WisdomTree Investments, Inc., et al.; Notice of Application, 55255-55257 [E7-19148]
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Federal Register / Vol. 72, No. 188 / Friday, September 28, 2007 / Notices
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[FR Doc. E7–19245 Filed 9–27–07; 8:45 am]
BILLING CODE 7590–01–P
SECURITIES AND EXCHANGE
COMMISSION
Proposed Collection; Comment
Request
Upon Written Request, Copies Available
From: Securities and Exchange
Commission, Office of Investor
Education and Advocacy,
Washington, DC 20549–0213
jlentini on PROD1PC65 with NOTICES
Extension: Form F–4; OMB Control No.
3235–0325; SEC File No. 270–288.
17:12 Sep 27, 2007
Jkt 211001
Dated: September 24, 2007.
Nancy M. Morris,
Secretary.
[FR Doc. E7–19185 Filed 9–27–07; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
Notice is hereby given that, pursuant
to the Paperwork Reduction Act of 1995
(44 U.S.C. 3501 et seq.), the Securities
and Exchange Commission
(‘‘Commission’’) is soliciting comments
on the collection of information
summarized below. The Commission
plans to submit this existing collection
of information to the Office of
Management and Budget for extension
and approval.
Form F–4 (17 CFR 239.34) is used by
foreign issuers to register securities in
business combinations, reorganizations
and exchange offers pursuant to the
Securities Act of 1933 (15 U.S.C. 77a et
seq.). The information collected is
intended to ensure that the information
required to be filed by the Commission
permits verification of compliance with
securities law requirements and assures
the public availability of such
information. Form F–4 takes
approximately 1,447 hours per response
and is filed by approximately 68
respondents. We estimate that 25% of
the 1,447 hours per response (361.75
hours) is prepared by the registrant for
VerDate Aug<31>2005
a total annual reporting burden of
24,599 hours (361.75 hours per response
x 68 responses). The remaining 75% of
the burden hours is attributed to outside
cost.
Written comments are invited on: (a)
Whether this proposed collection of
information is necessary for the proper
performance of the functions of the
agency, including whether the
information will have practical utility;
(b) the accuracy of the agency’s estimate
of the burden imposed by the collection
of information; (c) ways to enhance the
quality, utility, and clarity of the
information collected; and (d) ways to
minimize the burden of the collection of
information on respondents, including
through the use of automated collection
techniques or other forms of information
technology. Consideration will be given
to comments and suggestions submitted
in writing within 60 days of this
publication.
Please direct your written comments
to R. Corey Booth, Director/Chief
Information Officer, Securities and
Exchange Commission, C/O Shirley
Martinson, 6432 General Green Way,
Alexandria, Virginia 22312; or send an
e-mail to: PRA_Mailbox@sec.gov.
[Release No. IC–27976; 812–13417]
WisdomTree Investments, Inc., et al.;
Notice of Application
September 21, 2007.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application to amend
a prior 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), 22(e), and 24(d)
of the Act and rule 22c–1 under the Act,
under sections 6(c) and 17(b) of the Act
for an exemption from sections 17(a)(1)
and 17(a)(2) of the Act, and under
section 12(d)(1)(J) for an exemption
from sections 12(d)(1)(A) and
12(d)(1)(B) of the Act.
AGENCY:
Applicants
request an order (‘‘Order’’) to amend a
prior order that permits: (a) An openend management investment company,
whose series track the performance of
certain domestic and international
equity securities indexes developed by
SUMMARY OF APPLICATION:
PO 00000
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Fmt 4703
Sfmt 4703
55255
the parent company of the series’
investment adviser, to issue shares
(‘‘Shares’’) redeemable only in large
aggregations; (b) secondary market
transactions in Shares to occur at
negotiated prices; (c) dealers to sell
Shares to purchasers in the secondary
market unaccompanied by a prospectus
when prospectus delivery is not
required by the Securities Act of 1933
(‘‘Securities Act’’); (d) certain affiliated
persons of the series to deposit
securities into, and receive securities
from, the series in connection with the
purchase and redemption of
aggregations of the series’ Shares; (e)
under certain circumstances, the series
that track certain foreign equity
securities indexes to pay redemption
proceeds more than seven days after the
tender of Shares; and (f) certain
management investment companies and
unit investment trusts outside of the
same group of investment companies as
the series to acquire Shares (the ‘‘Prior
Order’’).1 Applicants seek to amend the
Prior Order in order to offer additional
series based on certain fixed income
securities indexes (the ‘‘New Funds’’).
