Kohlberg Capital Corporation; Notice of Application, 11164-11167 [E8-3845]
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Federal Register / Vol. 73, No. 41 / Friday, February 29, 2008 / Notices
eliminate from duty-free treatment
under the GSP program those carpets
found to be made with the worst forms
of child labor.
For further information, please refer
to the USTR FR Doc. E8–905, page
3495–3496, Federal Register Notice,
dated January 18, 2008, Vol. 73 FR 3485:
Notice Regarding the Initiation of Child
Labor Review in the Production of
Certain GSP-Eligible Hand-Loomed or
Hand-Hooked Carpets., No. 13/Friday,
January 18, 2008.
Opportunities for Public Comment
and Inspection of Comments: The GSP
Subcommittee of the TPSC invites
comments for this review. Submissions
should comply with 15 CFR Part 2007,
except as modified below. All
submissions should identify the subject
article(s) in terms of the country and the
eight-digit Harmonized Tariff Schedule
of the United States subheading
number. The deadline for submission of
comments is extended until March 14,
2008.
Requirements for Submissions: In
order to facilitate prompt processing of
submissions, USTR requires electronic
e-mail submissions in response to this
notice. Hand-delivered submissions will
not be accepted. These submissions
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E-mail submissions should use the
following subject line: ‘‘Child Labor
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GSP-Eligible Hand-loomed or Handhooked Carpet Lines’’ followed by the
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must also be submitted that indicates
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confidential submission must be clearly
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marked ‘‘BUSINESS CONFIDENTIAL’’
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Public versions of all documents
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Marideth J. Sandler,
Executive Director, Generalized System of
Preferences, Office of the U.S. Trade
Representative.
[FR Doc. E8–3925 Filed 2–28–08; 8:45 am]
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SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
28168; 812–13367]
Kohlberg Capital Corporation; Notice
of Application
February 25, 2008.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 6(c) of the
Investment Company Act of 1940 (the
‘‘Act’’) for an exemption from sections
23(a), 23(b) and 63 of the Act, and under
sections 57(a)(4) and 57(i) of the Act and
rule 17d–1 under the Act permitting
certain joint transactions otherwise
prohibited by section 57(a)(4) of the Act.
AGENCY:
Summary of the Application: Applicant,
Kohlberg Capital Corporation
(‘‘Kohlberg Capital’’) requests an order
to permit it to issue restricted shares of
its common stock to its officers and
employees under the terms of its equity
incentive plan.
Filing Dates: The application was filed
on February 27, 2007, and amended on
February 13, 2008 and February 22,
2008. Applicants have agreed to file an
amendment during the notice period,
the substance of which is reflected in
this notice.
Hearing or Notification of Hearing: An
order granting the application will be
issued unless the Commission orders a
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
applicant with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on March 21, 2008, and
should be accompanied by proof of
service on applicant, 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. Applicant, 295 Madison Avenue,
6th Floor, New York, NY 10017.
FOR FURTHER INFORMATION CONTACT:
Bruce R. MacNeil, Senior Counsel, at
(202) 551–6817, or Julia Kim Gilmer,
Branch Chief, at (202) 551–6821,
(Division of Investment Management,
Office of Investment Company
Regulation).
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The
following is a summary of the
application. The complete application
may be obtained for a fee at the
Commission’s Public Reference Desk,
100 F Street, NE., Washington, DC
20549–1520 (tel. 202–551–5850).
SUPPLEMENTARY INFORMATION:
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Applicant’s Representations
1. Kohlberg Capital, a Delaware
corporation, is an internally managed,
non-diversified, closed-end investment
company that has elected to be
regulated as a business development
company (‘‘BDC’’) under the Act.1
Kohlberg Capital provides debt and
equity growth capital to privately-held
middle market companies and its
investment objective is to generate
current income and capital appreciation
from the investments made by those
companies in senior secured term loans,
mezzanine debt and selected equity
investments. Kohlberg Capital may also
invest in loans to larger, publicly traded
companies, high-yield bonds, distressed
debt securities and debt and equity
securities issued by collateralized debt
obligation funds. Shares of Kohlberg
Capital’s common stock are traded on
the NASDAQ Global Select Market
under the symbol ‘‘KCAP.’’ As of
September 30, 2007, there were 17,
997,611 shares of Kohlberg Capital’s
common stock outstanding. As of that
date, Kohlberg Capital had 26
employees, including the employees of
its wholly-owned consolidated
subsidiaries.2
2. Kohlberg Capital currently has a
seven-member board of directors (the
‘‘Board’’) of whom three are ‘‘interested
persons’’ of Kohlberg Capital within the
meaning of section 2(a)(19) of the Act
and four are not interested persons (the
‘‘non-interested directors’’). The four
non-interested directors are neither
employees nor officers of Kohlberg
Capital (‘‘Non-employee Directors’’).
