Sun Life Assurance Company of Canada (U.S.), et al., Notice of Application, 1036-1040 [E7-61]
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1036
Federal Register / Vol. 72, No. 5 / Tuesday, January 9, 2007 / Notices
Applicants’ Condition
Applicants agree that any order
granting the requested relief shall be
subject to the following condition:
Any temporary exemption granted
pursuant to the application shall be
without prejudice to, and shall not limit
the Commission’s rights in any manner
with respect to, any Commission
investigation of, or administrative
proceedings involving or against,
Covered Persons, including, without
limitation, the consideration by the
Commission of a permanent exemption
from section 9(a) of the Act requested
pursuant to the application or the
revocation or removal of any temporary
exemption granted under the Act in
connection with the application.
Temporary Order
The Commission has considered the
matter and finds that Applicants have
made the necessary showing to justify
granting a temporary exemption.
Accordingly, it is hereby ordered,
pursuant to section 9(c) of the Act, that
the Covered Persons are granted a
temporary exemption from the
provisions of section 9(a), effective as of
the date of the Injunction, solely with
respect to the Injunction, subject to the
condition in the application, until the
date the Commission takes final action
on an application for a permanent order.
By the Commission.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. E7–60 Filed 1–8–07; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Rel. No. IC–27651; File No. 812–13282]
Sun Life Assurance Company of
Canada (U.S.), et al., Notice of
Application
December 29, 2006.
Securities and Exchange
Commission (the ‘‘Commission’’).
ACTION: Notice of application for an
order of approval pursuant to Section
26(c) of the Investment Company Act of
1940, as amended (the ‘‘Act’’), and an
order of exemption pursuant to Section
17(b) of the Act from Section 17(a) of
the Act.
AGENCY:
Sun Life Assurance
Company of Canada (U.S.) (‘‘Sun Life
U.S.’’), Sun Life Insurance and Annuity
Company of New York (‘‘Sun Life
N.Y.’’) (together with Sun Life U.S., the
‘‘Companies’’), Keyport Variable
Account A (‘‘Keyport Account A’’), Sun
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APPLICANTS:
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Life of Canada (U.S.) Variable Account
F (‘‘Account F’’), Sun Life of Canada
(U.S.) Variable Account I (‘‘Account I’’),
KBL Variable Annuity Account (‘‘KBL
Annuity Account’’), KBL Variable
Account A (‘‘KBL Account A’’), and Sun
Life (N.Y.) Variable Account C
(‘‘Account C’’) (collectively, the
‘‘Applicants’’). Applicants, together
with Sun Capital Advisers Trust (‘‘Sun
Capital Trust’’) are ‘‘Section 17(b)
Applicants.’’
SUMMARY OF APPLICATION: Applicants
seek an order approving the proposed
substitutions (the ‘‘Substitutions’’) of
Class O shares of Alger American
Growth Portfolio of the Alger American
Fund and Class A and Class B shares of
the AllianceBernstein VPS Large Cap
Growth Portfolio of the
AllianceBernstein Variable Product
Series Fund (collectively, the ‘‘Old
Portfolios’’) with Initial and Service
Class Shares of the SC FI Large Cap
Growth Fund of Sun Capital Trust (the
‘‘New Portfolio’’) under certain variable
life insurance policies and variable
annuity contracts (‘‘Contracts’’). Section
17(b) Applicants also seek an order
pursuant to Section 17(b) of the Act to
permit certain in-kind transactions in
connection with the Substitutions.
FILING DATE: The application was
originally filed on April 19, 2006, and
an amended and restated application
was filed on December 20, 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 Secretary of
the Commission and serving Applicants
with a copy of the request, personally or
by mail. Hearing requests must be
received by the Commission by 5:30
p.m. on January 24, 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 requester’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 Secretary of the
Commission.
The Commission: Secretary,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–1090; Applicants: c/o Maura A.
Murphy, Esq., Sun Life Assurance
Company of Canada (U.S.), One Sun
Life Executive Park, Wellesley Hills,
Massachusetts 02481.
FOR FURTHER INFORMATION CONTACT:
Rebecca A. Marquigny, Senior Counsel,
or Joyce M. Pickholz, Branch Chief,
ADDRESSES:
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Office of Insurance Products, Division of
Investment Management, at (202) 551–
6795.
The
following is a summary of the
application. The complete application is
available for a fee from the Public
Reference Branch of the Commission,
100 F Street, NE., Washington, DC
20549 (202–551–8090).
SUPPLEMENTARY INFORMATION:
Applicants’ and Section 17 Applicants’
Representations
1. Sun Life U.S. is a stock life
insurance company ultimately
controlled by Sun Life Financial Inc.
(‘‘Sun Life Financial’’), a Canadian
reporting company under the Securities
Exchange Act of 1934 (the ‘‘1934 Act’’).
Pursuant to a 2003 merger, Keyport Life
Insurance Company (‘‘Keyport’’) was
merged with and into Sun Life U.S. with
Sun Life U.S. as the survivor. Sun Life
U.S. is the depositor and sponsor of
Keyport Account A, Account F, and
Account I.
2. Keyport Account A is registered
with the Commission under the Act as
a unit investment trust (File No. 811–
07543) with interests are offered
through Contracts (the ‘‘Keyport
Contracts’’) registered under the
Securities Act of 1933 (‘‘1933 Act’’) on
Form N–4 (File Nos. 333–114126, 333–
114129, 333–114132, 333–111642, 333–
111645, 333–111646, 333–111647, and
333–111648). Account F is registered as
a unit investment trust (File No. 811–
05846); its interests are also offered
through Contracts (the ‘‘Account F
Contracts’’) registered under the 1933
Act on Form N-4 (File Nos. 33–29852,
33–41628, 333–37907, 333–05227, 333–
82957, 333–30844, 333–31248, 333–
41438, 333–74844, 333–83256, 333–
83362, 333–83364, 333–83516, 333–
74972, 333–115525, and 333–115536).
Account I, registered as a unit
investment trust (File No. 811–09137)
also offers its interests through
Contracts (the ‘‘Account I Contracts’’)
registered under the 1933 Act on Form
N–6 (File Nos. 333–68601, 333–59662,
333–94359, 333–100831, and 333–
100829).
3. Sun Life N.Y., a wholly owned
subsidiary of Sun Life U.S., is a stock
life insurance company which merged
with Keyport Benefit Life Insurance
Company (‘‘KBL’’), a subsidiary of
Keyport, in 2002. Sun Life N.Y. is the
depositor and sponsor of the KBL
Annuity Account, KBL Account A, and
Account C.
4. KBL Annuity Account is a
registered unit investment trust (File
No. 811–05422) for which interests are
offered through a Contract (the ‘‘KBL
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Annuity Contract’’) registered under the
1933 Act on Form N–4 (File No. 333–
102275). KBL Account A is a registered
unit investment trust (File No. 811–
08635) with interests are offered
through other Contracts (the ‘‘KBL
Account A Contracts’’) registered under
the 1933 Act on Form N–4 (File Nos.
333–102274, 333–102278, 333–102279,
and 333–102280). Account C, a
registered unit investment trust (File
No. 811–04440), also offers its interests
through certain Contracts (the ‘‘Account
C Contracts’’) registered under the 1933
Act on Form N–4 (File Nos. 33–41629,
333–05037, 333–67864, 333–100475,
333–100474, 333–99907, and 333–
107983).
