Delaware Management Business Trust, et al.; Notice of Application, 57161-57163 [E8-23042]
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Federal Register / Vol. 73, No. 191 / Wednesday, October 1, 2008 / Notices
Act, and that is eligible to invest in
securities (as defined in section 2(a)(36)
of the Act) in reliance on rule 12d1–2
under the Act, to also invest, to the
extent consistent with its investment
objective, policies, strategies and
limitations, in financial instruments that
may not be securities within the
meaning of section 2(a)(36) of the Act
(‘‘Other Investments’’).1
2. Consistent with its fiduciary
obligations under the Act, each
Applicant Fund’s board of trustees or
directors will review the advisory fees
charged by the Applicant Fund’s
investment adviser to ensure that they
are based on services provided that are
in addition to, rather than duplicative
of, services provided pursuant to the
advisory agreement of any investment
company in which the Applicant Fund
may invest.
jlentini on PROD1PC65 with NOTICES
Applicants’ Legal Analysis
1. Section 12(d)(1)(A) of the Act
provides that no registered investment
company (‘‘acquiring company’’) may
acquire securities of another investment
company (‘‘acquired company’’) if such
securities represent more than 3% of the
acquired company’s outstanding voting
stock or more than 5% of the acquiring
company’s total assets, or if such
securities, together with the securities of
other investment companies, represent
more than 10% of the acquiring
company’s total assets. Section
12(d)(1)(B) of the Act provides that no
registered open-end investment
company may sell its securities to
another investment company if the sale
will cause the acquiring company to
own more than 3% of the acquired
company’s voting stock, or cause more
than 10% of the acquired company’s
voting stock to be owned by investment
companies.
2. Section 12(d)(1)(G) of the Act
provides that section 12(d)(1) will not
apply to securities of an acquired
company purchased by an acquiring
company if: (i) The acquiring company
and acquired company are part of the
same group of investment companies;
(ii) the acquiring company holds only
securities of acquired companies that
are part of the same group of investment
companies, government securities, and
short-term paper; (iii) the aggregate sales
loads and distribution-related fees of the
acquiring company and the acquired
company are not excessive under rules
adopted pursuant to section 22(b) or
1 Every existing entity that currently intends to
rely on the requested order is named as an
applicant. Any existing or future entity that relies
on the order in the future will do so only in
accordance with the terms and condition in the
application.
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18:22 Sep 30, 2008
Jkt 214001
section 22(c) of the Act by a securities
association registered under section 15A
of the Exchange Act or by the
Commission; and (iv) the acquired
company has a policy that prohibits it
from acquiring securities of registered
open-end management investment
companies or registered unit investment
trusts in reliance on section 12(d)(1)(F)
or (G) of the Act.
3. Rule 12d1–2 under the Act permits
a registered open-end investment
company or a registered unit investment
trust that relies on section 12(d)(1)(G) of
the Act to acquire, in addition to
securities issued by another registered
investment company in the same group
of investment companies, government
securities, and short-term paper: (1)
Securities issued by an investment
company that is not in the same group
of investment companies, when the
acquisition is in reliance on section
12(d)(1)(A) or 12(d)(1)(F) of the Act; (2)
securities (other than securities issued
by an investment company); and (3)
securities issued by a money market
fund, when the investment is in reliance
on rule 12d1–1 under the Act. For the
purposes of rule 12d1–2, ‘‘securities’’
means any security as defined in section
2(a)(36) of the Act.
4. Section 6(c) of the Act provides that
the Commission may exempt any
person, security, or transaction from any
provision of the Act, or from any rule
under the Act, if such exemption is
necessary or appropriate in the public
interest and consistent with the
protection of investors and the purposes
fairly intended by the policies and
provisions of the Act.
5. Applicants state that the proposed
arrangement would comply with the
provisions of rule 12d1–2 under the Act,
but for the fact that the Applicant Funds
may invest a portion of their assets in
Other Investments. Applicants request
an order under section 6(c) of the Act
for an exemption from rule 12d1–2(a) to
allow the Applicant Funds to invest in
Other Investments. Applicants assert
that permitting the Applicant Funds to
invest in Other Investments as described
in the application would not raise any
of the concerns that the requirements of
section 12(d)(1) were designed to
address.
Applicants’ Condition
Applicants agree that the order
granting the requested relief will be
subject to the following condition:
Applicants will comply with all
provisions of rule 12d1–2 under the Act,
except for paragraph (a)(2), to the extent
that it restricts any Applicant Fund from
investing in Other Investments as
described in the application.