In addition, the Order would delete a
condition related to future relief in the
Prior Order.
APPLICANTS: WisdomTree Investments,
Inc. (‘‘WTI’’), WisdomTree Asset
Management, Inc. (the ‘‘Advisor’’), and
WisdomTree Trust (the ‘‘Trust’’).
FILING DATES: The application was filed
on August 13, 2007 and amended on
September 19, 2007.
HEARING OR NOTIFICATION OF HEARING: An
order granting the requested relief 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 October 16, 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: 48 Wall Street, Suite
1100, New York, NY 10005.
1 WisdomTree Investments, Inc., et al.,
Investment Company Act Release Nos. 27324 (May
18, 2006) (notice) and 27391 (June 12, 2006) (order).
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55256
Federal Register / Vol. 72, No. 188 / Friday, September 28, 2007 / Notices
FOR FURTHER INFORMATION CONTACT:
Courtney S. Thornton, Senior Counsel,
at (202) 551–6812, or Mary Kay Frech,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Office of Investment Company
Regulation).
The
following is a summary of the
application. The complete application
may be obtained for a fee at the
Commission’s Public Reference Branch,
100 F Street, NE., Washington, DC
20549–0102 (tel. 202–551–5850).
SUPPLEMENTARY INFORMATION:
jlentini on PROD1PC65 with NOTICES
Applicants’ Representations
1. The Trust, a Delaware statutory
trust registered under the Act as an
open-end management investment
company, is organized as a series fund
with multiple series (the ‘‘Equity
Funds’’). WTI, a Delaware corporation
with its principal offices in New York
City, is the sole shareholder of the
Advisor. WTI has developed and
maintains the proprietary indexes that
serve or will serve as the basis for the
Equity Funds and the New Funds. The
Advisor is a Delaware corporation that
is registered as an investment adviser
under the Investment Advisers Act of
1940 (‘‘Advisers Act’’). The Advisor
serves as investment adviser to the
Equity Funds, and the Advisor, or an
entity controlled by or under common
control with the Advisor, will serve as
investment adviser to the New Funds
and any future series of the Trust
(‘‘Future Funds’’). The Advisor and the
Trust intend to hire one or more
subadvisers (‘‘Subadvisers’’) for the New
Funds, each of which will be registered
as an investment adviser under the
Advisers Act and will not otherwise be
an affiliated person, or an affiliated
person of an affiliated person, of the
Trust, the Advisor, or WTI. ALPS
Distributors, Inc. (‘‘Distributor’’), a
broker-dealer registered under the
Securities Exchange Act of 1934
(‘‘Exchange Act’’), acts as distributor
and principal underwriter of the Equity
Funds and may perform such services
for the New Funds and any Future
Funds.
2. The Trust is currently permitted to
offer the Equity Funds, which track
equity securities indexes developed by
WTI, in reliance on the Prior Order.
Applicants seek to amend the Prior
Order to permit the Trust to offer the
New Funds, as well as Future Funds
(together with the Equity Funds and the
New Funds, the ‘‘Funds’’) that are
advised by the Advisor or an entity
controlled by or under common control
with the Advisor and that comply with
the terms and conditions of the Prior
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17:12 Sep 27, 2007
Jkt 211001
Order, as modified by the requested
relief.
3. The investment objective of each
New Fund will be to provide investment
results that correspond generally to the
price and yield performance of its
underlying index (‘‘Underlying Index’’)
by investing in a portfolio of securities
generally consisting of the component
securities (‘‘Component Securities’’) of
the Underlying Index.2 The Underlying
Index for each New Fund tracks fixed
income securities and will be
rebalanced monthly.3 The Underlying
Indexes for the New Funds, as well as
the Underlying Indexes for the Equity
Funds, have been created by WTI, an
affiliated person, as defined in section
2(a)(3) of the Act, of the Advisor and the
Trust. Future Funds may be based on
Underlying Indexes created, compiled,
sponsored, or maintained by WTI or
another index provider that is
controlled by or under common control
with WTI (a ‘‘WTI Index Provider’’) or
on Underlying Indexes created,
compiled, sponsored, or maintained by
an entity that is not an affiliated person,
or an affiliated person of an affiliated
person, of the Fund, the Advisor, the
Distributor, promoter, or any Subadviser
to a Fund (a ‘‘Non-Affiliated Index
Provider’’). Because Funds based on
Underlying Indexes created by a WTI
Index Provider could introduce
potential conflicts of interest, the Prior
Order contains certain representations
and undertakings relating to the
transparency of the methodology for
those Underlying Indexes, and the
establishment of certain policies and
procedures to limit communication
between index personnel and
employees of the Advisor and any
Subadviser. Applicants believe that
these conflicts of interest do not exist
where the index creator is a NonAffiliated Index Provider. Applicants
therefore seek to amend the Prior Order
to provide that the relevant
representations and undertakings in the
application for the Prior Order should
not apply to a Fund based on an
Underlying Index created by a NonAffiliated Index Provider.