5. All of the Contracts involved in the
Substitutions (a) reserve the right to
substitute shares of one portfolio for
shares of another; (b) permit transfers of
contract value among the subaccounts
pursuant to the limitations of the
particular Contract, (c) impose or
reserve the right to impose a transfer
charge; and (d) are subject to market
timing policies and procedures that may
operate to limit transfers.
6. Applicants represent that: (a) The
Keyport Contracts involved in the
Substitutions are no longer offered for
sale, except to certain employee plans;
(b) none of the Account I, KBL Account
A, or KBL Annuity Contracts involved
in the Substitutions are still offered for
sale; and (c), the subaccounts investing
in the Old Portfolios are no longer
offered as investment options to new
Contract owners under the Account F
Contracts and Account C Contracts.
7. Alger American Growth Portfolio
(‘‘Alger Growth’’ or ‘‘Old Portfolio’’) is
a portfolio of Alger American Fund, a
registered, diversified, open-end
management investment company (File
No. 811–05550). Class O and Class S of
its shares are registered under the 1933
Act on Form N–1A (File No. 33–21722).
The shares are the same except Class S
shares are subject to a distribution and
shareholder servicing fee while Class O
shares are not. The portfolio’s
investment adviser is Fred Alger
Management, Inc. (‘‘FAM’’).
8. AllianceBernstein VPS Large Cap
Growth Portfolio (‘‘AB Large Cap
Growth’’) is a portfolio of the
AllianceBernstein Variable Product
Series Fund, a registered diversified,
open-end management investment
company (File No. 811–05398). Class A
and B shares of AB Large Cap Growth
(also referred to as ‘‘Old Portfolio’’) are
registered under the 1933 Act on Form
N–1A (File No. 33–18647). The shares
are the same except Class B shares are
subject to a distribution fee and Class A
shares are not. AllianceBernstein L.P.
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(‘‘AB L.P.’’) is the portfolio’s investment
adviser.
9. SC FI Large Cap Growth Fund (‘‘SC
Large Cap Growth’’ or ‘‘New Portfolio’’)
is a portfolio of Sun Capital Trust, a
registered, diversified, open-end
management investment company (File
No. 811–08879). Initial and Service
Class shares of New Portfolio are
registered under the 1933 Act on Form
N–1A (File No. 333–59093); the shares
are the same except that Service Class
shares are subject to a distribution fee
and Initial Class shares are not.
10. Sun Capital Advisers LLC (‘‘Sun
Capital’’), an indirect, wholly owned
subsidiary of Sun Life Financial, is
investment adviser to all the Sun
Capital Trust portfolios. Through an
order from the Commission pursuant to
Section 6(c) of the Act, Sun Capital is
exempt from Section 15(a) of the Act
and Rule 18f–2 thereunder with respect
to subadvisory agreements (the
‘‘Manager of Managers Order’’).1
11. Applicants represent that the
relief granted in the Manager of
Managers Order extends to New
Portfolio permitting it to enter into and
materially amend investment
subadvisory agreements without
obtaining shareholder approval.
Applicants also indicate that the
prospectus for the New Portfolio
discloses and explains the existence,
substance and effect of the Manager of
Managers Order.
12. Applicants propose to substitute
(a) Initial Class shares of New Portfolio
for Class O shares of Alger Growth; (b)
Initial Class shares of New Portfolio for
Class A shares of AB Large Cap Growth;
and (c) Service Class shares of New
Portfolio for Class B shares of AB Large
Cap Growth. Applicants state that the
proposed Substitutions are part of an
overall business goal of the Companies
to make the Contracts more attractive to
Contract owners by providing a diverse
array of investment options that are not
redundant or duplicative in terms of the
investment types and styles of mutual
funds underlying such options.
Applicants assert their belief that:
(a) Reducing the number of
nonproprietary funds will provide the
Companies with more control over fund
changes that affect their Contracts,
allowing for appropriate long-term
strategic planning;
(b) The New Portfolio better promotes
their goals of increasing administrative
efficiency of, and control over, their
1 Sun Capital Advisers Trust and Sun Capital
Advisers, Inc., 1940 Act Rel. No. 24401 (April 24,
2000) (Order), File No. 812–11790; see also Sun
Capital Advisers Trust and Sun Capital Advisers,
Inc., 1940 Act Rel. No. 23793 (Apr. 20, 1999)
(Order), File No. 812-11464.
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Contracts because the New Portfolio is
part of their affiliated fund family;
(c) Streamlining the number of
nonproprietary funds available through
the Contracts and altering the available
portfolios will simplify the
administration of the Contracts,
particularly with regard to
communications with the fund families
and the preparation of various reports
and disclosure documents; and
(d) This streamlining will allow the
Companies to enhance their
communication efforts to Contract
owners and sales representatives
regarding the available portfolios, and
may provide for more enhanced and
timely reporting to the Companies from
fund families and therefore from the
Companies to Contract owners.
13. Regarding Contracts that offer both
of the Old Portfolios as investment
options, Applicants assert that a more
concentrated and streamlined array of
investment options could result in
increased operational and
administrative efficiencies and
economies of scale for the Companies.
Applicants note that Contract owners
could benefit from streamlining
Contract investment options.
Specifically, Applicants state that
Contracts that offer too many similar
investment options may be
unnecessarily confusing to Contract
owners and may increase the
Companies’ costs of administering the
Contracts.
14. Applicants represent that because
the New Portfolio operates pursuant to
the Manager of Managers Order, the
Substitutions would provide protection
to Contract owners by giving Sun
Capital the agility and flexibility to
change the subadviser of the New
Portfolio should such a change become
warranted or advisable. In support of
the Substitutions, Applicants further
represent that the Substitutions will
provide Contract owners with
substantially similar investment
vehicles. Specifically, Applicants assert
that the investment objectives, principal
investment strategies and principal
investment risks of the New Portfolio
are substantially similar to those of the
Old Portfolios. The following
summarizes the more complete
comparison of New and Old Portfolios
provided in the Application.
15. Alger Growth Substitution.
Applicants describe the investment
objective of Alger Growth as ‘‘to seek
long-term capital appreciation’’ and the
investment objective of New Portfolio as
‘‘to seek long-term growth of capital.’’
Applicants state that the principal
investment strategies of the two
portfolios are substantially similar
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noting that both invest primarily in
common stocks with an emphasis on
‘‘growth’’ stocks and the stocks of highly
capitalized companies. Alger Growth
invests at least 65% of its total assets in
equity securities of companies that, at
the time of purchase, have total market
capitalization of $1 billion or greater. SC
Large Cap Growth invests at least 80%
of its assets in the common stocks of
companies with large market
capitalizations. Both portfolios may
invest up to 20% of the value of their
total assets in foreign securities (not
including American Depositary
Receipts, American Depositary Shares,
or U.S. dollar denominated securities of
foreign issuers). Applicants represent
that both Alger Growth and New
Portfolio have substantially similar risk
characteristics and share substantially
similar risk profiles.
Charges for Class O of Alger Growth
include Management Fees of 0.75%,
Other Expenses of 0.06%, and no 12b–
1 Fee.2 Charges for the Initial Class
shares of New Portfolio include:
Management Fees of 0.75% and Other
Expenses of 0.30%; it does not charge a
12b–1 Fee. Alger Growth’s total gross
and net operating expenses are both
0.81%. Respectively, New Portfolio’s
total gross and net operating expenses
are 1.05% and 0.81% (reflecting a
0.24% contractual fee reduction
arrangement).