PO 00000
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57161
For the Commission, by the Division of
Investment Management, under delegated
authority.
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8–23044 Filed 9–30–08; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
28405; 812–13521]
Delaware Management Business Trust,
et al.; Notice of Application
September 24, 2008.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application under
section 6(c) of the Investment Company
Act of 1940 (‘‘Act’’) for an exemption
from rule 12d1–2(a) under the Act.
AGENCY:
Applicants
request an order to permit funds of
funds relying on rule 12d1–2 under the
Act to invest in certain financial
instruments.
APPLICANTS: Delaware Group Adviser
Funds, Delaware Group Cash Reserve,
Delaware Group Equity Funds I,
Delaware Group Equity Funds II,
Delaware Group Equity Funds III,
Delaware Group Equity Funds IV,
Delaware Group Equity Funds V,
Delaware Group Foundation Funds,
Delaware Group Global & International
Funds, Delaware Group Government
Fund, Delaware Group Income Funds,
Delaware Group Limited-Term
Government Funds, Delaware Group
State Tax-Free Income Trust, Delaware
Group Tax-Free Fund, Delaware Group
Tax-Free Money Fund, Delaware Pooled
Trust, Delaware VIP Trust, Voyageur
Insured Funds, Voyageur Intermediate
Tax-Free Funds, Delaware Investments
Municipal Trust (formerly Voyageur
Investment Trust), Voyageur Mutual
Funds, Voyageur Mutual Funds II,
Voyageur Mutual Funds III and
Voyageur Tax-Free Funds (collectively,
the ‘‘Trusts’’), Delaware Management
Business Trust (‘‘DMBT’’), on behalf of
its series, Delaware Management
Company (the ‘‘Adviser’’) and Delaware
Distributors, L.P. (the ‘‘Underwriter’’).
FILING DATE: The application was filed
on April 15, 2008, and amended on
September 19, 2008.
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
SUMMARY OF APPLICATION:
E:\FR\FM\01OCN1.SGM
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57162
Federal Register / Vol. 73, No. 191 / Wednesday, October 1, 2008 / Notices
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 20, 2008, 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, c/o Bruce G. Leto,
Esq. and/or Alison M. Fuller, Esq.,
Stradley, Ronon, Stevens & Young, LLP,
2600 One Commerce Square,
Philadelphia, PA 19103.
FOR FURTHER INFORMATION CONTACT:
Lewis Reich, Senior Counsel, at (202)
551–6919, or Janet M. Grossnickle,
Assistant Director, 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 Room,
100 F Street, NE., Washington, DC
20549–1520 (telephone (202) 551–5850).
jlentini on PROD1PC65 with NOTICES
SUPPLEMENTARY INFORMATION:
Applicants’ Representations
1. Each Trust is organized as a
Delaware statutory trust and is
registered as an open-end management
investment company under the Act.
Applicants request the exemption to the
extent necessary to permit any existing
or future registered open-end
management investment companies and
their series that are in the same group
of investment companies, as defined in
section 12(d)(1)(G) of the Act, as the
Trusts and which invests in other
registered open-end management
investment companies in reliance on
section 12(d)(1)(G) of the Act, and
which is also eligible to invest in
securities (as defined in section 2(a)(36)
of the Act) in reliance on rule 12d1–2
under the Act (together with the Trusts
and their series, the ‘‘Applicant
Funds’’), to also invest, to the extent
consistent with its investment objective,
policies, strategies and limitations, in
financial instruments that may not be
securities within the meaning of section
2(a)(36) of the Act (‘‘Other
Investments’’).1
1 Every existing entity that currently intends to
rely on the requested order is named as an
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18:22 Sep 30, 2008
Jkt 214001
2. The Adviser is a series of DMBT,
which is registered as an investment
adviser under the Investment Advisers
Act of 1940 (the ‘‘Advisers Act’’). The
Adviser serves as the investment adviser
to each series of the Trust. DMBT is a
Delaware statutory trust and an indirect,
wholly owned subsidiary of Delaware
Management Holdings, Inc., which is an
indirect subsidiary of the Lincoln
National Corporation. The Underwriter
serves as principal underwriter for all
the mutual funds in the Delaware
Investments Family of Funds, and is a
registered broker-dealer under the
Securities Exchange Act of 1934. The
Underwriter is organized as a limited
partnership under Delaware law, and
Delaware Distributors, Inc., a Delaware
corporation, is its general partner.
