AdvisorShares Investments, LLC and AdvisorShares Trust; Notice of Application, 80454-80457 [E8-31086]
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80454
Federal Register / Vol. 73, No. 251 / Wednesday, December 31, 2008 / Notices
expertise in providing Fund Service
Activities. Applicants further state that
prohibiting them from providing
advisory and distribution services
would not only adversely affect their
businesses, but would also adversely
affect over 450 employees that are
involved in those activities. Applicants
also state that disqualifying UBS AG
and ESC GP from continuing to provide
investment advisory services to ESCs is
not in the public interest or in
furtherance of the protection of
investors. Because the ESCs have been
formed for the benefit of key employees,
officers, directors and current
consultants of UBS AG and its affiliates,
it would not be consistent with the
purposes of the ESC provisions of the
Act to require another entity not
affiliated with UBS AG to manage the
ESCs. In addition, participants in the
ESCs have subscribed for interests in the
ESCs with the expectation that the ESCs
would be managed by an affiliate of
UBS AG.
7. Applicants state that UBS
Securities and certain other Applicants
have previously received an order under
section 9(c) of the Act.4 Applicants also
state that affiliated persons of UBS
Securities previously have received
exemptions under section 9(c) as the
result of conduct that triggered section
9(a), as described in greater detail in the
application.
Applicants’ Condition
Applicants agree that any order
granting the requested relief will be
subject to the following condition:
Any temporary exemption granted
pursuant to the application shall be
without prejudice to, and shall not limit
the Commission’s rights in any manner
with respect to, any Commission
investigation of, or administrative
proceedings involving or against,
Covered Persons, including without
limitation, the consideration by the
Commission of a permanent exemption
from section 9(a) of the Act requested
pursuant to the application or the
revocation or removal of any temporary
exemptions granted under the Act in
connection with the application.
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Temporary Order
The Commission has considered the
matter and finds that the Applicants
have made the necessary showing to
justify granting a temporary exemption.
Accordingly,
It is hereby ordered, pursuant to
section 9(c) of the Act, that Applicants
4 UBS Securities L.L.C., et al., Investment
Company Act Rel. Nos. 26245 (Oct. 31, 2003)
(notice) and 27047 (Apr. 25, 2005) (order).
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and any other Covered Persons are
granted a temporary exemption from the
provisions of section 9(a), solely with
respect to the Injunction, subject to the
condition in the application, from
December 23, 2008, until the
Commission takes final action on their
application for a permanent order.
By the Commission.
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8–31087 Filed 12–30–08; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
28568; 812–13488]
AdvisorShares Investments, LLC and
AdvisorShares Trust; Notice of
Application
December 23, 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
(‘‘Act’’) for an exemption from sections
2(a)(32), 5(a)(1) and 22(d) of the Act and
rule 22c–1 under the Act, and under
sections 6(c) and 17(b) of the Act for an
exemption from sections 17(a)(1) and
(a)(2) of the Act.
Applicants: AdvisorShares
Investments, LLC (the ‘‘Advisor’’) and
AdvisorShares Trust (the ‘‘Trust’’).
Summary of Application: Applicants
request an order that permits: (a) Series
of certain open-end management
investment companies to issue shares
(‘‘Shares’’) redeemable in large
aggregations only (‘‘Creation Units’’); (b)
secondary market transactions in Shares
to occur at negotiated market prices; and
(c) certain affiliated persons of the series
to deposit securities into, and receive
securities from, the series in connection
with the purchase and redemption of
Creation Units.
Filing Dates: The application was
filed on January 31, 2008, and amended
on October 17, 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 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
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by 5:30 p.m. on January 15, 2009, 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: Noah Hamman, c/o
Morgan, Lewis & Bockius LLP, 1111
Pennsylvania Avenue, NW.,
Washington, DC 20004.
FOR FURTHER INFORMATION CONTACT:
Courtney S. Thornton, Senior Counsel,
or Michael W. Mundt, 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 Desk,
100 F Street, NE., Washington, DC
20549–1520 (tel. 202–551–5850).
Applicants’ Representations
1. The Trust, a statutory trust
established under the laws of Delaware,
is registered with the Commission as an
open-end management investment
company. The Trust is organized as a
series investment company with one
initial series (the ‘‘Initial Fund’’). The
investment objective of the Initial Fund
will be to provide long term growth of
capital. The Initial Fund and all future
series of the Trust (‘‘Future Funds,’’
collectively with the Initial Fund,
‘‘Funds’’) will attempt to achieve their
investment objectives by utilizing active
management strategies based on various
formulas for asset allocation, security
selection, and portfolio construction.
Each Fund will primarily hold shares of
underlying exchange traded funds
(‘‘ETFs’’), as well as shares of certain
exchange traded products that are not
registered as investment companies
under the Act.1 Applicants will only
1 The Funds may invest in exchange traded
products that invest primarily in commodities or
currency, but otherwise operate in a manner similar
to exchange traded products registered under the
Act. In addition, the Funds may also invest in
equity securities or fixed income securities traded
in a U.S. or non-U.S. markets, as well as futures
contracts, options on such futures contracts, swaps,
forward contracts or other derivatives, and shares
of money market mutual funds or other investment
companies, all in accordance with their investment
objectives. The Funds may also invest in equity
securities or fixed income securities traded in
international markets or in a combination of equity,
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invest in unaffiliated ETFs that have
received certain exemptive relief from
the Commission to permit such
investments in excess of the limits of
section 12(d)(1)(A) and (B) of the Act.