Currently, Kohlberg Capital’s Nonemployee Directors are all noninterested Directors, but it is possible
that Kohlberg Capital may have Nonemployee Directors in the future who
1 Kohlberg Capital was organized on August 8,
2006. On December 4, 2006, Kohlberg Capital filed
with the Commission its registration statement on
Form N–2 under the Securities Act of 1933, as
amended, in connection with its initial public
offering of common stock (the ‘‘IPO’’). On December
5, 2006, Kohlberg Capital elected to be regulated as
a BDC. Section 2(a)(48) defines a BDC to be any
closed-end investment company that operates for
the purpose of making investments in securities
described in sections 55(a)(1) through 55(a)(3) of the
Act and makes available significant managerial
assistance with respect to the issuers of such
securities. Kohlberg Capital completed its IPO on
December 15, 2006.
2 Kohlberg Capital does not currently have any
wholly-owned consolidated subsidiaries.
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are interested persons of Kohlberg
Capital.
3. Kohlberg Capital believes that its
successful operation depends on its
ability to offer compensation packages
to its professionals that are competitive
with those offered by its competitors.
Kohlberg Capital believes its ability to
adopt a compensation plan providing
for the periodic issuance of shares of
restricted stock (i.e., stock that, at the
time of issuance, is subject to certain
forfeiture restrictions, and thus is
restricted as to its transferability until
such forfeiture restrictions have lapsed)
(the ‘‘Restricted Stock’’) is vital to its
future growth and success. Kohlberg
Capital wishes to adopt an equity-based
compensation plan (the ‘‘Plan’’) for its
officers and employees (‘‘Employees’’),
as well as employees of its wholly
owned consolidated subsidiaries
(together with the Employees, the
‘‘Participants’’).
4. The Plan will authorize the
issuance of shares of Restricted Stock
subject to certain forfeiture restrictions.
These restrictions may relate to
continued employment, the
performance of Kohlberg Capital, or
other restrictions deemed by the Board
to be appropriate. The Restricted Stock
will be subject to restrictions on
transferability and other restrictions as
required by the Board. Except to the
extent restricted under the terms of the
Plan, a Participant granted Restricted
Stock will have all the rights of any
other shareholder, including the right to
vote the Restricted Stock and the right
to receive dividends. During the
restriction period, the Restricted Stock
generally may not be sold, transferred,
pledged, hypothecated, margined, or
otherwise encumbered by the
Participant. Except as the Board
otherwise determines, upon termination
of a Participant’s employment during
the applicable restriction period,
Restricted Stock for which forfeiture
restrictions have not lapsed at the time
of such termination shall be forfeited.
5. The maximum amount of Restricted
Stock that may be issued under the Plan
will be 10% of the outstanding shares of
Kohlberg Capital’s common stock on the
effective date of the Plan plus 10% of
the outstanding shares of Kohlberg
Capital’s common stock issued or
delivered by Kohlberg Capital (other
than pursuant to compensation plans)
during the term of the Plan.3 The Plan
limits the total number of shares that
3 For purposes of calculating compliance with
this limit, Kohlberg Capital will count as Restricted
Stock all shares of its common stock that are issued
pursuant to the Plan less any shares that are
forfeited back to Kohlberg Capital and cancelled as
a result of forfeiture restrictions not lapsing.
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may be awarded to any single
Participant in a single year to 500,000
shares. In addition, no Restricted Stock
Participant may be granted more than
25% of the shares reserved for issuance
under the Plan. The Plan will be
administered by the Board, which will
award shares of Restricted Stock to the
Participants from time to time as part of
the Participants’ compensation based on
a Participant’s actual or expected
performance and value to Kohlberg
Capital.
6. Each issuance of Restricted Stock
under the Plan will be approved by the
required majority, as defined in section
57(o) of the Act,4 of Kohlberg Capital’s
directors on the basis that the issuance
is in the best interests of Kohlberg
Capital and its shareholders. The date
on which the required majority
approves an issuance of Restricted Stock
will be deemed the date on which the
subject Restricted Stock is granted.
7. The Plan was approved by the
Board on February 5, 2008, including by
a majority of the non-interested
directors and the required majority as
defined in section 57(o) of the Act. The
Plan will be submitted for approval to
Kohlberg Capital’s shareholders, and
will become effective upon such
approval, subject to and following
receipt of the order.
Applicant’s Legal Analysis
Sections 23(a) and (b), Section 63
1. Under section 63 of the Act, the
provisions of section 23(a) of the Act
generally prohibiting a registered
closed-end investment company from
issuing securities for services or for
property other than cash or securities
are made applicable to BDCs. This
provision would prohibit the issuance
of Restricted Stock as a part of the Plan.
2. Section 23(b) generally prohibits a
closed-end management investment
company from selling its common stock
at a price below its current net asset
value (‘‘NAV’’). Section 63(2) makes
section 23(b) applicable to BDCs unless
certain conditions are met. Because
Restricted Stock that would be granted
under the Plan would not meet the
terms of section 63(2), sections 23(b)
and 63 prohibit the issuance of the
Restricted Stock.
