Ziegler Exchange Traded Trust, et al.; Notice of Application, 163-167 [E6-22444]
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Federal Register / Vol. 72, No. 1 / Wednesday, January 3, 2007 / Notices
Secretary, Securities and
Exchange Commission, 100 F Street,
NE., Washington, DC 20549–1090.
Applicants: ProShares Trust and
Adviser, 7501 Wisconsin Avenue, Suite
1000, Bethesda, MD 20814; SEI
Investments Distribution Company, One
Freedom Valley Drive, Oaks, PA 19456.
FOR FURTHER INFORMATION CONTACT: John
Yoder, Senior Counsel, at (202) 551–
6878, or Julia Kim Gilmer, 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 Desk,
100 F Street, NE., Washington, DC
20549–0102 (tel. 202–551–5850).
ADDRESSES:
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Applicants’ Representations
1. The Trust is an open-end
management investment company
registered under the Act and organized
as a Delaware statutory trust. The Trust
is authorized to offer an unlimited
number of series. The Adviser is
registered as an investment adviser
under the Investment Advisers Act of
1940 (‘‘Advisers Act’’) and will advise
each Fund. The Adviser may enter into
subadvisory agreements with additional
investment advisers to act as subadviser
to the Trust and any Fund. Any
subadviser to the Trust or a Fund will
be registered under the Advisers Act.
The Distributor is registered as a brokerdealer under the Securities Exchange
Act of 1934 and will act as the
distributor and principal underwriter
for each Fund’s shares.
2. The Prior Order permits the Initial
Funds to seek daily investment results,
before fees and expenses, that
correspond to 100%, 125%, 150% or
200% of the performance, or the inverse
of the performance, or 125%, 150% or
200% of the inverse multiple of the
performance of particular equity
securities indices.2 Applicants seek to
2 The Prior Order permits the Trust to offer Initial
Funds based on the following underlying indices
only: S&P 500 Index, Nasdaq100 Index, Dow Jones
Industrial Average, S&P MidCap400 Index, Russell
2000 Index, S&P Small Cap 600 Index, Nasdaq
Composite Index, S&P 500/ Citigroup Value Index
(formerly S&P 500 BARRA Value Index), S&P 500/
Citigroup Growth Index (formerly S&P 500 BARRA
Growth Index), S&P MidCap400/ Citigroup Value
Index (formerly S&P MidCap400 BARRA Value
Index), S&P MidCap 400/ Citigroup Growth Index
(formerly S&P MidCap 400/BARRA Growth Index),
S&P SmallCap 600/ Citigroup Value Index (formerly
S&P SmallCap 600/Barra Value Index), S&P
SmallCap 600/ Citigroup Growth Index (formerly
S&P SmallCap 600/BARRA Growth Index), Dow
Jones U.S. Airlines Index, Dow Jones U.S. Banks
Index, Dow Jones U.S. Basic Materials Sector Index,
Dow Jones U.S. Biotechnology Index, Dow Jones
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amend the Prior Order to permit both
the Initial Funds and Additional Funds
to be offered using New Underlying
Indices.3 All Additional Funds will
operate in a manner identical to the
Initial Funds. No creator, provider or
compiler of a New 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, a promoter, the
Adviser, any subadviser to any Fund, or
the Distributor.
3. Applicants state that the Funds will
be offered pursuant to the same terms
and provisions contained in the
application for the Prior Order.
Applicants agree that the amended
order will subject applicants to the same
conditions as imposed by the Prior
Order. Applicants believe that the
requested relief continues to meet the
necessary exemptive standards.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. E6–22447 Filed 12–29–06; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
27610; 812–13224]
Ziegler Exchange Traded Trust, et al.;
Notice of Application
December 22, 2006.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 6(c) of the
AGENCY:
U.S. Composite Internet Index, Dow Jones U.S.
Consumer Services Index, Dow Jones U.S.
Consumer Goods Index, Dow Jones U.S. Oil & Gas
Index, Dow Jones U.S. Financials Index, Dow Jones
U.S. Health Care Index, Dow Jones U.S. Industrials
Index, Dow Jones U.S. Leisure Goods Index, Dow
Jones U.S. Oil Equipment, Services & Distribution
Index, Dow Jones U.S. Pharmaceuticals Index, Dow
Jones U.S. Precious Metals Index, Dow Jones U.S.
Real Estate Index, Dow Jones U.S. Semiconductors
Index, Dow Jones U.S. Technology Index, Dow
Jones U.S. Telecommunications Index, Dow Jones
U.S. Utilities Index and Dow Jones U.S. Mobile
Communications Index.
3 The New Underlying Indices are the S&P 500
Energy Sector Index, S&P 500 Materials Sector
Index, S&P 500 Industrials Sector Index, S&P 500
Consumer Discretionary Sector Index, S&P 500
Consumer Staples Sector Index, S&P 500 Health
Care Sector Index, S&P 500 Financials Sector Index,
S&P 500 Information Technology Sector Index, S&P
500 Telecommunication Services Sector Index, S&P
500 Utilities Sector Index, Russell 1000 Value
Index, Russell 1000 Growth Index, Russell MidCap
Value Index, Russell MidCap Growth Index, Russell
2000 Value Index, Russell 2000 Growth Index,
Russell 3000 Value Index and Russell 3000 Growth
Index.