Any Future Fund (a) will be advised by
the Advisor or an entity controlled by or
under common control with the
Advisor, and (b) will comply with the
terms and conditions of the order.
2. The Advisor, a Delaware limited
liability company, or a subsidiary of
such company, will serve as the
investment adviser to each Fund. The
Advisor will be registered as an
investment adviser of the Investment
Advisers Act of 1940 (‘‘Advisers Act’’)
prior to a Fund beginning operations.
Applicants anticipate that Funds also
may engage subadvisors
(‘‘Subadvisors’’).
3. Applicants anticipate that shares
(‘‘Shares’’) of the Funds will be sold at
a price of between $25 and $200 per
Share in Creation Units of 25,000 or
more Shares. All orders to purchase
Creation Units must be placed with the
principal underwriter and distributor of
the Creation Units (‘‘Distributor’’) by or
through a party that has entered into a
participant agreement with the
Distributor (‘‘Authorized Participant’’).
Authorized Participants will include
broker-dealers, banks, trust companies,
and clearing companies that are
participants in the Depository Trust
Company (‘‘DTC,’’ and such
participants, ‘‘DTC Participants’’).
Purchases of Creation Units of the
Funds will be made generally by means
of an in-kind tender of shares of specific
ETFs (the ‘‘Deposit Securities’’), with
any cash portion of the purchase price
(the ‘‘Cash Amount’’) to be kept to a
minimum. The Cash Amount is an
amount equal to the difference between
the NAV of a Creation Unit and the
market value of the Deposit Securities.
The Trust reserves the right to permit,
under certain circumstances, a
purchaser of Creation Units to substitute
cash in lieu of depositing some or all of
the requisite Deposit Securities. The
Trust may in the future determine that
Shares of one or more Funds may be
purchased in Creation Units on a cashonly basis if the Trust and the Advisor
believe such method would
substantially minimize the Trust’s
transactional costs or enhance its
operational efficiencies.
4. Each Fund will charge a fee
(‘‘Transaction Fee’’) in connection with
the sale or redemption of Creation Units
to protect existing shareholders from the
dilutive costs associated with the
fixed income and U.S. money market securities
and/or non-U.S. money market securities.
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purchase and redemption of Creation
Units. Each purchaser of a Creation Unit
will receive a prospectus (‘‘Prospectus’’)
that contains complete disclosure about
the Transaction Fee. All orders to
purchase Creation Units must be placed
with the Distributor no later than the
closing time of the regular trading
session on the NYSE (ordinarily 4 p.m.
ET) in order for the purchaser to receive
the NAV determined on that date. The
Distributor will transmit all purchase
orders to the relevant Fund and will
also maintain a record of Creation Unit
purchases, send out confirmations of
such purchases, and furnish a
Prospectus to purchasers of Creation
Units.
5. The Trust intends to list the Shares
of each Fund on a national securities
exchange (‘‘Listing Market’’) such as the
NYSE. It is expected that one or more
member firms will be designated to act
as a specialist and maintain a market for
the Shares trading on the Listing Market
(‘‘Exchange Specialist’’). The price of
Shares trading on the Listing Market
will be based on a current bid/offer
market. No secondary sales will be
made to brokers or dealers at a
concession by the Distributor or by a
Fund. Purchases and sales of Shares in
the secondary market, which will not
involve a Fund, will be subject to
customary brokerage commissions and
charges.
6. Purchasers of Shares in Creation
Units may hold such Shares or may sell
them into the secondary market.
Applicants expect that purchasers of
Creation Units will include institutional
investors and arbitrageurs, who will
purchase or redeem Creation Units of a
Fund in pursuit of arbitrage profit and
thereby enhance the liquidity of the
secondary market and keep the market
price of shares close to their NAV.
Applicants expect that secondary
market purchasers of Shares will
include both institutional investors and
retail investors for whom Shares will
provide a useful, retail-priced,
exchange-traded mechanism for
investing in a professionally managed,
diversified selection of ETFs.2
7. Shares will not be individually
redeemable, and owners of Shares may
acquire those Shares from a Fund, or
tender such Shares for redemption to
the Fund, in Creation Units only. To
redeem, an investor will have to
accumulate enough Shares to constitute
a Creation Unit. Redemption orders
must be placed by or through an
2 Shares will be registered in book-entry form
only. DTC or its nominee will be the registered
owner of all outstanding Shares. DTC or DTC
Participants will maintain records reflecting
beneficial owners of Shares.
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80455
Authorized Participant. A redeeming
investor will receive a basket of
securities designated to be delivered for
Creation Unit redemptions on the date
that the request for redemption is
submitted (‘‘Redemption Securities’’),
which in most cases will be the same as
the Deposit Securities required to
purchase Creation Units on that date,
and will either receive from or pay to
the Fund a balancing amount in cash. A
Fund may make redemptions partly in
cash in lieu of transferring one or more
Redemption Securities to a redeeming
investor if the Fund determines that
such alternative is warranted, such as if
the redeeming investor is unable, by law
or policy, to own a particular
Redemption Security. A redeeming
investor also must pay a Transaction
Fee to cover custodial costs.