3. Section 6(c) provides that the
Commission may, by order upon
application, conditionally or
4 The term ‘‘required majority,’’ when used with
respect to the approval of a proposed transaction,
plan, or arrangement, means both a majority of a
BDC’s directors or general partners who have no
financial interest in such transaction, plan, or
arrangement and a majority of such directors or
general partners who are not interested persons of
such company.
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unconditionally exempt any person,
security, or transaction, or any class or
classes of persons, securities or
transactions, from any provision of the
Act, if and to the extent that the
exemption is necessary or appropriate
in the public interest and consistent
with the protection of investors and the
purposes fairly intended by the policy
and provisions of the Act.
4. Kohlberg Capital requests an order
pursuant to section 6(c) of the Act
granting an exemption from the
provisions of sections 23(a) and (b) and
section 63 of the Act. Kohlberg Capital
states that the concerns underlying
those sections include: (a) Preferential
treatment of investment company
insiders and the use of options and
other rights by insiders to obtain control
of the investment company; (b)
complication of the investment
company’s structure that makes it
difficult to determine the value of the
company’s shares; and (c) dilution of
shareholders’ equity in the investment
company. Kohlberg Capital states that
the Plan does not raise the concern
about preferential treatment of Kohlberg
Capital’s insiders because the Plan is
bona fide compensation plan of the type
that is common among corporations
generally. In addition, section
61(a)(3)(B) of the Act permits a BDC to
issue to its officers, directors and
employees, pursuant to an executive
compensation plan, warrants, options
and rights to purchase the BDC’s voting
securities, subject to certain
requirements. Kohlberg Capital states
that, for reasons that are unclear, section
61 and its legislative history do not
address the issuance by a BDC of
restricted stock as incentive
compensation. Kohlberg Capital states,
however, that the issuance of Restricted
Stock is substantially similar, for
purposes of investor protection under
the Act, to the issuance of warrants,
options, and rights as contemplated by
section 61. Kohlberg Capital also asserts
that the Plan would not become a means
for insiders to obtain control of
Kohlberg Capital because the number of
shares of Kohlberg Capital issuable
under the Plan would be limited as set
forth in the application. Moreover, no
individual Restricted Stock Participant
could be issued more than 25% of the
shares reserved for issuance under the
Plan.
5. Kohlberg Capital further states that
the Plan will not unduly complicate
Kohlberg Capital’s capital structure
because equity-based compensation
arrangements are widely used among
corporations and commonly known to
investors. Kohlberg Capital notes that
the Plan will be submitted to its
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shareholders for their approval.
Kohlberg Capital represents that a
concise, ‘‘plain English’’ description of
the Plan, including its potential dilutive
effect, will be provided in the proxy
materials that will be submitted to
Kohlberg Capital’s shareholders.
Kohlberg Capital also states that it will
comply with the proxy disclosure
requirements in Item 10 of Schedule
14A under the Securities Exchange Act
of 1934 (the ‘‘Exchange Act’’). Kohlberg
Capital further notes that the Plan will
be disclosed to investors in accordance
with the requirements of the Form N–
2 registration statement for closed-end
investment companies, and pursuant to
the standards and guidelines adopted by
the Financial Accounting Standards
Board for operating companies. In
addition, Kohlberg Capital will comply
with the disclosure requirements for
executive compensation plans
applicable to operating companies
under the Exchange Act.5 Kohlberg
Capital thus concludes that the Plan
will be adequately disclosed to investors
and appropriately reflected in the
market value of Kohlberg Capital’s
shares.
6. Kohlberg Capital acknowledges
that, while awards granted under the
Plan would have a dilutive effect on the
shareholders’ equity in Kohlberg
Capital, that effect would be outweighed
by the anticipated benefits of the Plan
to Kohlberg Capital and its
shareholders. Kohlberg Capital asserts
that it needs the flexibility to provide
the requested equity-based employee
compensation in order to be able to
compete effectively with other financial
services firms for talented professionals.
These professionals, Kohlberg Capital
suggests, in turn are likely to increase
Kohlberg Capital’s performance and
shareholder value. Kohlberg Capital also
asserts that equity-based compensation
would more closely align the interests of
Kohlberg Capital’s Employees with
those of its shareholders. In addition,
Kohlberg Capital states that its
shareholders will be further protected
by the conditions to the requested order
that assure continuing oversight of the
5 Kohlberg Capital will comply with the
amendments to the disclosure requirements for
executive and director compensation, related party
transactions, director independence and other
corporate governance matters, and security
ownership of officers and directors to the extent
adopted and applicable to BDCs. See Executive
Compensation and Related Party Disclosure,
Securities Act Release No. 8655 (Jan. 27, 2006)
(proposed rule); Executive Compensation and
Related Party Disclosure, Securities Act Release No.