4. The applicants state that the
Component Securities of the
2 The Underlying Indexes for the New Funds are
the WisdomTree International Government ex Japan
Bond Index and the WisdomTree Government
Strategies Index.
3 The application for the Prior Order specified
that Underlying Indexes created, compiled,
sponsored, or maintained by a WTI Index Provider
(as defined below) would be reconstituted no more
frequently than quarterly. Applicants seek to amend
the Prior Order to allow such Underlying Indexes
to be reconstituted as frequently as monthly, which
applicants indicate is a common methodology for
fixed income indexes.
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WisdomTree International Government
ex Japan Bond Index include liquid
investment grade government bonds
denominated in developed market
currencies other than the U.S. dollar
and the Japanese yen, with a primary
focus on fixed-rate coupon bonds in
developed markets maturing between 3
and 10 years, and exclude securities
with embedded options, floating-rate
coupons, and zero coupons. The
Component Securities of the
WisdomTree Government Strategies
Index include U.S. Treasury securities,
obligations of U.S. government agencies
and quasi-government corporations, and
U.S. mortgage-backed securities.4 Each
New Fund may fully replicate its
Underlying Index, but each New Fund
currently intends to use a
‘‘representative sampling’’ strategy.
Under a representative sampling
strategy, a New Fund will hold a basket
of the Component Securities of its
Underlying Index, but may not hold all
of the Component Securities of its
Underlying Index. Each New Fund
generally will invest at least 80% of its
total assets in the Component Securities
of the relevant Underlying Index.
However, a New Fund may also at times
invest up to 20 percent of its total assets
in certain futures, options and swap
contracts, and cash and cash
equivalents, including money market
funds, as well as securities not included
in its Underlying Index, but which the
Advisor believes will help the New
Fund to track its Underlying Index. At
all times, a New Fund and any Future
Fund will hold in the aggregate at least
80% of its total assets in Component
Securities and investments that have
economic characteristics that are
substantially identical to the economic
characteristics of the Component
Securities of its Underlying Index.5
Applicants expect that each New Fund
will have a tracking error relative to the
performance of its respective
4 The Trust intends to substitute a cash-in-lieu
amount to replace any Deposit Security or Fund
Security (each as defined below) that is a ‘‘to-beannounced transaction’’ or ‘‘TBA Transaction.’’ A
TBA Transaction is a method of trading mortgagebacked securities where the buyer and seller agree
upon general trade parameters such as agency,
settlement date, par amount, and price. The actual
pools delivered are determined two days prior to
settlement date. The amount of substituted cash in
the case of TBA Transactions will be equivalent to
the value of the TBA Transaction listed as a Deposit
Security or Fund Security.
5 Applicants anticipate that investments that have
economic characteristics substantially identical to
those of the Component Securities of an Underlying
Index will encompass securities such as depository
receipts based on Component Securities and TBA
Transactions.
E:\FR\FM\28SEN1.SGM
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Federal Register / Vol. 72, No. 188 / Friday, September 28, 2007 / Notices
Underlying Index of no more than 5
percent.
5. Applicants state that the New
Funds will comply with the federal
securities laws in accepting a deposit of
a portfolio of securities designated by
the Advisor to correspond generally to
the price and yield performance of the
New Fund’s Underlying Index (‘‘Deposit
Securities’’) and satisfying redemptions
with portfolio securities of the New
Funds (‘‘Fund Securities’’), including
that the Deposit Securities and Fund
Securities are sold in transactions that
would be exempt from registration
under the Securities Act.6
6. Applicants state that the New
Funds will operate in a manner
identical to the operation of the Equity
Funds under the Prior Order, except as
specifically noted by applicants (and
summarized in this notice), and will
comply with all of the terms, provisions
and conditions of the Prior Order, as
amended by the present application.