8. The Trust will not be advertised or
marketed or otherwise ‘‘held out’’ as a
traditional open-end investment
company or a mutual fund. The
designation of the Trust and the Funds
in all marketing materials will be
limited to the terms ‘‘exchange-traded
fund,’’ ‘‘investment company,’’ ‘‘fund’’
and ‘‘trust’’ without reference to an
‘‘open-end fund’’ or a ‘‘mutual fund,’’
except to compare and contrast the
Trust and the Funds with traditional
mutual funds. Each Fund’s Prospectus
will also prominently disclose that the
Fund is an actively managed exchange
traded fund. All marketing materials
that describe the method of obtaining,
buying or selling Creation Units, or
Shares traded on the Listing Market, or
refer to redeemability, will prominently
disclose that Shares are not individually
redeemable and that the owners of
Shares may acquire or redeem Shares
from a Fund in Creation Units only. The
same approach will be followed in the
statement of additional information
(‘‘SAI’’), shareholder reports and
investor educational materials issued or
circulated in connection with the
Shares. The Trust will provide copies of
its annual and semi-annual shareholder
reports to DTC Participants for
distribution to beneficial owners of
Shares.
9. The Trust (or the Listing Market)
intends to maintain a Web site that will
be publicly available at no charge,
which will include the Prospectus and
other information about the Funds that
is updated on a daily basis. On each
Business Day, before the
commencement of trading in Shares on
the Listing Market, each Fund will
disclose the identities and quantities of
the securities (‘‘Portfolio Securities’’)
and other assets held in the Fund
portfolio that will form the basis for the
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Fund’s calculation of NAV at the end of
the Business Day.3
Applicants’ Legal Analysis
1. Applicants request an order under
section 6(c) of the Act granting an
exemption from sections 2(a)(32), 5(a)(1)
and 22(d) of the Act and rule 22c–1
under the Act, and under sections 6(c)
and 17(b) of the Act granting an
exemption from sections 17(a)(1) and
(a)(2) of the Act.
2. Section 6(c) of the Act provides that
the Commission may exempt any
person, security or transaction, or any
class of persons, securities or
transactions, from any provision of the
Act, if and to the extent that such
exemption is necessary or appropriate
in the public interest and consistent
with the protection of investors and the
purposes fairly intended by the policy
and provisions of the Act. Section 17(b)
of the Act authorizes the Commission to
exempt a proposed transaction from
section 17(a) of the Act if evidence
establishes that the terms of the
transaction, including the consideration
to be paid or received, are reasonable
and fair and do not involve
overreaching on the part of any person
concerned, and the proposed
transaction is consistent with the
policies of the registered investment
company and the general provisions of
the Act.
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Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an
‘‘open-end company’’ as a management
investment company that is offering for
sale or has outstanding any redeemable
security of which it is the issuer.
Section 2(a)(32) of the Act defines a
redeemable security as any security,
other than short-term paper, under the
terms of which the holder, upon its
presentation to the issuer, is entitled to
receive approximately his proportionate
share of the issuer’s current net assets,
or the cash equivalent. Because Shares
will not be individually redeemable,
applicants request an order that would
permit each Fund, as a series of an
open-end management investment
company, to issue Shares that are
redeemable in Creation Units only.
Applicants state that Creation Units will
always be redeemable. Applicants
further state that because Creation Units
may always be purchased and redeemed
3 Applicants note that under accounting
procedures followed by the Fund, trades made on
the prior Business Day (‘‘T’’) will be booked and
reflected in NAV on the current Business Day (‘‘T
+ 1’’). Accordingly, the Fund will be able to
disclose at the beginning of the Business Day the
portfolio that will form the basis for the NAV
calculation at the end of the Business Day.
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at NAV (less certain transactional
expenses), the price of Creation Units on
the secondary market and the price of
the individual Shares of a Creation Unit,
taken together, should not vary
substantially from the NAV of Creation
Units.
a result of unjust or discriminatory
manipulation. Finally, applicants
contend that the proposed distribution
system will be orderly because arbitrage
activity will ensure that the difference
between the market price of Shares and
their NAV remains narrow.
Section 22(d) of the Act and Rule
22c–1 under the Act
4. Section 22(d) of the Act, among
other things, prohibits a dealer from
selling a redeemable security, which is
currently being offered to the public by
or through a principal underwriter,
except at a current public offering price
described in the prospectus. Rule 22c–
1 under the Act generally requires that
a dealer selling, redeeming, or
repurchasing a redeemable security do
so only at a price based on its NAV.
Applicants state that trading in Shares
will take place on and away from the
Listing Market at all times on the basis
of current bid/offer prices, not at a
current offering price described in the
prospectus, and not at a price based on
NAV. Thus, purchases and sales of
Shares in the secondary market will not
comply with section 22(d) of the Act
and rule 22c–1 under the Act.
Applicants request an exemption under
section 6(c) from these provisions.
5. Applicants assert that the concerns
sought to be addressed by section 22(d)
of the Act and rule 22c–1 under the Act
with respect to pricing are equally
satisfied by the proposed method of
pricing Shares. Applicants maintain that
while there is little legislative history
regarding section 22(d), its provisions,
as well as those of rule 22c–1, appear to
have been designed to (a) prevent
dilution caused by certain risklesstrading schemes by principal
underwriters and contract dealers, (b)
prevent unjust discrimination or
preferential treatment among buyers,
and (c) assure an orderly distribution of
investment company shares by contract
dealers by eliminating price competition
from non-contract dealers who could
offer investors shares at less than the
published sales price and who could
pay investors a little more than the
published redemption price.