8732A (Aug. 29, 2006) (final rule and proposed
rule), as amended by Executive Compensation
Disclosure, Securities Act Release No. 8765 (Dec.
22, 2006) (adopted as interim final rules with
request for comments).
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operation of the Plan by Kohlberg
Capital’s Board.
Section 57(a)(4), Rule 17d–1
7. Section 57(a) proscribes certain
transactions between a BDC and persons
related to the BDC in the manner
described in section 57(b) (‘‘57(b)
persons’’), absent a Commission order.
Section 57(a)(4) generally prohibits a
57(b) person from effecting a transaction
in which the BDC is a joint participant
absent such an order. Rule 17d–1, made
applicable to BDCs by section 57(i),
proscribes participation in a ‘‘joint
enterprise or other joint arrangement or
profit-sharing plan,’’ which includes a
stock option or purchase plan.
Employees and directors of a BDC are
57(b) persons. Thus, the issuance of
shares of Restricted Stock could be
deemed to involve a joint transaction
involving a BDC and a 57(b) person in
contravention of section 57(a)(4). Rule
17d–1(b) provides that, in considering
relief pursuant to the rule, the
Commission will consider (i) whether
the participation of the company in a
joint enterprise is consistent with the
Act’s policies and purposes and (ii) the
extent to which that participation is on
a basis different from or less
advantageous than that of other
participants.
8. Kohlberg Capital requests an order
pursuant to section 57(a)(4) and rule
17d–1 to permit the Plan. Kohlberg
Capital states that the Plan, although
benefiting the Participants and Kohlberg
Capital in different ways, are in the
interests of Kohlberg Capital’s
shareholders because the Plan will help
Kohlberg Capital attract and retain
talented professionals, help align the
interests of Kohlberg Capital’s
employees with those of its
shareholders, and in turn help produce
a better return to Kohlberg Capital’s
shareholders.
Applicant’s Conditions
Applicant agrees that the order
granting the requested relief will be
subject to the following conditions:
1. The Plan will be authorized by
Kohlberg Capital’s shareholders.
2. Each issuance of Restricted Stock to
an Employee will be approved by the
required majority, as defined in section
57(o) of the Act, of Kohlberg Capital’s
directors on the basis that such issuance
is in the best interest of Kohlberg
Capital and its shareholders.
3. The amount of voting securities
that would result from the exercise of all
of Kohlberg Capital’s outstanding
warrants, options, and rights, together
with any Restricted Stock issued
pursuant to the Plan at the time of
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issuance shall not exceed 25% of the
outstanding voting securities of
Kohlberg Capital, except that if the
amount of voting securities that would
result from the exercise of all of
Kohlberg Capital’s outstanding
warrants, options, and rights issued to
Kohlberg Capital’s directors, officers,
and employees, together with any
Restricted Stock issued pursuant to the
Plan, would exceed 15% of the
outstanding voting securities of
Kohlberg Capital, then the total amount
of voting securities that would result
from the exercise of all outstanding
warrants, options, and rights, together
with any Restricted Stock issued
pursuant to the Plan, at the time of
issuance shall not exceed 20% of the
outstanding voting securities of
Kohlberg Capital.
4. The maximum amount of shares of
Restricted Stock that may be issued
under the Plan will be 10% of the
outstanding shares of common stock of
Kohlberg Capital on the effective date of
the Plan plus 10% of the number of
shares of Kohlberg Capital’s common
stock issued or delivered by Kohlberg
Capital (other than pursuant to
compensation plans) during the term of
the Plan.
5. The Board will review the Plan at
least annually. In addition, the Board
will review periodically the potential
impact that the issuance of Restricted
Stock under the Plan could have on
Kohlberg Capital’s earnings and NAV
per share, such review to take place
prior to any decisions to grant Restricted
Stock under the Plan, but in no event
less frequently than annually. Adequate
procedures and records will be
maintained to permit such review. The
Board will be authorized to take
appropriate steps to ensure that the
grant of Restricted Stock under the Plan
would not have an effect contrary to the
interests of Kohlberg Capital’s
shareholders. This authority will
include the authority to prevent or limit
the granting of additional Restricted
Stock under the Plan. All records
maintained pursuant to this condition
will be subject to examination by the
Commission and its staff.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E8–3845 Filed 2–28–08; 8:45 am]
19:22 Feb 28, 2008
[Release No. 34–57375; File No. SR–ISE–
2008–14]
Self-Regulatory Organizations;
International Securities Exchange,
LLC; Notice of Filing and Immediate
Effectiveness of Proposed Rule
Change Relating to Solicitation of
Interest Orders
February 22, 2008.
