permit the Trusts
and any Other Trust to send notification
of an upcoming repurchase offer to
shareholders at least seven days but no
more than fourteen calendar days in
advance of the repurchase request
deadline.
5. Applicants contend that monthly
repurchase offers are in the
shareholders’ best interests and
consistent with the policies underlying
rule 23c–3. Applicants assert that
monthly repurchase offers will provide
investors with more liquidity than
quarterly repurchase offers. Applicants
assert that shareholders will be better
able to manage their investments and
plan transactions, because if they decide
to forego a repurchase offer, they will
only need to wait one month for the
next offer. Applicants also contend that
the portfolios of the Trusts and any
Other Trust will be managed to provide
ample liquidity for monthly repurchase
offers. Applicants do not believe that a
change to monthly repurchases would
necessitate any change in portfolio
management practices of the Trusts or
any Other Trust in order to satisfy rule
23c–3. In fact, applicants expect limited
or no impact on overall portfolio
management or performance of such
trusts upon converting to monthly offers
and believe that it may be easier to
manage the cash of the portfolio for the
smaller monthly offers compared to the
larger quarterly ones.
6. Applicants propose to send
notification to shareholders at least
seven days, but no more than fourteen
calendar days, in advance of a
repurchase request deadline. Applicants
assert that, because the Trusts and any
Other Trust intend to price on the
repurchase request deadline and pay by
the third business day following the
pricing date, the entire procedure can be
completed before the next notification is
sent out to shareholders; thus avoiding
any overlap. Applicants believe that
these procedures will eliminate any
possibility of investor confusion.
Applicants also state that monthly
repurchase offers will be a fundamental
feature of the Trusts and any Other
Trust, and their prospectuses will
provide a clear explanation of the
repurchase program.
7. Applicants submit that for the
reasons given above the requested relief
is appropriate in the public interest and
is consistent with the protection of
investors and the purposes fairly
intended by the policy and provisions of
the Act.
PO 00000
Frm 00043
Fmt 4703
Sfmt 4703
Applicants’ Conditions
Applicants agree that any order
granting the requested relief shall be
subject to the following conditions:
1. Each Trust (and any Other Trust
relying on this relief) will make a
repurchase offer pursuant to rule 23c–
3(b) for a repurchase offer amount of not
less than 5% in any one-month period.
In addition, the repurchase offer amount
for the then-current monthly period,
plus the repurchase offer amounts for
the two monthly periods immediately
preceding the then-current monthly
period, will not exceed 25% of the
Trust’s (or Other Trust’s) outstanding
shares. Each Trust (or Other Trust
relying on this relief) may repurchase
additional tendered shares pursuant to
rule 23c–3(b)(5) only to the extent the
percentage of additional shares so
repurchased does not exceed 2% in any
three-month period.
2. Payment for repurchased shares
will occur at least five business days
before notification of the next
repurchase offer is sent to shareholders
of any Trust (or Other Trust relying on
this relief).
For the Commission, by the Division of
Investment Management, under delegated
authority.
J. Lynn Taylor,
Assistant Secretary.
[FR Doc. E6–7567 Filed 5–17–06; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
Sunshine Act Meetings
Notice is hereby given, pursuant to
the provisions of the Government in the
Sunshine Act, Public Law 94–409, that
the Securities and Exchange
Commission will hold the following
meetings during the week of May 22,
2006: An Open Meeting will be held on
Monday, May 22, 2006 at 10 a.m. in the
Auditorium, Room LL–002 and Closed
Meetings will be held on Monday, May
22, 2006 at 11 a.m. and on Thursday,
May 25, 2006 at 2 p.m.
Commissioners, Counsel to the
Commissioners, the Secretary to the
Commission, and recording secretaries
will attend the Closed Meetings. Certain
staff members who have an interest in
the matters may also be present.