Delaware Distributors, Inc. is a wholly
owned indirect subsidiary of Delaware
Management Holdings, Inc., and all of
the limited partnership interests of the
Underwriter are owned indirectly by
Delaware Management Holdings, Inc.
3. Consistent with its fiduciary
obligations under the Act, each
Applicant Fund’s board of trustees or
directors will review the advisory fees
charged by the Applicant Fund’s
investment adviser to ensure that they
are based on services provided that are
in addition to, rather than duplicative
of, services provided pursuant to the
advisory agreement of any investment
company in which the Applicant Fund
may invest.
Applicants’ Legal Analysis
1. Section 12(d)(1)(A) of the Act
provides that no registered investment
company (‘‘acquiring company’’) may
acquire securities of another investment
company (‘‘acquired company’’) if such
securities represent more than 3% of the
acquired company’s outstanding voting
stock or more than 5% of the acquiring
company’s total assets, or if such
securities, together with the securities of
other investment companies, represent
more than 10% of the acquiring
company’s total assets. Section
12(d)(1)(B) of the Act provides that no
registered open-end investment
company may sell its securities to
another investment company if the sale
will cause the acquiring company to
own more than 3% of the acquired
company’s voting stock, or cause more
than 10% of the acquired company’s
voting stock to be owned by investment
companies.
applicant. Any existing or future entity that relies
on the order in the future will do so only in
accordance with the terms and conditions in the
application.
PO 00000
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Fmt 4703
Sfmt 4703
2. Section 12(d)(1)(G) of the Act
provides that section 12(d)(1) will not
apply to securities of an acquired
company purchased by an acquiring
company if: (i) The acquiring company
and acquired company are part of the
same group of investment companies;
(ii) the acquiring company holds only
securities of acquired companies that
are part of the same group of investment
companies, government securities, and
short-term paper; (iii) the aggregate sales
loads and distribution-related fees of the
acquiring company and the acquired
company are not excessive under rules
adopted pursuant to section 22(b) or
section 22(c) of the Act by a securities
association registered under section 15A
of the Exchange Act or by the
Commission; and (iv) the acquired
company has a policy that prohibits it
from acquiring securities of registered
open-end management investment
companies or registered unit investment
trusts in reliance on section 12(d)(1)(F)
or (G) of the Act.
3. Rule 12d1–2 under the Act permits
a registered open-end investment
company or a registered unit investment
trust that relies on section 12(d)(1)(G) of
the Act to acquire, in addition to
securities issued by another registered
investment company in the same group
of investment companies, government
securities, and short-term paper: (1)
Securities issued by an investment
company that is not in the same group
of investment companies, when the
acquisition is in reliance on section
12(d)(1)(A) or 12(d)(1)(F) of the Act; (2)
securities (other than securities issued
by an investment company); and (3)
securities issued by a money market
fund, when the investment is in reliance
on rule 12d1–1 under the Act. For the
purposes of rule 12d1–2, ‘‘securities’’
means any security as defined in section
2(a)(36) of the Act.
4. Section 6(c) of the Act provides that
the Commission may exempt any
person, security, or transaction from any
provision of the Act, or from any rule
under the Act, if such exemption is
necessary or appropriate in the public
interest and consistent with the
protection of investors and the purposes
fairly intended by the policies and
provisions of the Act.
5. Applicants state that the proposed
arrangement would comply with the
provisions of rule 12d1–2 under the Act,
but for the fact that the Applicant Funds
may invest a portion of their assets in
Other Investments. Applicants request
an order under section 6(c) of the Act
for an exemption from rule 12d1–2(a) to
allow the Applicant Funds to invest in
Other Investments. Applicants assert
that permitting the Applicant Funds to
E:\FR\FM\01OCN1.SGM
01OCN1
Federal Register / Vol. 73, No. 191 / Wednesday, October 1, 2008 / Notices
invest in Other Investments as described
in the application would not raise any
of the concerns that the requirements of
section 12(d)(1) were designed to
address.