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163
Investment Company Act of 1940
(‘‘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, 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.
Applicants
request an order that would permit (a)
series of registered open-end
management investment companies, to
issue shares (‘‘Fund Shares’’) that can be
redeemed only in large aggregations
(‘‘Creation Unit Aggregations’’); (b)
secondary market transactions in Fund
Shares to occur at negotiated prices; (c)
dealers to sell Fund 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’’); and (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 Unit
Aggregations.
APPLICANTS: Ziegler Exchange Traded
Trust (‘‘Trust’’); Ziegler Capital
Management, LLC (‘‘Advisor’’); and B.C.
Ziegler and Company (‘‘Distributor’’).
FILING DATES: The application was filed
on August 16, 2005, and amended on
June 5, 2006, November 17, 2006, and
December 19, 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 January 17, 2007, 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, 250 East Wisconsin
Avenue, Suite 2200, Milwaukee, WI
53202.
FOR FURTHER INFORMATION CONTACT:
Deepak T. Pai, Senior Counsel at (202)
551–6876, or Stacy L. Fuller, Branch
Chief, at (202) 551–6821 (Division of
Investment Management, Office of
Investment Company Regulation).
SUMMARY OF APPLICATION:
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Federal Register / Vol. 72, No. 1 / Wednesday, January 3, 2007 / Notices
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.
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SUPPLEMENTARY INFORMATION:
Applicants’ Representations
1. The Trust is registered as an openend management investment company
and is organized as a Delaware statutory
trust that may offer multiple series
(‘‘Funds’’). Each Fund will track an
index of domestic equity securities
(‘‘Underlying Index’’). The initial Fund
(‘‘Initial Fund’’) will track the NYSE
Arca Tech 100 Index.
2. The Advisor is registered as an
investment adviser under the
Investment Advisers Act of 1940
(‘‘Advisers Act’’). The Advisor will
serve as the investment adviser to the
Initial Fund. The Adviser may enter into
sub-advisory agreements with other
investment advisers to act as ‘‘subadvisers’’ with respect to the Funds.
Any sub-adviser will be registered
under the Advisers Act. The Distributor,
a broker-dealer registered under the
Securities Exchange Act of 1934
(‘‘Exchange Act’’), will serve as the
principal underwriter and distributor of
Fund Shares.
3. Each Fund will hold certain U.S.
equity securities (‘‘Portfolio Securities’’)
including American Depository Receipts
(‘‘ADRs’’) selected to correspond
generally to the price and yield
performance, before fees and expenses,
of 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,
Advisor, Distributor, or promoter of or
any sub-adviser to, a Fund. The Trust
intends to offer additional Funds in the
future based on other Underlying
Indices (included in the defined term
‘‘Funds’’). Any such future Funds will
(a) comply with the terms and
conditions of any order granted
pursuant to the application and (b) be
advised by the Advisor or an entity
controlling, controlled by or under
common control with the Advisor
(included in the defined term
‘‘Advisor’’). All Funds that currently
intend to rely on the requested order are
named as applicants.
4. The investment objective of each
Fund will be to provide investment
results that correspond generally to the
price and yield performance of its
Underlying Index. Intra-day values of
the Underlying Index will be
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disseminated every 15 seconds
throughout the trading day. A Fund will
utilize either a ‘‘replication’’ or
‘‘representative sampling’’ strategy.1 A
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,
a 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 a 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 Fund
will have a tracking error relative to the
performance of its Underlying Index of
no more than five percent.
5. Fund Shares will be sold at a price
of between $20 and $300 per Fund
Share in Creation Unit Aggregations of
between 50,000 and 100,000 Fund
Shares. All orders to purchase Creation
Unit Aggregations 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
Fund generally will be sold in Creation
Unit Aggregations in exchange for an inkind deposit by the purchaser of a
portfolio of securities designated by the
Adviser (‘‘Deposit Securities’’), together
with the deposit of a specified cash
1 Applicants represent that a Fund will normally
invest at least 90% of its total assets in the
component securities that comprise its Underlying
Index. Each Fund may invest up to 10% of its assets
in certain futures, options and 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 Fund track it’s
Underlying Index.
2 Under the representative sampling strategy, the
Adviser will seek to construct a Fund’s portfolio to
have aggregate investment characteristics,
fundamental characteristics, and liquidity measures
similar to those of the Underlying Index.
