Notice of a Proposed Amendment to Prohibited Transaction Exemption (PTE) 90-29, 55 FR 21459 (May 24, 1990), as Amended by PTE 97-34, 62 FR 39021 (July 21, 1997), PTE 2000-58, 65 FR 67765 (November 13, 2000), PTE 2002-41, 67 FR 54487 (August 22,2002) and PTE 2007-05, 72 FR 13130 (March 20, 2007) as Corrected at 72 FR 16385 (April 4, 2007) (PTE 2007-05), (PTE 90-29), Involving Merrill Lynch, Pierce, Fenner & Smith, Inc., the Principal Subsidiary of Merrill Lynch & Co., Inc. and Its Affiliates (Merrill Lynch) and to PTE 2002-19, 67 FR 14979 (March 28, 2002) as Amended by PTE 2007-05, (PTE 2002-19), Involving J.P. Morgan Chase & Company and Its Affiliates (D-11519), 21002-21008 [E9-10362]
Download as PDF
21002
Federal Register / Vol. 74, No. 86 / Wednesday, May 6, 2009 / Notices
Signed at Washington, DC, this 3rd day of
April 2009.
Richard Church,
Trade Adjustment Assistance.
[FR Doc. E9–10385 Filed 5–5–09; 8:45 am]
BILLING CODE 4510–FN–P
DEPARTMENT OF LABOR
Employment and Training
Administration
[TA–W–65,620]
Foamade Industries, Inc.; Auburn Hills,
MI; Notice of Termination of
Investigation
Pursuant to Section 221 of the Trade
Act of 1974, as amended, an
investigation was initiated on March 17,
2009 in response to a petition filed by
company officials on behalf of workers
at Foamade Industries, Inc., Auburn
Hills, Michigan.
The petitioners have requested that
the petition be withdrawn.
Consequently, the investigation has
been terminated.
Signed at Washington, DC this 1st day of
April 2009.
Richard Church,
Certifying Officer, Division of Trade
Adjustment Assistance.
[FR Doc. E9–10387 Filed 5–5–09; 8:45 am]
DATES: Written comments and requests
for a hearing should be received by the
Department by June 5, 2009.
DEPARTMENT OF LABOR
Employee Benefits Security
Administration
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Notice of a Proposed Amendment to
Prohibited Transaction Exemption
(PTE) 90–29, 55 FR 21459 (May 24,
1990), as Amended by PTE 97–34, 62
FR 39021 (July 21, 1997), PTE 2000–58,
65 FR 67765 (November 13, 2000), PTE
2002–41, 67 FR 54487 (August 22,2002)
and PTE 2007–05, 72 FR 13130 (March
20, 2007) as Corrected at 72 FR 16385
(April 4, 2007) (PTE 2007–05), (PTE 90–
29), Involving Merrill Lynch, Pierce,
Fenner & Smith, Inc., the Principal
Subsidiary of Merrill Lynch & Co., Inc.
and Its Affiliates (Merrill Lynch) and to
PTE 2002–19, 67 FR 14979 (March 28,
2002) as Amended by PTE 2007–05,
(PTE 2002–19), Involving J.P. Morgan
Chase & Company and Its Affiliates
(D–11519)
SUMMARY: This document contains a
notice of pendency before the
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All written comments and
requests for a public hearing (preferably,
three copies) should be sent to the
Office of Exemption Determinations,
Employee Benefits Security
Administration, Room N–5700, U.S.
Department of Labor, 200 Constitution
Avenue, NW., Washington, DC 20210,
(Attention: Exemption Application
Number D–11519). Interested persons
are invited to submit comments and/or
hearing requests to the Department by
the end of the scheduled comment
period either by facsimile to (202) 219–
0204 or by electronic mail to
moffitt.betty@dol.gov. The application
pertaining to the Proposed Amendment
(Application) and the comments
received will be available for public
inspection in the Public Disclosure
Room of the Employee Benefits Security
Administration, U.S. Department of
Labor, Room N–1513, 200 Constitution
Avenue, NW., Washington, DC 20210.
ADDRESSES:
BILLING CODE 4510–FN–P
AGENCY: Employee Benefits Security
Administration, Department of Labor.
ACTION: Notice of a Proposed
Amendment to PTE 90–29.
Department of Labor (the Department) of
a proposed amendment to PTE 90–29
and PTE 2002–19, Underwriter
Exemptions.1 The Underwriter
Exemptions are individual exemptions
that provide relief for the origination
and operation of certain asset pool
investment trusts and the acquisition,
holding and disposition by employee
benefit plans (Plans) of certain assetbacked pass-through certificates
representing undivided interests in
those investment trusts. The proposed
amendment to PTE 90–29 and 2002–19,
if granted, would provide a six month
period to resolve certain affiliations, as
a result of Bank of America
Corporation’s acquisition of Merrill
Lynch, between Bank of America, N.A.,
the Trustee, and Merrill Lynch as
members of the Restricted Group, as
those terms are defined in the
Underwriter Exemptions (the Proposed
Amendment). The Proposed
Amendment, if granted, would affect the
participants and beneficiaries of the
Plans participating in such transactions
and the fiduciaries with respect to such
Plans.
FOR FURTHER INFORMATION CONTACT:
Wendy M. McColough of the
Department, telephone (202) 693–8540.
(This is not a toll-free number.)
1 The ‘‘Underwriter Exemptions’’ are a group of
individual exemptions that provide substantially
identical relief for the operation of certain assetbacked or mortgage-backed investment pools and
the acquisition and holding by Plans of certain
securities representing interests in those investment
pools.
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This
document contains a notice of pendency
before the Department of a proposed
exemption to amend PTE 90–29 and
PTE 2002–19, Underwriter Exemptions.
The Underwriter Exemptions are a
group of individual exemptions granted
by the Department that provide
substantially identical relief from
certain of the restrictions of sections 406
and 407 of the Employee Retirement
Income Security Act of 1974 (ERISA or
the Act) and from the taxes imposed by
sections 4975(a) and (b) of the Internal
Revenue Code of 1986, as amended
(Code), by reason of certain provisions
of section of 4975(c)(1) of the Code for
the operation of certain asset pool
investment trusts and the acquisition,
holding, and disposition by Plans of
certain asset-backed pass-through
certificates representing undivided
interests in those investment trusts.
All of the Underwriter Exemptions
were amended by PTE 97–34, 62 FR
39021 (July 21, 1997), PTE 2000–58, 65
FR 67765 (November 13, 2000), and PTE
2007–05, 72 FR 13130 (March 20, 2007),
as corrected at 72 FR 16385 (April 4,
2007). Certain of the Underwriter
Exemptions were amended by PTE
2002–41, 67 FR 54487 (August 22, 2002)
or modified by PTE 2002–19.
The Department is proposing this
amendment to PTE 90–29 and to PTE
2002–19 pursuant to section 408(a) of
the Act and section 4975(c)(2) of the
Code, and in accordance with the
procedures set forth in 29 CFR Part
2570, Subpart B (55 FR 32836, 32847,
August 10, 1990).2
1. The Underwriter Exemptions
permit Plans to invest in pass-through
securities representing undivided
interests in asset-backed or mortgagebacked investment pools (Securities).
The Securities generally take the form of
certificates issued by a trust (Trust). The
Underwriter Exemptions permit
transactions involving a Trust,
including the servicing, management
and operation of the Trust, and the sale,
exchange or transfer of Securities
evidencing interests therein, in the
initial issuance of the Securities or in
the secondary market for such Securities
(the Covered Transactions). The most
recent amendment to the Underwriter
Exemptions is PTE 2007–05, 72 FR
13130 (March 20, 2007), as corrected at
72 FR 16385 (April 4, 2007) (PTE 2007–
05). One of the General Conditions of
the Underwriter Exemptions, as
amended, requires that the Trustee not
SUPPLEMENTARY INFORMATION:
2 Section 102 of Reorganization Plan No. 4 of
1978 (5 U.S.C. App. 1 [1996]) generally transferred
the authority of the Secretary of the Treasury to
issue exemptions under section 4975(c)(2) of the
Code to the Secretary of Labor.
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be an ‘‘Affiliate’’ of any member of the
‘‘Restricted Group’’ other than an
‘‘Underwriter.’’ PTE 2007–05,
subsection II.A.(4). The term ‘‘Restricted
Group’’ is defined under section III.M.
as: (1) Each Underwriter; (2) Each
Insurer; (3) The Sponsor; (4) The
Trustee; (5) Each Servicer (6) Any
Obligor with respect to obligations or
receivables included in the Issuer
constituting more than 5 percent of the
aggregate unamortized principal balance
of the assets in the Issuer, determined
on the date of the initial issuance of
Securities by the Issuer; (7) Each
counterparty in an Eligible Swap
Agreement; or (8) Any Affiliate of a
person described in subsections
III.M.(1)-(7).’’ The term ‘‘Servicer’’ is
defined to include ‘‘the Master Servicer
and any Subservicer.’’ PTE 2007–05,
section III.G. The term ‘‘Affiliate’’ is
defined, in part, to include ‘‘(1) Any
person directly or indirectly, through
one or more intermediaries, controlling,
controlled by, or under common control
with such other person; (2) Any officer,
director, partner, employee * * * of
such other person; and (3) Any
corporation or partnership of which
such other person is an officer, director
or partner.’’ PTE 2007–05, section III.N.
2. On May 24, 1990, PTE 90–29 was
granted to Merrill Lynch, Pierce, Fenner
& Smith, Inc. (MLPFS), the principal
subsidiary of Merrill Lynch. MLPF&S is
a Delaware corporation registered with
and regulated by the SEC as a brokerdealer, and is a member of the New
York Stock Exchange, and the National
Association of Securities Dealers, Inc.
MLPFS is also regulated by the
Municipal Securities Rulemaking Board
(with respect to municipal securities
activities), the Commodity Futures
Trading Commission, and the National
Futures Association (with respect to
MLPFS’s activities as a futures
commission merchant). MLPFS is a
leading broker and/or dealer in the
purchase and sale of corporate equity
and debt securities, mutual funds,
money market instruments, government
securities, high yield bonds, municipal
securities, financial futures contracts,
and options. As a leading investment
banking firm, MLPFS provides
corporate, institutional, and government
clients with a wide variety of financial
services including underwriting the sale
of securities to the public, structured
and derivative financing, private
placements, mortgage and lease
financing, and financial advisory
services, which includes advice on
mergers and acquisitions. MLPFS also
acts as a prime broker for hedge funds.
Further, MLPFS operates mutual fund
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18:36 May 05, 2009
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advisory programs, which provide plans
governed by ERISA or section 4975 of
the Code investment advice concerning
purchasing mutual funds shares.