6. Applicants believe that none of
these purposes will be relevant issues
for secondary trading by dealers in
Shares of a Fund. Applicants state that
(a) secondary market trading in Shares
will not cause dilution for owners of
such Shares because such transactions
do not directly involve Fund assets, and
(b) to the extent different prices exist
during a given trading day, or from day
to day, such variances occur as a result
of third-party market forces, such as
supply and demand, but do not occur as
Sections 17(a)(1) and 17(a)(2) of the Act
7. Section 17(a)(1) and (2) of the Act
generally prohibit an affiliated person of
a registered investment company, or an
affiliated person of such a person
(‘‘second tier affiliate’’), from selling any
security to or purchasing any security
from the company. Section 2(a)(3) of the
Act defines ‘‘affiliated person’’ to
include any person directly or indirectly
owning, controlling, or holding with
power to vote 5 percent or more of the
outstanding voting securities of the
other person and any person directly or
indirectly controlling, controlled by, or
under common control with, the other
person. Section 2(a)(9) of the Act
provides that a control relationship will
be presumed where one person owns
more than 25 percent of another
person’s voting securities. The Funds
may be deemed to be controlled by the
Advisor or an entity controlling,
controlled by or under common control
with the Adviser and hence affiliated
persons of each other. In addition, the
Funds may be deemed to be under
common control with any other
registered investment company (or
series thereof) advised by the Advisor or
an entity controlling, controlled by or
under common control with the Advisor
(an ‘‘Affiliated Fund’’). Applicants state
that an investor could own 5 percent or
more of a Fund or the Trust, or in excess
of 25 percent of the outstanding Shares
of a Fund or the Trust, making that
investor an affiliated person of the Fund
or the Trust under section 2(a)(3)(A) or
2(a)(3)(C) of the Act. For so long as such
an investor was deemed to be an
affiliated person, section 17(a)(1) could
be read to prohibit that investor from
depositing the Deposit Securities with a
Fund in return for a Creation Unit.
Similarly, section 17(a)(2) could be read
to prohibit such an investor from
entering into an in-kind redemption
with a Fund.
8. Applicants request an exemption
from section 17(a) under sections 6(c)
and 17(b), to permit in-kind purchases
and redemptions by persons that are
affiliated persons or second tier
affiliates of the Funds solely by virtue
of one or more of the following: (1)
Holding 5 percent or more, or more than
25 percent, of the outstanding Shares of
the Trust or one or more Funds; (2) an
affiliation with a person with an
ownership interest described in (1); or
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(3) holding 5 percent or more, or more
than 25 percent, of the shares of one or
more Affiliated Funds.
9. Applicants contend that no useful
purpose would be served by prohibiting
the affiliated persons or second tier
affiliates of a Fund as described above
from purchasing or redeeming Creation
Units through ‘‘in-kind’’ transactions.
The purchase and redemption of
Creation Units of each Fund is on the
same terms for all investors, whether or
not such investor is an affiliate. In each
case, Creation Units are sold and
redeemed by the Trust at their NAV.
The Deposit Securities and Redemption
Securities will be valued in the same
manner as the securities in the Fund
portfolio. Accordingly, applicants
believe the proposed transactions
described above meet the section 17(b)
standards for relief because the terms of
such proposed transactions are
reasonable and fair and do not involve
overreaching on the part of any person
concerned, and the proposed
transactions will be consistent with the
policies of each Fund and with the
general purposes of the Act.
Applicants’ Conditions
The applicants agree that any order of
the Commission granting the requested
relief will be subject to the following
conditions:
1. Neither the Trust nor any Fund will
be advertised or marketed as an openend investment company or mutual
fund. Each Fund’s Prospectus will
prominently disclose that the Fund is an
actively managed exchange-traded fund.
Each Prospectus will prominently
disclose that the Shares are not
individually redeemable shares and will
disclose that the owners of the Shares
may acquire those Shares from the Fund
and tender those Shares for redemption
to the Fund in Creation Units only. Any
advertising material that describes the
purchase or sale of Creation Units or
refers to redeemability will prominently
disclose that the Shares are not
individually redeemable and that
owners of the Shares may acquire those
Shares from the Fund and tender those
Shares for redemption to the Fund in
Creation Units only.
2. Each Fund’s Prospectus will clearly
disclose that, for purposes of the Act,
Shares are issued by a registered
investment company and that the
acquisition of Shares by investment
companies and companies relying on
sections 3(c)(1) or 3(c)(7) of the Act is
subject to the restrictions of section
12(d)(1) of the Act.
3. The Web site for the Funds, which
will be publicly accessible at no charge,
will contain the following information,
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on a per Share basis, for each Fund: (a)
The prior Business Day’s NAV and the
reported closing price, and a calculation
of the premium or discount of the
closing price against such NAV; and (b)
data in chart format displaying the
frequency distribution of discounts and
premiums of the daily closing price
against the NAV, within appropriate
ranges, for each of the four previous
calendar quarters (or for the life of the
Fund, if shorter).
4. The Prospectus and annual report
for each Fund will also include: (a) The
information listed in condition 3(b), (i)
in the case of the Prospectus, for the
most recently completed year (and the
most recently completed quarter or
quarters, as applicable) and (ii) in the
case of the annual report, for the
immediately preceding five years (or for
the life of the Fund, if shorter), and (b)
the cumulative total return and the
average annual total return based on
NAV and closing price, calculated on a
per Share basis for one-, five- and tenyear periods (or life of the Fund, if
shorter).