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 February
19, 2008, the International Securities
Exchange, LLC (‘‘ISE’’ 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 prepared substantially by ISE. ISE
filed the proposed rule change pursuant
to Section 19(b)(3)(A) of the Act 3 and
Rule 19b–4(f)(6) thereunder,4 which
renders it effective upon filing with the
Commission. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The ISE is proposing to amend the
parameters governing Solicitation of
Interest orders (‘‘SOIs’’). The text of the
proposed rule change is available on the
Exchange’s Web site (https://
www.ise.com), at the Exchange, 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, ISE
included statements concerning the
purpose of and basis for the proposed
rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item IV below. ISE has prepared
summaries, set forth in Sections A, B,
and C below, of the most significant
aspects of such statements.
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A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The purpose of this filing is to amend
the parameters governing SOIs that are
entered into MidPoint Match (‘‘MPM’’).5
When an SOI order is entered, the
System sends Equity Electronic Access
Members (‘‘Equity EAMs’’) a solicitation
notice containing the name of the equity
security for which the order was
entered. Currently, an SOI order must be
at least 2,000 shares and cannot be
canceled or changed for five seconds.
An immediate-or-cancel (‘‘IOC’’) SOI
that is not executed within the five
second no-cancellation period is
automatically canceled.6
The Exchange proposes to reduce the
no cancellation parameter to one
second. The no cancellation parameter,
currently set at five seconds, requires
that Equity EAMs using SOIs relinquish
the right to cancel or change an SOI
order for five seconds. In the current
market environment, many potential
SOI users are reluctant to commit to a
time period of that duration. Instead,
Equity EAMs prefer a one second
timeout, enabling them to cancel or
revise the order in a timeframe that is
more consistent with algorithmic
trading patterns. Accordingly, an IOC
SOI will also time out in one second.
Additionally, the Exchange proposes
to reduce the minimum order size to
500 shares. The current minimum order
size of 2,000 shares is larger than the
typical order size generated by
algorithms. The Exchange proposes to
revise the minimum order size to 500
shares, which is more consistent with
algorithmic trading patterns.
2. Statutory Basis
The basis under the Act for this
proposed rule change is found in
Section 6(b) of the Act.7 Specifically,
the Exchange believes the proposed rule
change is consistent with Section 6(b)(5)
of the Act 8 requirements that the rules
of an exchange be designed to promote
just and equitable principles of trade,
serve to remove impediments to and
perfect the mechanism for a free and
open market and a national market
system, and, in general, to protect
investors and the public interest. In
particular, this filing will provide
investors with more flexibility in
5 See
ISE Rule 2129 (MidPoint Match).
regular SOI is converted to a Standard Order
in MPM if it is not executed or canceled within 10
seconds; see ISE Rule 2129(d)(2).
7 15 U.S.C. 78f(b).
8 15 U.S.C. 78f(b)(5).
6A
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 15 U.S.C. 78s(b)(3)(A).
4 17 CFR 240.19b–4(f)(6).
2 17
BILLING CODE 8011–01–P
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SECURITIES AND EXCHANGE
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[Federal Register Volume 73, Number 41 (Friday, February 29, 2008)]
[Notices]
[Pages 11164-11167]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-3845]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 28168; 812-13367]
Kohlberg Capital Corporation; Notice of Application
February 25, 2008.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under section 6(c) of the
Investment Company Act of 1940 (the ``Act'') for an exemption from
sections 23(a), 23(b) and 63 of the Act, and under sections 57(a)(4)
and 57(i) of the Act and rule 17d-1 under the Act permitting certain
joint transactions otherwise prohibited by section 57(a)(4) of the Act.
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Summary of the Application: Applicant, Kohlberg Capital Corporation
(``Kohlberg Capital'') requests an order to permit it to issue
restricted shares of its common stock to its officers and employees
under the terms of its equity incentive plan.
Filing Dates: The application was filed on February 27, 2007, and
amended on February 13, 2008 and February 22, 2008. Applicants have
agreed to file an amendment during the notice period, the substance of
which is reflected in this notice.
Hearing or Notification of Hearing: An order granting the application
will be issued unless the Commission orders a hearing. Interested
persons may request a hearing by writing to the Commission's Secretary
and serving applicant with a copy of the request, personally or by
mail. Hearing requests should be received by the Commission by 5:30
p.m. on March 21, 2008, and should be accompanied by proof of service
on applicant, 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. Applicant, 295 Madison Avenue,
6th Floor, New York, NY 10017.
FOR FURTHER INFORMATION CONTACT: Bruce R. MacNeil, Senior Counsel, at
(202) 551-6817, or Julia Kim Gilmer, Branch Chief, at (202) 551-6821,
(Division of Investment Management, Office of Investment Company
Regulation).
[[Page 11165]]
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained for a fee at the
Commission's Public Reference Desk, 100 F Street, NE., Washington, DC
20549-1520 (tel. 202-551-5850).