Applicants believe that the requested
relief continues to meet the necessary
exemptive standards.
jlentini on PROD1PC65 with NOTICES
Future Relief
7. Applicants also seek to amend the
Prior Order to modify the terms under
which the Trust may offer Future
Funds. The Prior Order is currently
subject to a condition that does not
permit applicants to register the shares
of any Future Fund by means of filing
a post-effective amendment to the
Trust’s registration statement or by any
other means, unless applicants have
requested and received with respect to
such Future Fund, either exemptive
relief from the Commission or a noaction letter from the Division of
Investment Management of the
Commission, or if the Future Fund
could be listed on a national securities
exchange (‘‘Exchange’’) without the
need for a filing pursuant to rule 19b–
4 under the Exchange Act.
8. The order would amend the Prior
Order to delete this condition. Any
Future Fund will (a) be advised by the
Advisor or an entity controlled by or
under common control with the
Advisor; (b) track Underlying Indexes
that are created, compiled, sponsored or
6 In accepting Deposit Securities and satisfying
redemptions with Fund Securities that are
restricted securities eligible for resale pursuant to
rule 144A under the Securities Act, the New Funds
will comply with the conditions of rule 144A,
including in satisfying redemptions with such rule
144A eligible restricted Fund Securities. The
prospectus for each New Fund will also state that
an authorized participant that is not a ‘‘Qualified
Institutional Buyer,’’ as defined in rule 144A under
the Securities Act, will not be able to receive, as
part of a redemption, restricted securities eligible
for resale under rule 144A.
VerDate Aug<31>2005
17:12 Sep 27, 2007
Jkt 211001
maintained by a WTI Index Provider or
a Non-Affiliated Index Provider; and (c)
comply with the respective terms and
conditions of the Prior Order, as
amended by the present application.
9. Applicants believe that the
modification of the future relief
available under the Prior Order would
be consistent with sections 6(c) and
17(b) of the Act and that granting the
requested relief will facilitate the timely
creation of Future Funds and the
commencement of secondary market
trading of such Future Funds by
removing the need to seek additional
exemptive relief. Applicants submit that
the terms and conditions of the Prior
Order have been appropriate for the
existing series of the Trust and would
remain appropriate for Future Funds.
Applicants also submit that tying
exemptive relief under the Act to the
ability of a Future Fund to be listed on
an Exchange without the need for a rule
19b–4 filing under the Exchange Act is
not necessary to meet the standards
under sections 6(c) and 17(b) of the Act.
Applicants’ Conditions
Applicants agree that any Order
granting the requested relief will be
subject to the same conditions as those
imposed by the Prior Order, except for
condition 1 to the Prior Order, which
will be deleted.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E7–19148 Filed 9–27–07; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
27975; 812–13382]
ProShares Trust, et al.; Notice of
Application
September 21, 2007.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application to
amend a prior order under section 6(c)
of the Investment Company Act of 1940
(‘‘Act’’) granting 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.
AGENCY:
Applicants: ProShares Trust
(‘‘Trust’’), ProShare Advisors LLC
(‘‘Adviser’’), and SEI Investments
Distribution Company (‘‘Distributor’’).
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55257
Summary of Application: Applicants
request an order to amend a prior order
that permits: (a) Series of an open-end
management investment company
(‘‘Initial Funds’’) to issue shares of
limited redeemability; (b) secondary
market transactions in the shares to
occur at negotiated prices; (c) dealers to
sell the shares to purchasers in the
secondary market unaccompanied by a
prospectus, when prospectus delivery is
not required by the Securities Act of
1933; and (d) certain affiliated persons
of the Initial Funds to deposit securities
into, and receive securities from, the
Initial Funds in connection with the
purchase and redemption of
aggregations of the shares (‘‘Prior
Order’’).1 Applicants seek to amend the
Prior Order to permit certain new series
(‘‘Additional Funds’’ and, together with
the Initial Funds, the ‘‘Funds’’) to be
offered using domestic equity securities
indices different than those permitted
under the Prior Order and certain
international equity securities indices
and debt securities indices (collectively,
‘‘New Underlying Indices’’).
Filing Dates: The application was
filed on May 11, 2007, and amended on
May 30, 2007, September 7, 2007 and
September 20, 2007.
Hearing or Notification of Hearing: An
order granting the requested relief 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 October 16, 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.