3. Bank of America Corporation (Bank
of America or the Applicant) notes that
it is the parent holding company of
Bank of America, N.A., the Trustee of
each of the commercial or residential
mortgage-backed securitizations in the
Covered Transactions. The Proposed
Amendment was requested by
application dated November 24, 2008,
and as updated by Bank of America (the
Application). The Applicant states that
on January 1, 2009 (the Acquisition
Date), Bank of America acquired Merrill
Lynch (the Acquisition). Merrill Lynch
is a holding company that, through its
subsidiaries, provides broker-dealer,
investment banking, financing, wealth
management, advisory, insurance,
lending and related products and
services on a global basis. Merrill Lynch
is a ‘‘Consolidated Supervised Entity,’’ 3
and is subject to group-wide supervision
by the SEC. On March 4, 2009, the
Applicant explained that Merrill Lynch
& Co., Inc. (Parent or Merrill Lynch) is
the ultimate parent of all of its
subsidiaries, and was (prior to its
acquisition by Bank of America) a
publicly traded holding company.
Among the direct subsidiaries of the
Parent, each 100% owned by Parent, are
Merrill Lynch Group, Inc. (MLG),
Merrill Lynch Bank & Trust Co., FSB
(MLBT) and Merrill Lynch, Pierce,
Fenner & Smith Incorporated (MLPFS).
For the Covered Transactions that are
the subject of the Applicant’s request,
Merrill Lynch Mortgage Capital Inc.
(Mortgage Capital) is the Sponsor of
certain transactions subject to PTE 90–
29 and is an indirect, 100% owned
subsidiary of MLG. Mortgage Capital’s
direct 100% owned subsidiaries include
Merrill Lynch Mortgage Lending, Inc.,
3 Effective August 2004, the Securities Exchange
Commission (Commission) adopted rule
amendments that established a voluntary,
alternative method for computing net capital for
certain broker-dealers. As a condition to its use of
the alternative method, a broker-dealer’s ultimate
holding company and affiliates (referred to
collectively as a consolidated supervised entity or
CSE) must consent to group-wide Commission
supervision. These rules, among other things,
respond to international developments.
Specifically, affiliates of certain US broker-dealers
that conduct business in the European Union (EU)
have stated that they must demonstrate that they are
subject to consolidated supervision at the ultimate
holding company level that is ‘‘equivalent’’ to EU
consolidated supervision. Commission supervision
incorporated into these rule amendments addresses
this standard. These amendments and the SEC’s
program for consolidated supervision of brokerdealers and affiliates will minimize duplicative
regulatory burdens on firms that are active in the
EU, as well as in other jurisdictions that may have
similar laws.
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21003
the Sponsor of certain Covered
Transactions, Merrill Lynch Mortgage
Investors, Inc., the Sponsor of one
Covered Transaction and Wilshire
Credit Corporation (Wilshire), the
Servicer of certain Covered
Transactions.
Mortgage Capital purchased Wilshire
in January 2004. MLBT is the 100%
parent of FF Mortgage Corporation,
which in turn is the 100% parent of
Home Loan Services, Inc. (HLS), a
Servicer of certain of the Covered
Transactions. On October 20, 2006,
MLBT acquired the subprime mortgage
assets of National City Bank, including
the stock of First Franklin Financial
Corporation (FFFC), National City Home
Loan Services (the related servicing
platform) and the mortgage loan
origination platform of National City
Bank (which operated as the First
Franklin Financial division of National
City Bank). The mortgage loan
origination platform was subsequently
transferred into First Franklin Financial
Corporation. With the acquisition, the
servicing division was renamed HLS
and this entity services First Franklin
loans. HLS is a direct 100% owned
subsidiary of MLBT. FFFC is the
Sponsor of certain of the Covered
Transactions. On March 5, 2008, Parent
announced that FFFC would no longer
originate loans. Concurrent with this
announcement, FF Mortgage
Corporation sold the stock of FFFC to
Merrill Lynch Mortgage Services
Corporation, a subsidiary of Mortgage
Capital (which actions were taken to
satisfy the Office of Thrift Supervision).
PTE 90–29 was granted to MLPFS, a
direct 100% owned subsidiary of Parent
and the Underwriter of certain of the
Covered Transactions.
4. The Acquisition caused certain
transactions previously subject to PTE
90–29 or PTE 2002–19 to fail to satisfy
the requirement under the Underwriter
Exemptions that the Trustee not be an
Affiliate of any member of the Restricted
Group other than an Underwriter. PTE
2007–05 subsection II.A.(4). Currently,
for transactions where Merrill Lynch is
the Servicer, a six-month period is
provided by the Underwriter
Exemptions to sever the affiliation
between the Servicer and the Trustee if
the affiliation occurred after the initial
issuance of the Securities. PTE 2007–05,
subsection II.A.(4)(b). However, there is
currently no transitional relief under
PTE 90–29 where Merrill Lynch is a
Sponsor, Underwriter or a Swap
Counterparty and Bank of America, N.A.
is the Trustee. Accordingly, Bank of
America seeks a temporary amendment
to PTE 90–29 to provide for a six-month
period for resolution of certain
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prohibited affiliations caused by the
Acquisition of Merrill Lynch by Bank of
America, the parent of the Trustee.
In addition, the Applicant requests
that the amendment provide similar
relief for one other Covered Transaction,
JPM 2003–ML1, where Bank of America
is Trustee and Merrill Lynch is a
Sponsor. In this transaction, the
Underwriter, J.P. Morgan Securities Inc.,
who is unrelated to Bank of America,
relies upon PTE 2002–19, granted to J.P.
Morgan Chase & Co. and its affiliates.
The Applicant provides that J.P. Morgan
Securities Inc. is the principal nonbank
subsidiary of J.P. Morgan Chase & Co. JP
Morgan Chase Commercial Mortgage
Securities Corp. is 100% owned by
JPMorgan Chase Bank, N.A., which in
turn, is 100% owned by J.P. Morgan
Chase & Co. JP Morgan Chase
Commercial Mortgage Securities Corp.
has confirmed to the Applicant that it
has been notified of the application for
the Proposed Amendment and has
agreed to coverage under the Proposed
Amendment. Bank of America
represents that it has placed a notice on
its web pages for each of the Covered
Transactions affected by the Acquisition
and that this notice would be updated
upon publication of the Proposed
Amendment, and if granted, the final
amendment. Further, the Web pages
will note the appointment of any cotrustee and the appointment of the
replacement trustee. The Applicant
states that Bank of America, N.A., in its
role of Trustee, will bear the cost of
appointing such co-trustee and that
there will be no financial impact on any
Underwriter.
5. Bank of America represents that the
Covered Transactions affected by the
Acquisition consist of 49 commercial or
residential mortgage-backed
securitizations (CMBS or RMBS)
(Securitizations) as detailed at section
III.KK of the Proposed Amendment (the
Securitizations List). Bank of America
states that all of the Securitizations were
structured and are managed to meet the
requirements of PTE 90–29 or in the
case of JPM 2003–ML1, PTE 2002–19, in
each case as amended by PTE 2007–05.
Bank of America, N.A. is the Trustee in
each of the Securitizations. The
Applicant represents that, in its role as
Trustee, Bank of America, N.A. is
obligated under both the operative
documents that securitize the loans, and
under state law relating to fiduciaries, to
protect the interests of security holders.
Specifically, the Trustee is required to
enforce the rights of security holders
against other parties to the transaction,
including Servicers, Swap
Counterparties and loan sellers. The
Applicant notes further that in practice,
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18:36 May 05, 2009
Jkt 217001
due to industry standards and
reputation concerns by the various
parties, little such protection or
enforcement is necessary, and the
Trustee’s role, while vigilant, is
relatively passive. Merrill Lynch is a
party to each of the Securitizations in
the capacity or capacities detailed in the
Securitizations List. The Applicant
states that, in any of these capacities,
Merrill Lynch is obligated, under the
operative documents of the transaction,
to perform its designated duties under
contractual and, in some cases, industry
standards for the benefit of security
holders. The Applicant represents that
each of the Pooling and Servicing
Agreements has been structured to
comply with PTE 90–29 or in the case
of JPM 2003–ML1, PTE 2002–19 and
that each of the Trusts has been
managed in accordance with the related
Pooling and Servicing Agreement.
Consequently, Securities issued by each
Trust currently are eligible for purchase
by Plans that meet the requirements of
PTE 90–29 or in the case of JPM 2003–
ML1, PTE 2002–19.
6. The Applicant states that none of
the Trusts were formed or marketed
with the knowledge that Bank of
America and Merrill Lynch would
become affiliated. In this regard, the
Applicant notes that there are no
securitizations on the Securitization List
that closed later than 2007; the
Acquisition was announced in the third
quarter of 2008. The Applicant states
that, in general, the Pooling and
Servicing Agreements governing the
applicable Securitizations permit the
cures detailed in their Application by
contemplating a Trustee’s resignation
and replacement so as to comply with
applicable law and providing the
Trustee the ability to appoint co-trustees
and other agents authorized to carry out
the Trustees’ duties. The Applicant
notes that the agreements do not
provide specific qualifications for cotrustees. While the agreements vary in
the detail, after due diligence, the
Applicant asserts that it is not aware of
any provisions of the agreements or SEC
requirements that preclude the cures
detailed in the Application.
7. Bank of America represents in its
Application that during the proposed
six month resolution period, for each
Securitization on the Securitization List,
the Trustee shall appoint a co-trustee,
which is not an Affiliate of Bank of
America, no later than the earlier of (a)
April 1, 2009 or (b) five business days
after Bank of America, N.A., the Trustee,
has become aware of a conflict between
the Trustee and any member of the
Restricted Group that is an Affiliate of
the Trustee. The co-trustee will be
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solely responsible for resolving such
conflict between the Trustee and any
member of the Restricted Group that has
become an Affiliate of the Trustee as a
result of the Acquisition; provided that
if the Trustee has resigned on or prior
to April 1, 2009, and no event described
in clause (b) has occurred, no co-trustee
shall be required since a replacement
trustee would be in place by April 1,
2009. Bank of America represents that
as Trustee, Bank of America, N.A. will
appoint a co-trustee with the knowledge
and skill necessary to resolve any
conflict arising between Bank of
America, N.A. and any Bank of America
affiliated member of the Restricted
Group. In the event that a co-trustee
were appointed, such co-trustee would
assume Bank of America, N.A.’s role
under the related Pooling and Servicing
Agreement (solely with respect to any
conflict between Bank of America, N.A.
and a Bank of America affiliate that is
a member of the Restricted Group) until
a replacement trustee replaced Bank of
America, N.A.
