Sun Life Assurance Company of Canada (U.S.), et al., Notice of Application, 80464-80468 [E8-31088]
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80464
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Management Company may invest.
These findings and their basis will be
recorded fully in the minute books of
the appropriate Investing Management
Company.
11. Any sales charges and/or service
fees charged with respect to shares of a
Fund of Funds will not exceed the
limits applicable to a Fund of Funds as
set forth in Rule 2830.
12. No Fund will acquire securities of
an investment company or company
relying on section 3(c)(1) or 3(c)(7) of
the Act in excess of the limits contained
in section 12(d)(1)(A) of the Act.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8–31089 Filed 12–30–08; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–28570; File No. 812–13402]
Sun Life Assurance Company of
Canada (U.S.), et al., Notice of
Application
December 23, 2008.
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AGENCY: Securities and Exchange
Commission (the ‘‘Commission’’).
ACTION: Notice of application for an
order of approval pursuant to Section
26(c) of the Investment Company Act of
1940, as amended (the ‘‘Act’’), and an
order of exemption pursuant to Section
17(b) of the Act from Section 17(a) of
the Act.
Applicants: Sun Life Assurance
Company of Canada (U.S.) (‘‘Sun Life
U.S.’’), Sun Life Insurance and Annuity
Company of New York (‘‘Sun Life
N.Y.’’) (together with Sun Life U.S., the
‘‘Companies’’), Sun Life of Canada
(U.S.) Variable Account F (‘‘Account
F’’), Sun Life of Canada (U.S.) Variable
Account G (‘‘Account G’’), Sun Life of
Canada (U.S.) Variable Account I
(‘‘Account I’’), Sun Life (N.Y.) Variable
Account C (‘‘Account C’’), Sun Life
(N.Y.) Variable Account D (‘‘Account
D’’), and Sun Life (N.Y.) Variable
Account J (‘‘Account J’’) (collectively,
the ‘‘Applicants’’). Applicants, together
with Sun Capital Advisers Trust (‘‘Sun
Capital Trust’’) are ‘‘Section 17(b)
Applicants.’’
Summary of Application: Applicants
seek an order approving the proposed
substitutions (the ‘‘Substitutions’’)
under certain variable life insurance
policies and variable annuity contracts
(‘‘Contracts’’) of Class VC shares of the
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Lord Abbett Growth and Income
Portfolio and the Lord Abbett Mid-Cap
Value Portfolio of Lord Abbett Series
Fund, Inc. (‘‘LA Series’’), and
Administrative Class shares of the
PIMCO High Yield Portfolio and the
PIMCO Low Duration Portfolio of the
PIMCO Variable Insurance Trust with
Initial Class shares of the following
portfolios of Sun Capital Trust,
respectively: The SC Lord Abbett
Growth & Income Fund, the SC
Goldman Sachs Mid Cap Value Fund,
the SC PIMCO High Yield Fund, and the
SC Goldman Sachs Short Duration
Fund. Section 17(b) Applicants also
seek an order pursuant to Section 17(b)
of the Act to permit certain in-kind
transactions in connection with the
Substitutions.
Filing Date: The application was
originally filed on July 9, 2007, and an
amended and restated application was
filed on December 18, 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 Secretary of
the Commission and serving Applicants
with a copy of the request, personally or
by mail. Hearing requests must be
received by the Commission by 5:30
p.m. on January 21, 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 requester’s interest, the reason for
the request, and the issues contested.
Persons who wish to be notified of a
hearing may request notification by
writing to the Secretary of the
Commission.
ADDRESSES: The Commission: Secretary,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–1090; Applicants: c/o Maura A.
Murphy, Esq., Sun Life Assurance
Company of Canada (U.S.), One Sun
Life Executive Park, Wellesley Hills,
Massachusetts 02481.
FOR FURTHER INFORMATION CONTACT:
Rebecca A. Marquigny, Senior Counsel,
or Joyce M. Pickholz, Branch Chief,
Office of Insurance Products, Division of
Investment Management, at (202) 551–
6795.
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application is
available for a fee from the Public
Reference Branch of the Commission,
100 F Street, NE., Washington, DC
20549 (202–551–8090).
Applicants’ and Section 17
Applicants’ Representations and
Conditions:
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1. Sun Life U.S. is a stock life
insurance company ultimately
controlled by Sun Life Financial Inc.
(‘‘Sun Life Financial’’), a Canadian
reporting company under the Securities
Exchange Act of 1934 (the ‘‘1934 Act’’).
Sun Life U.S. is the depositor and
sponsor of Account F, Account G, and
Account I.
2. Account F is registered as a unit
investment trust (File No. 811–05846);
its interests are offered through
Contracts (the ‘‘Account F Contracts’’)
registered under the Securities Act of
1933 (‘‘1933 Act’’) on Form N–4 (File
Nos. 033–41628, 333–37907, 333–
05227, 333–30844, 333–31248, 333–
41438, 333–74844, 333–82957, 333–
83362, 333–83364, 333–83516, 333–
115536, and 333–115525). Similarly,
Account G, registered as a unit
investment trust (File No. 811–07837)
offers its interests through Contracts (the
‘‘Account G Contracts’’) registered
under the 1933 Act on Form N–6 (File
Nos. 333–65048, 333–13087, and 333–
111688). Account I, registered as a unit
investment trust (File No. 811–09137)
also offers its interests through
Contracts (the ‘‘Account I Contracts’’)
registered under the 1933 Act on Form
N–6 (File Nos. 333–68601, 333–100831,
333–59662, 333–100829, 333–94359,
333–143353, 333–143354, and 333–
144628).
3. Sun Life N.Y., a wholly owned
subsidiary of Sun Life U.S., is a stock
life insurance company and is the
depositor and sponsor of Account C,
Account D, and Account J.
4. Account C, a registered unit
investment trust (File No. 811–04440),
also offers its interests through certain
Contracts (the ‘‘Account C Contracts’’)
registered under the 1933 Act on Form
N–4 (File Nos. 333–05037, 333–67864,
333–119151, 333–119154, 333–100474,
333–107983, 333–99907, and 333–
100475). Similarly, Account D,
registered as a unit investment trust
(File No. 811–04633) offers its interests
through Contracts (the ‘‘Account D
Contracts’’) registered under the 2933
Act on Form N–6 (File Nos. 333–
105437, 333–105438, and 333–105441).
Account J, registered as a unit
investment trust (File No. 811–21937)
also offers its interests through
Contracts (the ‘‘Account J Contracts’’)
registered under the 1933 Act on Form
N–6 (File Nos. 333–136433 and 333–
136435).
5. All of the Contracts involved in the
Substitutions (a) reserve the right to
substitute shares of one portfolio for
shares of another; (b) permit transfers of
contract value among the subaccounts
pursuant to the limitations of the
particular Contract, (c) impose or
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reserve the right to impose a transfer
charge (except Accounts G and J); and
(d) are subject to market timing policies
and procedures that may operate to
limit transfers.
6. Applicants represent that all of the
portfolios involved in the Substitutions
are currently available to new and
existing Contract owners (and will
continue to be available until the time
the substitutions occur) for the
allocation of purchase payments and
transfer of contract value.
7. Lord Abbett Growth and Income
Portfolio (‘‘Old Growth & Income’’) and
Lord Abbett Mid-Cap Value Portfolio
(‘‘Old Mid-Cap Value’’) (each,
individually, an ‘‘Old Portfolio’’ and
collectively, ‘‘Old LA Portfolios’’) are
portfolios of LA Series, a registered,
diversified, open-end management
investment company (File No. 811–
05876). Class VC shares of Old LA
Portfolios are registered under the 1933
Act on Form N–1A (File No. 33–31072).