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payment (‘‘Cash Amount’’).3 The Cash
Amount is generally an amount equal to
the difference between (a) the net asset
value (‘‘NAV’’) (per Creation Unit
Aggregation) of the Fund and (b) the
total aggregate market value (per
Creation Unit Aggregation) of the
Deposit Securities.4 Applicants state
that in some circumstances it may not
be practicable or convenient for a Fund
to operate exclusively on an ‘‘in-kind’’
basis. The Trust reserves the right to
permit, under certain circumstances, a
purchaser of Creation Unit Aggregations
to substitute cash in lieu of depositing
some or all of the requisite Deposit
Securities. An investor purchasing a
Creation Unit Aggregation from a 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 Unit
Aggregations.5 The Transaction Fees
relevant to each Fund (including the
maximum Transaction Fees) will be
fully disclosed in the prospectus of such
Fund (‘‘Prospectus’’), and the method
for calculating the Transaction Fees will
be disclosed in each Fund’s statement of
additional information (‘‘SAI’’). The
Distributor will be responsible for
transmitting orders to the Funds, for
delivering the Prospectus to those
persons purchasing Creation Unit
Aggregations and for maintaining
records of both the orders placed with
it and the confirmations of acceptance
furnished by it. In addition, the NSCC
or DTC, as appropriate, will maintain a
record of the instructions given to the
3 The Funds must comply with the federal
securities laws in accepting Deposit Securities and
satisfying redemptions with Redemptions
Securities, including that the Deposit Securities and
Redemption Securities are sold in transactions that
would be exempt from registration under the
Securities Act of 1933. The specified Deposit
Securities and Redemption Securities will generally
correspond pro rata to the Portfolio Securities.
4 The Trust will sell Creation Unit Aggregations
of each Fund on any ‘‘Business Day,’’ which is
defined to include any day that the Fund is open
for business, including as required by section 22(e)
of the Act. In addition to the list of names (and
amount of each security constituting the current
Deposit Securities), the Cash Amount effective as of
the previous Business Day will be made available.
Any Exchange on which Fund Shares are listed will
disseminate, every 15 seconds, during its regular
trading hours, through the facilities of the
Consolidated Tape Association, an approximate
amount per Fund 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
Fund Share basis.
5 Where a 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 to the
Fund of purchasing such Deposit Securities.
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Trust to implement the delivery of Fund
Shares.
6. Purchasers of Creation Unit
Aggregations of Fund Shares may hold
such Fund Shares or may sell such
Fund Shares into the secondary market.
Fund Shares will be listed and traded
on NYSE Arca, Inc. (‘‘NYSE Arca’’) and
NYSE Arca, LLC (‘‘NYSE Arca
Marketplace’’), respectively.6 Fund
Shares of future Funds may be listed
and traded on other Exchanges (‘‘Other
Exchanges’’). It is expected that one or
more of the market makers that are
members of NYSE Arca (‘‘Arca Market
Makers’’) will register to make a market
in Fund Shares listed on NYSE Arca.
With respect to listings of Fund Shares
on certain Other Exchanges, one or more
member firms of the Other Exchange
will be designated to act as a specialist
and maintain a market for Fund Shares
on the Exchange (a ‘‘Specialist’’). If
Nasdaq is the listing Exchange of Fund
Shares, one or more member firms of
Nasdaq will act as market makers
(‘‘Nasdaq Market Makers,’’ and together
with the Arca Market Makers, ‘‘Market
Makers’’) and maintain a market for
Fund Shares. Prices of Fund Shares
trading on an Exchange will be based on
the current bid/offer market. Fund
Shares sold in the secondary market
will be subject to customary brokerage
commissions and charges.
7. Applicants expect that purchasers
of Creation Unit Aggregations will
include institutional investors and
arbitrageurs (which could include
institutional investors). A Specialist or
Market Maker also may purchase
Creation Unit Aggregations for use in
market-making activities. Applicants
expect that secondary market
purchasers of Fund Shares will include
both institutional investors and retail
investors.7 Applicants expect that the
price at which Fund Shares trade will
be disciplined by arbitrage
opportunities created by the ability to
continually purchase or redeem
Creation Unit Aggregations at their
NAV, which should ensure that Fund
Shares will not trade at a material
discount or premium in relation to their
NAV.
8. Fund Shares will not be
individually redeemable, and owners of
Fund Shares may acquire those Fund
Shares from the Fund, and tender Fund
Shares for redemption to the Fund, in
Creation Unit Aggregations only. To
redeem, an investor will have to
accumulate enough Fund Shares to
constitute a Creation Unit Aggregation.
Redemption orders must be placed by or
through an Authorized Participant. An
investor redeeming a Creation Unit
Aggregation generally will receive (a) a
portfolio of securities designated to be
delivered for Creation Unit Aggregation
redemptions on the date that the request
for redemption is submitted
(‘‘Redemption Securities’’), which may
not be identical to the Deposit Securities
required to purchase Creation Unit
Aggregations on that date, and (b) a
‘‘Cash Redemption Payment,’’
consisting of an amount calculated in
the same manner as the Cash
Component. An investor may receive
the cash equivalent of a Redemption
Security in certain circumstances, such
as if the investor is constrained from
effecting transactions in the security by
regulation or policy. A redeeming
investor will pay a Transaction Fee,
calculated in the same manner as a
Transaction Fee payable in connection
with purchases of Creation Unit
Aggregations.
9. Neither the Trust nor any
individual 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 Fund Shares, or refer
to redeemability, will prominently
disclose that Fund Shares are not
individually redeemable and that the
owners of Fund Shares may purchase or
redeem Fund Shares from the Fund in
Creation Unit Aggregations only. The
same approach will be followed in the
SAI, shareholder reports and investor
educational materials issued or
circulated in connection with the Fund
Shares. The Funds will provide copies
of their annual and semi-annual
shareholder reports to DTC Participants
for distribution to beneficial owners of
Fund Shares.