Secretary, Securities and
Exchange Commission, 100 F Street,
NE., Washington, DC 20549–1090.
Applicants: ProShares Trust and
ProShare Advisors LLC, 7501 Wisconsin
Avenue, Suite 1000, Bethesda, MD
20814; SEI Investments Distribution
Company, One Freedom Valley Drive,
Oaks, PA 19456.
ADDRESSES:
1 ProShares Trust, et al., Investment Company Act
Release Nos. 27323 (May 18, 2006) (notice) and
27394 (June 13, 2006) (order), as subsequently
amended by ProShares Trust, et al., Investment
Company Act Release Nos. 27609 (Dec. 22, 2006)
(notice) and 27666 (Jan. 18, 2007) (order).
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Agencies
[Federal Register Volume 72, Number 188 (Friday, September 28, 2007)]
[Notices]
[Pages 55255-55257]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E7-19148]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-27976; 812-13417]
WisdomTree Investments, Inc., et al.; Notice of Application
September 21, 2007.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application to amend a prior 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), 22(e), and 24(d) of the Act and rule
22c-1 under the Act, under sections 6(c) and 17(b) of the Act for an
exemption from sections 17(a)(1) and 17(a)(2) of the Act, and under
section 12(d)(1)(J) for an exemption from sections 12(d)(1)(A) and
12(d)(1)(B) of the Act.
-----------------------------------------------------------------------
Summary of Application: Applicants request an order (``Order'') to
amend a prior order that permits: (a) An open-end management investment
company, whose series track the performance of certain domestic and
international equity securities indexes developed by the parent company
of the series' investment adviser, to issue shares (``Shares'')
redeemable only in large aggregations; (b) secondary market
transactions in Shares to occur at negotiated prices; (c) dealers to
sell Shares to purchasers in the secondary market unaccompanied by a
prospectus when prospectus delivery is not required by the Securities
Act of 1933 (``Securities Act''); (d) certain affiliated persons of the
series to deposit securities into, and receive securities from, the
series in connection with the purchase and redemption of aggregations
of the series' Shares; (e) under certain circumstances, the series that
track certain foreign equity securities indexes to pay redemption
proceeds more than seven days after the tender of Shares; and (f)
certain management investment companies and unit investment trusts
outside of the same group of investment companies as the series to
acquire Shares (the ``Prior Order'').\1\ Applicants seek to amend the
Prior Order in order to offer additional series based on certain fixed
income securities indexes (the ``New Funds''). In addition, the Order
would delete a condition related to future relief in the Prior Order.
---------------------------------------------------------------------------
\1\ WisdomTree Investments, Inc., et al., Investment Company Act
Release Nos. 27324 (May 18, 2006) (notice) and 27391 (June 12, 2006)
(order).
Applicants: WisdomTree Investments, Inc. (``WTI''), WisdomTree Asset
Management, Inc. (the ``Advisor''), and WisdomTree Trust (the
---------------------------------------------------------------------------
``Trust'').
Filing Dates: The application was filed on August 13, 2007 and amended
on September 19, 2007.
Hearing or Notification of Hearing: An order granting the requested
relief 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 October 16, 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: 48 Wall Street,
Suite 1100, New York, NY 10005.
[[Page 55256]]
FOR FURTHER INFORMATION CONTACT: Courtney S. Thornton, Senior Counsel,
at (202) 551-6812, or Mary Kay Frech, Branch Chief, at (202) 551-6821
(Division of Investment Management, Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained for a fee at the
Commission's Public Reference Branch, 100 F Street, NE., Washington, DC
20549-0102 (tel. 202-551-5850).
Applicants' Representations
1. The Trust, a Delaware statutory trust registered under the Act
as an open-end management investment company, is organized as a series
fund with multiple series (the ``Equity Funds''). WTI, a Delaware
corporation with its principal offices in New York City, is the sole
shareholder of the Advisor. WTI has developed and maintains the
proprietary indexes that serve or will serve as the basis for the
Equity Funds and the New Funds. The Advisor is a Delaware corporation
that is registered as an investment adviser under the Investment
Advisers Act of 1940 (``Advisers Act''). The Advisor serves as
investment adviser to the Equity Funds, and the Advisor, or an entity
controlled by or under common control with the Advisor, will serve as
investment adviser to the New Funds and any future series of the Trust
(``Future Funds''). The Advisor and the Trust intend to hire one or
more subadvisers (``Subadvisers'') for the New Funds, each of which
will be registered as an investment adviser under the Advisers Act and
will not otherwise be an affiliated person, or an affiliated person of
an affiliated person, of the Trust, the Advisor, or WTI. ALPS
Distributors, Inc. (``Distributor''), a broker-dealer registered under
the Securities Exchange Act of 1934 (``Exchange Act''), acts as
distributor and principal underwriter of the Equity Funds and may
perform such services for the New Funds and any Future Funds.