5. As long as the Funds operate in
reliance on the requested order, the
Shares of the Funds will be listed on a
Listing Market.
6. On each Business Day, before
commencement of trading in Shares on
a Fund’s Listing Market, the Fund will
disclose on its Web site the identities
and weightings of the component
securities and other assets held by the
Fund that will form the basis for the
Fund’s calculation of NAV at the end of
the Business Day.
7. The Advisor or any Subadvisor,
directly or indirectly, will not cause any
Authorized Participant (or any investor
on whose behalf an Authorized
Participant may transact with the Fund)
to acquire any Deposit Security for the
Fund through a transaction in which the
Fund could not engage directly.
8. The requested order will expire on
the effective date of any Commission
rule under the Act that provides relief
permitting the operation of actively
managed exchange-traded funds.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Florence E. Harmon,
Acting Secretary.
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80457
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
28571; 812–13440]
Grail Advisors, LLC and Grail
Advisors’ Alpha ETF Trust; Notice of
Application
December 23, 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
(‘‘Act’’) for an exemption from sections
2(a)(32), 5(a)(1), 22(d) and 22(e) 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, and under section
12(d)(1)(J) for an exemption from
sections 12(d)(1)(A) and (B) of the Act.
Grail Advisors, LLC
(‘‘Adviser’’) and Grail Advisors’ Alpha
ETF Trust (‘‘Trust’’).
SUMMARY OF APPLICATION: Applicants
request an order that permits: (a) Series
of certain open-end management
investment companies to issue shares
(‘‘Shares’’) redeemable in large
aggregations only (‘‘Creation Units’’); (b)
secondary market transactions in Shares
to occur at negotiated market prices; (c)
certain series to pay redemption
proceeds, under certain circumstances,
more than seven days from the tender of
Shares for redemption; (d) certain
affiliated persons of the series to deposit
securities into, and receive securities
from, the series in connection with the
purchase and redemption of Creation
Units; and (e) certain registered
management investment companies and
unit investment trusts outside of the
same group of investment companies as
the series to acquire Shares.
FILING DATES: The application was filed
on October 17, 2007 and amended on
August 1, 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 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 January 15, 2009, 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
APPLICANTS:
E:\FR\FM\31DEN1.SGM
31DEN1
Agencies
[Federal Register Volume 73, Number 251 (Wednesday, December 31, 2008)]
[Notices]
[Pages 80454-80457]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-31086]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 28568; 812-13488]
AdvisorShares Investments, LLC and AdvisorShares Trust; Notice of
Application
December 23, 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 (``Act'') for an exemption from sections
2(a)(32), 5(a)(1) and 22(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.
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Applicants: AdvisorShares Investments, LLC (the ``Advisor'') and
AdvisorShares Trust (the ``Trust'').
Summary of Application: Applicants request an order that permits:
(a) Series of certain open-end management investment companies to issue
shares (``Shares'') redeemable in large aggregations only (``Creation
Units''); (b) secondary market transactions in Shares to occur at
negotiated market prices; and (c) certain affiliated persons of the
series to deposit securities into, and receive securities from, the
series in connection with the purchase and redemption of Creation
Units.
Filing Dates: The application was filed on January 31, 2008, and
amended on October 17, 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 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 January 15, 2009, 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: Noah Hamman, c/o
Morgan, Lewis & Bockius LLP, 1111 Pennsylvania Avenue, NW., Washington,
DC 20004.
FOR FURTHER INFORMATION CONTACT: Courtney S. Thornton, Senior Counsel,
or Michael W. Mundt, 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 Desk, 100 F Street, NE., Washington, DC
20549-1520 (tel. 202-551-5850).
Applicants' Representations
1. The Trust, a statutory trust established under the laws of
Delaware, is registered with the Commission as an open-end management
investment company. The Trust is organized as a series investment
company with one initial series (the ``Initial Fund''). The investment
objective of the Initial Fund will be to provide long term growth of
capital. The Initial Fund and all future series of the Trust (``Future
Funds,'' collectively with the Initial Fund, ``Funds'') will attempt to
achieve their investment objectives by utilizing active management
strategies based on various formulas for asset allocation, security
selection, and portfolio construction. Each Fund will primarily hold
shares of underlying exchange traded funds (``ETFs''), as well as
shares of certain exchange traded products that are not registered as
investment companies under the Act.\1\ Applicants will only
[[Page 80455]]
invest in unaffiliated ETFs that have received certain exemptive relief
from the Commission to permit such investments in excess of the limits
of section 12(d)(1)(A) and (B) of the Act. Any Future Fund (a) will be
advised by the Advisor or an entity controlled by or under common
control with the Advisor, and (b) will comply with the terms and
conditions of the order.
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\1\ The Funds may invest in exchange traded products that invest
primarily in commodities or currency, but otherwise operate in a
manner similar to exchange traded products registered under the Act.
In addition, the Funds may also invest in equity securities or fixed
income securities traded in a U.S. or non-U.S. markets, as well as
futures contracts, options on such futures contracts, swaps, forward
contracts or other derivatives, and shares of money market mutual
funds or other investment companies, all in accordance with their
investment objectives. The Funds may also invest in equity
securities or fixed income securities traded in international
markets or in a combination of equity, fixed income and U.S. money
market securities and/or non-U.S. money market securities.