6 NYSE Arca is a national securities exchange, as
defined in section 2(a)(26) of the Act (‘‘Exchange’’).
The NYSE Arca Marketplace is the equities trading
facility of NYSE Arca. Trading on the NYSE Arca
Marketplace is subject to the rules (‘‘NYSE Arca
Equities Rules’’) of NYSE Arca Equities, Inc., a
subsidiary of NYSE Arca.
7 Fund Shares will be registered in book-entry
form only. DTC or its nominee will be the registered
owner of all outstanding Fund Shares. DTC or DTC
Participants will maintain records reflecting
beneficial owners of Fund 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, 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.
2. Section 6(c) of the Act provides that
the Commission may exempt any
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165
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 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.
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 Fund
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 Fund Shares that are
redeemable in Creation Units
Aggregations only. Applicants state that
investors may purchase Fund Shares in
Creation Unit Aggregations and redeem
Creation Unit Aggregations from each
Fund. Applicants further state that
because the market price of Fund Shares
will be disciplined by arbitrage
opportunities, investors should be able
to sell Fund 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 Fund Shares will take place
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at negotiated prices, not at a current
offering price described in a Prospectus,
and not at a price based on NAV. Thus,
purchases and sales of Fund Shares in
the secondary market will not comply
with section 22(d) and rule 22c–1.
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)
and rule 22c–1 with respect to pricing
are equally satisfied by the proposed
method of pricing Fund 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 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 Fund Shares to trade in the
secondary market at negotiated prices.
Applicants state that (a) secondary
market trading in Fund Shares does not
involve the Funds as parties and cannot
result in dilution of an investment in
Fund 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
Fund 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 Fund
Shares and their NAV remains narrow.
rwilkins on PROD1PC63 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
Fund Shares in the secondary market to
rely on the prospectus delivery
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exemption provided by section 4(3) of
the Securities Act.8
8. Applicants state that Fund 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 Fund 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 Fund 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, a website
will be maintained that will include
each Fund’s Prospectus and SAI, the
relevant Underlying Index for each
Fund, and additional quantitative
information that is updated on a daily
basis, including the closing price of
Fund Shares, the prior Business Day’s
NAV for each Fund, and a calculation
of the premium or discount of the
closing price against the NAV, as well
as data in chart format displaying the
frequency distribution of discounts and
premiums of the closing price against
8 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 Fund Shares from
the Funds or an underwriter. Applicants further
state that each Prospectus will caution brokerdealers 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 Unit
Aggregations from a Fund, breaks them down into
the constituent Fund Shares, and sells those Fund
Shares directly to customers, or if it chooses to
couple the creation of a supply of new Fund Shares
with an active selling effort involving solicitation of
secondary market demand for Fund Shares. Each
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 Prospectus will caution dealers who are not
‘‘underwriters’’ but are participating in a
distribution (as contrasted to ordinary secondary
market trading transactions), and thus dealing with
Fund 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.
PO 00000
Frm 00069
Fmt 4703
Sfmt 4703
the NAV, within appropriate ranges, for
each of the four previous calendar
quarters.
9. Applicants will arrange for brokerdealers selling Fund Shares in the
secondary market to provide purchasers
with a product description (‘‘Product
Description’’) that describes, in plain
English, the relevant Fund and the Fund
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 Fund Shares in the
secondary market.
Section 17(a)(1) and (2) of the Act
10. Section 17(a) of the Act generally
prohibits an affiliated person of a
registered investment company, or an
affiliated person of such a person, from
selling any security to, or purchasing
any security from, the company. Section
2(a)(3) of the Act defines ‘‘affiliated
person’’ to include 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, and 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 there exists the
possibility for investors, Specialists, and
Market Makers to own 5% or more, or
more than 25%, of the Fund Shares of
one or more Funds (‘‘first-tier
affiliates’’). Applicants also state that
there exists the possibility for investors
to own 5% or more, or more than 25%,
of the outstanding voting securities of
other registered investment companies
advised by the Advisor (together with
affiliated persons of first-tier affiliates
that are not otherwise affiliated with the
Funds, ‘‘second-tier affiliates’’).
11. Applicants request an exemption
from section 17(a) under sections 6(c)
and 17(b) to permit first-tier and secondtier affiliates to effectuate purchases and
redemptions in-kind. Applicants assert
that no useful purpose would be served
by prohibiting these types of affiliated
persons from purchasing or redeeming
Creation Unit Aggregations through inkind transactions. The deposit
procedures for in-kind purchases and
redemptions procedures for in-kind
redemptions of Creation Unit
Aggregations will be the same for all
purchases and redemptions. Deposit
Securities and Redemption Securities
will be valued in the same manner as
E:\FR\FM\03JAN1.SGM
03JAN1
Federal Register / Vol. 72, No. 1 / Wednesday, January 3, 2007 / Notices
rwilkins on PROD1PC63 with NOTICES
Portfolio Securities. Therefore,
applicants state, in-kind purchases and
redemptions will afford no opportunity
for these affiliated persons of a Fund to
effect a transaction detrimental to other
holders of Fund Shares. Applicants also
believe that in-kind purchases and
redemptions will not result in selfdealing or overreaching of the Fund.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
1. Each Fund’s Prospectus and
Produce Description will clearly
disclose that, for purposes of the Act,
Fund Shares are issued by the Funds
and that the acquisition of Fund Shares
by investment companies is subject to
the restrictions of section 12(d)(1) of the
Act.