The General Counsel of the
Commission, or his designee, has
certified that, in his opinion, one or
more of the exemptions set forth in 5
U.S.C. 552b(c)(3), (5), (7), (8), (9)(B), (10)
and 17 CFR 200.402(a)(3), (5), (7), (8),
(9)(ii), and (10) permit consideration of
E:\FR\FM\18MYN1.SGM
18MYN1
Agencies
[Federal Register Volume 71, Number 96 (Thursday, May 18, 2006)]
[Notices]
[Pages 28890-28892]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E6-7567]
=======================================================================
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 27317; 812-13156]
Van Kampen Asset Management, et al.; Notice of Application
May 12, 2006.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application for an order under sections 6(c) and
23(c)(3) of the Investment Company Act of 1940 (the ``Act'') for an
exemption from rule 23c-3 under the Act.
-----------------------------------------------------------------------
Applicants: Van Kampen Asset Management (the ``VK Adviser''), Van
Kampen Funds Inc. (the ``VK Distributor''), Van Kampen Senior Loan Fund
(formerly known as Van Kampen Prime Rate Income Trust) (the ``VK
Trust''), Morgan Stanley Investment Advisors Inc. (the ``MS Adviser''),
Morgan Stanley Distributors Inc. (the ``MS Distributor'') and Morgan
Stanley Prime Income Trust (the ``MS Trust'', and, together with the VK
Trust, the ``Trusts'').
Summary of Application: Applicants request an order under sections 6(c)
and 23(c)(3) of the Act for an exemption from certain provisions of
rule 23c-3 to permit certain registered closed-end investment companies
to make repurchase offers on a monthly basis.
Filing Dates: The application was filed on January 25, 2005 and amended
on December 29, 2005 and May 5, 2006.
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 June 6, 2006, and should be accompanied by proof of service on
the 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, c/o Charles B.
Taylor, Esq., Skadden, Arps, Slate, Meagher & Flom LLP, 333 West Wacker
Drive, Chicago, Illinois 60606.
FOR FURTHER INFORMATION CONTACT: Shannon Conaty, Senior Counsel, at
(202) 551-6827, or Janet M. Grossnickle, Branch Chief, 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
Commission's Public Reference Branch, 100 F Street, NE., Washington, DC
20549-0102 (tel. (202) 551-8090).
Applicants' Representations
1. Each of the Trusts is a closed-end management investment company
registered under the Act and organized as a Massachusetts business
trust. The VK Adviser and the MS Adviser, both investment advisers
registered under the Investment Advisers Act of 1940 (the ``Advisers
Act''), serve as investment adviser to the VK Trust and the MS Trust,
respectively. The VK Distributor, a broker-dealer registered under the
Securities Exchange Act of 1934 (the ``Exchange Act''), distributes the
VK Trust's shares and serves as the VK Trust's administrator. The MS
Distributor, a broker-dealer registered under the Exchange Act,
distributes the MS Trust's shares. The VK Adviser, the VK Distributor,
the MS Adviser and the MS Distributor are all direct or indirect
wholly-owned subsidiaries of Morgan Stanley. Applicants request that
any relief granted also apply to any registered closed-end management
investment company that operates as an interval fund pursuant to rule
23c-3 for which the VK Adviser, the VK Distributor, the MS Adviser, the
MS Distributor or any entity controlling, controlled by or under common
control (within the meaning of section 2(a)(9) of the Act) with the VK
Adviser, the VK Distributor, the MS Adviser or the MS Distributor acts
as investment adviser, principal underwriter or administrator
(collectively, the ``Other Trusts'').\1\
---------------------------------------------------------------------------
\1\ All entities currently intending to rely on the requested
relief have been named as applicants. Any entity that relies on the
requested order in the future will do so only in accordance with the
terms and conditions of the application.
---------------------------------------------------------------------------
2. The VK Trust's investment objective is to provide a high level
of current income, consistent with the preservation of capital. The VK
Trust invests primarily in adjustable rate senior loans made to
corporations and other borrowers. Under normal market conditions, the
VK Trust invests at least 80% of its net assets (plus any borrowings
for investment purposes) in adjustable rate senior loans. The VK Trust
may also invest up to 20% of its total assets in senior loans that are
not secured by any specific collateral, senior loans made to borrowers
located outside the U.S. (provided no more than 5% of these loans or
other assets are non-U.S. dollar denominated), and in any combination
of warrants and equity securities incidental to investment in senior
loans, junior debt securities, high quality short-term debt securities,
credit-linked deposits and Treasury Inflation Protected Securities (or
other inflation-indexed bonds issued by the U.S. government, its
agencies or instrumentalities).