The investment adviser to Old LA
Portfolios is Lord Abbett & Co., LLC
(‘‘Lord Abbett’’).
8. PIMCO High Yield Portfolio (‘‘Old
High Yield’’) and PIMCO Low Duration
Portfolio (‘‘Old Low Duration’’) (each,
individually, an ‘‘Old Portfolio’’ and
collectively, ‘‘Old PIMCO Portfolios’’)
are portfolios of PIMCO Variable
Insurance Trust, a registered,
diversified, open-end management
investment company (File No. 811–
08399). Administrative Class shares of
Old PIMCO Portfolios are registered
under the 1933 Act on Form N–1A (File
No. 333–37115). The investment adviser
to Old PIMCO Portfolios is Pacific
Investment Management Company LLC
(‘‘PIMCO’’).
9. The following ‘‘New Portfolios’’
(each, individually, a ‘‘New Portfolio’’)
are portfolios of Sun Capital Trust, a
registered, diversified, open-end
management investment company (File
No. 811–08879): SC Lord Abbett Growth
& Income Fund (‘‘New Growth &
Income’’), SC Goldman Sachs Mid Cap
Value Fund (‘‘New Mid Cap Value’’), SC
PIMCO High Yield Fund (‘‘New High
Yield’’), and SC Goldman Sachs Short
Duration Fund (‘‘New Short Duration’’).
Initial Class shares of New Portfolios are
registered under the 1933 Act on Form
N–1A (File No. 333–59093) and are not
subject to a distribution fee.
10. Sun Capital Advisers LLC (‘‘Sun
Capital’’), an indirect, wholly owned
subsidiary of Sun Life Financial, is
investment adviser to all the Sun
Capital Trust portfolios. Through an
order from the Commission pursuant to
Section 6(c) of the Act, Sun Capital is
exempt from Section 15(a) of the Act
and Rule 18f-2 thereunder with respect
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to subadvisory agreements (the
‘‘Manager of Managers Order’’).1
11. Applicants represent that the
relief granted in the Manager of
Managers Order extends to New
Portfolios permitting Sun Capital to
enter into and materially amend
investment subadvisory agreements
without obtaining shareholder approval.
Applicants also indicate that the
prospectus for the New Portfolios will
disclose and explain the existence,
substance and effect of the Manager of
Managers Order.
12. Applicants propose to substitute
Initial Class shares of (a) New Growth &
Income for Class VC shares of Old
Growth & Income; (b) New Mid Cap
Value for Class VC shares of Old Mid
Cap Value; (c) New High Yield for
Administrative Class shares of Old High
Yield; and (d) New Short Duration for
Administrative Class shares of Old Low
Duration. Applicants state that the
proposed Substitutions are not intended
to effect an overall reorganization or
merger of any of the underlying
investment options offered in the
Contracts. Applicants assert their belief
that:
(a) Reducing the number of
nonproprietary funds will provide the
Companies with more control over fund
changes that affect the Contracts;
(b) The New Portfolios better promote
their goals of increasing administrative
efficiency of, and control over, their
Contracts as the New Portfolios are part
of their proprietary fund family;
(c) This streamlining will allow the
Companies to enhance their
communication efforts to Contract
owners and sales representatives
regarding the available portfolios, and
may provide for more enhanced and
timely reporting from the Companies to
Contract owners with respect to changes
in the underlying funds.
13. Applicants represent that because
the New Portfolios operate pursuant to
the Manager of Managers Order (and
assuming that the Applicants first
obtain shareholder approval of a change
in a New Portfolio’s subadviser or of a
New Portfolio’s continued ability to rely
on the Manager of Manager’s Order), the
Substitutions would provide protection
to Contract owners by giving Sun
Capital the agility and flexibility to
change the subadviser of the New
Portfolios should such a change become
warranted or advisable. In support of
the Substitutions, Applicants assert that
the investment objectives and policies
of the New Portfolios are sufficiently
similar to those of the corresponding
Old Portfolios that Contract owners will
have reasonable continuity in
investment expectations. The following
summarizes the more complete
comparison of New and Old Portfolios
provided in the Application.
14. Growth & Income Portfolio
Substitution
Applicants state that both Old Growth
& Income and New Growth & Income
share the identical investment objective
to ‘‘seek long-term growth of capital and
income without excessive fluctuations
in market value.’’ Applicants state that
the principal investment strategies of
the two portfolios are virtually identical
noting that both invest at least 80% of
net assets in equity securities of large
companies defined as those having
capitalization within the range of the
companies in the Russell 1000 Index at
the time of purchase. Both portfolios
primarily purchase equity securities of
large, seasoned, U.S. and multinational
companies that are believed to be
undervalued, and both attempt to invest
in securities selling at reasonable prices
in relation to their potential value.
Applicants also represent that both
portfolios share substantially similar
risk profiles.
Charges for Class VC of Old Growth
& Income include Management Fees of
0.47% and Other Expenses of 0.41%.2
Total Operating Expenses for Initial
Class shares of New Growth & Income
are 0.88% which represents 0.01% in
Other Expenses and a 0.87% unified
management fee (subject to a 0.87%
contractual limitation on Total
Operating Expenses). Neither portfolio
charges a 12b–1 Fee. Old Growth &
Income’s total gross and net operating
expenses are both 0.88%. Respectively,
New Growth & Income’s total gross and
net operating expenses are 0.88% and
0.87% (reflecting the contractual
expense limitation agreement).
15. Mid Cap Value Portfolio
Substitution
Applicants state that both Old Mid
Cap Value and New Mid Cap Value
share a similar investment objective
because Old Mid Cap Value ‘‘seeks
capital appreciation through
investments, primarily in equity
securities, which are believed to be
undervalued in the marketplace’’ and
New Mid Cap Value ‘‘seeks long-term
return of capital.’’ Applicants state that
1 Sun Capital Advisers Trust and Sun Capital
Advisers, Inc., 1940 Act Rel. No. 24401 (April 24,
2000) (Order), File No. 812–11790; see also Sun
Capital Advisers Trust and Sun Capital Advisers,
Inc., 1940 Act Rel. No. 23793 (Apr. 20, 1999)
(Order), File No. 812–11464.
2 For the descriptions of charges involved in the
Substitution, all percentages for the Management
Fees, 12b–1 Fees, Other Expenses, Fee Reductions,
Total Gross and Net Annual Operating Expenses,
and Separate Account Fees represent a percentage
of average annual assets.
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the principal investment strategies of
the two portfolios are similar noting that
both employ a value approach to
investing and normally invest at least
80% of net assets, plus the amount of
any borrowings for investment
purposes, in securities of mid-sized
companies. Applicants represent that
both Old Mid Cap Value and New Mid
Cap Value have substantially similar
risk characteristics which are presented
in greater detail in the Application.
Charges for Class VC of Old Mid Cap
Value include Management Fees of
0.74% and Other Expenses of 0.38%.
Total Operating Expenses for Initial
Class shares of New Mid Cap Value are
1.06% which represents 0.01% in Other
Expenses and a 1.05% unified
management fee (subject to a 1.07%
contractual limitation on Total
Operating Expenses). Neither portfolio
charges a 12b–1 Fee. Old Mid Cap
Value’s total gross and net operating
expenses are both 1.12% while New
Mid Cap Value’s total gross and net
operating expenses are both 1.06%.