2. As long as a Trust operates in
reliance on the requested order, Fund
Shares will be listed on an Exchange.
3. Neither the Trust nor any Fund will
be advertised or marketed as an openend fund or a mutual fund. Each Fund’s
Prospectus will prominently disclose
that Fund Shares are not individually
redeemable shares and will disclose that
the owners of Fund Shares may acquire
those Fund Shares from a Fund and
tender those Fund Shares for
redemption to a Fund only in Creation
Unit Aggregations. Any advertising
material that describes the purchase or
sale of Creation Unit Aggregations or
refers to redeemability will prominently
disclose that Fund Shares are not
individually redeemable and that
owners of Fund Shares may acquire
those Fund Shares from a Fund and
tender those Fund Shares for
redemption to a Fund in Creation Unit
Aggregations only.
4. The Web site for the Trust, which
is and will be publicly accessible at no
charge, will contain the following
information, on a per Fund Share basis,
for each Fund: (a) The prior Business
Day’s NAV and the reported closed
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 each Fund
will state that the Web site for the Trust
has information about the premiums
and discounts at which Fund Shares
have traded.
5. The Prospectus and annual report
for each Fund will also include: (a) The
information listed in condition 4(b), (i)
in the case of the Prospectus, for the
VerDate Aug<31>2005
19:02 Dec 29, 2006
Jkt 211001
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 Fund Share basis for
one, five and ten year periods (or life of
the 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.
6. Before a 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 Fund Shares to deliver a
Product Description to purchasers of
Fund Shares.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E6–22444 Filed 12–29–06; 8:45 am]
BILLING CODE 8011–01–P
Sunshine Act Meeting
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
meeting during the week of January 1,
2007:
A closed meeting will be held on
Thursday, January 4, 2007 at 2 p.m.
Commissioners, Counsels to the
Commissioners, the Secretary to the
Commission, and recording secretaries
will attend the Closed Meeting. 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), (4), (5), (7), (8), (9)(B)
and (10) and 17 CFR 200.402(a) (3), (4),
(5), (7), (8), (9)(ii), and (10) permit
consideration of the scheduled matters
at the Closed Meeting.
Commissioner Campos, as duty
officer, voted to consider the items
listed for the closed meeting in closed
session.
The subject matters of the closed
meeting scheduled for Thursday,
January 4, 2007 will be:
Formal orders of investigation;
Frm 00070
Fmt 4703
Institution and settlement of
injunctive actions;
Institution and settlement of
administrative proceedings of an
enforcement nature;
An adjudicatory matter;
Regulatory matters regarding financial
institutions; and
Other matters relating to enforcement
proceedings.
At times, changes in Commission
priorities require alterations in the
scheduling of meeting items.
For further information and to
ascertain what, if any, matters have been
added, deleted or postponed, please
contact:
The Office of the Secretary at (202)
551–5400.
Dated: December 28, 2006.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 06–9968 Filed 12–28–06; 10:58 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
SECURITIES AND EXCHANGE
COMMISSION
PO 00000
167
Sfmt 4703
[Release No. 34–55001; File No. SR–CBOE–
2006–35]
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change to Amend Its Trading
Rotation Rules
December 21, 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 December
6, 2006, the Chicago Board Options
Exchange, Incorporated (‘‘Exchange’’ or
‘‘CBOE’’) filed with the Securities and
Exchange Commission (the
‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III below, which Items have been
prepared by the Exchange. The
Exchange filed the proposal as a ‘‘noncontroversial’’ proposed rule change
pursuant to Section 19(b)(3)(A)(iii) of
the Act 3 and Rule 19b–4(f)(6)
thereunder.4 The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 15 U.S.C. 78s(b)(3)(A)(iii).
4 17 CFR 240.19b–4(f)(6).
2 17
E:\FR\FM\03JAN1.SGM
03JAN1
Agencies
[Federal Register Volume 72, Number 1 (Wednesday, January 3, 2007)]
[Notices]
[Pages 163-167]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E6-22444]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 27610; 812-13224]
Ziegler Exchange Traded Trust, et al.; Notice of Application
December 22, 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 (``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, 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.
-----------------------------------------------------------------------
Summary of Application: Applicants request an order that would permit
(a) series of registered open-end management investment companies, to
issue shares (``Fund Shares'') that can be redeemed only in large
aggregations (``Creation Unit Aggregations''); (b) secondary market
transactions in Fund Shares to occur at negotiated prices; (c) dealers
to sell Fund 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''); and (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 Unit Aggregations.
Applicants: Ziegler Exchange Traded Trust (``Trust''); Ziegler Capital
Management, LLC (``Advisor''); and B.C. Ziegler and Company
(``Distributor'').