3. The MS Trust's investment objective is to provide a high level
of current income, consistent with the preservation of capital. The MS
Trust
[[Page 28891]]
invests primarily in collateralized senior loans made to corporations,
partnerships or other entities. Under normal market conditions, the MS
Trust invests at least 80% of its total assets in collateralized senior
loans. The MS Trust may also invest up to 20% of its total assets in
cash or short-term high quality money market instruments, credit-linked
deposits, junior debt securities or securities with a lien on
collateral that is lower than a senior claim on collateral, and in
loans that hold the most senior position in a borrower's capital
structure, but are unsecured.
4. The VK Trust continuously offers three classes of shares to the
public at net asset value. The VK Trust currently operates as an
``interval fund'' pursuant to rule 23c-3 under the Act, and makes
quarterly tender offers to repurchase its shares.\2\ The MS Trust
continuously offers one class of shares to the public at net asset
value, but it intends to add multiple classes of shares. The MS Trust
also intends to operate as an ``interval fund'' pursuant to rule 23c-3
under the Act, and make quarterly tender offers to repurchase its
shares.\3\ Applicants request an order to permit each of the VK Trust
and the MS Trust (and any Other Trust) to offer to repurchase a portion
of its common shares at one-month intervals, rather than the three,
six, or twelve-month intervals specified by rule 23c-3. Shares of the
VK Trust and the MS Trust are offered with initial or deferred sales
charges and certain classes of the VK Trust's shares also carry asset-
based distribution and service fees.\4\ The Trusts or any Other Trust
may in the future offer additional classes of common shares with a
front-end sales charge, an EWC and/or asset-based distribution or
service fees. The Trusts' common shares are not offered or traded in
the secondary market and are not listed on any exchange or quoted on
any quotation medium.
---------------------------------------------------------------------------
\2\ From its inception in 1989 until February 2005, the VK Trust
considered each quarter to offer to repurchase a portion of its
outstanding shares at their then-current net asset value pursuant to
rule 13e-4 of the Exchange Act. In February 2005, the VK Trust began
operating as an interval fund making quarterly repurchases pursuant
to Rule 23c-3.
\3\ From its inception in 1989, the MS Trust has considered each
quarter to offer to repurchase a portion of its outstanding shares
at their then-current net asset value pursuant to rule 13e-4 of the
Exchange Act. The MS Trust is currently in the process of converting
to an interval fund making quarterly repurchases pursuant to Rule
23c-3.
\4\ The VK Trust currently offers Class A, B and C shares. (The
VK Trust also has IB shares and IC shares which are not continuously
offered.) Each class of continuously offered shares is subject to
annual asset-based distribution and service fees. Class B and C
shares are subject to early withdrawal charges (``EWCs''). The MS
Trust's single class of shares is not subject to any annual asset-
based distribution and service fees, but is subject to an EWC. The
applicants previously obtained exemptive relief from the Commission
as it relates to the imposition of EWCs. See In the Matter of Van
Kampen Investment Advisory Corp., et al., Investment Company Act
Rel. Nos. 25924 (February 3, 2003) (notice) and 25951 (March 3,
2003) (order).
---------------------------------------------------------------------------
5. Each of the Trusts and any Other Trust will disclose in its
prospectus and annual reports its fundamental policy to make monthly
offers to repurchase a portion of its common shares at net asset value,
less deduction of a repurchase fee, if any, as permitted by rule 23c-
3(b)(1), and the imposition of EWCs as permitted pursuant to exemptive
relief previously granted by the Commission. The fundamental policy
will be changeable only by a majority vote of the holders of such
trust's outstanding voting securities. Under the fundamental policy,
the repurchase offer amount will be determined by the board of trustees
of the relevant Trust or Other Trust (``Board'') prior to each
repurchase offer. The Trusts and any Other Trust will comply with rule
23c-3(b)(8)'s requirements with respect to its trustees who are not
interested persons of the VK Trust, the MS Trust or Other Trust, as
applicable, within the meaning of section 2(a)(19) of the Act
(``Disinterested Trustees'') and their legal counsel. Under its
fundamental policy, each Trust and Other Trust will make monthly offers
to repurchase not less than 5% of its outstanding shares at the time of
the repurchase request deadline. The repurchase offer amounts for the
then-current monthly period, plus the repurchase offer amounts for the
two monthly periods immediately preceding the then-current monthly
period, will not exceed 25% of the outstanding common shares of the
relevant Trust or Other Trust.