On January 29, 2009, The Applicant
informed the Department that Bank of
America, N. A. is resigning as Trustee
from a total of 70 transactions (this
number includes transactions where the
conflict is not ERISA-related and the
transaction is not on the Securitization
List). Bank of America, N.A. resigned
from 12 of these transactions on
December 31, 2008, will resign from 50
of these transactions by March 31, 2009,
and will resign from the remaining 8 no
later than June 30, 2009. Of the 12
transactions BofA resigned from on
December. 31, 2008, it resigned from 2
solely for ERISA purposes and 10 solely
for securities law purposes. As of
January 29, 2009, 27 transactions had
received replacement trustees. The
Applicant represented that the
replacement trustees for the remaining
transactions were currently being
negotiated. On March 16, 2009, the
Applicant informed the Department that
for all 49 of the Covered Transactions on
the Securitization List, the replacement
trustees will be in place as of March 31,
2009. Wells Fargo Bank, N.A. will be the
replacement trustee for five of the
Covered Transactions and U.S. Bank
National Association will be the
replacement trustee for the remaining 44
Covered Transactions. The Applicant
has further indicated that there were no
actual conflicts from the date that the
affiliation arose, January 1, 2009
through March 20, 2009. Thus, no cotrustee had to be appointed during that
period. The Applicant noted that in
cases where the Trustee is also the
securities administrator, Bank of
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America, N.A. will resign as Trustee and
remain securities administrator.
For purposes of this Proposed
Amendment, a conflict would arise
whenever (a) Merrill Lynch is a member
of the Restricted Group and fails to
perform in accordance with the
timeframes contained in the relevant
Pooling and Servicing Agreement
following a request for performance
from Bank of America, N.A., as Trustee,
or (b) Bank of America, N.A., as Trustee,
fails to perform in accordance with the
timeframes contained in the relevant
Pooling and Servicing Agreement
following a request for performance
from Merrill Lynch, a member of the
Restricted Group. The time as of which
a conflict occurs is the earlier of the day
immediately following the last day on
which compliance is required under the
relevant Pooling and Servicing
Agreement; or the day on which a party
affirmatively responds that it will not
comply with a request for performance.
Additionally, for purposes of this
Proposed Amendment, the term conflict
includes but is not limited to, the
following: (1) Merrill Lynch’s failure, as
Sponsor, to repurchase a loan for breach
of representation within the time period
prescribed in the relevant Pooling and
Servicing Agreement, following Bank of
America, N.A.’s request, as Trustee, for
performance; (2) Merrill Lynch, as
Sponsor, notifies Bank of America, N.A.,
as Trustee, that it will not repurchase a
loan for breach of representation,
following Bank of America, N.A.’s
request that Merrill Lynch repurchase
such loan within the time period
prescribed in the relevant Pooling and
Servicing Agreement (the notification
occurs prior to the expiration of the
prescribed time period for the
repurchase); and (3) Merrill Lynch, as
Swap Counterparty, makes or requests a
payment based on a value of LIBOR 4
that Bank of America, N.A., as Trustee,
considers erroneous.
8. In correspondence dated January
29, and February 3, 2009, Bank of
America represented to the Department
that it and Merrill Lynch were currently
identifying replacement trustees to
replace Bank of America, N.A. as
Trustee in approximately 70
transactions. The Applicant stated that
it intends to complete the negotiations
and paperwork on an ongoing basis,
with the effective date for all changes to
be April 1, 2009. The Applicant noted
that in contrast to co-trustees, any
replacement trustee will have to meet
the requirements of the related Trust
agreement for qualification as a Trustee
(i.e., will meet the same requirements
4 The
London Interbank Offered Rate.
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18:36 May 05, 2009
Jkt 217001
that Bank of America, N.A. (and its
predecessor, LaSalle Bank, N.A. had to
meet). A copy of a typical Pooling and
Servicing Agreement requirements for a
Trustee was provided to the
Department. The Applicant further
noted that if a conflict were to arise
prior to April 1, 2009 with respect to
any Trust, the most likely course would
be that Bank of America, N.A. would
promptly resign as Trustee and the
replacement trustee would assume its
role earlier than scheduled. The next
most likely scenario is that the party
that would become the replacement
trustee (and hence meets the
requirements of the related Pooling and
Servicing Agreement for qualification as
a Trustee) would be appointed cotrustee under the terms of the Proposed
Amendment. The Applicant stated,
however, there might be situations
where either such course of action
would be impossible or impractical, in
which case the parties would have to
appoint a different co-trustee until the
replacement trustee assumed its role.
The Applicant states that in certain
cases, Bank of America, N.A. will
continue as a securities administrator,
retaining certain reporting requirements
but be responsible to the replacement
trustee. The replacement trustee will
have legal title to the assets of the trust,
will have fiduciary responsibility to the
securities holders and will be
responsible for supervising Bank of
America, N.A. in whatever role it
retains.
9. Bank of America represents that, as
of March 20, 2009, there was no
outstanding conflict requiring resolution
involving Bank of America, N.A. and
any Merrill Lynch entity involved in the
transactions listed in the Securitizations
List. Further, Bank of America has
stated that it would notify the
Department of Labor of any conflict that
arose prior to the replacement of Bank
of America, N.A. as Trustee in any of
these transactions. The Applicant notes
that, as a technical matter, in the most
likely case (e.g. the assertion of a breach
of representation or warranty by the
Sponsor), the Pooling and Servicing
Agreements all require that the Trustee
provide the offending party 90 days to
cure the issue before the Trustee may
take any action to do so itself.
Consequently, if an issue would have
arisen after January 1, 2009; the Trustee
would not have been able to take any
action to cure the issue until after April
1, 2009. The Applicant asserts that since
it is expected that the Trustee
replacements will be made by April 1,
2009, it is not anticipated that a conflict
will arise while Bank of America, N.A.
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Fmt 4703
Sfmt 4703
21005
is the Trustee of any of the Covered
Transactions.
10. The Applicant notes that Plans
acquired Securities issued under the
Securitizations in reliance on the
exemptive relief provided by the
Underwriter Exemptions. Absent
additional relief, the Acquisition has
caused these granted exemptions to
cease to apply to several of the
Securitizations. Bank of America
represents that the Securities issued in
transactions such as the Securitizations
are attractive investments for Plans
subject to Title I of ERISA or section
4975 of the Code and conversely, such
plans are an important market for
issuers of such Securities. Bank of
America asserts that to force Bank of
America, N.A. to resign as Trustee in all
of the Securitizations before the
Acquisition was not administratively
feasible because the number of available
trustees is limited and there is work
required in changing trustees. Similarly,
to have the exemptions no longer apply
to the Securitizations would force the
Plans to sell their securities in the
current unstable market, likely at a loss.
The Applicant additionally notes that
although the Acquisition has been
widely covered, it is conceivable that
Plan fiduciaries would not realize that
the Underwriter Exemption relied upon
by the Plans had ceased to apply, raising
the possibility that a Plan would not sell
and that non-exempt prohibited
transactions would occur.
11. Bank of America states that the
Plans purchased Securities in reliance
on PTE 90–29 or PTE 2002–19. At that
time, the Plans had no knowledge that
the Trustee would become an Affiliate
of one or more members of the
Restricted Group. On or after the
Acquisition, except in cases covered by
PTE 90–29 as amended by PTE 2000–58
(providing a six-month window for
Trustee-Servicer affiliations) or PTE
2002–41 (Trustee-Underwriter
affiliations), the purchased Securities
would no longer be afforded coverage
under the Underwriter Exemptions and
the Plans would have been obligated to
sell the Securities prior to January 1,
2009. The Applicant asserts that this is
problematic for several reasons. First, as
is customary for such transactions, the
physical securities are not used in most
cases. Rather, an electronic system,
usually the Depository Trust Company’s
electronic system, is utilized and the
securities are in global form. In such
cases, it is difficult (and may be
impossible) to ascertain the beneficial
ownership of the securities, meaning
that it is not known whether Plans are
owners and to what extent. The
Applicant asserts that identifying the
E:\FR\FM\06MYN1.SGM
06MYN1
21006
Federal Register / Vol. 74, No. 86 / Wednesday, May 6, 2009 / Notices
mstockstill on PROD1PC66 with NOTICES
affected Plans would be time consuming
and expensive, and may be impossible
to do with complete accuracy because of
the book-entry system under which
Securities were issued. As stated above,
the Applicant represents that notice of
this request for relief was posted on the
Trustee’s website at the time this
Application was submitted, which
would be updated to reflect any action
of the Department with respect to the
Application. The Applicant has
informed the Department that, although
Bank of America, N.A. will have been
replaced as Trustee by April 1, 2009,
Bank of America, N.A. will remain as
the Securities Administrator for any of
the Securitizations on the Securitization
List for which it was providing such
services. Further, the Applicant has
indicated that either Bank of America,
N.A. (in cases where Bank of America,
N.A. continues as Securities
Administrator) or the replacement
trustee (in all other cases) will continue
to update its website concerning the
status of the Proposed Amendment. In
this regard, the Applicant also requests
that the publication of the Proposed
Amendment in the Federal Register
serve as the Notice to Interested Persons
for purposes of this submission.
Second, and more importantly, the
current disruption in the mortgagebacked securities market makes sales
problematic, both in terms of finding
buyers and establishing proper
valuation. Granting the requested relief
prevents these problems. The Applicant
states further that the relief is of the
same duration, six months, as that
already provided by the Department for
Trustee-Servicer affiliations, suggesting
that the Department has already
determined that this period is
sufficiently brief to prevent serious
conflicts of interest from arising.
12. Bank of America requests that the
relief, if granted, be made retroactive to
January 1, 2009, the Acquisition Date. If
the relief is granted retroactively, Plans
would be able to retain their prior
Securitization investments and to
purchase Securities in the secondary
market relying upon the Underwriter
Exemptions once exemptive relief is
granted, even if the transactions
originally closed or will close prior to
the date the final Amendment is
published in the Federal Register, if
granted by the Department.
General Information
The attention of interested persons is
directed to the following:
1. The fact that a transaction is the
subject of an exemption under section
408(a) of the Act and section 4975(c)(2)
of the Code does not relieve a fiduciary
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18:36 May 05, 2009
Jkt 217001
or other party in interest or disqualified
person from certain other provisions of
the Act and the Code, including any
prohibited transaction provisions to
which the exemption does not apply
and the general fiduciary responsibility
provisions of section 404 of the Act,
which require, among other things, a
fiduciary to discharge his or her duties
respecting the plan solely in the interest
of the participants and beneficiaries of
the plan and in a prudent fashion in
accordance with section 404(a)(1)(B) of
the Act; nor does it affect the
requirements of section 401(a) of the
Code that the plan operate for the
exclusive benefit of the employees of
the employer maintaining the plan and
their beneficiaries;
2. Before an exemption can be granted
under section 408(a) of the Act and
section 4975(c)(2) of the Code, the
Department must find that the
exemption is administratively feasible,
in the interest of the plans and of their
participants and beneficiaries and
protective of the rights of participants
and beneficiaries of the plans; and
3. The proposed amendment, if
granted, will be supplemental to, and
not in derogation of, any other
provisions of the Act and/or the Code,
including statutory or administrative
exemptions and transitional rules.
Furthermore, the fact that a transaction
is subject to an administrative or
statutory exemption is not dispositive of
whether the transaction is in fact a
prohibited transaction.
Written Comments and Hearing
Requests
All interested persons are invited to
submit written comments or requests for
a hearing on the pending amendment to
the address above, within the time
frame set forth above, after the
publication of this proposed
amendment in the Federal Register. All
comments will be made a part of the
record. Comments received will be
available for public inspection with the
Application at the address set forth
above.