16. AB Large Cap Growth
Substitutions.
Applicants represent that the
investment objectives of AB Large Cap
Growth and New Portfolio are identical;
both portfolios see long-term growth of
capital. Applicants state that the
principal investment strategies of the
two portfolios are substantially similar
noting that New Portfolio invests at least
80% of its net assets in common stocks
of large-capitalization companies based
on the market capitalization of
companies in the Russell 1000 Index or
the S&P 500. Old Portfolio invests an
identical 80% of its assets in common
stock of companies with large market
capitalizations based on the market
capitalization range of companies
appearing in the Russell 1000 Growth
Index. Applicants represent that both
AB Large Cap Growth and New Portfolio
have substantially similar risk
characteristics as both invest in
substantially similar securities.
For the proposed substitution
involving Class A of AB Large Cap
2 For the descriptions of charges involved in the
Substitution, all percentages for the Management
Fees, 12b–1 Fees, Other Expenses, Fee Reductions,
Total Gross and Net Annual Operating Expenses,
and Separate Account Fees represent a percentage
of average annual assets.
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Growth, charges for Class A of Old
Portfolio include Management Fees of
0.75% and Other Expenses of 0.06%.
Charges for the Initial Class of New
Portfolio include Management Fees of
0.75% and Other Expenses of 0.30%.
Neither imposes a 12b–1 Fee. The Old
Portfolio’s total gross and net operating
expenses for Class A shares are both
0.81%. Respectively, New Portfolio’s
total gross and net operating expenses
for Initial Class shares are 1.05% and
0.81% (reflecting a 0.24% contractual
fee reduction arrangement).
For the proposed substitution
involving Class B of AB Large Cap
Growth, charges for Class B of Old
Portfolio include Management Fees of
0.75%, 12b–1 Fees of 0.25%, and Other
Expenses of 0.06%. Charges for the
Service Class of New Portfolio include
Management Fees of 0.75%, 12b–1 Fees
of 0.25%, and Other Expenses of 0.30%.
The Old Portfolio’s total gross and net
operating expenses for Class B shares
are both 1.06%. Respectively, New
Portfolio’s total gross and net operating
expenses for Service Class shares are
1.30% and 1.06% (reflecting a 0.24%
contractual fee reduction arrangement).
17. Applicants assert that as of the
effective date of the Substitutions
(‘‘Effective Date’’), each Separate
Account will redeem shares of the
applicable Old Portfolio in-kind.
Applicants state that if Sun Capital
declines to accept particular portfolio
securities of either of the Old Portfolios
for purchase in-kind of shares of the
New Portfolio, the applicable Old
Portfolio will liquidate portfolio
securities as necessary and shares of the
New Portfolio will be purchased with
cash. Applicants represent that in either
event, the proceeds of such redemptions
will then be used to purchase shares of
the corresponding class of the New
Portfolio, with each subaccount of the
applicable Separate Account investing
the proceeds of its redemption from the
Old Portfolios in the applicable class of
the New Portfolio.
18. Applicants further state that
redemption requests and purchase
orders will be placed simultaneously so
that contract values will remain fully
invested at all times. Applicants
represent that all redemptions of shares
of the Old Portfolios and purchases of
shares of the New Portfolios will be
effected in accordance with Section
22(c) of the Act and Rule 22c–1
thereunder. Applicants state that the
Substitutions will take place at relative
net asset value as of the Effective Date
with no change in the amount of any
Contract owner’s contract value or death
benefit or in the dollar value of his or
her investments in any of the
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subaccounts. Applicants represent that
Contract owners will receive Service
Class shares of the New Portfolio in the
Substitutions only if they are currently
invested in Class B shares of the AB
Large Cap Growth, which also imposes
a distribution fee.
19. Applicants further represent that
all expenses incurred in connection
with the Substitutions, including legal,
accounting, transactional, and other fees
and expenses, including brokerage
commissions, will be paid by Sun Life
U.S. or Sun Life N.Y. Applicants also
state that, as a result of the
Substitutions, Contract owners will not
incur any additional fees or charges, nor
will their rights or insurance benefits or
the Companies’ obligations under the
Contracts be altered. Applicants assert
that the Substitutions: (a) Will not
impose any tax liability on Contract
owners; and (b) will not cause the
Contract fees and charges currently
being paid by existing Contract owners
to be greater after the Substitutions than
before the Substitutions. Applicants
represent that neither Sun Life U.S. nor
Sun Life N.Y. will exercise any right
either may have under the Contracts to
impose restrictions on transfers under
the Contracts for a period of at least
thirty days following the Substitutions.
20. Applicants represent that during
the twenty-four months following the
date of the Substitutions, the total net
operating expenses of the applicable
class of the New Portfolio (taking into
account any expense waiver or
reimbursement) will not exceed the net
expense level of the corresponding class
of the Old Portfolio for the fiscal year
ended December 31, 2005. Applicants
also state that through the twenty-four
months following the date of the
Substitutions, Sun Capital has
contractually agreed to waive its
management fee and, if necessary, to
limit other ordinary operating expenses
so that total operating expenses, as a
percentage of average net assets, do not
exceed 0.81% or 1.06%, as applicable.
In addition, Applicants represent that
for twenty-four months following the
date of the Substitutions, the Companies
will not increase asset-based fees or
charges for Contracts outstanding on the
date of the Substitutions.
21. Applicants represent that a
prospectus for the New Portfolio
containing disclosure about the Manager
of Managers Order will be provided to
each Contract owner prior to or at the
time of the Substitutions.
Notwithstanding the Manager of
Managers Order, after the Effective Date
of the Substitutions, the Applicants
agree not to change the New Portfolio’s
subadviser, add a new subadviser, or
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otherwise rely on the Manager of
Managers Order without first obtaining
shareholder approval of either: (1) The
subadviser change; or (2) the New
Portfolio’s continued ability to rely on
the Manager of Managers Order.
22. Applicants state that Contract
owners were notified of the initial
application by means of a prospectus
supplement for each of the Contracts
stating that the Applicants filed the
initial application and seek approval for
the Substitutions (‘‘Pre-Substitution
Notice’’). The Pre-Substitution Notice
set forth the anticipated Effective Date
and advised Contract owners that
contract values attributable to
investments in the Old Portfolios will be
transferred to the New Portfolios,
without charge (including sales charges
or surrender charges) and without
counting toward the number of transfers
that may be permitted without charge,
on the Effective Date. Applicants
indicate that the Pre-Substitution Notice
stated that, from the date the initial
application was filed with the
Commission through the date thirty
days after the Substitutions, Contract
owners may make one transfer of
contract value from the subaccounts
investing in the Old Portfolios (before
the Substitutions) or the New Portfolio
(after the Substitutions) to one or more
other subaccount(s) without charge
(including sales charges or surrender
charges) and without that transfer
counting against their contractual
transfer limitations.
23. Applicants represent that all
Contract owners will have received a
copy of the most recent New Portfolio
prospectus prior to the Substitutions.