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2. The Advisor, a Delaware limited liability company, or a
subsidiary of such company, will serve as the investment adviser to
each Fund. The Advisor will be registered as an investment adviser of
the Investment Advisers Act of 1940 (``Advisers Act'') prior to a Fund
beginning operations. Applicants anticipate that Funds also may engage
subadvisors (``Subadvisors'').
3. Applicants anticipate that shares (``Shares'') of the Funds will
be sold at a price of between $25 and $200 per Share in Creation Units
of 25,000 or more Shares. All orders to purchase Creation Units must be
placed with the principal underwriter and distributor of the Creation
Units (``Distributor'') by or through a party that has entered into a
participant agreement with the Distributor (``Authorized
Participant''). Authorized Participants will include broker-dealers,
banks, trust companies, and clearing companies that are participants in
the Depository Trust Company (``DTC,'' and such participants, ``DTC
Participants''). Purchases of Creation Units of the Funds will be made
generally by means of an in-kind tender of shares of specific ETFs (the
``Deposit Securities''), with any cash portion of the purchase price
(the ``Cash Amount'') to be kept to a minimum. The Cash Amount is an
amount equal to the difference between the NAV of a Creation Unit and
the market value of the Deposit Securities. The Trust reserves the
right to permit, under certain circumstances, a purchaser of Creation
Units to substitute cash in lieu of depositing some or all of the
requisite Deposit Securities. The Trust may in the future determine
that Shares of one or more Funds may be purchased in Creation Units on
a cash-only basis if the Trust and the Advisor believe such method
would substantially minimize the Trust's transactional costs or enhance
its operational efficiencies.
4. Each Fund will charge a fee (``Transaction Fee'') in connection
with the sale or redemption of Creation Units to protect existing
shareholders from the dilutive costs associated with the purchase and
redemption of Creation Units. Each purchaser of a Creation Unit will
receive a prospectus (``Prospectus'') that contains complete disclosure
about the Transaction Fee. All orders to purchase Creation Units must
be placed with the Distributor no later than the closing time of the
regular trading session on the NYSE (ordinarily 4 p.m. ET) in order for
the purchaser to receive the NAV determined on that date. The
Distributor will transmit all purchase orders to the relevant Fund and
will also maintain a record of Creation Unit purchases, send out
confirmations of such purchases, and furnish a Prospectus to purchasers
of Creation Units.
5. The Trust intends to list the Shares of each Fund on a national
securities exchange (``Listing Market'') such as the NYSE. It is
expected that one or more member firms will be designated to act as a
specialist and maintain a market for the Shares trading on the Listing
Market (``Exchange Specialist''). The price of Shares trading on the
Listing Market will be based on a current bid/offer market. No
secondary sales will be made to brokers or dealers at a concession by
the Distributor or by a Fund. Purchases and sales of Shares in the
secondary market, which will not involve a Fund, will be subject to
customary brokerage commissions and charges.
6. Purchasers of Shares in Creation Units may hold such Shares or
may sell them into the secondary market. Applicants expect that
purchasers of Creation Units will include institutional investors and
arbitrageurs, who will purchase or redeem Creation Units of a Fund in
pursuit of arbitrage profit and thereby enhance the liquidity of the
secondary market and keep the market price of shares close to their
NAV. Applicants expect that secondary market purchasers of Shares will
include both institutional investors and retail investors for whom
Shares will provide a useful, retail-priced, exchange-traded mechanism
for investing in a professionally managed, diversified selection of
ETFs.\2\
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\2\ Shares will be registered in book-entry form only. DTC or
its nominee will be the registered owner of all outstanding Shares.
DTC or DTC Participants will maintain records reflecting beneficial
owners of Shares.
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7. Shares will not be individually redeemable, and owners of Shares
may acquire those Shares from a Fund, or tender such Shares for
redemption to the Fund, in Creation Units only. To redeem, an investor
will have to accumulate enough Shares to constitute a Creation Unit.
Redemption orders must be placed by or through an Authorized
Participant. A redeeming investor will receive a basket of securities
designated to be delivered for Creation Unit redemptions on the date
that the request for redemption is submitted (``Redemption
Securities''), which in most cases will be the same as the Deposit
Securities required to purchase Creation Units on that date, and will
either receive from or pay to the Fund a balancing amount in cash. A
Fund may make redemptions partly in cash in lieu of transferring one or
more Redemption Securities to a redeeming investor if the Fund
determines that such alternative is warranted, such as if the redeeming
investor is unable, by law or policy, to own a particular Redemption
Security. A redeeming investor also must pay a Transaction Fee to cover
custodial costs.
8. The Trust will not be advertised or marketed or otherwise ``held
out'' as a traditional open-end investment company or a mutual fund.
The designation of the Trust and the Funds in all marketing materials
will be limited to the terms ``exchange-traded fund,'' ``investment
company,'' ``fund'' and ``trust'' without reference to an ``open-end
fund'' or a ``mutual fund,'' except to compare and contrast the Trust
and the Funds with traditional mutual funds. Each Fund's Prospectus
will also prominently disclose that the Fund is an actively managed
exchange traded fund. All marketing materials that describe the method
of obtaining, buying or selling Creation Units, or Shares traded on the
Listing Market, or refer to redeemability, will prominently disclose
that Shares are not individually redeemable and that the owners of
Shares may acquire or redeem Shares from a Fund in Creation Units only.