Filing Dates: The application was filed on August 16, 2005, and amended
on June 5, 2006, November 17, 2006, and December 19, 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 January 17, 2007, 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, 250 East Wisconsin
Avenue, Suite 2200, Milwaukee, WI 53202.
FOR FURTHER INFORMATION CONTACT: Deepak T. Pai, Senior Counsel at (202)
551-6876, or Stacy L. Fuller, Branch Chief, at (202) 551-6821 (Division
of Investment Management, Office of Investment Company Regulation).
[[Page 164]]
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 statutory trust that may offer
multiple series (``Funds''). Each Fund will track an index of domestic
equity securities (``Underlying Index''). The initial Fund (``Initial
Fund'') will track the NYSE Arca Tech 100 Index.
2. The Advisor is registered as an investment adviser under the
Investment Advisers Act of 1940 (``Advisers Act''). The Advisor will
serve as the investment adviser to the Initial Fund. The Adviser may
enter into sub-advisory agreements with other investment advisers to
act as ``sub-advisers'' with respect to the Funds. Any sub-adviser will
be registered under the Advisers Act. The Distributor, a broker-dealer
registered under the Securities Exchange Act of 1934 (``Exchange
Act''), will serve as the principal underwriter and distributor of Fund
Shares.
3. Each Fund will hold certain U.S. equity securities (``Portfolio
Securities'') including American Depository Receipts (``ADRs'')
selected to correspond generally to the price and yield performance,
before fees and expenses, of 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, Advisor,
Distributor, or promoter of or any sub-adviser to, a Fund. The Trust
intends to offer additional Funds in the future based on other
Underlying Indices (included in the defined term ``Funds''). Any such
future Funds will (a) comply with the terms and conditions of any order
granted pursuant to the application and (b) be advised by the Advisor
or an entity controlling, controlled by or under common control with
the Advisor (included in the defined term ``Advisor''). All Funds that
currently intend to rely on the requested order are named as
applicants.
4. The investment objective of each Fund will be to provide
investment results that correspond generally to the price and yield
performance of its Underlying Index. Intra-day values of the Underlying
Index will be disseminated every 15 seconds throughout the trading day.
A Fund will utilize either a ``replication'' or ``representative
sampling'' strategy.\1\ A 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, a 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 a 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 Fund
will have a tracking error relative to the performance of its
Underlying Index of no more than five percent.
---------------------------------------------------------------------------
\1\ Applicants represent that a Fund will normally invest at
least 90% of its total assets in the component securities that
comprise its Underlying Index. Each Fund may invest up to 10% of its
assets in certain futures, options and 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 Fund track it's
Underlying Index.
\2\ Under the representative sampling strategy, the Adviser will
seek to construct a Fund's portfolio to have aggregate investment
characteristics, fundamental characteristics, and liquidity measures
similar to those of the Underlying Index.
---------------------------------------------------------------------------
5. Fund Shares will be sold at a price of between $20 and $300 per
Fund Share in Creation Unit Aggregations of between 50,000 and 100,000
Fund Shares. All orders to purchase Creation Unit Aggregations 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 Fund generally will be sold in Creation
Unit Aggregations in exchange for an in-kind deposit by the purchaser
of a portfolio of securities designated by the Adviser (``Deposit
Securities''), together with the deposit of a specified cash payment
(``Cash Amount'').\3\ The Cash Amount is generally an amount equal to
the difference between (a) the net asset value (``NAV'') (per Creation
Unit Aggregation) of the Fund and (b) the total aggregate market value
(per Creation Unit Aggregation) of the Deposit Securities.\4\
Applicants state that in some circumstances it may not be practicable
or convenient for a Fund to operate exclusively on an ``in-kind''
basis. The Trust reserves the right to permit, under certain
circumstances, a purchaser of Creation Unit Aggregations to substitute
cash in lieu of depositing some or all of the requisite Deposit
Securities. An investor purchasing a Creation Unit Aggregation from a
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 Unit Aggregations.\5\
The Transaction Fees relevant to each Fund (including the maximum
Transaction Fees) will be fully disclosed in the prospectus of such
Fund (``Prospectus''), and the method for calculating the Transaction
Fees will be disclosed in each Fund's statement of additional
information (``SAI''). The Distributor will be responsible for
transmitting orders to the Funds, for delivering the Prospectus to
those persons purchasing Creation Unit Aggregations and for maintaining
records of both the orders placed with it and the confirmations of
acceptance furnished by it. In addition, the NSCC or DTC, as
appropriate, will maintain a record of the instructions given to the
[[Page 165]]
Trust to implement the delivery of Fund Shares.
---------------------------------------------------------------------------
\3\ The Funds must comply with the federal securities laws in
accepting Deposit Securities and satisfying redemptions with
Redemptions Securities, including that the Deposit Securities and
Redemption Securities are sold in transactions that would be exempt
from registration under the Securities Act of 1933. The specified
Deposit Securities and Redemption Securities will generally
correspond pro rata to the Portfolio Securities.