Proposed Exemption
Based on the facts and representations
set forth in the application, under the
authority of section 408(a) of the Act
and section 4975(c)(2) of the Code and
in accordance with the procedures set
forth in 29 CFR Part 2570, Subpart B (55
FR 32836, August 10, 1990), the
Department proposes to modify
Prohibited Transaction Exemption (PTE)
90–29, 55 FR 21459 (May 24, 1990), as
amended by PTE 97–34, 62 FR 39021
(July 21, 1997), PTE 2000–58, 65 FR
67765 (November 13, 2000), PTE 2002–
PO 00000
Frm 00108
Fmt 4703
Sfmt 4703
41, 67 FR 54487 (August 22, 2002) and
PTE 2007–05, 72 FR 13130 (March 20,
2007), as corrected at 72 FR 16385
(April 4, 2007) (PTE 2007–05), (PTE 90–
29) and to modify PTE 2002–19, 67 FR
14979 (March 28, 2002) as amended by
PTE 2007–05, (PTE 2002–19).
1. Subsection II.A.(4) of PTE 90–29
and PTE 2002–19 is amended to add a
new subsection (c) that reads as follows:
(c) Effective January 1, 2009 through July
1, 2009, Bank of America, N.A., the Trustee,
shall not be considered to be an Affiliate of
any member of the Restricted Group solely as
the result of the acquisition of Merrill Lynch
& Co., Inc. and its affiliates (Merrill Lynch)
by Bank of America Corporation and its
subsidiaries (Bank of America), the parent
holding company of Bank of America, N.A.
(the Acquisition), which occurred after the
initial issuance of the Securities, provided
that:
(i) The Trustee, Bank of America, N.A.,
ceases to be an Affiliate of any member of the
Restricted Group no later than July 1, 2009;
(ii) Any member of the Restricted Group
that is an Affiliate of the Trustee, Bank of
America, N.A., did not breach any of its
obligations under the Pooling and Servicing
Agreement, unless such breach was
immaterial and timely cured in accordance
with the terms of such agreement, during the
period from January 1, 2009 through the date
the member of the Restricted Group ceased
to be an Affiliate of the Trustee, Bank of
America, N.A.; and
(iii) In accordance with each Pooling and
Servicing Agreement, the Trustee, Bank of
America, N.A., appoints a co-trustee, which
is not an Affiliate of Merrill Lynch or any
other member of the Restricted Group, no
later than the earlier of (A) April 1, 2009 or
(B) five business days after Bank of America,
N.A. becomes aware of a conflict between the
Trustee and any member of the Restricted
Group that is an Affiliate of the Trustee. The
co-trustee will be responsible for resolving
any conflict between the Trustee and any
member of the Restricted Group that has
become an Affiliate of the Trustee as a result
of the Acquisition; provided, that if the
Trustee has resigned on or prior to April 1,
2009 and no event described in clause (B) has
occurred, no co-trustee shall be required.
(iv) For purposes of this subsection
II.A.(4)(c), a conflict arises whenever (A)
Merrill Lynch, as a member of the Restricted
Group, fails to perform in accordance with
the timeframes contained in the relevant
Pooling and Servicing Agreement following a
request for performance from Bank of
America, N.A., as Trustee, or (B) Bank of
America, N.A., as Trustee, fails to perform in
accordance with the timeframes contained in
the relevant Pooling and Servicing
Agreement following a request for
performance from Merrill Lynch, a member
of the Restricted Group.
The time as of which a conflict occurs is
the earlier of: the day immediately following
the last day on which compliance is required
under the relevant Pooling and Servicing
Agreement; or the day on which a party
affirmatively responds that it will not comply
with a request for performance.
E:\FR\FM\06MYN1.SGM
06MYN1
21007
Federal Register / Vol. 74, No. 86 / Wednesday, May 6, 2009 / Notices
For purposes of this subsection II.A.(4)(c),
the term ‘‘conflict’’ includes but is not
limited to, the following: (1) Merrill Lynch’s
failure, as Sponsor, to repurchase a loan for
breach of representation within the time
period prescribed in the relevant Pooling and
Servicing Agreement, following Bank of
America, N.A.’s request, as Trustee, for
performance; (2) Merrill Lynch, as Sponsor,
notifies Bank of America, N.A., as Trustee,
that it will not repurchase a loan for breach
of representation, following Bank of America,
N.A.’s request that Merrill Lynch repurchase
such loan within the time period prescribed
in the relevant Pooling and Servicing
Agreement (the notification occurs prior to
the expiration of the prescribed time period
for the repurchase); and (3) Merrill Lynch, as
Swap Counterparty, makes or requests a
payment based on a value of the London
Interbank Offered Rate (LIBOR) that Bank of
America, N.A., as Trustee, considers
erroneous.
2. The Definition of ‘‘Underwriter’’ at
section III.C. of PTE 90–29 and PTE
2002–19 is temporarily replaced with a
definition that includes J.P. Morgan
Securities Inc. and reads:
C. Effective January 1, 2009 through
July 1, 2009, ’’Underwriter’’ means:
(1) Merrill Lynch or J.P. Morgan Securities
Inc.;
(2) Any person directly or indirectly,
through one or more intermediaries,
controlling, controlled by or under common
control with such entities; or
(3) Any member of an underwriting
syndicate or selling group of which such firm
or person described in subsections III.C.(1) or
(2) is a manager or co-manager with respect
to the Securities.
3. The Definition of ‘‘Sponsor’’ at
section III.D. of PTE 90–29 and PTE
2002–19 is temporarily extended to
include language applicable to
transactions on the Securitization List at
section III.KK and reads:
D. ‘‘Sponsor’’ means:
(1) The entity that organizes an Issuer by
depositing obligations therein in exchange
for Securities; or
(2) Effective January 1, 2009 through July
1, 2009, for those transactions listed on the
Securitization List at section III.KK., Merrill
Lynch.
4. Section III of PTE 90–29 and PTE
2002–19 is temporarily amended to add
a new section III.KK that reads as
follows:
KK. Effective January 1, 2009 through
July 1, 2009,
‘‘Securitization List’’ means:
Issuance
type
mstockstill on PROD1PC66 with NOTICES
Name
CMAC Series 1997 ML1 .........................................................................................................................................................
WFPD 1996 WFP–D ...............................................................................................................................................................
Merrill Lynch 2003–KEY 1 ......................................................................................................................................................
Merrill Lynch Series 1997–C1 .................................................................................................................................................
Merrill Lynch Series 2004–KEY 2 ...........................................................................................................................................
Merrill Lynch Series 2006–C2 .................................................................................................................................................
Mezz Cap 2004–C2 ................................................................................................................................................................
C–BASS 2007–CB4 ................................................................................................................................................................
First Franklin MLT 2006–FF18 ................................................................................................................................................
First Franklin MLT 2007–01 ....................................................................................................................................................
First Franklin MLT 2007–02 ....................................................................................................................................................
First Franklin MLT 2007–03 ....................................................................................................................................................
First Franklin MLT 2007–4 ......................................................................................................................................................
First Franklin MLT 2007–5 ......................................................................................................................................................
First Franklin MLT 2007–A ......................................................................................................................................................
First Franklin MLT 2007–FF1 ..................................................................................................................................................
First Franklin MLT 2007–FF2 ..................................................................................................................................................
First Franklin MLT 2007–FFA .................................................................................................................................................
First Franklin MLT 2007–FFC .................................................................................................................................................
First Franklin MLT 2007–H1 ...................................................................................................................................................
Merrill Lynch Series 2005–SL3 ...............................................................................................................................................
Merrill Lynch Series 2006–AHL1 ............................................................................................................................................
Merrill Lynch Series 2006–AR1 ..............................................................................................................................................
Merrill Lynch Series 2006–FF1 ...............................................................................................................................................
Merrill Lynch Series 2006–FM1 ..............................................................................................................................................
Merrill Lynch Series 2006–HE2 ..............................................................................................................................................
Merrill Lynch Series 2006–HE3 ..............................................................................................................................................
Merrill Lynch Series 2006–HE4 ..............................................................................................................................................
Merrill Lynch Series 2006–HE6 ..............................................................................................................................................
Merrill Lynch Series 2006–MLN1 ............................................................................................................................................
Merrill Lynch Series 2006–OPT1 ............................................................................................................................................
Merrill Lynch Series 2006–RM1 ..............................................................................................................................................
Merrill Lynch Series 2006–RM2 ..............................................................................................................................................
Merrill Lynch Series 2006–RM3 ..............................................................................................................................................
Merrill Lynch Series 2006–RM4 ..............................................................................................................................................
Merrill Lynch Series 2006–RM5 ..............................................................................................................................................
Merrill Lynch Series 2006–SD1 ..............................................................................................................................................
Merrill Lynch Series 2006–SL1 ...............................................................................................................................................
Merrill Lynch Series 2006–WMC2 ..........................................................................................................................................
Merrill Lynch Series 2007–HE1 ..............................................................................................................................................
Merrill Lynch Series 2007–HE3 ..............................................................................................................................................
Merrill Lynch Series 2007–SD1 ..............................................................................................................................................
MLMI Trust 2002–AFC1 ..........................................................................................................................................................
Ownit Mort Loan ABS 2006–3 ................................................................................................................................................
Ownit Mort Loan ABS 2006–4 ................................................................................................................................................
Ownit Mort Loan ABS 2006–5 ................................................................................................................................................
Ownit Mort Loan ABS 2006–6 ................................................................................................................................................
Ownit Mort Loan ABS 2006–7 ................................................................................................................................................
VerDate Nov<24>2008
18:36 May 05, 2009
Jkt 217001
PO 00000
Frm 00109
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E:\FR\FM\06MYN1.SGM
06MYN1
C
C
C
C
C
C
C
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
R
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............
............
MLynch
role
S, U
S, U
S, U
S, U
S, U
S, U
S, U
S, U
S, U, MS
S, U, MS
U, MS
U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U
S, U, MS
S, U, MS
S, U
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U, MS
S, U
S, U
S, U
S, U
S, U
S, U
21008
Federal Register / Vol. 74, No. 86 / Wednesday, May 6, 2009 / Notices
Name
Issuance
type
JP Morgan Chase 2003–ML1 (U—JP Morgan Securities Inc.) ..............................................................................................
C ............
MLynch
role
S
Legend: C = Commercial mortgage-backed securitizations.
R = Residential mortgage-backed securitizations.
U = Underwriter.
S = Sponsor.
MS = Master Servicer (either HLS or Wilshire).
MLynch = Merrill Lynch.
The availability of this amendment, if
granted, is subject to the express
condition that the material facts and
representations contained in the
Application are true and complete and
accurately describe all material terms of
the transactions. In the case of
continuing transactions, if any of the
material facts or representations
described in the Application change, the
amendment will cease to apply as of the
date of such change. In the event of any
such change, an application for a new
amendment must be made to the
Department.
Signed at Washington, DC, this 30th day of
April, 2009.