The same approach will be followed in the statement of additional
information (``SAI''), shareholder reports and investor educational
materials issued or circulated in connection with the Shares. The Trust
will provide copies of its annual and semi-annual shareholder reports
to DTC Participants for distribution to beneficial owners of Shares.
9. The Trust (or the Listing Market) intends to maintain a Web site
that will be publicly available at no charge, which will include the
Prospectus and other information about the Funds that is updated on a
daily basis. On each Business Day, before the commencement of trading
in Shares on the Listing Market, each Fund will disclose the identities
and quantities of the securities (``Portfolio Securities'') and other
assets held in the Fund portfolio that will form the basis for the
[[Page 80456]]
Fund's calculation of NAV at the end of the Business Day.\3\
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\3\ Applicants note that under accounting procedures followed by
the Fund, trades made on the prior Business Day (``T'') will be
booked and reflected in NAV on the current Business Day (``T + 1'').
Accordingly, the Fund will be able to disclose at the beginning of
the Business Day the portfolio that will form the basis for the NAV
calculation at the end of the Business Day.
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Applicants' Legal Analysis
1. Applicants request an order under section 6(c) of the Act
granting an exemption from sections 2(a)(32), 5(a)(1) and 22(d) of the
Act and rule 22c-1 under the Act, and under sections 6(c) and 17(b) of
the Act granting an exemption from sections 17(a)(1) and (a)(2) of the
Act.
2. Section 6(c) of the Act provides that the Commission may exempt
any person, security or transaction, or any class of persons,
securities or transactions, from any provision of the Act, if and to
the extent that such exemption is necessary or appropriate in the
public interest and consistent with the protection of investors and the
purposes fairly intended by the policy and provisions of the Act.
Section 17(b) of the Act authorizes the Commission to exempt a proposed
transaction from section 17(a) of the Act if evidence establishes that
the terms of the transaction, including the consideration to be paid or
received, are reasonable and fair and do not involve overreaching on
the part of any person concerned, and the proposed transaction is
consistent with the policies of the registered investment company and
the general provisions of the Act.
Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an ``open-end company'' as a
management investment company that is offering for sale or has
outstanding any redeemable security of which it is the issuer. Section
2(a)(32) of the Act defines a redeemable security as any security,
other than short-term paper, under the terms of which the holder, upon
its presentation to the issuer, is entitled to receive approximately
his proportionate share of the issuer's current net assets, or the cash
equivalent. Because Shares will not be individually redeemable,
applicants request an order that would permit each Fund, as a series of
an open-end management investment company, to issue Shares that are
redeemable in Creation Units only. Applicants state that Creation Units
will always be redeemable. Applicants further state that because
Creation Units may always be purchased and redeemed at NAV (less
certain transactional expenses), the price of Creation Units on the
secondary market and the price of the individual Shares of a Creation
Unit, taken together, should not vary substantially from the NAV of
Creation Units.
Section 22(d) of the Act and Rule 22c-1 under the Act
4. Section 22(d) of the Act, among other things, prohibits a dealer
from selling a redeemable security, which is currently being offered to
the public by or through a principal underwriter, except at a current
public offering price described in the prospectus. Rule 22c-1 under the
Act generally requires that a dealer selling, redeeming, or
repurchasing a redeemable security do so only at a price based on its
NAV. Applicants state that trading in Shares will take place on and
away from the Listing Market at all times on the basis of current bid/
offer prices, not at a current offering price described in the
prospectus, and not at a price based on NAV. Thus, purchases and sales
of Shares in the secondary market will not comply with section 22(d) of
the Act and rule 22c-1 under the Act. Applicants request an exemption
under section 6(c) from these provisions.
5. Applicants assert that the concerns sought to be addressed by
section 22(d) of the Act and rule 22c-1 under the Act with respect to
pricing are equally satisfied by the proposed method of pricing Shares.
Applicants maintain that while there is little legislative history
regarding section 22(d), its provisions, as well as those of rule 22c-
1, appear to have been designed to (a) prevent dilution caused by
certain riskless-trading schemes by principal underwriters and contract
dealers, (b) prevent unjust discrimination or preferential treatment
among buyers, and (c) assure an orderly distribution of investment
company shares by contract dealers by eliminating price competition
from non-contract dealers who could offer investors shares at less than
the published sales price and who could pay investors a little more
than the published redemption price.
6. Applicants believe that none of these purposes will be relevant
issues for secondary trading by dealers in Shares of a Fund. Applicants
state that (a) secondary market trading in Shares will not cause
dilution for owners of such Shares because such transactions do not
directly involve Fund assets, and (b) to the extent different prices
exist during a given trading day, or from day to day, such variances
occur as a result of third-party market forces, such as supply and
demand, but do not occur as a result of unjust or discriminatory
manipulation. Finally, applicants contend that the proposed
distribution system will be orderly because arbitrage activity will
ensure that the difference between the market price of Shares and their
NAV remains narrow.