Applicants’ Condition
Applicants agree that any order
granting the requested relief will be
subject to the following condition:
Applicants will comply with all
provisions of rule 12d1–2 under the Act,
except for paragraph (a)(2) to the extent
that it restricts any Fund from investing
in Other Investments as described in the
application.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8–23042 Filed 9–30–08; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
28406; 812–13506]
Van Kampen Retirement Strategy
Trust, et al.; Notice of Application
September 25, 2008.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under section 12(d)(1)(J) of the
Investment Company Act of 1940
(‘‘Act’’) for an exemption from sections
12(d)(1)(A) and (B) of the Act, and
under sections 6(c) and 17(b) of the Act
for an exemption from section 17(a) of
the Act.
jlentini on PROD1PC65 with NOTICES
AGENCY:
SUMMARY OF THE APPLICATION:
Applicants request an order that would
permit certain registered open-end
management investment companies to
acquire shares of other registered openend management investment companies
and unit investment trusts that are
within and outside the same group of
investment companies.
APPLICANTS: Van Kampen Retirement
Strategy Trust (‘‘VK Trust’’), Van
Kampen Asset Management (‘‘VKAM’’
or ‘‘Adviser’’) and Morgan Stanley
Investment Management Limited
(‘‘MSIM Ltd.’’).
FILING DATES: The application was filed
on March 7, 2008 and amended on
September 19, 2008.
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
VerDate Aug<31>2005
18:22 Sep 30, 2008
Jkt 214001
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, 2008, 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: VK Trust and VKAM,
522 Fifth Avenue, New York, New York
10036; MSIM Ltd., 25 Bank Street,
Canary Wharf, London, United Kingdom
E14 4AD.
FOR FURTHER INFORMATION CONTACT:
Emerson S. Davis, Sr., Senior Counsel,
at (202) 551–6868, or Mary Kay Frech,
Branch Chief, at (202) 551–6821 (Office
of Investment Company Regulation,
Division of Investment Management).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained for a fee at the
Commission’s Public Reference Desk,
100 F Street, NE., Washington, DC
20549–0102 (telephone (202) 551–5850).
Applicants’ Representations
1. The VK Trust, organized as a
Delaware statutory trust, is registered
under the Act as an open-end
management investment company. The
VK Trust currently offers ten series,
each with its own investment objective
and policies (the ‘‘VK Funds’’).1 The
Adviser, a wholly-owned subsidiary of
Van Kampen Investments Inc., which is
an indirect wholly-owned subsidiary of
Morgan Stanley, is registered as an
investment adviser under the
Investment Advisers Act of 1940 (the
‘‘Advisers Act’’). The Adviser serves as
the investment adviser to each VK
Fund. MSIM Ltd., a wholly-owned
subsidiary of Morgan Stanley, is an
investment adviser registered under the
1 Applicants request that the order extend to any
other existing or future registered open-end
management investment companies and their series
that are part of the same group of investment
companies, as defined in section 12(d)(1)(G) of the
Act, as VK Trust and are, or may in the future be,
advised by the Adviser or any existing or future
entity controlling, controlled by, or under common
control with the Adviser. All entities that currently
intend to rely on the requested order are named as
applicants and any other entity that relies on the
order in the future will comply with the terms and
conditions of the application.
PO 00000
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Fmt 4703
Sfmt 4703
57163
Advisers Act and serves as subadviser
for certain VK Funds.
2. Applicants request relief to permit
certain VK Funds (each such VK Fund,
a ‘‘Fund of Funds’’) to invest in: (a)
other VK Funds (‘‘Affiliated Underlying
Funds’’), and (b) registered open-end
management investment companies and
registered unit investment trusts
(‘‘UITs’’) that are not part of the same
‘‘group of investment companies’’ (as
defined in section 12(d)(1)(G)(ii) of the
Act) as the VK Funds (‘‘Unaffiliated
Underlying Funds,’’ and together with
the Affiliated Underlying Funds, the
‘‘Underlying Funds’’). The Unaffiliated
Underlying Funds may include UITs
(‘‘Unaffiliated Trusts’’) and open-end
management investment companies
(‘‘Unaffiliated Funds’’) registered under
the Act. The relief also would permit
the Underlying Funds, their principal
underwriter and any broker or dealer to
sell the shares of the Underlying Funds
to the Fund of Funds. Certain of the
Unaffiliated Underlying Funds may
have received exemptive relief to sell
their shares on a national securities
exchange at negotiated prices (‘‘ETFs’’).
Each Fund of Funds may also invest in
other securities and financial
instruments that are not issued by
registered investment companies and
which are consistent with its investment
objective. Applicants state that each
Fund of Funds seeks to provide, in a
single investment vehicle, an asset
allocation strategy designed for
investors planning to retire on or about
a specific year or to provide income for
investors who have already retired.