Ivan L. Strasfeld,
Director of Exemption Determinations,
Employee Benefits Security Administration,
U.S. Department of Labor.
[FR Doc. E9–10362 Filed 5–5–09; 8:45 am]
BILLING CODE 4510–29–P
DEPARTMENT OF LABOR
Russell Brands, LLC, Coosa River Yarn
Division, Wetumpka, AL; Notice of
Termination of Investigation
In accordance with Section 221 of the
Trade Act of 1974, as amended, an
investigation was initiated on March 18,
2009 in response to a petition filed by
a company official on behalf of workers
of Russell Brands, LLC, Coosa River
Yarn, Wetumpka, Alabama.
The petitioner has requested that the
petition be withdrawn. Consequently,
the investigation has been terminated.
Signed in Washington, DC, this 1st day of
April, 2009
Richard Church,
Certifying Officer, Division of Trade
Adjustment Assistance.
[FR Doc. E9–10388 Filed 5–5–09; 8:45 am]
[MCC FR 09–09]
Superior Fabrication Company LLC,
Kincheloe, MI; Notice of Termination of
Investigation
Pursuant to Section 221 of the Trade
Act of 1974, as amended, an
investigation was initiated on February
9, 2009 in response to a petition filed by
a company official on behalf of workers
of Superior Fabrication Company LLC,
Kincheloe, Michigan.
The petitioner has requested that the
petition be withdrawn. Therefore, the
investigation under this petition has
been terminated.
mstockstill on PROD1PC66 with NOTICES
[TA–W–65,626]
MILLENNIUM CHALLENGE
CORPORATION
[TA–W–65,173]
Signed at Washington, DC, this 1st day of
April, 2009.
Richard Church,
Certifying Officer, Division of Trade
Adjustment Assistance.
[FR Doc. E9–10375 Filed 5–5–09; 8:45 am]
BILLING CODE 4510–FN–P
18:36 May 05, 2009
Employment and Training
Administration
BILLING CODE 4510–FN–P
Employment and Training
Administration
VerDate Nov<24>2008
DEPARTMENT OF LABOR
Jkt 217001
Request for Information From the
Private Sector for Malawi Compact
Program Development
AGENCY: Millennium Challenge
Corporation.
ACTION: Invitation for private sector
input.
Authority: 22 U.S.C. 7701 et seq.
The Millennium Challenge
Corporation (‘‘MCC’’) is a U.S.
Government agency created in 2004 to
administer the Millennium Challenge
Account. Its mission is to reduce
poverty through the promotion of
sustainable economic growth. Since
2004, MCC has signed Compact
programs with eighteen partner
countries ranging from $66 million to
$698 million. In April 2009, the
Government of Malawi (‘‘GoM’’)
through ‘‘MCA–Malawi’’ presented a
SUMMARY:
PO 00000
Frm 00110
Fmt 4703
Sfmt 4703
proposal including three projects to
MCC for potential Compact funding.
This Request for Information (‘‘RFI’’)
aims to solicit feedback from the private
sector on these projects.
SUPPLEMENTARY INFORMATION: This
solicitation has the following objectives:
(a) Share best practices and private
sector experiences on similar projects
from other countries; (b) Generate
opportunities for leverage of Compact
funds with private sector financing,
trade, and investment; and (c) Solicit
information about opportunities and
challenges facing businesses in the
sectors which have been identified for
possible Compact projects.
This solicitation is focused on the
three following project proposals, which
are posted publicly in full detail at
https://www.mca-m.gov.mw/index.php/
concept-papers/81:
b The proposed ‘‘Energy’’ project
would fund increased availability of
reliable and quality power, access to
power, efficient power service delivery,
and improved natural resources
management.
b The proposed ‘‘Transport’’ project
would fund more reliable, efficient and
affordable transport options through
road and rail investments.
b The proposed ‘‘Governance’’
project would fund improvements to the
public financial management and
budget oversight system as well as
assistance to GoM anti-corruption
agencies.
Where possible, respondents are
encouraged to provide information
based on experience in the country.
Experiences from other countries may
also be applicable. MCA–Malawi may
use information provided by the private
sector to structure projects for Compact
funding.
FOR FURTHER INFORMATION: Visit https://
www.mca-rn.gov.mw/. Responses to and
questions about this Request for
Information should be e-mailed to
info@mca-m.gov.mw and to
psi@mcc.gov.
DATES: Companies, other organizations,
and individuals are invited to submit
responses on or before Friday, May 15,
2009.
E:\FR\FM\06MYN1.SGM
06MYN1
Agencies
[Federal Register Volume 74, Number 86 (Wednesday, May 6, 2009)]
[Notices]
[Pages 21002-21008]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-10362]
-----------------------------------------------------------------------
DEPARTMENT OF LABOR
Employee Benefits Security Administration
Notice of a Proposed Amendment to Prohibited Transaction
Exemption (PTE) 90-29, 55 FR 21459 (May 24, 1990), as Amended by PTE
97-34, 62 FR 39021 (July 21, 1997), PTE 2000-58, 65 FR 67765 (November
13, 2000), PTE 2002-41, 67 FR 54487 (August 22,2002) and PTE 2007-05,
72 FR 13130 (March 20, 2007) as Corrected at 72 FR 16385 (April 4,
2007) (PTE 2007-05), (PTE 90-29), Involving Merrill Lynch, Pierce,
Fenner & Smith, Inc., the Principal Subsidiary of Merrill Lynch & Co.,
Inc. and Its Affiliates (Merrill Lynch) and to PTE 2002-19, 67 FR 14979
(March 28, 2002) as Amended by PTE 2007-05, (PTE 2002-19), Involving
J.P. Morgan Chase & Company and Its Affiliates (D-11519)
AGENCY: Employee Benefits Security Administration, Department of Labor.
ACTION: Notice of a Proposed Amendment to PTE 90-29.
-----------------------------------------------------------------------
SUMMARY: This document contains a notice of pendency before the
Department of Labor (the Department) of a proposed amendment to PTE 90-
29 and PTE 2002-19, Underwriter Exemptions.\1\ The Underwriter
Exemptions are individual exemptions that provide relief for the
origination and operation of certain asset pool investment trusts and
the acquisition, holding and disposition by employee benefit plans
(Plans) of certain asset-backed pass-through certificates representing
undivided interests in those investment trusts. The proposed amendment
to PTE 90-29 and 2002-19, if granted, would provide a six month period
to resolve certain affiliations, as a result of Bank of America
Corporation's acquisition of Merrill Lynch, between Bank of America,
N.A., the Trustee, and Merrill Lynch as members of the Restricted
Group, as those terms are defined in the Underwriter Exemptions (the
Proposed Amendment). The Proposed Amendment, if granted, would affect
the participants and beneficiaries of the Plans participating in such
transactions and the fiduciaries with respect to such Plans.
---------------------------------------------------------------------------
\1\ The ``Underwriter Exemptions'' are a group of individual
exemptions that provide substantially identical relief for the
operation of certain asset-backed or mortgage-backed investment
pools and the acquisition and holding by Plans of certain securities
representing interests in those investment pools.
DATES: Written comments and requests for a hearing should be received
---------------------------------------------------------------------------
by the Department by June 5, 2009.
ADDRESSES: All written comments and requests for a public hearing
(preferably, three copies) should be sent to the Office of Exemption
Determinations, Employee Benefits Security Administration, Room N-5700,
U.S. Department of Labor, 200 Constitution Avenue, NW., Washington, DC
20210, (Attention: Exemption Application Number D-11519). Interested
persons are invited to submit comments and/or hearing requests to the
Department by the end of the scheduled comment period either by
facsimile to (202) 219-0204 or by electronic mail to
moffitt.betty@dol.gov. The application pertaining to the Proposed
Amendment (Application) and the comments received will be available for
public inspection in the Public Disclosure Room of the Employee
Benefits Security Administration, U.S. Department of Labor, Room N-
1513, 200 Constitution Avenue, NW., Washington, DC 20210.
FOR FURTHER INFORMATION CONTACT: Wendy M. McColough of the Department,
telephone (202) 693-8540. (This is not a toll-free number.)
SUPPLEMENTARY INFORMATION: This document contains a notice of pendency
before the Department of a proposed exemption to amend PTE 90-29 and
PTE 2002-19, Underwriter Exemptions. The Underwriter Exemptions are a
group of individual exemptions granted by the Department that provide
substantially identical relief from certain of the restrictions of
sections 406 and 407 of the Employee Retirement Income Security Act of
1974 (ERISA or the Act) and from the taxes imposed by sections 4975(a)
and (b) of the Internal Revenue Code of 1986, as amended (Code), by
reason of certain provisions of section of 4975(c)(1) of the Code for
the operation of certain asset pool investment trusts and the
acquisition, holding, and disposition by Plans of certain asset-backed
pass-through certificates representing undivided interests in those
investment trusts.
All of the Underwriter Exemptions were amended by PTE 97-34, 62 FR
39021 (July 21, 1997), PTE 2000-58, 65 FR 67765 (November 13, 2000),
and PTE 2007-05, 72 FR 13130 (March 20, 2007), as corrected at 72 FR
16385 (April 4, 2007). Certain of the Underwriter Exemptions were
amended by PTE 2002-41, 67 FR 54487 (August 22, 2002) or modified by
PTE 2002-19.
The Department is proposing this amendment to PTE 90-29 and to PTE
2002-19 pursuant to section 408(a) of the Act and section 4975(c)(2) of
the Code, and in accordance with the procedures set forth in 29 CFR
Part 2570, Subpart B (55 FR 32836, 32847, August 10, 1990).\2\
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\2\ Section 102 of Reorganization Plan No. 4 of 1978 (5 U.S.C.
App. 1 [1996]) generally transferred the authority of the Secretary
of the Treasury to issue exemptions under section 4975(c)(2) of the
Code to the Secretary of Labor.
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1. The Underwriter Exemptions permit Plans to invest in pass-
through securities representing undivided interests in asset-backed or
mortgage-backed investment pools (Securities). The Securities generally
take the form of certificates issued by a trust (Trust). The
Underwriter Exemptions permit transactions involving a Trust, including
the servicing, management and operation of the Trust, and the sale,
exchange or transfer of Securities evidencing interests therein, in the
initial issuance of the Securities or in the secondary market for such
Securities (the Covered Transactions). The most recent amendment to the
Underwriter Exemptions is PTE 2007-05, 72 FR 13130 (March 20, 2007), as
corrected at 72 FR 16385 (April 4, 2007) (PTE 2007-05). One of the
General Conditions of the Underwriter Exemptions, as amended, requires
that the Trustee not
[[Page 21003]]
be an ``Affiliate'' of any member of the ``Restricted Group'' other
than an ``Underwriter.'' PTE 2007-05, subsection II.A.(4). The term
``Restricted Group'' is defined under section III.M. as: (1) Each
Underwriter; (2) Each Insurer; (3) The Sponsor; (4) The Trustee; (5)
Each Servicer (6) Any Obligor with respect to obligations or
receivables included in the Issuer constituting more than 5 percent of
the aggregate unamortized principal balance of the assets in the
Issuer, determined on the date of the initial issuance of Securities by
the Issuer; (7) Each counterparty in an Eligible Swap Agreement; or (8)
Any Affiliate of a person described in subsections III.M.(1)-(7).'' The
term ``Servicer'' is defined to include ``the Master Servicer and any
Subservicer.'' PTE 2007-05, section III.G. The term ``Affiliate'' is
defined, in part, to include ``(1) Any person directly or indirectly,
through one or more intermediaries, controlling, controlled by, or
under common control with such other person; (2) Any officer, director,
partner, employee * * * of such other person; and (3) Any corporation
or partnership of which such other person is an officer, director or
partner.'' PTE 2007-05, section III.N.