16. High Yield Portfolio Substitutions
Applicants represent that Old High
Yield and New High Yield share a
virtually identical investment objective
because New High Yield seeks
‘‘maximum total return, consistent with
capital preservation’’ and Old High
Yield seeks the same ‘‘and prudent
investment management.’’ Applicants
represent that under normal
circumstances both invest at least 80%
of assets in a diversified portfolio of
high yield junk bonds rated at least Caa
by Moody’s or equivalently rated by
S&P or Fitch, or, if unrated, determined
by the adviser or subadviser to be of
comparable quality. Applicants state
that neither portfolio may invest more
than 5% of total assets in securities of
equal or lower rating. Applicants
represent that both portfolios employ an
average portfolio duration within a twoto-six year time frame and may invest
up to the same percentages of total
assets in issuers located in countries
with developing economies. Applicants
assert that the limits for investment in
foreign currency denominated securities
and U.S. dollar-denominated securities
of foreign issuers are the same for both
portfolios. Applicants also identify
other similar strategies including that
both portfolios may invest all of their
assets in derivative instruments. In
addition, Applicants represent that both
Old High Yield and New High Yield
have substantially similar risk
characteristics discussed at length in the
Application.
Charges for Administrative Class
shares of Old High Yield include
Management Fees of 0.25%, Service
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Fees of 0.15%, and Other Expenses of
0.35%. Charges for Initial Class shares
of New High Yield include a 0.74%
unified management fee and 0.01% in
Other Expenses. New High Yield does
not charge a service fee, and neither
portfolio charges a 12b–1 Fee. The total
gross and net operating expenses for
both Old High Yield and New High
Yield are 0.75%. In addition, New High
Yield’s fees are also subject to a 0.75%
contractual expense limitation on total
operating expenses for at least 24
months following the date of the
Substitutions.
17. Low/Short Duration Portfolio
Substitutions
Applicants represent that Old Low
Duration and New Short Duration share
a similar investment objective in that
Old Low Duration ‘‘seeks maximum
total return, consistent with
preservation of capital and prudent
investment management,’’ while New
Short Duration ‘‘primarily seeks a high
level of current income, with capital
appreciation as a secondary goal.’’
Applicants also represent that the
principal investment strategies of the
two portfolios are similar. Both invest
primarily in fixed income securities at
levels of total assets equal to at least
65% for Old Low Duration and 80% for
New Short Duration. In addition,
Applicants represent that both Old Low
Duration and New Short Duration have
similar risk characteristics discussed at
length in the Application.
Charges for Administrative Class
shares of Old Low Duration include
Management Fees of 0.25%, Service
Fees of 0.15%, and Other Expenses of
0.25%. Charges for Initial Class shares
of New Short Duration include a 0.64%
unified management fee and 0.01% in
Other Expenses. New Short Duration
does not charge a service fee, and
neither portfolio charges a 12b–1 Fee.
The total gross and net operating
expenses for both Old Low Duration and
New Short Duration are 0.65%. In
addition, New Short Duration’s fees are
also subject to a 0.65% contractual
expense limitation on total operating
expenses for at least 24 months
following the date of the Substitutions.
18. Applicants assert that as of the
effective date of the Substitutions
(‘‘Effective Date’’ or ‘‘Substitution
Date’’), each Separate Account will
redeem shares of the applicable Old
Portfolio in-kind. Applicants state that if
Sun Capital declines to accept particular
portfolio securities of any of the Old
Portfolios for purchase in-kind of shares
of the New Portfolios, the applicable
Old Portfolio will liquidate portfolio
securities as necessary, and shares of the
New Portfolio will be purchased with
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cash. Applicants represent that in either
event, the proceeds of such redemptions
will then be used to purchase shares of
the New Portfolios, with each
subaccount of the applicable Separate
Account investing the proceeds of its
redemption from the Old Portfolios in
the applicable New Portfolio.
19. Applicants further state that
redemption requests and purchase
orders will be placed simultaneously so
that contract values will remain fully
invested at all times. Applicants
represent that all redemptions of shares
of the Old Portfolios and purchases of
shares of the New Portfolios will be
effected in accordance with Section
22(c) of the Act and Rule 22c–1
thereunder. Applicants state that the
Substitutions will take place at relative
net asset value as of the Effective Date
with no change in the amount of any
Contract owner’s contract value or death
benefit or in the dollar value of his or
her investments in any of the
subaccounts. Applicants represent that
Contract values attributable to
investments in the Old Portfolios will be
transferred to the New Portfolios
without charge and without counting
toward the number of transfers that may
be permitted without charge.
20. Applicants further represent that
all expenses incurred in connection
with the Substitutions, including legal,
accounting, transactional, and other fees
and expenses, including brokerage
commissions, will be paid by Sun Life
U.S. or Sun Life N.Y. Applicants also
state that, as a result of the
Substitutions, Contract owners will not
incur any additional fees or charges, nor
will their rights or insurance benefits or
the Companies’ obligations under the
Contracts be altered. Applicants assert
that the Substitutions: (a) Will not
impose any tax liability on Contract
owners; and (b) will not cause the
Contract fees and charges currently
being paid by existing Contract owners
to be greater after the Substitutions than
before the Substitutions. Applicants
represent that neither Sun Life U.S. nor
Sun Life N.Y. will exercise any right
either may have under the Contracts to
impose restrictions on transfers under
the Contracts for the period from the
date the Application was filed with the
Commission through at least thirty days
following the Effective Date.
21. The Companies represent that
during the twenty-four months
following the Effective Date, the total
net operating expenses of each New
Portfolio (taking into account any
expense waiver or reimbursement) will
not exceed the net expense level of the
corresponding Old Portfolio for the
fiscal year ended December 31, 2007.
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Applicants also state that for at least
twenty-four months following the date
of the Substitutions, Sun Capital has
contractually agreed to waive its
management fee and, if necessary, to
limit other ordinary operating expenses
so that total operating expenses, as a
percentage of average net assets, do not
exceed 0.87%, 1.07%, 0.75%, or 0.65%,
as applicable. In addition, Applicants
represent that for twenty-four months
following the date of the Substitutions,
the Companies will not increase assetbased fees or charges for Contracts
outstanding on the Effective Date.
22. Applicants represent that a
prospectus for the New Portfolio
containing disclosure describing the
existence, substance and effect of the
Manager of Managers Order will be
provided to each Contract owner prior
to or at the time of the Substitutions.
Notwithstanding the Manager of
Managers Order, the Applicants agree
not to change any New Portfolio’s
subadviser, add a new subadviser, or
otherwise rely on the Manager of
Managers Order without first obtaining
shareholder approval, following the
Effective Date of the Substitutions, of
either: (1) The subadviser change; or (2)
the New Portfolio’s continued ability to
rely on the Manager of Managers Order.
23. Applicants state that Contract
owners were or will be notified of the
proposed Substitutions by means of a
prospectus or prospectus supplement
for each of the Contracts stating that the
Applicants filed the Application and
seek approval for the Substitutions
(‘‘Pre-Substitution Notice’’). The PreSubstitution Notice sets forth the
anticipated Effective Date and explains
that contract values attributable to
investments in the Old Portfolios will be
transferred to the New Portfolios on the
Effective Date without charge (including
sales charges or surrender charges) and
without counting toward the number of
transfers that may be permitted without
charge. Applicants indicate that the PreSubstitution Notice states that, from the
date the initial application was filed
with the Commission through the date
thirty days after the Substitutions,
Contract owners may make one transfer
of contract value from each subaccount
investing in the Old Portfolios (before
the Substitutions) or a New Portfolio
(after the Substitutions) to one or more
other subaccount(s) without a transfer
charge and without that transfer
counting against their contractual
transfer limitations.