\4\ The Trust will sell Creation Unit Aggregations of each Fund
on any ``Business Day,'' which is defined to include any day that
the Fund is open for business, including as required by section
22(e) of the Act. In addition to the list of names (and amount of
each security constituting the current Deposit Securities), the Cash
Amount effective as of the previous Business Day will be made
available. Any Exchange on which Fund Shares are listed will
disseminate, every 15 seconds, during its regular trading hours,
through the facilities of the Consolidated Tape Association, an
approximate amount per Fund 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 Fund Share basis.
\5\ Where a 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
to the Fund of purchasing such Deposit Securities.
---------------------------------------------------------------------------
6. Purchasers of Creation Unit Aggregations of Fund Shares may hold
such Fund Shares or may sell such Fund Shares into the secondary
market. Fund Shares will be listed and traded on NYSE Arca, Inc.
(``NYSE Arca'') and NYSE Arca, LLC (``NYSE Arca Marketplace''),
respectively.\6\ Fund Shares of future Funds may be listed and traded
on other Exchanges (``Other Exchanges''). It is expected that one or
more of the market makers that are members of NYSE Arca (``Arca Market
Makers'') will register to make a market in Fund Shares listed on NYSE
Arca. With respect to listings of Fund Shares on certain Other
Exchanges, one or more member firms of the Other Exchange will be
designated to act as a specialist and maintain a market for Fund Shares
on the Exchange (a ``Specialist''). If Nasdaq is the listing Exchange
of Fund Shares, one or more member firms of Nasdaq will act as market
makers (``Nasdaq Market Makers,'' and together with the Arca Market
Makers, ``Market Makers'') and maintain a market for Fund Shares.
Prices of Fund Shares trading on an Exchange will be based on the
current bid/offer market. Fund Shares sold in the secondary market will
be subject to customary brokerage commissions and charges.
---------------------------------------------------------------------------
\6\ NYSE Arca is a national securities exchange, as defined in
section 2(a)(26) of the Act (``Exchange''). The NYSE Arca
Marketplace is the equities trading facility of NYSE Arca. Trading
on the NYSE Arca Marketplace is subject to the rules (``NYSE Arca
Equities Rules'') of NYSE Arca Equities, Inc., a subsidiary of NYSE
Arca.
---------------------------------------------------------------------------
7. Applicants expect that purchasers of Creation Unit Aggregations
will include institutional investors and arbitrageurs (which could
include institutional investors). A Specialist or Market Maker also may
purchase Creation Unit Aggregations for use in market-making
activities. Applicants expect that secondary market purchasers of Fund
Shares will include both institutional investors and retail
investors.\7\ Applicants expect that the price at which Fund Shares
trade will be disciplined by arbitrage opportunities created by the
ability to continually purchase or redeem Creation Unit Aggregations at
their NAV, which should ensure that Fund Shares will not trade at a
material discount or premium in relation to their NAV.
---------------------------------------------------------------------------
\7\ Fund Shares will be registered in book-entry form only. DTC
or its nominee will be the registered owner of all outstanding Fund
Shares. DTC or DTC Participants will maintain records reflecting
beneficial owners of Fund Shares.
---------------------------------------------------------------------------
8. Fund Shares will not be individually redeemable, and owners of
Fund Shares may acquire those Fund Shares from the Fund, and tender
Fund Shares for redemption to the Fund, in Creation Unit Aggregations
only. To redeem, an investor will have to accumulate enough Fund Shares
to constitute a Creation Unit Aggregation. Redemption orders must be
placed by or through an Authorized Participant. An investor redeeming a
Creation Unit Aggregation generally will receive (a) a portfolio of
securities designated to be delivered for Creation Unit Aggregation
redemptions on the date that the request for redemption is submitted
(``Redemption Securities''), which may not be identical to the Deposit
Securities required to purchase Creation Unit Aggregations on that
date, and (b) a ``Cash Redemption Payment,'' consisting of an amount
calculated in the same manner as the Cash Component. An investor may
receive the cash equivalent of a Redemption Security in certain
circumstances, such as if the investor is constrained from effecting
transactions in the security by regulation or policy. A redeeming
investor will pay a Transaction Fee, calculated in the same manner as a
Transaction Fee payable in connection with purchases of Creation Unit
Aggregations.
9. Neither the Trust nor any individual 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 Fund Shares, or refer to redeemability, will prominently
disclose that Fund Shares are not individually redeemable and that the
owners of Fund Shares may purchase or redeem Fund Shares from the Fund
in Creation Unit Aggregations only. The same approach will be followed
in the SAI, shareholder reports and investor educational materials
issued or circulated in connection with the Fund Shares. The Funds will
provide copies of their annual and semi-annual shareholder reports to
DTC Participants for distribution to beneficial owners of Fund 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, 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.
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 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.