2. On May 24, 1990, PTE 90-29 was granted to Merrill Lynch, Pierce,
Fenner & Smith, Inc. (MLPFS), the principal subsidiary of Merrill
Lynch. MLPF&S is a Delaware corporation registered with and regulated
by the SEC as a broker-dealer, and is a member of the New York Stock
Exchange, and the National Association of Securities Dealers, Inc.
MLPFS is also regulated by the Municipal Securities Rulemaking Board
(with respect to municipal securities activities), the Commodity
Futures Trading Commission, and the National Futures Association (with
respect to MLPFS's activities as a futures commission merchant). MLPFS
is a leading broker and/or dealer in the purchase and sale of corporate
equity and debt securities, mutual funds, money market instruments,
government securities, high yield bonds, municipal securities,
financial futures contracts, and options. As a leading investment
banking firm, MLPFS provides corporate, institutional, and government
clients with a wide variety of financial services including
underwriting the sale of securities to the public, structured and
derivative financing, private placements, mortgage and lease financing,
and financial advisory services, which includes advice on mergers and
acquisitions. MLPFS also acts as a prime broker for hedge funds.
Further, MLPFS operates mutual fund advisory programs, which provide
plans governed by ERISA or section 4975 of the Code investment advice
concerning purchasing mutual funds shares.
3. Bank of America Corporation (Bank of America or the Applicant)
notes that it is the parent holding company of Bank of America, N.A.,
the Trustee of each of the commercial or residential mortgage-backed
securitizations in the Covered Transactions. The Proposed Amendment was
requested by application dated November 24, 2008, and as updated by
Bank of America (the Application). The Applicant states that on January
1, 2009 (the Acquisition Date), Bank of America acquired Merrill Lynch
(the Acquisition). Merrill Lynch is a holding company that, through its
subsidiaries, provides broker-dealer, investment banking, financing,
wealth management, advisory, insurance, lending and related products
and services on a global basis. Merrill Lynch is a ``Consolidated
Supervised Entity,'' \3\ and is subject to group-wide supervision by
the SEC. On March 4, 2009, the Applicant explained that Merrill Lynch &
Co., Inc. (Parent or Merrill Lynch) is the ultimate parent of all of
its subsidiaries, and was (prior to its acquisition by Bank of America)
a publicly traded holding company. Among the direct subsidiaries of the
Parent, each 100% owned by Parent, are Merrill Lynch Group, Inc. (MLG),
Merrill Lynch Bank & Trust Co., FSB (MLBT) and Merrill Lynch, Pierce,
Fenner & Smith Incorporated (MLPFS).
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\3\ Effective August 2004, the Securities Exchange Commission
(Commission) adopted rule amendments that established a voluntary,
alternative method for computing net capital for certain broker-
dealers. As a condition to its use of the alternative method, a
broker-dealer's ultimate holding company and affiliates (referred to
collectively as a consolidated supervised entity or CSE) must
consent to group-wide Commission supervision. These rules, among
other things, respond to international developments. Specifically,
affiliates of certain US broker-dealers that conduct business in the
European Union (EU) have stated that they must demonstrate that they
are subject to consolidated supervision at the ultimate holding
company level that is ``equivalent'' to EU consolidated supervision.
Commission supervision incorporated into these rule amendments
addresses this standard. These amendments and the SEC's program for
consolidated supervision of broker-dealers and affiliates will
minimize duplicative regulatory burdens on firms that are active in
the EU, as well as in other jurisdictions that may have similar
laws.
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For the Covered Transactions that are the subject of the
Applicant's request, Merrill Lynch Mortgage Capital Inc. (Mortgage
Capital) is the Sponsor of certain transactions subject to PTE 90-29
and is an indirect, 100% owned subsidiary of MLG. Mortgage Capital's
direct 100% owned subsidiaries include Merrill Lynch Mortgage Lending,
Inc., the Sponsor of certain Covered Transactions, Merrill Lynch
Mortgage Investors, Inc., the Sponsor of one Covered Transaction and
Wilshire Credit Corporation (Wilshire), the Servicer of certain Covered
Transactions.
Mortgage Capital purchased Wilshire in January 2004. MLBT is the
100% parent of FF Mortgage Corporation, which in turn is the 100%
parent of Home Loan Services, Inc. (HLS), a Servicer of certain of the
Covered Transactions. On October 20, 2006, MLBT acquired the subprime
mortgage assets of National City Bank, including the stock of First
Franklin Financial Corporation (FFFC), National City Home Loan Services
(the related servicing platform) and the mortgage loan origination
platform of National City Bank (which operated as the First Franklin
Financial division of National City Bank). The mortgage loan
origination platform was subsequently transferred into First Franklin
Financial Corporation. With the acquisition, the servicing division was
renamed HLS and this entity services First Franklin loans. HLS is a
direct 100% owned subsidiary of MLBT. FFFC is the Sponsor of certain of
the Covered Transactions. On March 5, 2008, Parent announced that FFFC
would no longer originate loans. Concurrent with this announcement, FF
Mortgage Corporation sold the stock of FFFC to Merrill Lynch Mortgage
Services Corporation, a subsidiary of Mortgage Capital (which actions
were taken to satisfy the Office of Thrift Supervision). PTE 90-29 was
granted to MLPFS, a direct 100% owned subsidiary of Parent and the
Underwriter of certain of the Covered Transactions.
4. The Acquisition caused certain transactions previously subject
to PTE 90-29 or PTE 2002-19 to fail to satisfy the requirement under
the Underwriter Exemptions that the Trustee not be an Affiliate of any
member of the Restricted Group other than an Underwriter. PTE 2007-05
subsection II.A.(4). Currently, for transactions where Merrill Lynch is
the Servicer, a six-month period is provided by the Underwriter
Exemptions to sever the affiliation between the Servicer and the
Trustee if the affiliation occurred after the initial issuance of the
Securities. PTE 2007-05, subsection II.A.(4)(b). However, there is
currently no transitional relief under PTE 90-29 where Merrill Lynch is
a Sponsor, Underwriter or a Swap Counterparty and Bank of America, N.A.
is the Trustee. Accordingly, Bank of America seeks a temporary
amendment to PTE 90-29 to provide for a six-month period for resolution
of certain
[[Page 21004]]
prohibited affiliations caused by the Acquisition of Merrill Lynch by
Bank of America, the parent of the Trustee.
In addition, the Applicant requests that the amendment provide
similar relief for one other Covered Transaction, JPM 2003-ML1, where
Bank of America is Trustee and Merrill Lynch is a Sponsor. In this
transaction, the Underwriter, J.P. Morgan Securities Inc., who is
unrelated to Bank of America, relies upon PTE 2002-19, granted to J.P.
Morgan Chase & Co. and its affiliates. The Applicant provides that J.P.
Morgan Securities Inc. is the principal nonbank subsidiary of J.P.
Morgan Chase & Co. JP Morgan Chase Commercial Mortgage Securities Corp.
is 100% owned by JPMorgan Chase Bank, N.A., which in turn, is 100%
owned by J.P. Morgan Chase & Co. JP Morgan Chase Commercial Mortgage
Securities Corp. has confirmed to the Applicant that it has been
notified of the application for the Proposed Amendment and has agreed
to coverage under the Proposed Amendment. Bank of America represents
that it has placed a notice on its web pages for each of the Covered
Transactions affected by the Acquisition and that this notice would be
updated upon publication of the Proposed Amendment, and if granted, the
final amendment. Further, the Web pages will note the appointment of
any co-trustee and the appointment of the replacement trustee. The
Applicant states that Bank of America, N.A., in its role of Trustee,
will bear the cost of appointing such co-trustee and that there will be
no financial impact on any Underwriter.
5. Bank of America represents that the Covered Transactions
affected by the Acquisition consist of 49 commercial or residential
mortgage-backed securitizations (CMBS or RMBS) (Securitizations) as
detailed at section III.KK of the Proposed Amendment (the
Securitizations List). Bank of America states that all of the
Securitizations were structured and are managed to meet the
requirements of PTE 90-29 or in the case of JPM 2003-ML1, PTE 2002-19,
in each case as amended by PTE 2007-05. Bank of America, N.A. is the
Trustee in each of the Securitizations. The Applicant represents that,
in its role as Trustee, Bank of America, N.A. is obligated under both
the operative documents that securitize the loans, and under state law
relating to fiduciaries, to protect the interests of security holders.
Specifically, the Trustee is required to enforce the rights of security
holders against other parties to the transaction, including Servicers,
Swap Counterparties and loan sellers. The Applicant notes further that
in practice, due to industry standards and reputation concerns by the
various parties, little such protection or enforcement is necessary,
and the Trustee's role, while vigilant, is relatively passive. Merrill
Lynch is a party to each of the Securitizations in the capacity or
capacities detailed in the Securitizations List. The Applicant states
that, in any of these capacities, Merrill Lynch is obligated, under the
operative documents of the transaction, to perform its designated
duties under contractual and, in some cases, industry standards for the
benefit of security holders. The Applicant represents that each of the
Pooling and Servicing Agreements has been structured to comply with PTE
90-29 or in the case of JPM 2003-ML1, PTE 2002-19 and that each of the
Trusts has been managed in accordance with the related Pooling and
Servicing Agreement. Consequently, Securities issued by each Trust
currently are eligible for purchase by Plans that meet the requirements
of PTE 90-29 or in the case of JPM 2003-ML1, PTE 2002-19.
6. The Applicant states that none of the Trusts were formed or
marketed with the knowledge that Bank of America and Merrill Lynch
would become affiliated. In this regard, the Applicant notes that there
are no securitizations on the Securitization List that closed later
than 2007; the Acquisition was announced in the third quarter of 2008.
The Applicant states that, in general, the Pooling and Servicing
Agreements governing the applicable Securitizations permit the cures
detailed in their Application by contemplating a Trustee's resignation
and replacement so as to comply with applicable law and providing the
Trustee the ability to appoint co-trustees and other agents authorized
to carry out the Trustees' duties. The Applicant notes that the
agreements do not provide specific qualifications for co-trustees.
While the agreements vary in the detail, after due diligence, the
Applicant asserts that it is not aware of any provisions of the
agreements or SEC requirements that preclude the cures detailed in the
Application.