Applicant's Representations
1. Kohlberg Capital, a Delaware corporation, is an internally
managed, non-diversified, closed-end investment company that has
elected to be regulated as a business development company (``BDC'')
under the Act.\1\ Kohlberg Capital provides debt and equity growth
capital to privately-held middle market companies and its investment
objective is to generate current income and capital appreciation from
the investments made by those companies in senior secured term loans,
mezzanine debt and selected equity investments. Kohlberg Capital may
also invest in loans to larger, publicly traded companies, high-yield
bonds, distressed debt securities and debt and equity securities issued
by collateralized debt obligation funds. Shares of Kohlberg Capital's
common stock are traded on the NASDAQ Global Select Market under the
symbol ``KCAP.'' As of September 30, 2007, there were 17, 997,611
shares of Kohlberg Capital's common stock outstanding. As of that date,
Kohlberg Capital had 26 employees, including the employees of its
wholly-owned consolidated subsidiaries.\2\
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\1\ Kohlberg Capital was organized on August 8, 2006. On
December 4, 2006, Kohlberg Capital filed with the Commission its
registration statement on Form N-2 under the Securities Act of 1933,
as amended, in connection with its initial public offering of common
stock (the ``IPO''). On December 5, 2006, Kohlberg Capital elected
to be regulated as a BDC. Section 2(a)(48) defines a BDC to be any
closed-end investment company that operates for the purpose of
making investments in securities described in sections 55(a)(1)
through 55(a)(3) of the Act and makes available significant
managerial assistance with respect to the issuers of such
securities. Kohlberg Capital completed its IPO on December 15, 2006.
\2\ Kohlberg Capital does not currently have any wholly-owned
consolidated subsidiaries.
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2. Kohlberg Capital currently has a seven-member board of directors
(the ``Board'') of whom three are ``interested persons'' of Kohlberg
Capital within the meaning of section 2(a)(19) of the Act and four are
not interested persons (the ``non-interested directors''). The four
non-interested directors are neither employees nor officers of Kohlberg
Capital (``Non-employee Directors''). Currently, Kohlberg Capital's
Non-employee Directors are all non-interested Directors, but it is
possible that Kohlberg Capital may have Non-employee Directors in the
future who are interested persons of Kohlberg Capital.
3. Kohlberg Capital believes that its successful operation depends
on its ability to offer compensation packages to its professionals that
are competitive with those offered by its competitors. Kohlberg Capital
believes its ability to adopt a compensation plan providing for the
periodic issuance of shares of restricted stock (i.e., stock that, at
the time of issuance, is subject to certain forfeiture restrictions,
and thus is restricted as to its transferability until such forfeiture
restrictions have lapsed) (the ``Restricted Stock'') is vital to its
future growth and success. Kohlberg Capital wishes to adopt an equity-
based compensation plan (the ``Plan'') for its officers and employees
(``Employees''), as well as employees of its wholly owned consolidated
subsidiaries (together with the Employees, the ``Participants'').
4. The Plan will authorize the issuance of shares of Restricted
Stock subject to certain forfeiture restrictions. These restrictions
may relate to continued employment, the performance of Kohlberg
Capital, or other restrictions deemed by the Board to be appropriate.
The Restricted Stock will be subject to restrictions on transferability
and other restrictions as required by the Board. Except to the extent
restricted under the terms of the Plan, a Participant granted
Restricted Stock will have all the rights of any other shareholder,
including the right to vote the Restricted Stock and the right to
receive dividends. During the restriction period, the Restricted Stock
generally may not be sold, transferred, pledged, hypothecated,
margined, or otherwise encumbered by the Participant. Except as the
Board otherwise determines, upon termination of a Participant's
employment during the applicable restriction period, Restricted Stock
for which forfeiture restrictions have not lapsed at the time of such
termination shall be forfeited.
5. The maximum amount of Restricted Stock that may be issued under
the Plan will be 10% of the outstanding shares of Kohlberg Capital's
common stock on the effective date of the Plan plus 10% of the
outstanding shares of Kohlberg Capital's common stock issued or
delivered by Kohlberg Capital (other than pursuant to compensation
plans) during the term of the Plan.\3\ The Plan limits the total number
of shares that may be awarded to any single Participant in a single
year to 500,000 shares. In addition, no Restricted Stock Participant
may be granted more than 25% of the shares reserved for issuance under
the Plan. The Plan will be administered by the Board, which will award
shares of Restricted Stock to the Participants from time to time as
part of the Participants' compensation based on a Participant's actual
or expected performance and value to Kohlberg Capital.
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\3\ For purposes of calculating compliance with this limit,
Kohlberg Capital will count as Restricted Stock all shares of its
common stock that are issued pursuant to the Plan less any shares
that are forfeited back to Kohlberg Capital and cancelled as a
result of forfeiture restrictions not lapsing.
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6. Each issuance of Restricted Stock under the Plan will be
approved by the required majority, as defined in section 57(o) of the
Act,\4\ of Kohlberg Capital's directors on the basis that the issuance
is in the best interests of Kohlberg Capital and its shareholders. The
date on which the required majority approves an issuance of Restricted
Stock will be deemed the date on which the subject Restricted Stock is
granted.