6. The prospectus of each Trust and Other Trust will state the
means to determine the repurchase request deadline and the maximum
number of days between each repurchase request deadline and the
repurchase pricing date. Each Trust's or Other Trust's repurchase
pricing date normally will be the same date as the repurchase request
deadline and pricing will be determined after close of business on that
date.
7. Pursuant to rule 23c-3(b)(1), each Trust and any Other Trust
will repurchase shares for cash on or before the repurchase payment
deadline, which will be no later than seven calendar days after the
repurchase pricing date. Each Trust and Other Trust currently intends
to make payment by the third business day following the repurchase
pricing date. Each Trust and Other Trust will make payment for shares
repurchased in the previous month's repurchase offer at least five
business days before sending notification of the next repurchase offer.
The VK Trust has not and currently does not intend to deduct any
repurchase fees from the repurchase proceeds payable to tendering
shareholders, but the Trusts and Other Trusts reserve the right to do
so in compliance with rule 23c-3(b)(1).
8. Each Trust and Other Trust will provide common shareholders with
notification of each repurchase offer no less than seven days and no
more than fourteen days prior to the repurchase request deadline. The
notification will include all information required by rule 23c-
3(b)(4)(i). Each Trust and Other Trust will file the notification and
the Form N-23c-3 with the Commission within three business days after
sending the notification to its respective common shareholders.
9. Each Trust and Other Trust will not suspend or postpone a
repurchase offer except pursuant to the vote of a majority of its
Disinterested Trustees, and only under the limited circumstances
specified in rule 23c-3(b)(3)(i). The Trusts and any Other Trust will
not condition a repurchase offer upon tender of any minimum amount of
shares. In addition, each of the Trusts and any Other Trust will comply
with the pro ration and other allocation requirements of rule 23c-
3(b)(5) if common shareholders tender more than the repurchase offer
amount. Further, each Trust and any Other Trust will permit tenders to
be withdrawn or modified at any time until the repurchase request
deadline, but will not permit tenders to be withdrawn or modified
thereafter.
10. From the time a Trust or any Other Trust sends its notification
to shareholders of the repurchase offer until the repurchase pricing
date, a percentage of such trust's assets equal to at least 100% of the
repurchase offer amount will consist of: (a) Assets that can be sold or
disposed of in the ordinary course of business at approximately the
price at which such trust has valued such investment within a period
equal to the period between the repurchase request deadline and the
repurchase payment deadline; or (b) assets that mature by the next
repurchase payment deadline. In the event the assets of a Trust or
Other Trust fail to comply with this requirement, the Board will cause
such trust to take such action as it deems appropriate to ensure
compliance.
11. In compliance with the asset coverage requirements of section
18 of
[[Page 28892]]
the Act, any senior security issued by, or other indebtedness of, each
of the Trusts and any Other Trust will either mature by the next
repurchase pricing date or provide for such trust's ability to call,
repay or redeem such senior security or other indebtedness by the next
repurchase pricing date, either in whole or in part, without penalty or
premium, as necessary to permit that trust to complete the repurchase
offer in such amounts determined by its Board.
12. The Board of each Trust and any Other Trust will adopt written
procedures to ensure that such trust's portfolio assets are
sufficiently liquid so that it can comply with its fundamental policy
on repurchases and the liquidity requirements of rule 23c-3(b)(10)(i).
The Board will review the overall composition of the portfolio and make
and approve such changes to the procedures as it deems necessary.
Applicants' Legal Analysis
1. Section 6(c) 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 provision of the Act or
rule thereunder, if and to the extent that such exemption is necessary
or appropriate in the public interest and consistent with the
protection of investors and the purposes fairly intended by the policy
and provisions of the Act.