Applicants’ Legal Analysis
A. Section 12(d)(1)
1. Section 12(d)(1)(A) of the Act
prohibits a registered investment
company from acquiring shares of an
investment company if the securities
represent more than 3% of the total
outstanding voting stock of the acquired
company, more than 5% of the total
assets of the acquiring company, or,
together with the securities of any other
investment companies, more than 10%
of the total assets of the acquiring
company. Section 12(d)(1)(B) of the Act
prohibits a registered open-end
investment company, its principal
underwriter and any broker or dealer
from selling the shares of the investment
company to another investment
company if the sale will cause the
acquiring company to own more than
3% of the acquired company’s voting
stock, or if the sale will cause more than
10% of the acquired company’s voting
stock to be owned by investment
companies generally.
E:\FR\FM\01OCN1.SGM
01OCN1
Agencies
[Federal Register Volume 73, Number 191 (Wednesday, October 1, 2008)]
[Notices]
[Pages 57161-57163]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-23042]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 28405; 812-13521]
Delaware Management Business Trust, et al.; Notice of Application
September 24, 2008.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application under section 6(c) of the Investment
Company Act of 1940 (``Act'') for an exemption from rule 12d1-2(a)
under the Act.
-----------------------------------------------------------------------
Summary of Application: Applicants request an order to permit funds of
funds relying on rule 12d1-2 under the Act to invest in certain
financial instruments.
Applicants: Delaware Group Adviser Funds, Delaware Group Cash Reserve,
Delaware Group Equity Funds I, Delaware Group Equity Funds II, Delaware
Group Equity Funds III, Delaware Group Equity Funds IV, Delaware Group
Equity Funds V, Delaware Group Foundation Funds, Delaware Group Global
& International Funds, Delaware Group Government Fund, Delaware Group
Income Funds, Delaware Group Limited-Term Government Funds, Delaware
Group State Tax-Free Income Trust, Delaware Group Tax-Free Fund,
Delaware Group Tax-Free Money Fund, Delaware Pooled Trust, Delaware VIP
Trust, Voyageur Insured Funds, Voyageur Intermediate Tax-Free Funds,
Delaware Investments Municipal Trust (formerly Voyageur Investment
Trust), Voyageur Mutual Funds, Voyageur Mutual Funds II, Voyageur
Mutual Funds III and Voyageur Tax-Free Funds (collectively, the
``Trusts''), Delaware Management Business Trust (``DMBT''), on behalf
of its series, Delaware Management Company (the ``Adviser'') and
Delaware Distributors, L.P. (the ``Underwriter'').
Filing Date: The application was filed on April 15, 2008, and amended
on September 19, 2008.
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
[[Page 57162]]
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
20, 2008, 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, c/o Bruce G. Leto,
Esq. and/or Alison M. Fuller, Esq., Stradley, Ronon, Stevens & Young,
LLP, 2600 One Commerce Square, Philadelphia, PA 19103.
FOR FURTHER INFORMATION CONTACT: Lewis Reich, Senior Counsel, at (202)
551-6919, or Janet M. Grossnickle, Assistant Director, 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 Room, 100 F Street, NE., Washington, DC
20549-1520 (telephone (202) 551-5850).
Applicants' Representations
1. Each Trust is organized as a Delaware statutory trust and is
registered as an open-end management investment company under the Act.
Applicants request the exemption to the extent necessary to permit any
existing or future registered open-end management investment companies
and their series that are in the same group of investment companies, as
defined in section 12(d)(1)(G) of the Act, as the Trusts and which
invests in other registered open-end management investment companies in
reliance on section 12(d)(1)(G) of the Act, and which is also eligible
to invest in securities (as defined in section 2(a)(36) of the Act) in
reliance on rule 12d1-2 under the Act (together with the Trusts and
their series, the ``Applicant Funds''), to also invest, to the extent
consistent with its investment objective, policies, strategies and
limitations, in financial instruments that may not be securities within
the meaning of section 2(a)(36) of the Act (``Other Investments'').\1\
---------------------------------------------------------------------------
\1\ Every existing entity that currently intends to rely on the
requested order is named as an applicant. Any existing or future
entity that relies on the order in the future will do so only in
accordance with the terms and conditions in the application.