Applicants also agree that, within five
days following the Substitutions,
Contract owners affected by the
Substitutions will be notified in writing
that the Substitutions were carried out
and that this notice will restate the
information set forth in the PreSubstitution Notice.
Applicants’ Legal Analysis
1. Section 26(c) of the Act makes it
unlawful for any depositor or trustee of
a registered unit investment trust
holding the security of a single issuer to
substitute another security for such
security unless the Commission
approves the substitution. The
Commission may approve such a
substitution if the evidence establishes
that it is consistent with the protection
of investors and the purposes fairly
intended by the policy and provisions of
the Act.
2. Applicants submit that the
Substitutions meet the standards set
forth in Section 26(c) and assert that
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replacement of the Old Portfolios with
the New Portfolio is consistent with the
protection of Contract owners and the
purposes fairly intended by the policy
and provisions of the Act. Applicants
have reserved the right to make such a
substitution under the Contracts and
represent that this reserved right is
disclosed in the prospectus for the
Contracts.
3. Section 17(a)(1) of the Act, in
relevant part, prohibits any affiliated
person of a registered investment
company, or any affiliated person of
such person, acting as principal, from
knowingly selling any security or other
property to that company. Section
17(a)(2) of the Act generally prohibits
the persons described above, acting as
principal, from knowingly purchasing
any security or other property from the
registered company. Pursuant to Section
10(a)(1) of the Act, the Section 17(b)
Applicants may be considered affiliates
of one or more of the portfolios involved
in the Substitutions. Because the
Substitutions may be effected, in whole
or in part, by means of in-kind
redemptions and subsequent purchases
of shares and by means of in-kind
transactions, the Substitutions may be
deemed to involve one or more
purchases or sales of securities or
property between affiliates.
4. Section 17(b) of the Act provides
that the Commission may, upon
application, grant an order exempting
any transaction from the prohibitions of
Section 17(a) if the evidence establishes
that: The terms of the proposed
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; the proposed transaction is
consistent with the policy of each
registered investment company
concerned, as recited in its registration
statement and records filed under the
Act; and the proposed transaction is
consistent with the general purposes of
the Act.
5. The Section 17(b) Applicants state
that the terms under which the in-kind
redemptions and purchases will be
effected are reasonable and fair and do
not involve overreaching on the part of
any person principally because the
Substitutions will conform with all but
two of the conditions enumerated in
Rule 17a–7. Applicants assert that the
use of in-kind transactions will not
cause Contract owner interests to be
diluted. In support, Applicants
represent that: (a) The proposed
transactions will take place at relative
net asset value as of the Effective Date
in conformity with the requirements of
Section 22(c) of the 1940 Act and Rule
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22c–1 thereunder with no change in the
amount of any Contract owner’s contract
value or death benefit or in the dollar
value of his or her investment in any of
the Separate Accounts; (b) Contract
owners will not suffer any adverse tax
consequences as a result of the
Substitutions; and (c) Fees and charges
under the Contracts will not increase
because of the Substitutions.
6. Further, though the Section 17(b)
Applicants may not rely on Rule 17a–
7 because they cannot meet all of its
conditions, the Section 17(b) Applicants
agree to carry out the proposed in-kind
purchases in conformity with all of the
conditions of Rule 17a–7 and the
procedures adopted thereunder, except
that: (1) The consideration paid for the
securities being purchased or sold may
not be entirely cash; and (2) the Sun
Capital Trust board will not separately
review each portfolio security
purchased by the New Portfolio.
However, Applicants assert that the
circumstances surrounding the
Substitutions will offer the same degree
of protection to the New Portfolio from
overreaching that Rule 17a–7 provides
to it generally in connection with its
purchase and sale of securities under
that Rule in the ordinary course of its
business.
7. Applicants assert that the Board of
Sun Capital Trust has adopted
procedures, as required by Rule 17a–7,
and that Sun Capital or any subadviser
to the New Portfolio will review the
securities holdings of the Old Portfolio
to determine whether their portfolio
holdings would be suitable investments
for the New Portfolio in the overall
context of its investment objectives and
policies and consistent with its
management. Applicants also note that
the Companies (or any of their affiliates)
cannot effect the proposed Substitutions
at a price disadvantageous to the New
Portfolio. Although the Substitutions
may not be entirely for cash, Applicants
represent that each will be effected
based upon (1) the independent market
price of the portfolio securities valued
as specified in paragraph (b) of Rule
17a–7, and (2) the net asset value per
share of each portfolio involved valued
according to the procedures disclosed in
its registration statement and as
required by Rule 22c–1 under the Act.
The Section 17(b) Applicants state that
securities to be paid out as redemption
proceeds and subsequently contributed
to the New Portfolio to effect the in-kind
purchases of shares will be valued based
on the normal valuation procedures of
the redeeming and purchasing
Portfolios, and redeeming and
purchasing values will be the same.
Applicants note that if Sun Capital
E:\FR\FM\09JAN1.SGM
09JAN1
1040
Federal Register / Vol. 72, No. 5 / Tuesday, January 9, 2007 / Notices
declines to accept particular portfolio
securities of either of the Old Portfolios
for purchase in-kind of shares of the
New Portfolio, the applicable Old
Portfolio will liquidate portfolio
securities as necessary and purchase
New Portfolio shares with cash.
Consistent with Rule 17a–7(d),
Applicants also agree that no brokerage
commissions, fees, or other
remuneration will be paid in connection
with the in-kind transactions.
Conclusions
1. Applicants submit that for the
reasons and upon the facts set forth in
their application, the requested order
meets the standards set forth in Section
26(c) and should, therefore, be granted.
2. Section 17 Applicants represent
that the proposed in-kind transactions
meet all of the requirements of Section
17(b) of the Act and that an exemption
should be granted, to the extent
necessary, from the provisions of
Section 17(a).
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Nancy M. Morris,
Secretary.
[FR Doc. E7–61 Filed 1–8–07; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–55018; File No. SR–Amex–
2006–109]
Self-Regulatory Organizations;
American Stock Exchange LLC; Notice
of Filing and Order Granting
Accelerated Approval of a Proposed
Rule Change and Amendment No. 1
Thereto Relating to Listing Standards
for Series of Portfolio Depositary
Receipts and Index Fund Shares
ycherry on PROD1PC63 with NOTICES
December 28, 2006.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on November
21, 2006, the American Stock Exchange
LLC (‘‘Amex’’ or ‘‘Exchange’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been substantially prepared by the
Exchange. Amex filed Amendment No.
1 with the Commission on December 20,
2006. This order provides notice of the
proposed rule change as modified by
Amendment No. 1 and approves the
1 15
2 17
U.S.C. 78s(b)(l).
CFR 240. 19b–4.