24. Applicants represent that all
Contract owners will have received a
copy of the most recent prospectus for
the New Portfolios prior to the
Substitutions. Applicants also agree
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that, within five days following the
Substitutions, Contract owners affected
by the Substitutions will be notified in
writing that the Substitutions were
carried out and that this notice will
restate the information set forth in the
Pre-Substitution Notice.
Applicants’ Legal Analysis
1. Section 26(c) of the Act makes it
unlawful for any depositor or trustee of
a registered unit investment trust
holding the security of a single issuer to
substitute another security for such
security unless the Commission
approves the substitution. The
Commission shall approve such a
substitution if the evidence establishes
that it is consistent with the protection
of investors and the purposes fairly
intended by the policy and provisions of
the Act.
2. Applicants submit that the
Substitutions meet the standards set
forth in Section 26(c) and assert that
replacement of the Old Portfolios with
the New Portfolio is consistent with the
protection of Contract owners and the
purposes fairly intended by the policy
and provisions of the Act. Applicants
have reserved the right to make such a
substitution under the Contracts and
represent that this reserved right is
disclosed in the prospectus for the
Contracts.
3. Section 17(a)(1) of the Act, in
relevant part, prohibits any affiliated
person of a registered investment
company, or any affiliated person of
such person, acting as principal, from
knowingly selling any security or other
property to that company. Section
17(a)(2) of the Act generally prohibits
the persons described above, acting as
principal, from knowingly purchasing
any security or other property from the
registered company. Pursuant to Section
17(a)(1) of the Act, the Section 17(b)
Applicants may be considered affiliates
of one or more of the portfolios involved
in the Substitutions. Because the
Substitutions may be effected, in whole
or in part, by means of in-kind
redemptions and subsequent purchases
of shares and by means of in-kind
transactions, the Substitutions may be
deemed to involve one or more
purchases or sales of securities or
property between affiliates.
4. Section 17(b) of the Act provides
that the Commission may, upon
application, grant an order exempting
any transaction from the prohibitions of
Section 17(a) if the evidence establishes
that: the terms of the proposed
transaction, including the consideration
to be paid or received, are reasonable
and fair and do not involve
overreaching on the part of any person
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80467
concerned; the proposed transaction is
consistent with the policy of each
registered investment company
concerned, as recited in its registration
statement and records filed under the
Act; and the proposed transaction is
consistent with the general purposes of
the Act.
5. The Section 17(b) Applicants state
that the terms under which the in-kind
redemptions and purchases will be
effected are reasonable and fair and do
not involve overreaching on the part of
any person principally because the
Substitutions will conform with all but
one of the conditions enumerated in
Rule 17a–7. Applicants assert that the
use of in-kind transactions will not
cause Contract owner interests to be
diluted. In support, Applicants
represent that: (a) The proposed
transactions will take place at relative
net asset value as of the Effective Date
in conformity with the requirements of
Section 22(c) of the 1940 Act and Rule
22c–1 thereunder with no change in the
amount of any Contract owner’s contract
value or death benefit or in the dollar
value of his or her investment in any of
the Separate Accounts; (b) Contract
owners will not suffer any adverse tax
consequences as a result of the
Substitutions; and (c) fees and charges
under the Contracts will not increase
because of the Substitutions.
6. Further, though the Section 17(b)
Applicants may not rely on Rule 17a–
7 because they cannot meet all of its
conditions, the Section 17(b) Applicants
agree to carry out the proposed in-kind
purchases in conformity with all of the
conditions of Rule 17a–7 and the
procedures adopted thereunder, except
that the consideration paid for the
securities being purchased or sold may
not be entirely cash. However,
Applicants assert that the circumstances
surrounding the Substitutions will offer
the same degree of protection to the
New Portfolios from overreaching that
Rule 17a–7 provides to it generally in
connection with its purchase and sale of
securities under that Rule in the
ordinary course of its business.
7. Applicants assert that the Board of
Sun Capital Trust has adopted
procedures, as required by paragraph
(e)(1) of Rule 17a–7, pursuant to which
its portfolios may purchase and sell
securities to and from their affiliates.
Applicants also note that the Companies
(or any of their affiliates) cannot effect
the proposed Substitutions at a price
disadvantageous to the New Portfolio.
Although the Substitutions may not be
entirely for cash, Applicants represent
that each will be effected based upon (1)
the independent market price of the
portfolio securities valued as specified
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Federal Register / Vol. 73, No. 251 / Wednesday, December 31, 2008 / Notices
in paragraph (b) of Rule 17a–7, and (2)
the net asset value per share of each
portfolio involved valued according to
the procedures disclosed in its
registration statement and as required
by Rule 22c–1 under the Act. The
Section 17(b) Applicants state that if
Sun Capital declines to accept particular
portfolio securities of either of the Old
Portfolios for purchase in-kind of shares
of a New Portfolio, the applicable Old
Portfolio will liquidate portfolio
securities as necessary and shares of the
New Portfolios will be purchased with
cash. Consistent with Rule 17a–7(d),
Applicants also agree that no brokerage
commissions, fees, or other
remuneration will be paid in connection
with the in-kind transactions.
SECURITIES AND EXCHANGE
COMMISSION
Conclusions
On November 3, 2008, the Boston
Stock Exchange (‘‘BSE’’ or ‘‘Exchange’’),
filed with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’),1 and
Rule 19b–4 thereunder,2 a proposed rule
change to: (i) Adopt new rules
governing membership, the regulatory
obligations of members, listing, and
equity trading (‘‘Equity Rules’’); (ii)
amend its certificate of incorporation
(‘‘Certificate’’) and by-laws (‘‘By-laws’’)
to reflect the proposed change in the
name of the Exchange to NASDAQ OMX
BX, Inc; (iii) amend and restate the
Operating Agreement of BSX Group LLC
(‘‘Operating Agreement’’), which will
operate the Exchange’s cash equities
trading business, and which will be
renamed NASDAQ OMX BX Equities
LLC (‘‘BX Equities LLC’’); and (iv) to
adopt a Delegation Agreement
(‘‘Delegation Agreement’’) between the
Exchange and BX Equities LLC
(formerly, BSX Group LLC). The
proposed rule change was published for
comment in the Federal Register on
November 19, 2008.3 On November 12,
2008, the Exchange filed Amendment
No. 1 to the proposed rule change.4 On
December 23, 2008, the Exchange filed
Amendment No. 2 to the proposed rule
change.5 Because Amendment Nos. 1
1. Applicants submit that for the
reasons and upon the facts set forth in
their application, the requested order
pursuant to Section 26(c) of the Act is
consistent with the protection of
investors and the purposes fairly
intended by the policy of the Contracts
and provisions of the Act and should,
therefore, be granted.
2. Section 17 Applicants represent
that the proposed in-kind transactions
are consistent with the general purposes
of the Act, do not present any of the
conditions or abuses the Act was
designed to prevent, and that an
exemption should be granted, to the
extent necessary, from the provisions of
Section 17(a).
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8–31088 Filed 12–30–08; 8:45 am]
BILLING CODE 8011–01–P
[Release No. 34–59154; File No. SR–BSE–
2008–48]
Self-Regulatory Organizations; Boston
Stock Exchange, Incorporated; Order
Approving a Proposed Rule Change,
as Modified by Amendment Nos. 1 and
2, To Establish New Rules for
Membership, Member Conduct, and
the Listing and Trading of Cash Equity
Securities; Order Granting an
Exemption for the Boston Stock
Exchange, Incorporated From Section
11A(b) of the Securities Exchange Act
of 1934
December 23, 2008.
I. Introduction
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 58927
(November 10, 2008), 73 FR 69685 (‘‘Notice’’).