2. The Trust is currently permitted to offer the Equity Funds,
which track equity securities indexes developed by WTI, in reliance on
the Prior Order. Applicants seek to amend the Prior Order to permit the
Trust to offer the New Funds, as well as Future Funds (together with
the Equity Funds and the New Funds, the ``Funds'') that are advised by
the Advisor or an entity controlled by or under common control with the
Advisor and that comply with the terms and conditions of the Prior
Order, as modified by the requested relief.
3. The investment objective of each New Fund will be to provide
investment results that correspond generally to the price and yield
performance of its underlying index (``Underlying Index'') by investing
in a portfolio of securities generally consisting of the component
securities (``Component Securities'') of the Underlying Index.\2\ The
Underlying Index for each New Fund tracks fixed income securities and
will be rebalanced monthly.\3\ The Underlying Indexes for the New
Funds, as well as the Underlying Indexes for the Equity Funds, have
been created by WTI, an affiliated person, as defined in section
2(a)(3) of the Act, of the Advisor and the Trust. Future Funds may be
based on Underlying Indexes created, compiled, sponsored, or maintained
by WTI or another index provider that is controlled by or under common
control with WTI (a ``WTI Index Provider'') or on Underlying Indexes
created, compiled, sponsored, or maintained by an entity that is not an
affiliated person, or an affiliated person of an affiliated person, of
the Fund, the Advisor, the Distributor, promoter, or any Subadviser to
a Fund (a ``Non-Affiliated Index Provider''). Because Funds based on
Underlying Indexes created by a WTI Index Provider could introduce
potential conflicts of interest, the Prior Order contains certain
representations and undertakings relating to the transparency of the
methodology for those Underlying Indexes, and the establishment of
certain policies and procedures to limit communication between index
personnel and employees of the Advisor and any Subadviser. Applicants
believe that these conflicts of interest do not exist where the index
creator is a Non-Affiliated Index Provider. Applicants therefore seek
to amend the Prior Order to provide that the relevant representations
and undertakings in the application for the Prior Order should not
apply to a Fund based on an Underlying Index created by a Non-
Affiliated Index Provider.
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\2\ The Underlying Indexes for the New Funds are the WisdomTree
International Government ex Japan Bond Index and the WisdomTree
Government Strategies Index.
\3\ The application for the Prior Order specified that
Underlying Indexes created, compiled, sponsored, or maintained by a
WTI Index Provider (as defined below) would be reconstituted no more
frequently than quarterly. Applicants seek to amend the Prior Order
to allow such Underlying Indexes to be reconstituted as frequently
as monthly, which applicants indicate is a common methodology for
fixed income indexes.
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4. The applicants state that the Component Securities of the
WisdomTree International Government ex Japan Bond Index include liquid
investment grade government bonds denominated in developed market
currencies other than the U.S. dollar and the Japanese yen, with a
primary focus on fixed-rate coupon bonds in developed markets maturing
between 3 and 10 years, and exclude securities with embedded options,
floating-rate coupons, and zero coupons. The Component Securities of
the WisdomTree Government Strategies Index include U.S. Treasury
securities, obligations of U.S. government agencies and quasi-
government corporations, and U.S. mortgage-backed securities.\4\ Each
New Fund may fully replicate its Underlying Index, but each New Fund
currently intends to use a ``representative sampling'' strategy. Under
a representative sampling strategy, a New Fund will hold a basket of
the Component Securities of its Underlying Index, but may not hold all
of the Component Securities of its Underlying Index. Each New Fund
generally will invest at least 80% of its total assets in the Component
Securities of the relevant Underlying Index. However, a New Fund may
also at times invest up to 20 percent of its total assets in certain
futures, options and swap contracts, and cash and cash equivalents,
including money market funds, as well as securities not included in its
Underlying Index, but which the Advisor believes will help the New Fund
to track its Underlying Index. At all times, a New Fund and any Future
Fund will hold in the aggregate at least 80% of its total assets in
Component Securities and investments that have economic characteristics
that are substantially identical to the economic characteristics of the
Component Securities of its Underlying Index.\5\ Applicants expect that
each New Fund will have a tracking error relative to the performance of
its respective
[[Page 55257]]
Underlying Index of no more than 5 percent.