VerDate Aug<31>2005
13:55 Jan 08, 2007
Jkt 211001
proposed rule change on an accelerated
basis.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to make
clarifying changes to Amex Rules 1000,
1002, 1000A and 1002A and minor,
typographical changes to Amex Rules
1000, 1002 and 1002A, relating to listing
standards for series of portfolio
depositary receipts and index fund
shares (collectively, ‘‘exchange-traded
funds’’ or ‘‘ETFs’’). The text of the
proposed rule change is available at
Amex, at https://www.amex.com, and at
the Commission’s Public Reference
Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Amex included statements concerning
the purpose of, and basis for, the
proposed rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item III below. The Amex has
prepared summaries, set forth in
sections A, B, and C below, of the most
significant aspects of such statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and the
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to clarify the
listing standards in Amex Rules 1000,
1002, 1000A and 1002A governing
ETFs, amendments to which were
approved by the Commission on
November 9, 2006.3 In particular, the
Commission approved changes to Rules
1000 and 1000A to include generic
listing standards for series of ETFs that
are based on international or global
indexes. Additionally, the Commission
approved revisions to Amex Rules 1000
and 1000A to include generic listing
standards for ETFs that are based on
indexes or portfolios previously
approved by the Commission as an
underlying benchmark for the trading of
ETFs, options or other specified indexbased securities. These changes enable
the Exchange to list exchange-traded
funds pursuant to Rule 19b–4(e) of the
Act 4 if each of the conditions set forth
in Commentary .03 to Rule 1000 or
3 See Securities Exchange Act Release No. 54739
(November 9, 2006), 71 FR 66993 (November 17,
2006) (SR–Amex–2006–78).
4 17 CFR 240.19b–4(e).
PO 00000
Frm 00105
Fmt 4703
Sfmt 4703
Commentary .02 to Rule 1000A is
satisfied.
Rule 19b–4(e) provides that the listing
and trading of a new derivative
securities product by a self-regulatory
organization shall not be deemed a
proposed rule change under Rule 19b–
4(c)(1) of the Act 5 if the Commission
has approved, pursuant to Section 19(b)
of the Act, the self-regulatory
organization’s trading rules, procedures
and listing standards for the product
class that would include the new
derivatives securities product and the
self-regulatory organization has a
surveillance program for the product
class.6
The Commission also approved other
minor clarifying changes to Amex Rules
1000, 1002, 1000A and 1002A.
In connection with those approved
changes, the Exchange now proposes to
make additional clarifying changes to
Rules 1000, 1002, 1000A and 1002A.
Specifically, the Exchange proposes to
amend the definition of ‘‘US Component
Stock’’ in Rules 1000(b)(3) and
1000A(b)(3). The definition of U.S.
Component Stock was designed to
include any equity security that is
registered under Sections 12(b) or 12(g)
of the Act, and therefore to comprise all
securities that are subject to
Commission oversight through
registration. This definition was
intended to include American
Depositary Receipts (‘‘ADRs’’), the
underlying security of which is
registered under Section 12(b) or 12(g)
of the Act. In the case of listed ADRs,
it is the equity security underlying an
ADR that is registered pursuant to
Section 12 of the Act, not the ADRs.7
Under Amex’s generic listing
standards,8 the ADR would also be
required to be listed on a national
securities exchange and be an NMS
Stock as defined in Rule 600 of
Regulation NMS.9 Consequently, the
Exchange proposes to revise the
definition of U.S. Component Stock to
clarify that, while the ADR would be
considered the U.S. Component Stock
and therefore the index component for
purposes of satisfying the eligibility
criteria, the ADR can only qualify as a
‘‘US Component Stock’’ if the equity
security underlying that ADR is
5 17
CFR 240.19b–4(c)(1).
relying on Rule 19b–4(e), the SRO must
submit Form 19b–4(e) to the Commission within
five business days after the exchange begins trading
the new derivative securities products. See
Exchange Act Release No. 40761 (December 8,
1998), 63 FR 70952 (December 22, 1998).
7 See 17 CFR 240.12a–8.
8 See Amex Rule 1000, Commentary .03(a)(A)(5),
(a)(B)(5) and (a)(C), and Amex Rule 1000A,
Commentary .02(a)(A)(5), (a)(B)(5) and (a)(C).
9 17 CFR 242.600.
6 When
E:\FR\FM\09JAN1.SGM
09JAN1
Agencies
[Federal Register Volume 72, Number 5 (Tuesday, January 9, 2007)]
[Notices]
[Pages 1036-1040]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E7-61]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Rel. No. IC-27651; File No. 812-13282]
Sun Life Assurance Company of Canada (U.S.), et al., Notice of
Application
December 29, 2006.
AGENCY: Securities and Exchange Commission (the ``Commission'').
ACTION: Notice of application for an order of approval pursuant to
Section 26(c) of the Investment Company Act of 1940, as amended (the
``Act''), and an order of exemption pursuant to Section 17(b) of the
Act from Section 17(a) of the Act.
-----------------------------------------------------------------------
APPLICANTS: Sun Life Assurance Company of Canada (U.S.) (``Sun Life
U.S.''), Sun Life Insurance and Annuity Company of New York (``Sun Life
N.Y.'') (together with Sun Life U.S., the ``Companies''), Keyport
Variable Account A (``Keyport Account A''), Sun Life of Canada (U.S.)
Variable Account F (``Account F''), Sun Life of Canada (U.S.) Variable
Account I (``Account I''), KBL Variable Annuity Account (``KBL Annuity
Account''), KBL Variable Account A (``KBL Account A''), and Sun Life
(N.Y.) Variable Account C (``Account C'') (collectively, the
``Applicants''). Applicants, together with Sun Capital Advisers Trust
(``Sun Capital Trust'') are ``Section 17(b) Applicants.''
SUMMARY OF APPLICATION: Applicants seek an order approving the proposed
substitutions (the ``Substitutions'') of Class O shares of Alger
American Growth Portfolio of the Alger American Fund and Class A and
Class B shares of the AllianceBernstein VPS Large Cap Growth Portfolio
of the AllianceBernstein Variable Product Series Fund (collectively,
the ``Old Portfolios'') with Initial and Service Class Shares of the SC
FI Large Cap Growth Fund of Sun Capital Trust (the ``New Portfolio'')
under certain variable life insurance policies and variable annuity
contracts (``Contracts''). Section 17(b) Applicants also seek an order
pursuant to Section 17(b) of the Act to permit certain in-kind
transactions in connection with the Substitutions.
Filing Date: The application was originally filed on April 19, 2006,
and an amended and restated application was filed on December 20, 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 Secretary of the
Commission and serving Applicants with a copy of the request,
personally or by mail. Hearing requests must be received by the
Commission by 5:30 p.m. on January 24, 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 requester'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 Secretary of the Commission.
ADDRESSES: The Commission: Secretary, Securities and Exchange
Commission, 100 F Street, NE., Washington, DC 20549-1090; Applicants:
c/o Maura A. Murphy, Esq., Sun Life Assurance Company of Canada (U.S.),
One Sun Life Executive Park, Wellesley Hills, Massachusetts 02481.
FOR FURTHER INFORMATION CONTACT: Rebecca A. Marquigny, Senior Counsel,
or Joyce M. Pickholz, Branch Chief, Office of Insurance Products,
Division of Investment Management, at (202) 551-6795.
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application is available for a fee from the
Public Reference Branch of the Commission, 100 F Street, NE.,
Washington, DC 20549 (202-551-8090).
Applicants' and Section 17 Applicants' Representations
1. Sun Life U.S. is a stock life insurance company ultimately
controlled by Sun Life Financial Inc. (``Sun Life Financial''), a
Canadian reporting company under the Securities Exchange Act of 1934
(the ``1934 Act''). Pursuant to a 2003 merger, Keyport Life Insurance
Company (``Keyport'') was merged with and into Sun Life U.S. with Sun
Life U.S. as the survivor. Sun Life U.S. is the depositor and sponsor
of Keyport Account A, Account F, and Account I.