4 Amendment No. 1 states that the Board of
Directors of the Exchange and the Board of
Directors of BSX Group LLC have completed all
action required to be taken in connection with the
proposed rule change.
5 Amendment No. 2 clarifies that: (1) Confidential
information pertaining to the self-regulatory
function of the Exchange or any market
responsibility delegated by the Exchange to BX
Equities LLC that comes into the possession of BX
Equities LLC shall not be used for any non-
pwalker on PROD1PC71 with NOTICES
2 17
VerDate Aug<31>2005
17:41 Dec 30, 2008
Jkt 217001
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Frm 00108
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and 2 make technical modifications to
the original rule proposal, the
Commission is not publishing them for
comment. The Commission received no
comment letters regarding the proposed
rule change. This order approves the
proposed rule change, as modified by
Amendment Nos. 1 and 2.
On December 23, 2008, the Exchange
requested that the Commission grant BX
Equities LLC a permanent exemption
from the requirement under Section
11A(b) of the Act, and Rule 609
thereunder, that a securities information
processor (‘‘SIP’’) acting as an exclusive
processor register with the
Commission.6 This order grants the
requested exemption.
II. Background
On August 7, 2008, the Commission
approved, along with related proposals,
a BSE proposed rule change relating to
governing documents and certain rules
of the Exchange to accommodate the
acquisition of the Exchange by The
NASDAQ OMX Group, Inc. (‘‘NASDAQ
OMX’’), the parent corporation of
Nasdaq.7 Among other things, the BSE
Approval Order: (i) Amended and
restated BSE’s Certificate to reflect the
Exchange’s status as a wholly owned
subsidiary of NASDAQ OMX; (ii)
established new By-laws that are similar
to the by-laws of Nasdaq; (iii) amended
the Operating Agreement of BSX Group
LLC, the entity that operated the
Exchange’s cash equities trading
business prior to the Exchange’s
acquisition by NASDAQ OMX; 8 (iv)
prohibited an Exchange member or its
associated persons from beneficially
owning more than 20% of the
outstanding voting securities of
NASDAQ OMX; and (v) limited the
circumstances under which the
Exchange may be affiliated with a
member, and approved the affiliation
regulatory purposes; and (2) the proposal to accept
orders routed by Nasdaq Execution Services, LLC
(‘‘NES’’) to the Exchange on a one-year pilot basis
is made by the Exchange, rather than by The
NASDAQ Stock Market, LLC (‘‘Nasdaq’’).
6 See letter from John Zecca, Chief Regulatory
Officer, Exchange, to Dr. Erik Sirri, Director,
Division of Trading and Markets, Commission,
dated December 23, 2008 (‘‘SIP Exemption Request
Letter’’). See also 15 U.S.C. 78k–1(b). Rule 609
under the Act, 17 CFR 242.609, requires that the
registration of a securities information processor be
on Form SIP, 17 CFR 249.1001.
7 See Securities Exchange Act Release No. 58324,
73 FR 46936 (August 12, 2008) (SR–BSE–2008–02;
SR–BSE–2008–23; SR–BSE–2008–25; SR–BSECC–
2008–01) (‘‘BSE Approval Order’’).
8 BSX Group LLC was formed in 2004 as a joint
venture between BSE and several investors to
operate an electronic trading facility, the Boston
Equities Exchange (‘‘BeX’’), for the trading of cash
equity securities. BeX ceased its operations in
September 2007. See Securities Exchange Act
Release No. 57757 (May 1, 2008), 73 FR 26159.
E:\FR\FM\31DEN1.SGM
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Agencies
[Federal Register Volume 73, Number 251 (Wednesday, December 31, 2008)]
[Notices]
[Pages 80464-80468]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-31088]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-28570; File No. 812-13402]
Sun Life Assurance Company of Canada (U.S.), et al., Notice of
Application
December 23, 2008.
AGENCY: Securities and Exchange Commission (the ``Commission'').
ACTION: Notice of application for an order of approval pursuant to
Section 26(c) of the Investment Company Act of 1940, as amended (the
``Act''), and an order of exemption pursuant to Section 17(b) of the
Act from Section 17(a) of the Act.
-----------------------------------------------------------------------
Applicants: Sun Life Assurance Company of Canada (U.S.) (``Sun Life
U.S.''), Sun Life Insurance and Annuity Company of New York (``Sun Life
N.Y.'') (together with Sun Life U.S., the ``Companies''), Sun Life of
Canada (U.S.) Variable Account F (``Account F''), Sun Life of Canada
(U.S.) Variable Account G (``Account G''), Sun Life of Canada (U.S.)
Variable Account I (``Account I''), Sun Life (N.Y.) Variable Account C
(``Account C''), Sun Life (N.Y.) Variable Account D (``Account D''),
and Sun Life (N.Y.) Variable Account J (``Account J'') (collectively,
the ``Applicants''). Applicants, together with Sun Capital Advisers
Trust (``Sun Capital Trust'') are ``Section 17(b) Applicants.''
Summary of Application: Applicants seek an order approving the
proposed substitutions (the ``Substitutions'') under certain variable
life insurance policies and variable annuity contracts (``Contracts'')
of Class VC shares of the Lord Abbett Growth and Income Portfolio and
the Lord Abbett Mid-Cap Value Portfolio of Lord Abbett Series Fund,
Inc. (``LA Series''), and Administrative Class shares of the PIMCO High
Yield Portfolio and the PIMCO Low Duration Portfolio of the PIMCO
Variable Insurance Trust with Initial Class shares of the following
portfolios of Sun Capital Trust, respectively: The SC Lord Abbett
Growth & Income Fund, the SC Goldman Sachs Mid Cap Value Fund, the SC
PIMCO High Yield Fund, and the SC Goldman Sachs Short Duration Fund.
Section 17(b) Applicants also seek an order pursuant to Section 17(b)
of the Act to permit certain in-kind transactions in connection with
the Substitutions.
Filing Date: The application was originally filed on July 9, 2007,
and an amended and restated application was filed on December 18, 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 Secretary of
the Commission and serving Applicants with a copy of the request,
personally or by mail. Hearing requests must be received by the
Commission by 5:30 p.m. on January 21, 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 requester's interest, the reason for the request, and the
issues contested. Persons who wish to be notified of a hearing may
request notification by writing to the Secretary of the Commission.
ADDRESSES: The Commission: Secretary, Securities and Exchange
Commission, 100 F Street, NE., Washington, DC 20549-1090; Applicants:
c/o Maura A. Murphy, Esq., Sun Life Assurance Company of Canada (U.S.),
One Sun Life Executive Park, Wellesley Hills, Massachusetts 02481.
FOR FURTHER INFORMATION CONTACT: Rebecca A. Marquigny, Senior Counsel,
or Joyce M. Pickholz, Branch Chief, Office of Insurance Products,
Division of Investment Management, at (202) 551-6795.
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application is available for a fee from the
Public Reference Branch of the Commission, 100 F Street, NE.,
Washington, DC 20549 (202-551-8090).
Applicants' and Section 17 Applicants' Representations and
Conditions:
1. Sun Life U.S. is a stock life insurance company ultimately
controlled by Sun Life Financial Inc. (``Sun Life Financial''), a
Canadian reporting company under the Securities Exchange Act of 1934
(the ``1934 Act''). Sun Life U.S. is the depositor and sponsor of
Account F, Account G, and Account I.