2. Section 23(c) of the Act provides in relevant part that no
registered closed-end investment company shall purchase any securities
of any class of which it is the issuer except: (a) On a securities
exchange or other open market; (b) pursuant to tenders, after
reasonable opportunity to submit tenders given to all holders of
securities of the class to be purchased; or (c) under such other
circumstances as the Commission may permit by rules and regulations or
orders for the protection of investors.
3. Rule 23c-3 under the Act permits a registered closed-end
investment company to make repurchase offers for its common stock at
net asset value at periodic intervals pursuant to a fundamental policy
of the investment company. ``Periodic interval'' is defined in rule
23c-3(a)(1) as an interval of three, six, or twelve months. Rule 23c-
3(b)(4) requires that notification of each repurchase offer be sent to
shareholders no less than 21 calendar days and no more than 42 calendar
days before the repurchase request deadline.
4. Applicants request an order pursuant to sections 6(c) and 23(c)
of the Act exempting them from rule 23c-3(a)(1) to the extent necessary
to permit the Trusts and any Other Trust to make monthly repurchase
offers. Applicants also request an exemption from the notice provisions
of rule 23c-3(b)(4) to the extent necessary to permit the Trusts and
any Other Trust to send notification of an upcoming repurchase offer to
shareholders at least seven days but no more than fourteen calendar
days in advance of the repurchase request deadline.
5. Applicants contend that monthly repurchase offers are in the
shareholders' best interests and consistent with the policies
underlying rule 23c-3. Applicants assert that monthly repurchase offers
will provide investors with more liquidity than quarterly repurchase
offers. Applicants assert that shareholders will be better able to
manage their investments and plan transactions, because if they decide
to forego a repurchase offer, they will only need to wait one month for
the next offer. Applicants also contend that the portfolios of the
Trusts and any Other Trust will be managed to provide ample liquidity
for monthly repurchase offers. Applicants do not believe that a change
to monthly repurchases would necessitate any change in portfolio
management practices of the Trusts or any Other Trust in order to
satisfy rule 23c-3. In fact, applicants expect limited or no impact on
overall portfolio management or performance of such trusts upon
converting to monthly offers and believe that it may be easier to
manage the cash of the portfolio for the smaller monthly offers
compared to the larger quarterly ones.
6. Applicants propose to send notification to shareholders at least
seven days, but no more than fourteen calendar days, in advance of a
repurchase request deadline. Applicants assert that, because the Trusts
and any Other Trust intend to price on the repurchase request deadline
and pay by the third business day following the pricing date, the
entire procedure can be completed before the next notification is sent
out to shareholders; thus avoiding any overlap. Applicants believe that
these procedures will eliminate any possibility of investor confusion.
Applicants also state that monthly repurchase offers will be a
fundamental feature of the Trusts and any Other Trust, and their
prospectuses will provide a clear explanation of the repurchase
program.
7. Applicants submit that for the reasons given above the requested
relief is appropriate in the public interest and is consistent with the
protection of investors and the purposes fairly intended by the policy
and provisions of the Act.
Applicants' Conditions
Applicants agree that any order granting the requested relief shall
be subject to the following conditions:
1. Each Trust (and any Other Trust relying on this relief) will
make a repurchase offer pursuant to rule 23c-3(b) for a repurchase
offer amount of not less than 5% in any one-month period. In addition,
the repurchase offer amount for the then-current monthly period, plus
the repurchase offer amounts for the two monthly periods immediately
preceding the then-current monthly period, will not exceed 25% of the
Trust's (or Other Trust's) outstanding shares. Each Trust (or Other
Trust relying on this relief) may repurchase additional tendered shares
pursuant to rule 23c-3(b)(5) only to the extent the percentage of
additional shares so repurchased does not exceed 2% in any three-month
period.
2. Payment for repurchased shares will occur at least five business
days before notification of the next repurchase offer is sent to
shareholders of any Trust (or Other Trust relying on this relief).
For the Commission, by the Division of Investment Management,
under delegated authority.
J. Lynn Taylor,
Assistant Secretary.
[FR Doc. E6-7567 Filed 5-17-06; 8:45 am]
BILLING CODE 8010-01-P