2. Keyport Account A is registered with the Commission under the
Act as a unit investment trust (File No. 811-07543) with interests are
offered through Contracts (the ``Keyport Contracts'') registered under
the Securities Act of 1933 (``1933 Act'') on Form N-4 (File Nos. 333-
114126, 333-114129, 333-114132, 333-111642, 333-111645, 333-111646,
333-111647, and 333-111648). Account F is registered as a unit
investment trust (File No. 811-05846); its interests are also offered
through Contracts (the ``Account F Contracts'') registered under the
1933 Act on Form N-4 (File Nos. 33-29852, 33-41628, 333-37907, 333-
05227, 333-82957, 333-30844, 333-31248, 333-41438, 333-74844, 333-
83256, 333-83362, 333-83364, 333-83516, 333-74972, 333-115525, and 333-
115536). Account I, registered as a unit investment trust (File No.
811-09137) also offers its interests through Contracts (the ``Account I
Contracts'') registered under the 1933 Act on Form N-6 (File Nos. 333-
68601, 333-59662, 333-94359, 333-100831, and 333-100829).
3. Sun Life N.Y., a wholly owned subsidiary of Sun Life U.S., is a
stock life insurance company which merged with Keyport Benefit Life
Insurance Company (``KBL''), a subsidiary of Keyport, in 2002. Sun Life
N.Y. is the depositor and sponsor of the KBL Annuity Account, KBL
Account A, and Account C.
4. KBL Annuity Account is a registered unit investment trust (File
No. 811-05422) for which interests are offered through a Contract (the
``KBL
[[Page 1037]]
Annuity Contract'') registered under the 1933 Act on Form N-4 (File No.
333-102275). KBL Account A is a registered unit investment trust (File
No. 811-08635) with interests are offered through other Contracts (the
``KBL Account A Contracts'') registered under the 1933 Act on Form N-4
(File Nos. 333-102274, 333-102278, 333-102279, and 333-102280). Account
C, a registered unit investment trust (File No. 811-04440), also offers
its interests through certain Contracts (the ``Account C Contracts'')
registered under the 1933 Act on Form N-4 (File Nos. 33-41629, 333-
05037, 333-67864, 333-100475, 333-100474, 333-99907, and 333-107983).
5. All of the Contracts involved in the Substitutions (a) reserve
the right to substitute shares of one portfolio for shares of another;
(b) permit transfers of contract value among the subaccounts pursuant
to the limitations of the particular Contract, (c) impose or reserve
the right to impose a transfer charge; and (d) are subject to market
timing policies and procedures that may operate to limit transfers.
6. Applicants represent that: (a) The Keyport Contracts involved in
the Substitutions are no longer offered for sale, except to certain
employee plans; (b) none of the Account I, KBL Account A, or KBL
Annuity Contracts involved in the Substitutions are still offered for
sale; and (c), the subaccounts investing in the Old Portfolios are no
longer offered as investment options to new Contract owners under the
Account F Contracts and Account C Contracts.
7. Alger American Growth Portfolio (``Alger Growth'' or ``Old
Portfolio'') is a portfolio of Alger American Fund, a registered,
diversified, open-end management investment company (File No. 811-
05550). Class O and Class S of its shares are registered under the 1933
Act on Form N-1A (File No. 33-21722). The shares are the same except
Class S shares are subject to a distribution and shareholder servicing
fee while Class O shares are not. The portfolio's investment adviser is
Fred Alger Management, Inc. (``FAM'').
8. AllianceBernstein VPS Large Cap Growth Portfolio (``AB Large Cap
Growth'') is a portfolio of the AllianceBernstein Variable Product
Series Fund, a registered diversified, open-end management investment
company (File No. 811-05398). Class A and B shares of AB Large Cap
Growth (also referred to as ``Old Portfolio'') are registered under the
1933 Act on Form N-1A (File No. 33-18647). The shares are the same
except Class B shares are subject to a distribution fee and Class A
shares are not. AllianceBernstein L.P. (``AB L.P.'') is the portfolio's
investment adviser.
9. SC FI Large Cap Growth Fund (``SC Large Cap Growth'' or ``New
Portfolio'') is a portfolio of Sun Capital Trust, a registered,
diversified, open-end management investment company (File No. 811-
08879). Initial and Service Class shares of New Portfolio are
registered under the 1933 Act on Form N-1A (File No. 333-59093); the
shares are the same except that Service Class shares are subject to a
distribution fee and Initial Class shares are not.
10. Sun Capital Advisers LLC (``Sun Capital''), an indirect, wholly
owned subsidiary of Sun Life Financial, is investment adviser to all
the Sun Capital Trust portfolios. Through an order from the Commission
pursuant to Section 6(c) of the Act, Sun Capital is exempt from Section
15(a) of the Act and Rule 18f-2 thereunder with respect to subadvisory
agreements (the ``Manager of Managers Order'').\1\
---------------------------------------------------------------------------
\1\ Sun Capital Advisers Trust and Sun Capital Advisers, Inc.,
1940 Act Rel. No. 24401 (April 24, 2000) (Order), File No. 812-
11790; see also Sun Capital Advisers Trust and Sun Capital Advisers,
Inc., 1940 Act Rel. No. 23793 (Apr. 20, 1999) (Order), File No. 812-
11464.
---------------------------------------------------------------------------
11. Applicants represent that the relief granted in the Manager of
Managers Order extends to New Portfolio permitting it to enter into and
materially amend investment subadvisory agreements without obtaining
shareholder approval. Applicants also indicate that the prospectus for
the New Portfolio discloses and explains the existence, substance and
effect of the Manager of Managers Order.
12. Applicants propose to substitute (a) Initial Class shares of
New Portfolio for Class O shares of Alger Growth; (b) Initial Class
shares of New Portfolio for Class A shares of AB Large Cap Growth; and
(c) Service Class shares of New Portfolio for Class B shares of AB
Large Cap Growth. Applicants state that the proposed Substitutions are
part of an overall business goal of the Companies to make the Contracts
more attractive to Contract owners by providing a diverse array of
investment options that are not redundant or duplicative in terms of
the investment types and styles of mutual funds underlying such
options. Applicants assert their belief that:
(a) Reducing the number of nonproprietary funds will provide the
Companies with more control over fund changes that affect their
Contracts, allowing for appropriate long-term strategic planning;
(b) The New Portfolio better promotes their goals of increasing
administrative efficiency of, and control over, their Contracts because
the New Portfolio is part of their affiliated fund family;
(c) Streamlining the number of nonproprietary funds available
through the Contracts and altering the available portfolios will
simplify the administration of the Contracts, particularly with regard
to communications with the fund families and the preparation of various
reports and disclosure documents; and
(d) This streamlining will allow the Companies to enhance their
communication efforts to Contract owners and sales representatives
regarding the available portfolios, and may provide for more enhanced
and timely reporting to the Companies from fund families and therefore
from the Companies to Contract owners.
13. Regarding Contracts that offer both of the Old Portfolios as
investment options, Applicants assert that a more concentrated and
streamlined array of investment options could result in increased
operational and administrative efficiencies and economies of scale for
the Companies. Applicants note that Contract owners could benefit from
streamlining Contract investment options. Specifically, Applicants
state that Contracts that offer too many similar investment options may
be unnecessarily confusing to Contract owners and may increase the
Companies' costs of administering the Contracts.