2. Account F is registered as a unit investment trust (File No.
811-05846); its interests are offered through Contracts (the ``Account
F Contracts'') registered under the Securities Act of 1933 (``1933
Act'') on Form N-4 (File Nos. 033-41628, 333-37907, 333-05227, 333-
30844, 333-31248, 333-41438, 333-74844, 333-82957, 333-83362, 333-
83364, 333-83516, 333-115536, and 333-115525). Similarly, Account G,
registered as a unit investment trust (File No. 811-07837) offers its
interests through Contracts (the ``Account G Contracts'') registered
under the 1933 Act on Form N-6 (File Nos. 333-65048, 333-13087, and
333-111688). Account I, registered as a unit investment trust (File No.
811-09137) also offers its interests through Contracts (the ``Account I
Contracts'') registered under the 1933 Act on Form N-6 (File Nos. 333-
68601, 333-100831, 333-59662, 333-100829, 333-94359, 333-143353, 333-
143354, and 333-144628).
3. Sun Life N.Y., a wholly owned subsidiary of Sun Life U.S., is a
stock life insurance company and is the depositor and sponsor of
Account C, Account D, and Account J.
4. Account C, a registered unit investment trust (File No. 811-
04440), also offers its interests through certain Contracts (the
``Account C Contracts'') registered under the 1933 Act on Form N-4
(File Nos. 333-05037, 333-67864, 333-119151, 333-119154, 333-100474,
333-107983, 333-99907, and 333-100475). Similarly, Account D,
registered as a unit investment trust (File No. 811-04633) offers its
interests through Contracts (the ``Account D Contracts'') registered
under the 2933 Act on Form N-6 (File Nos. 333-105437, 333-105438, and
333-105441). Account J, registered as a unit investment trust (File No.
811-21937) also offers its interests through Contracts (the ``Account J
Contracts'') registered under the 1933 Act on Form N-6 (File Nos. 333-
136433 and 333-136435).
5. All of the Contracts involved in the Substitutions (a) reserve
the right to substitute shares of one portfolio for shares of another;
(b) permit transfers of contract value among the subaccounts pursuant
to the limitations of the particular Contract, (c) impose or
[[Page 80465]]
reserve the right to impose a transfer charge (except Accounts G and
J); and (d) are subject to market timing policies and procedures that
may operate to limit transfers.
6. Applicants represent that all of the portfolios involved in the
Substitutions are currently available to new and existing Contract
owners (and will continue to be available until the time the
substitutions occur) for the allocation of purchase payments and
transfer of contract value.
7. Lord Abbett Growth and Income Portfolio (``Old Growth &
Income'') and Lord Abbett Mid-Cap Value Portfolio (``Old Mid-Cap
Value'') (each, individually, an ``Old Portfolio'' and collectively,
``Old LA Portfolios'') are portfolios of LA Series, a registered,
diversified, open-end management investment company (File No. 811-
05876). Class VC shares of Old LA Portfolios are registered under the
1933 Act on Form N-1A (File No. 33-31072). The investment adviser to
Old LA Portfolios is Lord Abbett & Co., LLC (``Lord Abbett'').
8. PIMCO High Yield Portfolio (``Old High Yield'') and PIMCO Low
Duration Portfolio (``Old Low Duration'') (each, individually, an ``Old
Portfolio'' and collectively, ``Old PIMCO Portfolios'') are portfolios
of PIMCO Variable Insurance Trust, a registered, diversified, open-end
management investment company (File No. 811-08399). Administrative
Class shares of Old PIMCO Portfolios are registered under the 1933 Act
on Form N-1A (File No. 333-37115). The investment adviser to Old PIMCO
Portfolios is Pacific Investment Management Company LLC (``PIMCO'').
9. The following ``New Portfolios'' (each, individually, a ``New
Portfolio'') are portfolios of Sun Capital Trust, a registered,
diversified, open-end management investment company (File No. 811-
08879): SC Lord Abbett Growth & Income Fund (``New Growth & Income''),
SC Goldman Sachs Mid Cap Value Fund (``New Mid Cap Value''), SC PIMCO
High Yield Fund (``New High Yield''), and SC Goldman Sachs Short
Duration Fund (``New Short Duration''). Initial Class shares of New
Portfolios are registered under the 1933 Act on Form N-1A (File No.
333-59093) and are not subject to a distribution fee.
10. Sun Capital Advisers LLC (``Sun Capital''), an indirect, wholly
owned subsidiary of Sun Life Financial, is investment adviser to all
the Sun Capital Trust portfolios. Through an order from the Commission
pursuant to Section 6(c) of the Act, Sun Capital is exempt from Section
15(a) of the Act and Rule 18f-2 thereunder with respect to subadvisory
agreements (the ``Manager of Managers Order'').\1\
---------------------------------------------------------------------------
\1\ Sun Capital Advisers Trust and Sun Capital Advisers, Inc.,
1940 Act Rel. No. 24401 (April 24, 2000) (Order), File No. 812-
11790; see also Sun Capital Advisers Trust and Sun Capital Advisers,
Inc., 1940 Act Rel. No. 23793 (Apr. 20, 1999) (Order), File No. 812-
11464.
---------------------------------------------------------------------------
11. Applicants represent that the relief granted in the Manager of
Managers Order extends to New Portfolios permitting Sun Capital to
enter into and materially amend investment subadvisory agreements
without obtaining shareholder approval. Applicants also indicate that
the prospectus for the New Portfolios will disclose and explain the
existence, substance and effect of the Manager of Managers Order.
12. Applicants propose to substitute Initial Class shares of (a)
New Growth & Income for Class VC shares of Old Growth & Income; (b) New
Mid Cap Value for Class VC shares of Old Mid Cap Value; (c) New High
Yield for Administrative Class shares of Old High Yield; and (d) New
Short Duration for Administrative Class shares of Old Low Duration.
Applicants state that the proposed Substitutions are not intended to
effect an overall reorganization or merger of any of the underlying
investment options offered in the Contracts. Applicants assert their
belief that:
(a) Reducing the number of nonproprietary funds will provide the
Companies with more control over fund changes that affect the
Contracts;
(b) The New Portfolios better promote their goals of increasing
administrative efficiency of, and control over, their Contracts as the
New Portfolios are part of their proprietary fund family;
(c) This streamlining will allow the Companies to enhance their
communication efforts to Contract owners and sales representatives
regarding the available portfolios, and may provide for more enhanced
and timely reporting from the Companies to Contract owners with respect
to changes in the underlying funds.
13. Applicants represent that because the New Portfolios operate
pursuant to the Manager of Managers Order (and assuming that the
Applicants first obtain shareholder approval of a change in a New
Portfolio's subadviser or of a New Portfolio's continued ability to
rely on the Manager of Manager's Order), the Substitutions would
provide protection to Contract owners by giving Sun Capital the agility
and flexibility to change the subadviser of the New Portfolios should
such a change become warranted or advisable. In support of the
Substitutions, Applicants assert that the investment objectives and
policies of the New Portfolios are sufficiently similar to those of the
corresponding Old Portfolios that Contract owners will have reasonable
continuity in investment expectations. The following summarizes the
more complete comparison of New and Old Portfolios provided in the
Application.
14. Growth & Income Portfolio Substitution
Applicants state that both Old Growth & Income and New Growth &
Income share the identical investment objective to ``seek long-term
growth of capital and income without excessive fluctuations in market
value.'' Applicants state that the principal investment strategies of
the two portfolios are virtually identical noting that both invest at
least 80% of net assets in equity securities of large companies defined
as those having capitalization within the range of the companies in the
Russell 1000 Index at the time of purchase. Both portfolios primarily
purchase equity securities of large, seasoned, U.S. and multinational
companies that are believed to be undervalued, and both attempt to
invest in securities selling at reasonable prices in relation to their
potential value. Applicants also represent that both portfolios share
substantially similar risk profiles.