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\4\ The term ``required majority,'' when used with respect to
the approval of a proposed transaction, plan, or arrangement, means
both a majority of a BDC's directors or general partners who have no
financial interest in such transaction, plan, or arrangement and a
majority of such directors or general partners who are not
interested persons of such company.
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7. The Plan was approved by the Board on February 5, 2008,
including by a majority of the non-interested directors and the
required majority as defined in section 57(o) of the Act. The Plan will
be submitted for approval to Kohlberg Capital's shareholders, and will
become effective upon such approval, subject to and following receipt
of the order.
Applicant's Legal Analysis
Sections 23(a) and (b), Section 63
1. Under section 63 of the Act, the provisions of section 23(a) of
the Act generally prohibiting a registered closed-end investment
company from issuing securities for services or for property other than
cash or securities are made applicable to BDCs. This provision would
prohibit the issuance of Restricted Stock as a part of the Plan.
2. Section 23(b) generally prohibits a closed-end management
investment company from selling its common stock at a price below its
current net asset value (``NAV''). Section 63(2) makes section 23(b)
applicable to BDCs unless certain conditions are met. Because
Restricted Stock that would be granted under the Plan would not meet
the terms of section 63(2), sections 23(b) and 63 prohibit the issuance
of the Restricted Stock.
3. Section 6(c) provides that the Commission may, by order upon
application, conditionally or
[[Page 11166]]
unconditionally exempt any person, security, or transaction, or any
class or classes of persons, securities or transactions, from any
provision of the Act, if and to the extent that the exemption is
necessary or appropriate in the public interest and consistent with the
protection of investors and the purposes fairly intended by the policy
and provisions of the Act.
4. Kohlberg Capital requests an order pursuant to section 6(c) of
the Act granting an exemption from the provisions of sections 23(a) and
(b) and section 63 of the Act. Kohlberg Capital states that the
concerns underlying those sections include: (a) Preferential treatment
of investment company insiders and the use of options and other rights
by insiders to obtain control of the investment company; (b)
complication of the investment company's structure that makes it
difficult to determine the value of the company's shares; and (c)
dilution of shareholders' equity in the investment company. Kohlberg
Capital states that the Plan does not raise the concern about
preferential treatment of Kohlberg Capital's insiders because the Plan
is bona fide compensation plan of the type that is common among
corporations generally. In addition, section 61(a)(3)(B) of the Act
permits a BDC to issue to its officers, directors and employees,
pursuant to an executive compensation plan, warrants, options and
rights to purchase the BDC's voting securities, subject to certain
requirements. Kohlberg Capital states that, for reasons that are
unclear, section 61 and its legislative history do not address the
issuance by a BDC of restricted stock as incentive compensation.
Kohlberg Capital states, however, that the issuance of Restricted Stock
is substantially similar, for purposes of investor protection under the
Act, to the issuance of warrants, options, and rights as contemplated
by section 61. Kohlberg Capital also asserts that the Plan would not
become a means for insiders to obtain control of Kohlberg Capital
because the number of shares of Kohlberg Capital issuable under the
Plan would be limited as set forth in the application. Moreover, no
individual Restricted Stock Participant could be issued more than 25%
of the shares reserved for issuance under the Plan.
5. Kohlberg Capital further states that the Plan will not unduly
complicate Kohlberg Capital's capital structure because equity-based
compensation arrangements are widely used among corporations and
commonly known to investors. Kohlberg Capital notes that the Plan will
be submitted to its shareholders for their approval. Kohlberg Capital
represents that a concise, ``plain English'' description of the Plan,
including its potential dilutive effect, will be provided in the proxy
materials that will be submitted to Kohlberg Capital's shareholders.
Kohlberg Capital also states that it will comply with the proxy
disclosure requirements in Item 10 of Schedule 14A under the Securities
Exchange Act of 1934 (the ``Exchange Act''). Kohlberg Capital further
notes that the Plan will be disclosed to investors in accordance with
the requirements of the Form N-2 registration statement for closed-end
investment companies, and pursuant to the standards and guidelines
adopted by the Financial Accounting Standards Board for operating
companies. In addition, Kohlberg Capital will comply with the
disclosure requirements for executive compensation plans applicable to
operating companies under the Exchange Act.\5\ Kohlberg Capital thus
concludes that the Plan will be adequately disclosed to investors and
appropriately reflected in the market value of Kohlberg Capital's
shares.
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\5\ Kohlberg Capital will comply with the amendments to the
disclosure requirements for executive and director compensation,
related party transactions, director independence and other
corporate governance matters, and security ownership of officers and
directors to the extent adopted and applicable to BDCs. See
Executive Compensation and Related Party Disclosure, Securities Act
Release No. 8655 (Jan. 27, 2006) (proposed rule); Executive
Compensation and Related Party Disclosure, Securities Act Release
No. 8732A (Aug. 29, 2006) (final rule and proposed rule), as amended
by Executive Compensation Disclosure, Securities Act Release No.