14. Applicants represent that because the New Portfolio operates
pursuant to the Manager of Managers Order, the Substitutions would
provide protection to Contract owners by giving Sun Capital the agility
and flexibility to change the subadviser of the New Portfolio should
such a change become warranted or advisable. In support of the
Substitutions, Applicants further represent that the Substitutions will
provide Contract owners with substantially similar investment vehicles.
Specifically, Applicants assert that the investment objectives,
principal investment strategies and principal investment risks of the
New Portfolio are substantially similar to those of the Old Portfolios.
The following summarizes the more complete comparison of New and Old
Portfolios provided in the Application.
15. Alger Growth Substitution.
Applicants describe the investment objective of Alger Growth as
``to seek long-term capital appreciation'' and the investment objective
of New Portfolio as ``to seek long-term growth of capital.'' Applicants
state that the principal investment strategies of the two portfolios
are substantially similar
[[Page 1038]]
noting that both invest primarily in common stocks with an emphasis on
``growth'' stocks and the stocks of highly capitalized companies. Alger
Growth invests at least 65% of its total assets in equity securities of
companies that, at the time of purchase, have total market
capitalization of $1 billion or greater. SC Large Cap Growth invests at
least 80% of its assets in the common stocks of companies with large
market capitalizations. Both portfolios may invest up to 20% of the
value of their total assets in foreign securities (not including
American Depositary Receipts, American Depositary Shares, or U.S.
dollar denominated securities of foreign issuers). Applicants represent
that both Alger Growth and New Portfolio have substantially similar
risk characteristics and share substantially similar risk profiles.
Charges for Class O of Alger Growth include Management Fees of
0.75%, Other Expenses of 0.06%, and no 12b-1 Fee.\2\ Charges for the
Initial Class shares of New Portfolio include: Management Fees of 0.75%
and Other Expenses of 0.30%; it does not charge a 12b-1 Fee. Alger
Growth's total gross and net operating expenses are both 0.81%.
Respectively, New Portfolio's total gross and net operating expenses
are 1.05% and 0.81% (reflecting a 0.24% contractual fee reduction
arrangement).
---------------------------------------------------------------------------
\2\ For the descriptions of charges involved in the
Substitution, all percentages for the Management Fees, 12b-1 Fees,
Other Expenses, Fee Reductions, Total Gross and Net Annual Operating
Expenses, and Separate Account Fees represent a percentage of
average annual assets.
---------------------------------------------------------------------------
16. AB Large Cap Growth Substitutions.
Applicants represent that the investment objectives of AB Large Cap
Growth and New Portfolio are identical; both portfolios see long-term
growth of capital. Applicants state that the principal investment
strategies of the two portfolios are substantially similar noting that
New Portfolio invests at least 80% of its net assets in common stocks
of large-capitalization companies based on the market capitalization of
companies in the Russell 1000 Index or the S&P 500. Old Portfolio
invests an identical 80% of its assets in common stock of companies
with large market capitalizations based on the market capitalization
range of companies appearing in the Russell 1000 Growth Index.
Applicants represent that both AB Large Cap Growth and New Portfolio
have substantially similar risk characteristics as both invest in
substantially similar securities.
For the proposed substitution involving Class A of AB Large Cap
Growth, charges for Class A of Old Portfolio include Management Fees of
0.75% and Other Expenses of 0.06%. Charges for the Initial Class of New
Portfolio include Management Fees of 0.75% and Other Expenses of 0.30%.
Neither imposes a 12b-1 Fee. The Old Portfolio's total gross and net
operating expenses for Class A shares are both 0.81%. Respectively, New
Portfolio's total gross and net operating expenses for Initial Class
shares are 1.05% and 0.81% (reflecting a 0.24% contractual fee
reduction arrangement).
For the proposed substitution involving Class B of AB Large Cap
Growth, charges for Class B of Old Portfolio include Management Fees of
0.75%, 12b-1 Fees of 0.25%, and Other Expenses of 0.06%. Charges for
the Service Class of New Portfolio include Management Fees of 0.75%,
12b-1 Fees of 0.25%, and Other Expenses of 0.30%. The Old Portfolio's
total gross and net operating expenses for Class B shares are both
1.06%. Respectively, New Portfolio's total gross and net operating
expenses for Service Class shares are 1.30% and 1.06% (reflecting a
0.24% contractual fee reduction arrangement).
17. Applicants assert that as of the effective date of the
Substitutions (``Effective Date''), each Separate Account will redeem
shares of the applicable Old Portfolio in-kind. Applicants state that
if Sun Capital declines to accept particular portfolio securities of
either of the Old Portfolios for purchase in-kind of shares of the New
Portfolio, the applicable Old Portfolio will liquidate portfolio
securities as necessary and shares of the New Portfolio will be
purchased with cash. Applicants represent that in either event, the
proceeds of such redemptions will then be used to purchase shares of
the corresponding class of the New Portfolio, with each subaccount of
the applicable Separate Account investing the proceeds of its
redemption from the Old Portfolios in the applicable class of the New
Portfolio.
18. Applicants further state that redemption requests and purchase
orders will be placed simultaneously so that contract values will
remain fully invested at all times. Applicants represent that all
redemptions of shares of the Old Portfolios and purchases of shares of
the New Portfolios will be effected in accordance with Section 22(c) of
the Act and Rule 22c-1 thereunder. Applicants state that the
Substitutions will take place at relative net asset value as of the
Effective Date with no change in the amount of any Contract owner's
contract value or death benefit or in the dollar value of his or her
investments in any of the subaccounts. Applicants represent that
Contract owners will receive Service Class shares of the New Portfolio
in the Substitutions only if they are currently invested in Class B
shares of the AB Large Cap Growth, which also imposes a distribution
fee.
19. Applicants further represent that all expenses incurred in
connection with the Substitutions, including legal, accounting,
transactional, and other fees and expenses, including brokerage
commissions, will be paid by Sun Life U.S. or Sun Life N.Y. Applicants
also state that, as a result of the Substitutions, Contract owners will
not incur any additional fees or charges, nor will their rights or
insurance benefits or the Companies' obligations under the Contracts be
altered. Applicants assert that the Substitutions: (a) Will not impose
any tax liability on Contract owners; and (b) will not cause the
Contract fees and charges currently being paid by existing Contract
owners to be greater after the Substitutions than before the
Substitutions. Applicants represent that neither Sun Life U.S. nor Sun
Life N.Y. will exercise any right either may have under the Contracts
to impose restrictions on transfers under the Contracts for a period of
at least thirty days following the Substitutions.
20. Applicants represent that during the twenty-four months
following the date of the Substitutions, the total net operating
expenses of the applicable class of the New Portfolio (taking into
account any expense waiver or reimbursement) will not exceed the net
expense level of the corresponding class of the Old Portfolio for the
fiscal year ended December 31, 2005. Applicants also state that through
the twenty-four months following the date of the Substitutions, Sun
Capital has contractually agreed to waive its management fee and, if
necessary, to limit other ordinary operating expenses so that total
operating expenses, as a percentage of average net assets, do not
exceed 0.81% or 1.06%, as applicable. In addition, Applicants represent
that for twenty-four months following the date of the Substitutions,
the Companies will not increase asset-based fees or charges for
Contracts outstanding on the date of the Substitutions.