Charges for Class VC of Old Growth & Income include Management Fees
of 0.47% and Other Expenses of 0.41%.\2\ Total Operating Expenses for
Initial Class shares of New Growth & Income are 0.88% which represents
0.01% in Other Expenses and a 0.87% unified management fee (subject to
a 0.87% contractual limitation on Total Operating Expenses). Neither
portfolio charges a 12b-1 Fee. Old Growth & Income's total gross and
net operating expenses are both 0.88%. Respectively, New Growth &
Income's total gross and net operating expenses are 0.88% and 0.87%
(reflecting the contractual expense limitation agreement).
---------------------------------------------------------------------------
\2\ For the descriptions of charges involved in the
Substitution, all percentages for the Management Fees, 12b-1 Fees,
Other Expenses, Fee Reductions, Total Gross and Net Annual Operating
Expenses, and Separate Account Fees represent a percentage of
average annual assets.
---------------------------------------------------------------------------
15. Mid Cap Value Portfolio Substitution
Applicants state that both Old Mid Cap Value and New Mid Cap Value
share a similar investment objective because Old Mid Cap Value ``seeks
capital appreciation through investments, primarily in equity
securities, which are believed to be undervalued in the marketplace''
and New Mid Cap Value ``seeks long-term return of capital.'' Applicants
state that
[[Page 80466]]
the principal investment strategies of the two portfolios are similar
noting that both employ a value approach to investing and normally
invest at least 80% of net assets, plus the amount of any borrowings
for investment purposes, in securities of mid-sized companies.
Applicants represent that both Old Mid Cap Value and New Mid Cap Value
have substantially similar risk characteristics which are presented in
greater detail in the Application.
Charges for Class VC of Old Mid Cap Value include Management Fees
of 0.74% and Other Expenses of 0.38%. Total Operating Expenses for
Initial Class shares of New Mid Cap Value are 1.06% which represents
0.01% in Other Expenses and a 1.05% unified management fee (subject to
a 1.07% contractual limitation on Total Operating Expenses). Neither
portfolio charges a 12b-1 Fee. Old Mid Cap Value's total gross and net
operating expenses are both 1.12% while New Mid Cap Value's total gross
and net operating expenses are both 1.06%.
16. High Yield Portfolio Substitutions
Applicants represent that Old High Yield and New High Yield share a
virtually identical investment objective because New High Yield seeks
``maximum total return, consistent with capital preservation'' and Old
High Yield seeks the same ``and prudent investment management.''
Applicants represent that under normal circumstances both invest at
least 80% of assets in a diversified portfolio of high yield junk bonds
rated at least Caa by Moody's or equivalently rated by S&P or Fitch,
or, if unrated, determined by the adviser or subadviser to be of
comparable quality. Applicants state that neither portfolio may invest
more than 5% of total assets in securities of equal or lower rating.
Applicants represent that both portfolios employ an average portfolio
duration within a two-to-six year time frame and may invest up to the
same percentages of total assets in issuers located in countries with
developing economies. Applicants assert that the limits for investment
in foreign currency denominated securities and U.S. dollar-denominated
securities of foreign issuers are the same for both portfolios.
Applicants also identify other similar strategies including that both
portfolios may invest all of their assets in derivative instruments. In
addition, Applicants represent that both Old High Yield and New High
Yield have substantially similar risk characteristics discussed at
length in the Application.
Charges for Administrative Class shares of Old High Yield include
Management Fees of 0.25%, Service Fees of 0.15%, and Other Expenses of
0.35%. Charges for Initial Class shares of New High Yield include a
0.74% unified management fee and 0.01% in Other Expenses. New High
Yield does not charge a service fee, and neither portfolio charges a
12b-1 Fee. The total gross and net operating expenses for both Old High
Yield and New High Yield are 0.75%. In addition, New High Yield's fees
are also subject to a 0.75% contractual expense limitation on total
operating expenses for at least 24 months following the date of the
Substitutions.
17. Low/Short Duration Portfolio Substitutions
Applicants represent that Old Low Duration and New Short Duration
share a similar investment objective in that Old Low Duration ``seeks
maximum total return, consistent with preservation of capital and
prudent investment management,'' while New Short Duration ``primarily
seeks a high level of current income, with capital appreciation as a
secondary goal.'' Applicants also represent that the principal
investment strategies of the two portfolios are similar. Both invest
primarily in fixed income securities at levels of total assets equal to
at least 65% for Old Low Duration and 80% for New Short Duration. In
addition, Applicants represent that both Old Low Duration and New Short
Duration have similar risk characteristics discussed at length in the
Application.
Charges for Administrative Class shares of Old Low Duration include
Management Fees of 0.25%, Service Fees of 0.15%, and Other Expenses of
0.25%. Charges for Initial Class shares of New Short Duration include a
0.64% unified management fee and 0.01% in Other Expenses. New Short
Duration does not charge a service fee, and neither portfolio charges a
12b-1 Fee. The total gross and net operating expenses for both Old Low
Duration and New Short Duration are 0.65%. In addition, New Short
Duration's fees are also subject to a 0.65% contractual expense
limitation on total operating expenses for at least 24 months following
the date of the Substitutions.
18. Applicants assert that as of the effective date of the
Substitutions (``Effective Date'' or ``Substitution Date''), each
Separate Account will redeem shares of the applicable Old Portfolio in-
kind. Applicants state that if Sun Capital declines to accept
particular portfolio securities of any of the Old Portfolios for
purchase in-kind of shares of the New Portfolios, the applicable Old
Portfolio will liquidate portfolio securities as necessary, and shares
of the New Portfolio will be purchased with cash. Applicants represent
that in either event, the proceeds of such redemptions will then be
used to purchase shares of the New Portfolios, with each subaccount of
the applicable Separate Account investing the proceeds of its
redemption from the Old Portfolios in the applicable New Portfolio.
19. Applicants further state that redemption requests and purchase
orders will be placed simultaneously so that contract values will
remain fully invested at all times. Applicants represent that all
redemptions of shares of the Old Portfolios and purchases of shares of
the New Portfolios will be effected in accordance with Section 22(c) of
the Act and Rule 22c-1 thereunder. Applicants state that the
Substitutions will take place at relative net asset value as of the
Effective Date with no change in the amount of any Contract owner's
contract value or death benefit or in the dollar value of his or her
investments in any of the subaccounts. Applicants represent that
Contract values attributable to investments in the Old Portfolios will
be transferred to the New Portfolios without charge and without
counting toward the number of transfers that may be permitted without
charge.
20. Applicants further represent that all expenses incurred in
connection with the Substitutions, including legal, accounting,
transactional, and other fees and expenses, including brokerage
commissions, will be paid by Sun Life U.S. or Sun Life N.Y. Applicants
also state that, as a result of the Substitutions, Contract owners will
not incur any additional fees or charges, nor will their rights or
insurance benefits or the Companies' obligations under the Contracts be
altered. Applicants assert that the Substitutions: (a) Will not impose
any tax liability on Contract owners; and (b) will not cause the
Contract fees and charges currently being paid by existing Contract
owners to be greater after the Substitutions than before the
Substitutions. Applicants represent that neither Sun Life U.S. nor Sun
Life N.Y. will exercise any right either may have under the Contracts
to impose restrictions on transfers under the Contracts for the period
from the date the Application was filed with the Commission through at
least thirty days following the Effective Date.
21. The Companies represent that during the twenty-four months
following the Effective Date, the total net operating expenses of each
New Portfolio (taking into account any expense waiver or reimbursement)
will not exceed the net expense level of the corresponding Old
Portfolio for the fiscal year ended December 31, 2007.