7. Bank of America represents in its Application that during the
proposed six month resolution period, for each Securitization on the
Securitization List, the Trustee shall appoint a co-trustee, which is
not an Affiliate of Bank of America, no later than the earlier of (a)
April 1, 2009 or (b) five business days after Bank of America, N.A.,
the Trustee, has become aware of a conflict between the Trustee and any
member of the Restricted Group that is an Affiliate of the Trustee. The
co-trustee will be solely responsible for resolving such conflict
between the Trustee and any member of the Restricted Group that has
become an Affiliate of the Trustee as a result of the Acquisition;
provided that if the Trustee has resigned on or prior to April 1, 2009,
and no event described in clause (b) has occurred, no co-trustee shall
be required since a replacement trustee would be in place by April 1,
2009. Bank of America represents that as Trustee, Bank of America, N.A.
will appoint a co-trustee with the knowledge and skill necessary to
resolve any conflict arising between Bank of America, N.A. and any Bank
of America affiliated member of the Restricted Group. In the event that
a co-trustee were appointed, such co-trustee would assume Bank of
America, N.A.'s role under the related Pooling and Servicing Agreement
(solely with respect to any conflict between Bank of America, N.A. and
a Bank of America affiliate that is a member of the Restricted Group)
until a replacement trustee replaced Bank of America, N.A.
On January 29, 2009, The Applicant informed the Department that
Bank of America, N. A. is resigning as Trustee from a total of 70
transactions (this number includes transactions where the conflict is
not ERISA-related and the transaction is not on the Securitization
List). Bank of America, N.A. resigned from 12 of these transactions on
December 31, 2008, will resign from 50 of these transactions by March
31, 2009, and will resign from the remaining 8 no later than June 30,
2009. Of the 12 transactions BofA resigned from on December. 31, 2008,
it resigned from 2 solely for ERISA purposes and 10 solely for
securities law purposes. As of January 29, 2009, 27 transactions had
received replacement trustees. The Applicant represented that the
replacement trustees for the remaining transactions were currently
being negotiated. On March 16, 2009, the Applicant informed the
Department that for all 49 of the Covered Transactions on the
Securitization List, the replacement trustees will be in place as of
March 31, 2009. Wells Fargo Bank, N.A. will be the replacement trustee
for five of the Covered Transactions and U.S. Bank National Association
will be the replacement trustee for the remaining 44 Covered
Transactions. The Applicant has further indicated that there were no
actual conflicts from the date that the affiliation arose, January 1,
2009 through March 20, 2009. Thus, no co-trustee had to be appointed
during that period. The Applicant noted that in cases where the Trustee
is also the securities administrator, Bank of
[[Page 21005]]
America, N.A. will resign as Trustee and remain securities
administrator.
For purposes of this Proposed Amendment, a conflict would arise
whenever (a) Merrill Lynch is a member of the Restricted Group and
fails to perform in accordance with the timeframes contained in the
relevant Pooling and Servicing Agreement following a request for
performance from Bank of America, N.A., as Trustee, or (b) Bank of
America, N.A., as Trustee, fails to perform in accordance with the
timeframes contained in the relevant Pooling and Servicing Agreement
following a request for performance from Merrill Lynch, a member of the
Restricted Group. The time as of which a conflict occurs is the earlier
of the day immediately following the last day on which compliance is
required under the relevant Pooling and Servicing Agreement; or the day
on which a party affirmatively responds that it will not comply with a
request for performance.
Additionally, for purposes of this Proposed Amendment, the term
conflict includes but is not limited to, the following: (1) Merrill
Lynch's failure, as Sponsor, to repurchase a loan for breach of
representation within the time period prescribed in the relevant
Pooling and Servicing Agreement, following Bank of America, N.A.'s
request, as Trustee, for performance; (2) Merrill Lynch, as Sponsor,
notifies Bank of America, N.A., as Trustee, that it will not repurchase
a loan for breach of representation, following Bank of America, N.A.'s
request that Merrill Lynch repurchase such loan within the time period
prescribed in the relevant Pooling and Servicing Agreement (the
notification occurs prior to the expiration of the prescribed time
period for the repurchase); and (3) Merrill Lynch, as Swap
Counterparty, makes or requests a payment based on a value of LIBOR \4\
that Bank of America, N.A., as Trustee, considers erroneous.
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\4\ The London Interbank Offered Rate.
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8. In correspondence dated January 29, and February 3, 2009, Bank
of America represented to the Department that it and Merrill Lynch were
currently identifying replacement trustees to replace Bank of America,
N.A. as Trustee in approximately 70 transactions. The Applicant stated
that it intends to complete the negotiations and paperwork on an
ongoing basis, with the effective date for all changes to be April 1,
2009. The Applicant noted that in contrast to co-trustees, any
replacement trustee will have to meet the requirements of the related
Trust agreement for qualification as a Trustee (i.e., will meet the
same requirements that Bank of America, N.A. (and its predecessor,
LaSalle Bank, N.A. had to meet). A copy of a typical Pooling and
Servicing Agreement requirements for a Trustee was provided to the
Department. The Applicant further noted that if a conflict were to
arise prior to April 1, 2009 with respect to any Trust, the most likely
course would be that Bank of America, N.A. would promptly resign as
Trustee and the replacement trustee would assume its role earlier than
scheduled. The next most likely scenario is that the party that would
become the replacement trustee (and hence meets the requirements of the
related Pooling and Servicing Agreement for qualification as a Trustee)
would be appointed co-trustee under the terms of the Proposed
Amendment. The Applicant stated, however, there might be situations
where either such course of action would be impossible or impractical,
in which case the parties would have to appoint a different co-trustee
until the replacement trustee assumed its role.
The Applicant states that in certain cases, Bank of America, N.A.
will continue as a securities administrator, retaining certain
reporting requirements but be responsible to the replacement trustee.
The replacement trustee will have legal title to the assets of the
trust, will have fiduciary responsibility to the securities holders and
will be responsible for supervising Bank of America, N.A. in whatever
role it retains.
9. Bank of America represents that, as of March 20, 2009, there was
no outstanding conflict requiring resolution involving Bank of America,
N.A. and any Merrill Lynch entity involved in the transactions listed
in the Securitizations List. Further, Bank of America has stated that
it would notify the Department of Labor of any conflict that arose
prior to the replacement of Bank of America, N.A. as Trustee in any of
these transactions. The Applicant notes that, as a technical matter, in
the most likely case (e.g. the assertion of a breach of representation
or warranty by the Sponsor), the Pooling and Servicing Agreements all
require that the Trustee provide the offending party 90 days to cure
the issue before the Trustee may take any action to do so itself.
Consequently, if an issue would have arisen after January 1, 2009; the
Trustee would not have been able to take any action to cure the issue
until after April 1, 2009. The Applicant asserts that since it is
expected that the Trustee replacements will be made by April 1, 2009,
it is not anticipated that a conflict will arise while Bank of America,
N.A. is the Trustee of any of the Covered Transactions.
10. The Applicant notes that Plans acquired Securities issued under
the Securitizations in reliance on the exemptive relief provided by the
Underwriter Exemptions. Absent additional relief, the Acquisition has
caused these granted exemptions to cease to apply to several of the
Securitizations. Bank of America represents that the Securities issued
in transactions such as the Securitizations are attractive investments
for Plans subject to Title I of ERISA or section 4975 of the Code and
conversely, such plans are an important market for issuers of such
Securities. Bank of America asserts that to force Bank of America, N.A.
to resign as Trustee in all of the Securitizations before the
Acquisition was not administratively feasible because the number of
available trustees is limited and there is work required in changing
trustees. Similarly, to have the exemptions no longer apply to the
Securitizations would force the Plans to sell their securities in the
current unstable market, likely at a loss. The Applicant additionally
notes that although the Acquisition has been widely covered, it is
conceivable that Plan fiduciaries would not realize that the
Underwriter Exemption relied upon by the Plans had ceased to apply,
raising the possibility that a Plan would not sell and that non-exempt
prohibited transactions would occur.
11. Bank of America states that the Plans purchased Securities in
reliance on PTE 90-29 or PTE 2002-19. At that time, the Plans had no
knowledge that the Trustee would become an Affiliate of one or more
members of the Restricted Group. On or after the Acquisition, except in
cases covered by PTE 90-29 as amended by PTE 2000-58 (providing a six-
month window for Trustee-Servicer affiliations) or PTE 2002-41
(Trustee-Underwriter affiliations), the purchased Securities would no
longer be afforded coverage under the Underwriter Exemptions and the
Plans would have been obligated to sell the Securities prior to January
1, 2009. The Applicant asserts that this is problematic for several
reasons. First, as is customary for such transactions, the physical
securities are not used in most cases. Rather, an electronic system,
usually the Depository Trust Company's electronic system, is utilized
and the securities are in global form. In such cases, it is difficult
(and may be impossible) to ascertain the beneficial ownership of the
securities, meaning that it is not known whether Plans are owners and
to what extent. The Applicant asserts that identifying the
[[Page 21006]]
affected Plans would be time consuming and expensive, and may be
impossible to do with complete accuracy because of the book-entry
system under which Securities were issued. As stated above, the
Applicant represents that notice of this request for relief was posted
on the Trustee's website at the time this Application was submitted,
which would be updated to reflect any action of the Department with
respect to the Application. The Applicant has informed the Department
that, although Bank of America, N.A. will have been replaced as Trustee
by April 1, 2009, Bank of America, N.A. will remain as the Securities
Administrator for any of the Securitizations on the Securitization List
for which it was providing such services. Further, the Applicant has
indicated that either Bank of America, N.A. (in cases where Bank of
America, N.A. continues as Securities Administrator) or the replacement
trustee (in all other cases) will continue to update its website
concerning the status of the Proposed Amendment. In this regard, the
Applicant also requests that the publication of the Proposed Amendment
in the Federal Register serve as the Notice to Interested Persons for
purposes of this submission.
Second, and more importantly, the current disruption in the
mortgage-backed securities market makes sales problematic, both in
terms of finding buyers and establishing proper valuation. Granting the
requested relief prevents these problems. The Applicant states further
that the relief is of the same duration, six months, as that already
provided by the Department for Trustee-Servicer affiliations,
suggesting that the Department has already determined that this period
is sufficiently brief to prevent serious conflicts of interest from
arising.
12. Bank of America requests that the relief, if granted, be made
retroactive to January 1, 2009, the Acquisition Date. If the relief is
granted retroactively, Plans would be able to retain their prior
Securitization investments and to purchase Securities in the secondary
market relying upon the Underwriter Exemptions once exemptive relief is
granted, even if the transactions originally closed or will close prior
to the date the final Amendment is published in the Federal Register,
if granted by the Department.