21. Applicants represent that a prospectus for the New Portfolio
containing disclosure about the Manager of Managers Order will be
provided to each Contract owner prior to or at the time of the
Substitutions. Notwithstanding the Manager of Managers Order, after the
Effective Date of the Substitutions, the Applicants agree not to change
the New Portfolio's subadviser, add a new subadviser, or
[[Page 1039]]
otherwise rely on the Manager of Managers Order without first obtaining
shareholder approval of either: (1) The subadviser change; or (2) the
New Portfolio's continued ability to rely on the Manager of Managers
Order.
22. Applicants state that Contract owners were notified of the
initial application by means of a prospectus supplement for each of the
Contracts stating that the Applicants filed the initial application and
seek approval for the Substitutions (``Pre-Substitution Notice''). The
Pre-Substitution Notice set forth the anticipated Effective Date and
advised Contract owners that contract values attributable to
investments in the Old Portfolios will be transferred to the New
Portfolios, without charge (including sales charges or surrender
charges) and without counting toward the number of transfers that may
be permitted without charge, on the Effective Date. Applicants indicate
that the Pre-Substitution Notice stated that, from the date the initial
application was filed with the Commission through the date thirty days
after the Substitutions, Contract owners may make one transfer of
contract value from the subaccounts investing in the Old Portfolios
(before the Substitutions) or the New Portfolio (after the
Substitutions) to one or more other subaccount(s) without charge
(including sales charges or surrender charges) and without that
transfer counting against their contractual transfer limitations.
23. Applicants represent that all Contract owners will have
received a copy of the most recent New Portfolio prospectus prior to
the Substitutions. Applicants also agree that, within five days
following the Substitutions, Contract owners affected by the
Substitutions will be notified in writing that the Substitutions were
carried out and that this notice will restate the information set forth
in the Pre-Substitution Notice.
Applicants' Legal Analysis
1. Section 26(c) of the Act makes it unlawful for any depositor or
trustee of a registered unit investment trust holding the security of a
single issuer to substitute another security for such security unless
the Commission approves the substitution. The Commission may approve
such a substitution if the evidence establishes that it is consistent
with the protection of investors and the purposes fairly intended by
the policy and provisions of the Act.
2. Applicants submit that the Substitutions meet the standards set
forth in Section 26(c) and assert that replacement of the Old
Portfolios with the New Portfolio is consistent with the protection of
Contract owners and the purposes fairly intended by the policy and
provisions of the Act. Applicants have reserved the right to make such
a substitution under the Contracts and represent that this reserved
right is disclosed in the prospectus for the Contracts.
3. Section 17(a)(1) of the Act, in relevant part, prohibits any
affiliated person of a registered investment company, or any affiliated
person of such person, acting as principal, from knowingly selling any
security or other property to that company. Section 17(a)(2) of the Act
generally prohibits the persons described above, acting as principal,
from knowingly purchasing any security or other property from the
registered company. Pursuant to Section 10(a)(1) of the Act, the
Section 17(b) Applicants may be considered affiliates of one or more of
the portfolios involved in the Substitutions. Because the Substitutions
may be effected, in whole or in part, by means of in-kind redemptions
and subsequent purchases of shares and by means of in-kind
transactions, the Substitutions may be deemed to involve one or more
purchases or sales of securities or property between affiliates.
4. Section 17(b) of the Act provides that the Commission may, upon
application, grant an order exempting any transaction from the
prohibitions of Section 17(a) if the evidence establishes that: The
terms of the proposed 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; the proposed
transaction is consistent with the policy of each registered investment
company concerned, as recited in its registration statement and records
filed under the Act; and the proposed transaction is consistent with
the general purposes of the Act.
5. The Section 17(b) Applicants state that the terms under which
the in-kind redemptions and purchases will be effected are reasonable
and fair and do not involve overreaching on the part of any person
principally because the Substitutions will conform with all but two of
the conditions enumerated in Rule 17a-7. Applicants assert that the use
of in-kind transactions will not cause Contract owner interests to be
diluted. In support, Applicants represent that: (a) The proposed
transactions will take place at relative net asset value as of the
Effective Date in conformity with the requirements of Section 22(c) of
the 1940 Act and Rule 22c-1 thereunder with no change in the amount of
any Contract owner's contract value or death benefit or in the dollar
value of his or her investment in any of the Separate Accounts; (b)
Contract owners will not suffer any adverse tax consequences as a
result of the Substitutions; and (c) Fees and charges under the
Contracts will not increase because of the Substitutions.
6. Further, though the Section 17(b) Applicants may not rely on
Rule 17a-7 because they cannot meet all of its conditions, the Section
17(b) Applicants agree to carry out the proposed in-kind purchases in
conformity with all of the conditions of Rule 17a-7 and the procedures
adopted thereunder, except that: (1) The consideration paid for the
securities being purchased or sold may not be entirely cash; and (2)
the Sun Capital Trust board will not separately review each portfolio
security purchased by the New Portfolio. However, Applicants assert
that the circumstances surrounding the Substitutions will offer the
same degree of protection to the New Portfolio from overreaching that
Rule 17a-7 provides to it generally in connection with its purchase and
sale of securities under that Rule in the ordinary course of its
business.
7. Applicants assert that the Board of Sun Capital Trust has
adopted procedures, as required by Rule 17a-7, and that Sun Capital or
any subadviser to the New Portfolio will review the securities holdings
of the Old Portfolio to determine whether their portfolio holdings
would be suitable investments for the New Portfolio in the overall
context of its investment objectives and policies and consistent with
its management. Applicants also note that the Companies (or any of
their affiliates) cannot effect the proposed Substitutions at a price
disadvantageous to the New Portfolio. Although the Substitutions may
not be entirely for cash, Applicants represent that each will be
effected based upon (1) the independent market price of the portfolio
securities valued as specified in paragraph (b) of Rule 17a-7, and (2)
the net asset value per share of each portfolio involved valued
according to the procedures disclosed in its registration statement and
as required by Rule 22c-1 under the Act. The Section 17(b) Applicants
state that securities to be paid out as redemption proceeds and
subsequently contributed to the New Portfolio to effect the in-kind
purchases of shares will be valued based on the normal valuation
procedures of the redeeming and purchasing Portfolios, and redeeming
and purchasing values will be the same. Applicants note that if Sun
Capital
[[Page 1040]]
declines to accept particular portfolio securities of either of the Old
Portfolios for purchase in-kind of shares of the New Portfolio, the
applicable Old Portfolio will liquidate portfolio securities as
necessary and purchase New Portfolio shares with cash. Consistent with
Rule 17a-7(d), Applicants also agree that no brokerage commissions,
fees, or other remuneration will be paid in connection with the in-kind
transactions.
Conclusions
1. Applicants submit that for the reasons and upon the facts set
forth in their application, the requested order meets the standards set
forth in Section 26(c) and should, therefore, be granted.
2. Section 17 Applicants represent that the proposed in-kind
transactions meet all of the requirements of Section 17(b) of the Act
and that an exemption should be granted, to the extent necessary, from
the provisions of Section 17(a).
For the Commission, by the Division of Investment Management,
pursuant to delegated authority.
Nancy M. Morris,
Secretary.
[FR Doc. E7-61 Filed 1-8-07; 8:45 am]
BILLING CODE 8011-01-P