8765 (Dec. 22, 2006) (adopted as interim final rules with request
for comments).
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6. Kohlberg Capital acknowledges that, while awards granted under
the Plan would have a dilutive effect on the shareholders' equity in
Kohlberg Capital, that effect would be outweighed by the anticipated
benefits of the Plan to Kohlberg Capital and its shareholders. Kohlberg
Capital asserts that it needs the flexibility to provide the requested
equity-based employee compensation in order to be able to compete
effectively with other financial services firms for talented
professionals. These professionals, Kohlberg Capital suggests, in turn
are likely to increase Kohlberg Capital's performance and shareholder
value. Kohlberg Capital also asserts that equity-based compensation
would more closely align the interests of Kohlberg Capital's Employees
with those of its shareholders. In addition, Kohlberg Capital states
that its shareholders will be further protected by the conditions to
the requested order that assure continuing oversight of the operation
of the Plan by Kohlberg Capital's Board.
Section 57(a)(4), Rule 17d-1
7. Section 57(a) proscribes certain transactions between a BDC and
persons related to the BDC in the manner described in section 57(b)
(``57(b) persons''), absent a Commission order. Section 57(a)(4)
generally prohibits a 57(b) person from effecting a transaction in
which the BDC is a joint participant absent such an order. Rule 17d-1,
made applicable to BDCs by section 57(i), proscribes participation in a
``joint enterprise or other joint arrangement or profit-sharing plan,''
which includes a stock option or purchase plan. Employees and directors
of a BDC are 57(b) persons. Thus, the issuance of shares of Restricted
Stock could be deemed to involve a joint transaction involving a BDC
and a 57(b) person in contravention of section 57(a)(4). Rule 17d-1(b)
provides that, in considering relief pursuant to the rule, the
Commission will consider (i) whether the participation of the company
in a joint enterprise is consistent with the Act's policies and
purposes and (ii) the extent to which that participation is on a basis
different from or less advantageous than that of other participants.
8. Kohlberg Capital requests an order pursuant to section 57(a)(4)
and rule 17d-1 to permit the Plan. Kohlberg Capital states that the
Plan, although benefiting the Participants and Kohlberg Capital in
different ways, are in the interests of Kohlberg Capital's shareholders
because the Plan will help Kohlberg Capital attract and retain talented
professionals, help align the interests of Kohlberg Capital's employees
with those of its shareholders, and in turn help produce a better
return to Kohlberg Capital's shareholders.
Applicant's Conditions
Applicant agrees that the order granting the requested relief will
be subject to the following conditions:
1. The Plan will be authorized by Kohlberg Capital's shareholders.
2. Each issuance of Restricted Stock to an Employee will be
approved by the required majority, as defined in section 57(o) of the
Act, of Kohlberg Capital's directors on the basis that such issuance is
in the best interest of Kohlberg Capital and its shareholders.
3. The amount of voting securities that would result from the
exercise of all of Kohlberg Capital's outstanding warrants, options,
and rights, together with any Restricted Stock issued pursuant to the
Plan at the time of
[[Page 11167]]
issuance shall not exceed 25% of the outstanding voting securities of
Kohlberg Capital, except that if the amount of voting securities that
would result from the exercise of all of Kohlberg Capital's outstanding
warrants, options, and rights issued to Kohlberg Capital's directors,
officers, and employees, together with any Restricted Stock issued
pursuant to the Plan, would exceed 15% of the outstanding voting
securities of Kohlberg Capital, then the total amount of voting
securities that would result from the exercise of all outstanding
warrants, options, and rights, together with any Restricted Stock
issued pursuant to the Plan, at the time of issuance shall not exceed
20% of the outstanding voting securities of Kohlberg Capital.
4. The maximum amount of shares of Restricted Stock that may be
issued under the Plan will be 10% of the outstanding shares of common
stock of Kohlberg Capital on the effective date of the Plan plus 10% of
the number of shares of Kohlberg Capital's common stock issued or
delivered by Kohlberg Capital (other than pursuant to compensation
plans) during the term of the Plan.
5. The Board will review the Plan at least annually. In addition,
the Board will review periodically the potential impact that the
issuance of Restricted Stock under the Plan could have on Kohlberg
Capital's earnings and NAV per share, such review to take place prior
to any decisions to grant Restricted Stock under the Plan, but in no
event less frequently than annually. Adequate procedures and records
will be maintained to permit such review. The Board will be authorized
to take appropriate steps to ensure that the grant of Restricted Stock
under the Plan would not have an effect contrary to the interests of
Kohlberg Capital's shareholders. This authority will include the
authority to prevent or limit the granting of additional Restricted
Stock under the Plan. All records maintained pursuant to this condition
will be subject to examination by the Commission and its staff.
For the Commission, by the Division of Investment Management,
pursuant to delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E8-3845 Filed 2-28-08; 8:45 am]
BILLING CODE 8011-01-P