Sections 17(a)(1) and 17(a)(2) of the Act
7. Section 17(a)(1) and (2) of the Act generally prohibit an
affiliated person of a registered investment company, or an affiliated
person of such a person (``second tier affiliate''), from selling any
security to or purchasing any security from the company. Section
2(a)(3) of the Act defines ``affiliated person'' to include any person
directly or indirectly owning, controlling, or holding with power to
vote 5 percent or more of the outstanding voting securities of the
other person and any person directly or indirectly controlling,
controlled by, or under common control with, the other person. Section
2(a)(9) of the Act provides that a control relationship will be
presumed where one person owns more than 25 percent of another person's
voting securities. The Funds may be deemed to be controlled by the
Advisor or an entity controlling, controlled by or under common control
with the Adviser and hence affiliated persons of each other. In
addition, the Funds may be deemed to be under common control with any
other registered investment company (or series thereof) advised by the
Advisor or an entity controlling, controlled by or under common control
with the Advisor (an ``Affiliated Fund''). Applicants state that an
investor could own 5 percent or more of a Fund or the Trust, or in
excess of 25 percent of the outstanding Shares of a Fund or the Trust,
making that investor an affiliated person of the Fund or the Trust
under section 2(a)(3)(A) or 2(a)(3)(C) of the Act. For so long as such
an investor was deemed to be an affiliated person, section 17(a)(1)
could be read to prohibit that investor from depositing the Deposit
Securities with a Fund in return for a Creation Unit. Similarly,
section 17(a)(2) could be read to prohibit such an investor from
entering into an in-kind redemption with a Fund.
8. Applicants request an exemption from section 17(a) under
sections 6(c) and 17(b), to permit in-kind purchases and redemptions by
persons that are affiliated persons or second tier affiliates of the
Funds solely by virtue of one or more of the following: (1) Holding 5
percent or more, or more than 25 percent, of the outstanding Shares of
the Trust or one or more Funds; (2) an affiliation with a person with
an ownership interest described in (1); or
[[Page 80457]]
(3) holding 5 percent or more, or more than 25 percent, of the shares
of one or more Affiliated Funds.
9. Applicants contend that no useful purpose would be served by
prohibiting the affiliated persons or second tier affiliates of a Fund
as described above from purchasing or redeeming Creation Units through
``in-kind'' transactions. The purchase and redemption of Creation Units
of each Fund is on the same terms for all investors, whether or not
such investor is an affiliate. In each case, Creation Units are sold
and redeemed by the Trust at their NAV. The Deposit Securities and
Redemption Securities will be valued in the same manner as the
securities in the Fund portfolio. Accordingly, applicants believe the
proposed transactions described above meet the section 17(b) standards
for relief because the terms of such proposed transactions are
reasonable and fair and do not involve overreaching on the part of any
person concerned, and the proposed transactions will be consistent with
the policies of each Fund and with the general purposes of the Act.
Applicants' Conditions
The applicants agree that any order of the Commission granting the
requested relief will be subject to the following conditions:
1. Neither the Trust nor any Fund will be advertised or marketed as
an open-end investment company or mutual fund. Each Fund's Prospectus
will prominently disclose that the Fund is an actively managed
exchange-traded fund. Each Prospectus will prominently disclose that
the Shares are not individually redeemable shares and will disclose
that the owners of the Shares may acquire those Shares from the Fund
and tender those Shares for redemption to the Fund in Creation Units
only. Any advertising material that describes the purchase or sale of
Creation Units or refers to redeemability will prominently disclose
that the Shares are not individually redeemable and that owners of the
Shares may acquire those Shares from the Fund and tender those Shares
for redemption to the Fund in Creation Units only.
2. Each Fund's Prospectus will clearly disclose that, for purposes
of the Act, Shares are issued by a registered investment company and
that the acquisition of Shares by investment companies and companies
relying on sections 3(c)(1) or 3(c)(7) of the Act is subject to the
restrictions of section 12(d)(1) of the Act.
3. The Web site for the Funds, which will be publicly accessible at
no charge, will contain the following information, on a per Share
basis, for each Fund: (a) The prior Business Day's NAV and the reported
closing price, and a calculation of the premium or discount of the
closing price against such NAV; and (b) data in chart format displaying
the frequency distribution of discounts and premiums of the daily
closing price against the NAV, within appropriate ranges, for each of
the four previous calendar quarters (or for the life of the Fund, if
shorter).
4. The Prospectus and annual report for each Fund will also
include: (a) The information listed in condition 3(b), (i) in the case
of the Prospectus, for the most recently completed year (and the most
recently completed quarter or quarters, as applicable) and (ii) in the
case of the annual report, for the immediately preceding five years (or
for the life of the Fund, if shorter), and (b) the cumulative total
return and the average annual total return based on NAV and closing
price, calculated on a per Share basis for one-, five- and ten-year
periods (or life of the Fund, if shorter).
5. As long as the Funds operate in reliance on the requested order,
the Shares of the Funds will be listed on a Listing Market.
6. On each Business Day, before commencement of trading in Shares
on a Fund's Listing Market, the Fund will disclose on its Web site the
identities and weightings of the component securities and other assets
held by the Fund that will form the basis for the Fund's calculation of
NAV at the end of the Business Day.
7. The Advisor or any Subadvisor, directly or indirectly, will not
cause any Authorized Participant (or any investor on whose behalf an
Authorized Participant may transact with the Fund) to acquire any
Deposit Security for the Fund through a transaction in which the Fund
could not engage directly.
8. The requested order will expire on the effective date of any
Commission rule under the Act that provides relief permitting the
operation of actively managed exchange-traded funds.
For the Commission, by the Division of Investment Management,
under delegated authority.
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8-31086 Filed 12-30-08; 8:45 am]
BILLING CODE 8011-01-P