---------------------------------------------------------------------------
2. The Adviser is a series of DMBT, which is registered as an
investment adviser under the Investment Advisers Act of 1940 (the
``Advisers Act''). The Adviser serves as the investment adviser to each
series of the Trust. DMBT is a Delaware statutory trust and an
indirect, wholly owned subsidiary of Delaware Management Holdings,
Inc., which is an indirect subsidiary of the Lincoln National
Corporation. The Underwriter serves as principal underwriter for all
the mutual funds in the Delaware Investments Family of Funds, and is a
registered broker-dealer under the Securities Exchange Act of 1934. The
Underwriter is organized as a limited partnership under Delaware law,
and Delaware Distributors, Inc., a Delaware corporation, is its general
partner. Delaware Distributors, Inc. is a wholly owned indirect
subsidiary of Delaware Management Holdings, Inc., and all of the
limited partnership interests of the Underwriter are owned indirectly
by Delaware Management Holdings, Inc.
3. Consistent with its fiduciary obligations under the Act, each
Applicant Fund's board of trustees or directors will review the
advisory fees charged by the Applicant Fund's investment adviser to
ensure that they are based on services provided that are in addition
to, rather than duplicative of, services provided pursuant to the
advisory agreement of any investment company in which the Applicant
Fund may invest.
Applicants' Legal Analysis
1. Section 12(d)(1)(A) of the Act provides that no registered
investment company (``acquiring company'') may acquire securities of
another investment company (``acquired company'') if such securities
represent more than 3% of the acquired company's outstanding voting
stock or more than 5% of the acquiring company's total assets, or if
such securities, together with the securities of other investment
companies, represent more than 10% of the acquiring company's total
assets. Section 12(d)(1)(B) of the Act provides that no registered
open-end investment company may sell its securities to another
investment company if the sale will cause the acquiring company to own
more than 3% of the acquired company's voting stock, or cause more than
10% of the acquired company's voting stock to be owned by investment
companies.
2. Section 12(d)(1)(G) of the Act provides that section 12(d)(1)
will not apply to securities of an acquired company purchased by an
acquiring company if: (i) The acquiring company and acquired company
are part of the same group of investment companies; (ii) the acquiring
company holds only securities of acquired companies that are part of
the same group of investment companies, government securities, and
short-term paper; (iii) the aggregate sales loads and distribution-
related fees of the acquiring company and the acquired company are not
excessive under rules adopted pursuant to section 22(b) or section
22(c) of the Act by a securities association registered under section
15A of the Exchange Act or by the Commission; and (iv) the acquired
company has a policy that prohibits it from acquiring securities of
registered open-end management investment companies or registered unit
investment trusts in reliance on section 12(d)(1)(F) or (G) of the Act.
3. Rule 12d1-2 under the Act permits a registered open-end
investment company or a registered unit investment trust that relies on
section 12(d)(1)(G) of the Act to acquire, in addition to securities
issued by another registered investment company in the same group of
investment companies, government securities, and short-term paper: (1)
Securities issued by an investment company that is not in the same
group of investment companies, when the acquisition is in reliance on
section 12(d)(1)(A) or 12(d)(1)(F) of the Act; (2) securities (other
than securities issued by an investment company); and (3) securities
issued by a money market fund, when the investment is in reliance on
rule 12d1-1 under the Act. For the purposes of rule 12d1-2,
``securities'' means any security as defined in section 2(a)(36) of the
Act.
4. Section 6(c) of the Act provides that the Commission may exempt
any person, security, or transaction from any provision of the Act, or
from any rule under the Act, if such exemption is necessary or
appropriate in the public interest and consistent with the protection
of investors and the purposes fairly intended by the policies and
provisions of the Act.
5. Applicants state that the proposed arrangement would comply with
the provisions of rule 12d1-2 under the Act, but for the fact that the
Applicant Funds may invest a portion of their assets in Other
Investments. Applicants request an order under section 6(c) of the Act
for an exemption from rule 12d1-2(a) to allow the Applicant Funds to
invest in Other Investments. Applicants assert that permitting the
Applicant Funds to
[[Page 57163]]
invest in Other Investments as described in the application would not
raise any of the concerns that the requirements of section 12(d)(1)
were designed to address.
Applicants' Condition
Applicants agree that any order granting the requested relief will
be subject to the following condition:
Applicants will comply with all provisions of rule 12d1-2 under the
Act, except for paragraph (a)(2) to the extent that it restricts any
Fund from investing in Other Investments as described in the
application.
For the Commission, by the Division of Investment Management,
under delegated authority.
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8-23042 Filed 9-30-08; 8:45 am]
BILLING CODE 8011-01-P