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\4\ The Trust intends to substitute a cash-in-lieu amount to
replace any Deposit Security or Fund Security (each as defined
below) that is a ``to-be-announced transaction'' or ``TBA
Transaction.'' A TBA Transaction is a method of trading mortgage-
backed securities where the buyer and seller agree upon general
trade parameters such as agency, settlement date, par amount, and
price. The actual pools delivered are determined two days prior to
settlement date. The amount of substituted cash in the case of TBA
Transactions will be equivalent to the value of the TBA Transaction
listed as a Deposit Security or Fund Security.
\5\ Applicants anticipate that investments that have economic
characteristics substantially identical to those of the Component
Securities of an Underlying Index will encompass securities such as
depository receipts based on Component Securities and TBA
Transactions.
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5. Applicants state that the New Funds will comply with the federal
securities laws in accepting a deposit of a portfolio of securities
designated by the Advisor to correspond generally to the price and
yield performance of the New Fund's Underlying Index (``Deposit
Securities'') and satisfying redemptions with portfolio securities of
the New Funds (``Fund Securities''), including that the Deposit
Securities and Fund Securities are sold in transactions that would be
exempt from registration under the Securities Act.\6\
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\6\ In accepting Deposit Securities and satisfying redemptions
with Fund Securities that are restricted securities eligible for
resale pursuant to rule 144A under the Securities Act, the New Funds
will comply with the conditions of rule 144A, including in
satisfying redemptions with such rule 144A eligible restricted Fund
Securities. The prospectus for each New Fund will also state that an
authorized participant that is not a ``Qualified Institutional
Buyer,'' as defined in rule 144A under the Securities Act, will not
be able to receive, as part of a redemption, restricted securities
eligible for resale under rule 144A.
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6. Applicants state that the New Funds will operate in a manner
identical to the operation of the Equity Funds under the Prior Order,
except as specifically noted by applicants (and summarized in this
notice), and will comply with all of the terms, provisions and
conditions of the Prior Order, as amended by the present application.
Applicants believe that the requested relief continues to meet the
necessary exemptive standards.
Future Relief
7. Applicants also seek to amend the Prior Order to modify the
terms under which the Trust may offer Future Funds. The Prior Order is
currently subject to a condition that does not permit applicants to
register the shares of any Future Fund by means of filing a post-
effective amendment to the Trust's registration statement or by any
other means, unless applicants have requested and received with respect
to such Future Fund, either exemptive relief from the Commission or a
no-action letter from the Division of Investment Management of the
Commission, or if the Future Fund could be listed on a national
securities exchange (``Exchange'') without the need for a filing
pursuant to rule 19b-4 under the Exchange Act.
8. The order would amend the Prior Order to delete this condition.
Any Future Fund will (a) be advised by the Advisor or an entity
controlled by or under common control with the Advisor; (b) track
Underlying Indexes that are created, compiled, sponsored or maintained
by a WTI Index Provider or a Non-Affiliated Index Provider; and (c)
comply with the respective terms and conditions of the Prior Order, as
amended by the present application.
9. Applicants believe that the modification of the future relief
available under the Prior Order would be consistent with sections 6(c)
and 17(b) of the Act and that granting the requested relief will
facilitate the timely creation of Future Funds and the commencement of
secondary market trading of such Future Funds by removing the need to
seek additional exemptive relief. Applicants submit that the terms and
conditions of the Prior Order have been appropriate for the existing
series of the Trust and would remain appropriate for Future Funds.
Applicants also submit that tying exemptive relief under the Act to the
ability of a Future Fund to be listed on an Exchange without the need
for a rule 19b-4 filing under the Exchange Act is not necessary to meet
the standards under sections 6(c) and 17(b) of the Act.
Applicants' Conditions
Applicants agree that any Order granting the requested relief will
be subject to the same conditions as those imposed by the Prior Order,
except for condition 1 to the Prior Order, which will be deleted.
For the Commission, by the Division of Investment Management,
pursuant to delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E7-19148 Filed 9-27-07; 8:45 am]
BILLING CODE 8010-01-P