[[Page 80467]]
Applicants also state that for at least twenty-four months following
the date of the Substitutions, Sun Capital has contractually agreed to
waive its management fee and, if necessary, to limit other ordinary
operating expenses so that total operating expenses, as a percentage of
average net assets, do not exceed 0.87%, 1.07%, 0.75%, or 0.65%, as
applicable. In addition, Applicants represent that for twenty-four
months following the date of the Substitutions, the Companies will not
increase asset-based fees or charges for Contracts outstanding on the
Effective Date.
22. Applicants represent that a prospectus for the New Portfolio
containing disclosure describing the existence, substance and effect of
the Manager of Managers Order will be provided to each Contract owner
prior to or at the time of the Substitutions. Notwithstanding the
Manager of Managers Order, the Applicants agree not to change any New
Portfolio's subadviser, add a new subadviser, or otherwise rely on the
Manager of Managers Order without first obtaining shareholder approval,
following the Effective Date of the Substitutions, of either: (1) The
subadviser change; or (2) the New Portfolio's continued ability to rely
on the Manager of Managers Order.
23. Applicants state that Contract owners were or will be notified
of the proposed Substitutions by means of a prospectus or prospectus
supplement for each of the Contracts stating that the Applicants filed
the Application and seek approval for the Substitutions (``Pre-
Substitution Notice''). The Pre-Substitution Notice sets forth the
anticipated Effective Date and explains that contract values
attributable to investments in the Old Portfolios will be transferred
to the New Portfolios on the Effective Date without charge (including
sales charges or surrender charges) and without counting toward the
number of transfers that may be permitted without charge. Applicants
indicate that the Pre-Substitution Notice states that, from the date
the initial application was filed with the Commission through the date
thirty days after the Substitutions, Contract owners may make one
transfer of contract value from each subaccount investing in the Old
Portfolios (before the Substitutions) or a New Portfolio (after the
Substitutions) to one or more other subaccount(s) without a transfer
charge and without that transfer counting against their contractual
transfer limitations.
24. Applicants represent that all Contract owners will have
received a copy of the most recent prospectus for the New Portfolios
prior to the Substitutions. Applicants also agree that, within five
days following the Substitutions, Contract owners affected by the
Substitutions will be notified in writing that the Substitutions were
carried out and that this notice will restate the information set forth
in the Pre-Substitution Notice.
Applicants' Legal Analysis
1. Section 26(c) of the Act makes it unlawful for any depositor or
trustee of a registered unit investment trust holding the security of a
single issuer to substitute another security for such security unless
the Commission approves the substitution. The Commission shall approve
such a substitution if the evidence establishes that it is consistent
with the protection of investors and the purposes fairly intended by
the policy and provisions of the Act.
2. Applicants submit that the Substitutions meet the standards set
forth in Section 26(c) and assert that replacement of the Old
Portfolios with the New Portfolio is consistent with the protection of
Contract owners and the purposes fairly intended by the policy and
provisions of the Act. Applicants have reserved the right to make such
a substitution under the Contracts and represent that this reserved
right is disclosed in the prospectus for the Contracts.
3. Section 17(a)(1) of the Act, in relevant part, prohibits any
affiliated person of a registered investment company, or any affiliated
person of such person, acting as principal, from knowingly selling any
security or other property to that company. Section 17(a)(2) of the Act
generally prohibits the persons described above, acting as principal,
from knowingly purchasing any security or other property from the
registered company. Pursuant to Section 17(a)(1) of the Act, the
Section 17(b) Applicants may be considered affiliates of one or more of
the portfolios involved in the Substitutions. Because the Substitutions
may be effected, in whole or in part, by means of in-kind redemptions
and subsequent purchases of shares and by means of in-kind
transactions, the Substitutions may be deemed to involve one or more
purchases or sales of securities or property between affiliates.
4. Section 17(b) of the Act provides that the Commission may, upon
application, grant an order exempting any transaction from the
prohibitions of Section 17(a) if the evidence establishes that: the
terms of the proposed transaction, including the consideration to be
paid or received, are reasonable and fair and do not involve
overreaching on the part of any person concerned; the proposed
transaction is consistent with the policy of each registered investment
company concerned, as recited in its registration statement and records
filed under the Act; and the proposed transaction is consistent with
the general purposes of the Act.
5. The Section 17(b) Applicants state that the terms under which
the in-kind redemptions and purchases will be effected are reasonable
and fair and do not involve overreaching on the part of any person
principally because the Substitutions will conform with all but one of
the conditions enumerated in Rule 17a-7. Applicants assert that the use
of in-kind transactions will not cause Contract owner interests to be
diluted. In support, Applicants represent that: (a) The proposed
transactions will take place at relative net asset value as of the
Effective Date in conformity with the requirements of Section 22(c) of
the 1940 Act and Rule 22c-1 thereunder with no change in the amount of
any Contract owner's contract value or death benefit or in the dollar
value of his or her investment in any of the Separate Accounts; (b)
Contract owners will not suffer any adverse tax consequences as a
result of the Substitutions; and (c) fees and charges under the
Contracts will not increase because of the Substitutions.
6. Further, though the Section 17(b) Applicants may not rely on
Rule 17a-7 because they cannot meet all of its conditions, the Section
17(b) Applicants agree to carry out the proposed in-kind purchases in
conformity with all of the conditions of Rule 17a-7 and the procedures
adopted thereunder, except that the consideration paid for the
securities being purchased or sold may not be entirely cash. However,
Applicants assert that the circumstances surrounding the Substitutions
will offer the same degree of protection to the New Portfolios from
overreaching that Rule 17a-7 provides to it generally in connection
with its purchase and sale of securities under that Rule in the
ordinary course of its business.
7. Applicants assert that the Board of Sun Capital Trust has
adopted procedures, as required by paragraph (e)(1) of Rule 17a-7,
pursuant to which its portfolios may purchase and sell securities to
and from their affiliates. Applicants also note that the Companies (or
any of their affiliates) cannot effect the proposed Substitutions at a
price disadvantageous to the New Portfolio. Although the Substitutions
may not be entirely for cash, Applicants represent that each will be
effected based upon (1) the independent market price of the portfolio
securities valued as specified
[[Page 80468]]
in paragraph (b) of Rule 17a-7, and (2) the net asset value per share
of each portfolio involved valued according to the procedures disclosed
in its registration statement and as required by Rule 22c-1 under the
Act. The Section 17(b) Applicants state that if Sun Capital declines to
accept particular portfolio securities of either of the Old Portfolios
for purchase in-kind of shares of a New Portfolio, the applicable Old
Portfolio will liquidate portfolio securities as necessary and shares
of the New Portfolios will be purchased with cash. Consistent with Rule
17a-7(d), Applicants also agree that no brokerage commissions, fees, or
other remuneration will be paid in connection with the in-kind
transactions.
Conclusions
1. Applicants submit that for the reasons and upon the facts set
forth in their application, the requested order pursuant to Section
26(c) of the Act is consistent with the protection of investors and the
purposes fairly intended by the policy of the Contracts and provisions
of the Act and should, therefore, be granted.
2. Section 17 Applicants represent that the proposed in-kind
transactions are consistent with the general purposes of the Act, do
not present any of the conditions or abuses the Act was designed to
prevent, and that an exemption should be granted, to the extent
necessary, from the provisions of Section 17(a).
For the Commission, by the Division of Investment Management,
pursuant to delegated authority.
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8-31088 Filed 12-30-08; 8:45 am]
BILLING CODE 8011-01-P