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 Fund 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 Fund Shares that
are redeemable in Creation Units Aggregations only. Applicants state
that investors may purchase Fund Shares in Creation Unit Aggregations
and redeem Creation Unit Aggregations from each Fund. Applicants
further state that because the market price of Fund Shares will be
disciplined by arbitrage opportunities, investors should be able to
sell Fund 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 Fund Shares will take
place
[[Page 166]]
at negotiated prices, not at a current offering price described in a
Prospectus, and not at a price based on NAV. Thus, purchases and sales
of Fund Shares in the secondary market will not comply with section
22(d) and rule 22c-1. 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) and rule 22c-1 with respect to pricing are equally
satisfied by the proposed method of pricing Fund 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 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 Fund Shares to trade in the secondary market at
negotiated prices. Applicants state that (a) secondary market trading
in Fund Shares does not involve the Funds as parties and cannot result
in dilution of an investment in Fund 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 Fund 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
Fund 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
Fund Shares in the secondary market to rely on the prospectus delivery
exemption provided by section 4(3) of the Securities Act.\8\
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\8\ 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
Fund Shares from the Funds or an underwriter. Applicants further
state that each 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 Unit
Aggregations from a Fund, breaks them down into the constituent Fund
Shares, and sells those Fund Shares directly to customers, or if it
chooses to couple the creation of a supply of new Fund Shares with
an active selling effort involving solicitation of secondary market
demand for Fund Shares. Each 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
Prospectus will caution dealers who are not ``underwriters'' but are
participating in a distribution (as contrasted to ordinary secondary
market trading transactions), and thus dealing with Fund 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.
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8. Applicants state that Fund 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 Fund
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 Fund 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, a website will be maintained that will include each Fund's
Prospectus and SAI, the relevant Underlying Index for each Fund, and
additional quantitative information that is updated on a daily basis,
including the closing price of Fund Shares, the prior Business Day's
NAV for each Fund, and a calculation of the premium or discount of the
closing price against the NAV, as well as data in chart format
displaying the frequency distribution of discounts and premiums of the
closing price against the NAV, within appropriate ranges, for each of
the four previous calendar quarters.
9. Applicants will arrange for broker-dealers selling Fund Shares
in the secondary market to provide purchasers with a product
description (``Product Description'') that describes, in plain English,
the relevant Fund and the Fund 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 Fund
Shares in the secondary market.
Section 17(a)(1) and (2) of the Act
10. Section 17(a) of the Act generally prohibits an affiliated
person of a registered investment company, or an affiliated person of
such a person, from selling any security to, or purchasing any security
from, the company. Section 2(a)(3) of the Act defines ``affiliated
person'' to include 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, and 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 there exists
the possibility for investors, Specialists, and Market Makers to own 5%
or more, or more than 25%, of the Fund Shares of one or more Funds
(``first-tier affiliates''). Applicants also state that there exists
the possibility for investors to own 5% or more, or more than 25%, of
the outstanding voting securities of other registered investment
companies advised by the Advisor (together with affiliated persons of
first-tier affiliates that are not otherwise affiliated with the Funds,
``second-tier affiliates'').
11. Applicants request an exemption from section 17(a) under
sections 6(c) and 17(b) to permit first-tier and second-tier affiliates
to effectuate purchases and redemptions in-kind. Applicants assert that
no useful purpose would be served by prohibiting these types of
affiliated persons from purchasing or redeeming Creation Unit
Aggregations through in-kind transactions. The deposit procedures for
in-kind purchases and redemptions procedures for in-kind redemptions of
Creation Unit Aggregations will be the same for all purchases and
redemptions. Deposit Securities and Redemption Securities will be
valued in the same manner as
[[Page 167]]
Portfolio Securities. Therefore, applicants state, in-kind purchases
and redemptions will afford no opportunity for these affiliated persons
of a Fund to effect a transaction detrimental to other holders of Fund
Shares. Applicants also believe that in-kind purchases and redemptions
will not result in self-dealing or overreaching of the Fund.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
1. Each Fund's Prospectus and Produce Description will clearly
disclose that, for purposes of the Act, Fund Shares are issued by the
Funds and that the acquisition of Fund Shares by investment companies
is subject to the restrictions of section 12(d)(1) of the Act.
2. As long as a Trust operates in reliance on the requested order,
Fund Shares will be listed on an Exchange.
3. Neither the Trust nor any Fund will be advertised or marketed as
an open-end fund or a mutual fund. Each Fund's Prospectus will
prominently disclose that Fund Shares are not individually redeemable
shares and will disclose that the owners of Fund Shares may acquire
those Fund Shares from a Fund and tender those Fund Shares for
redemption to a Fund only in Creation Unit Aggregations. Any
advertising material that describes the purchase or sale of Creation
Unit Aggregations or refers to redeemability will prominently disclose
that Fund Shares are not individually redeemable and that owners of
Fund Shares may acquire those Fund Shares from a Fund and tender those
Fund Shares for redemption to a Fund in Creation Unit Aggregations
only.
4. The Web site for the Trust, which is and will be publicly
accessible at no charge, will contain the following information, on a
per Fund Share basis, for each Fund: (a) The prior Business Day's NAV
and the reported closed 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 each Fund will state that the Web site for the Trust
has information about the premiums and discounts at which Fund Shares
have traded.
5. The Prospectus and annual report for each Fund will also
include: (a) The information listed in condition 4(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 Fund Share
basis for one, five and ten year periods (or life of the 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.
6. Before a 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 Fund Shares to deliver a Product Description to
purchasers of Fund Shares.
For the Commission, by the Division of Investment Management,
under delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E6-22444 Filed 12-29-06; 8:45 am]
BILLING CODE 8011-01-P