General Information
The attention of interested persons is directed to the following:
1. The fact that a transaction is the subject of an exemption under
section 408(a) of the Act and section 4975(c)(2) of the Code does not
relieve a fiduciary or other party in interest or disqualified person
from certain other provisions of the Act and the Code, including any
prohibited transaction provisions to which the exemption does not apply
and the general fiduciary responsibility provisions of section 404 of
the Act, which require, among other things, a fiduciary to discharge
his or her duties respecting the plan solely in the interest of the
participants and beneficiaries of the plan and in a prudent fashion in
accordance with section 404(a)(1)(B) of the Act; nor does it affect the
requirements of section 401(a) of the Code that the plan operate for
the exclusive benefit of the employees of the employer maintaining the
plan and their beneficiaries;
2. Before an exemption can be granted under section 408(a) of the
Act and section 4975(c)(2) of the Code, the Department must find that
the exemption is administratively feasible, in the interest of the
plans and of their participants and beneficiaries and protective of the
rights of participants and beneficiaries of the plans; and
3. The proposed amendment, if granted, will be supplemental to, and
not in derogation of, any other provisions of the Act and/or the Code,
including statutory or administrative exemptions and transitional
rules. Furthermore, the fact that a transaction is subject to an
administrative or statutory exemption is not dispositive of whether the
transaction is in fact a prohibited transaction.
Written Comments and Hearing Requests
All interested persons are invited to submit written comments or
requests for a hearing on the pending amendment to the address above,
within the time frame set forth above, after the publication of this
proposed amendment in the Federal Register. All comments will be made a
part of the record. Comments received will be available for public
inspection with the Application at the address set forth above.
Proposed Exemption
Based on the facts and representations set forth in the
application, under the authority of section 408(a) of the Act and
section 4975(c)(2) of the Code and in accordance with the procedures
set forth in 29 CFR Part 2570, Subpart B (55 FR 32836, August 10,
1990), the Department proposes to modify Prohibited Transaction
Exemption (PTE) 90-29, 55 FR 21459 (May 24, 1990), as amended by PTE
97-34, 62 FR 39021 (July 21, 1997), PTE 2000-58, 65 FR 67765 (November
13, 2000), PTE 2002-41, 67 FR 54487 (August 22, 2002) and PTE 2007-05,
72 FR 13130 (March 20, 2007), as corrected at 72 FR 16385 (April 4,
2007) (PTE 2007-05), (PTE 90-29) and to modify PTE 2002-19, 67 FR 14979
(March 28, 2002) as amended by PTE 2007-05, (PTE 2002-19).
1. Subsection II.A.(4) of PTE 90-29 and PTE 2002-19 is amended to
add a new subsection (c) that reads as follows:
(c) Effective January 1, 2009 through July 1, 2009, Bank of
America, N.A., the Trustee, shall not be considered to be an
Affiliate of any member of the Restricted Group solely as the result
of the acquisition of Merrill Lynch & Co., Inc. and its affiliates
(Merrill Lynch) by Bank of America Corporation and its subsidiaries
(Bank of America), the parent holding company of Bank of America,
N.A. (the Acquisition), which occurred after the initial issuance of
the Securities, provided that:
(i) The Trustee, Bank of America, N.A., ceases to be an
Affiliate of any member of the Restricted Group no later than July
1, 2009;
(ii) Any member of the Restricted Group that is an Affiliate of
the Trustee, Bank of America, N.A., did not breach any of its
obligations under the Pooling and Servicing Agreement, unless such
breach was immaterial and timely cured in accordance with the terms
of such agreement, during the period from January 1, 2009 through
the date the member of the Restricted Group ceased to be an
Affiliate of the Trustee, Bank of America, N.A.; and
(iii) In accordance with each Pooling and Servicing Agreement,
the Trustee, Bank of America, N.A., appoints a co-trustee, which is
not an Affiliate of Merrill Lynch or any other member of the
Restricted Group, no later than the earlier of (A) April 1, 2009 or
(B) five business days after Bank of America, N.A. becomes aware of
a conflict between the Trustee and any member of the Restricted
Group that is an Affiliate of the Trustee. The co-trustee will be
responsible for resolving any conflict between the Trustee and any
member of the Restricted Group that has become an Affiliate of the
Trustee as a result of the Acquisition; provided, that if the
Trustee has resigned on or prior to April 1, 2009 and no event
described in clause (B) has occurred, no co-trustee shall be
required.
(iv) For purposes of this subsection II.A.(4)(c), a conflict
arises whenever (A) Merrill Lynch, as a member of the Restricted
Group, fails to perform in accordance with the timeframes contained
in the relevant Pooling and Servicing Agreement following a request
for performance from Bank of America, N.A., as Trustee, or (B) Bank
of America, N.A., as Trustee, fails to perform in accordance with
the timeframes contained in the relevant Pooling and Servicing
Agreement following a request for performance from Merrill Lynch, a
member of the Restricted Group.
The time as of which a conflict occurs is the earlier of: the
day immediately following the last day on which compliance is
required under the relevant Pooling and Servicing Agreement; or the
day on which a party affirmatively responds that it will not comply
with a request for performance.
[[Page 21007]]
For purposes of this subsection II.A.(4)(c), the term
``conflict'' includes but is not limited to, the following: (1)
Merrill Lynch's failure, as Sponsor, to repurchase a loan for breach
of representation within the time period prescribed in the relevant
Pooling and Servicing Agreement, following Bank of America, N.A.'s
request, as Trustee, for performance; (2) Merrill Lynch, as Sponsor,
notifies Bank of America, N.A., as Trustee, that it will not
repurchase a loan for breach of representation, following Bank of
America, N.A.'s request that Merrill Lynch repurchase such loan
within the time period prescribed in the relevant Pooling and
Servicing Agreement (the notification occurs prior to the expiration
of the prescribed time period for the repurchase); and (3) Merrill
Lynch, as Swap Counterparty, makes or requests a payment based on a
value of the London Interbank Offered Rate (LIBOR) that Bank of
America, N.A., as Trustee, considers erroneous.
2. The Definition of ``Underwriter'' at section III.C. of PTE 90-29
and PTE 2002-19 is temporarily replaced with a definition that includes
J.P. Morgan Securities Inc. and reads:
C. Effective January 1, 2009 through July 1, 2009, ''Underwriter''
means:
(1) Merrill Lynch or J.P. Morgan Securities Inc.;
(2) Any person directly or indirectly, through one or more
intermediaries, controlling, controlled by or under common control
with such entities; or
(3) Any member of an underwriting syndicate or selling group of
which such firm or person described in subsections III.C.(1) or (2)
is a manager or co-manager with respect to the Securities.
3. The Definition of ``Sponsor'' at section III.D. of PTE 90-29 and
PTE 2002-19 is temporarily extended to include language applicable to
transactions on the Securitization List at section III.KK and reads:
D. ``Sponsor'' means:
(1) The entity that organizes an Issuer by depositing
obligations therein in exchange for Securities; or
(2) Effective January 1, 2009 through July 1, 2009, for those
transactions listed on the Securitization List at section III.KK.,
Merrill Lynch.
4. Section III of PTE 90-29 and PTE 2002-19 is temporarily amended
to add a new section III.KK that reads as follows:
KK. Effective January 1, 2009 through July 1, 2009,
``Securitization List'' means:
------------------------------------------------------------------------
Name Issuance type MLynch role
------------------------------------------------------------------------
CMAC Series 1997 ML1............... C................ S, U
WFPD 1996 WFP-D.................... C................ S, U
Merrill Lynch 2003-KEY 1........... C................ S, U
Merrill Lynch Series 1997-C1....... C................ S, U
Merrill Lynch Series 2004-KEY 2.... C................ S, U
Merrill Lynch Series 2006-C2....... C................ S, U
Mezz Cap 2004-C2................... C................ S, U
C-BASS 2007-CB4.................... R................ S, U
First Franklin MLT 2006-FF18....... R................ S, U, MS
First Franklin MLT 2007-01......... R................ S, U, MS
First Franklin MLT 2007-02......... R................ U, MS
First Franklin MLT 2007-03......... R................ U, MS
First Franklin MLT 2007-4.......... R................ S, U, MS
First Franklin MLT 2007-5.......... R................ S, U, MS
First Franklin MLT 2007-A.......... R................ S, U, MS
First Franklin MLT 2007-FF1........ R................ S, U, MS
First Franklin MLT 2007-FF2........ R................ S, U, MS
First Franklin MLT 2007-FFA........ R................ S, U, MS
First Franklin MLT 2007-FFC........ R................ S, U, MS
First Franklin MLT 2007-H1......... R................ S, U, MS
Merrill Lynch Series 2005-SL3...... R................ S, U, MS
Merrill Lynch Series 2006-AHL1..... R................ S, U, MS
Merrill Lynch Series 2006-AR1...... R................ S, U, MS
Merrill Lynch Series 2006-FF1...... R................ S, U, MS
Merrill Lynch Series 2006-FM1...... R................ S, U, MS
Merrill Lynch Series 2006-HE2...... R................ S, U, MS
Merrill Lynch Series 2006-HE3...... R................ S, U, MS
Merrill Lynch Series 2006-HE4...... R................ S, U, MS
Merrill Lynch Series 2006-HE6...... R................ S, U, MS
Merrill Lynch Series 2006-MLN1..... R................ S, U, MS
Merrill Lynch Series 2006-OPT1..... R................ S, U
Merrill Lynch Series 2006-RM1...... R................ S, U, MS
Merrill Lynch Series 2006-RM2...... R................ S, U, MS
Merrill Lynch Series 2006-RM3...... R................ S, U
Merrill Lynch Series 2006-RM4...... R................ S, U, MS
Merrill Lynch Series 2006-RM5...... R................ S, U, MS
Merrill Lynch Series 2006-SD1...... R................ S, U, MS
Merrill Lynch Series 2006-SL1...... R................ S, U, MS
Merrill Lynch Series 2006-WMC2..... R................ S, U, MS
Merrill Lynch Series 2007-HE1...... R................ S, U, MS
Merrill Lynch Series 2007-HE3...... R................ S, U, MS
Merrill Lynch Series 2007-SD1...... R................ S, U, MS
MLMI Trust 2002-AFC1............... R................ S, U
Ownit Mort Loan ABS 2006-3......... R................ S, U
Ownit Mort Loan ABS 2006-4......... R................ S, U
Ownit Mort Loan ABS 2006-5......... R................ S, U
Ownit Mort Loan ABS 2006-6......... R................ S, U
Ownit Mort Loan ABS 2006-7......... R................ S, U
[[Page 21008]]
JP Morgan Chase 2003-ML1 (U--JP C................ S
Morgan Securities Inc.).
------------------------------------------------------------------------
Legend: C = Commercial mortgage-backed securitizations.
R = Residential mortgage-backed securitizations.
U = Underwriter.
S = Sponsor.
MS = Master Servicer (either HLS or Wilshire).
MLynch = Merrill Lynch.
The availability of this amendment, if granted, is subject to the
express condition that the material facts and representations contained
in the Application are true and complete and accurately describe all
material terms of the transactions. In the case of continuing
transactions, if any of the material facts or representations described
in the Application change, the amendment will cease to apply as of the
date of such change. In the event of any such change, an application
for a new amendment must be made to the Department.
Signed at Washington, DC, this 30th day of April, 2009.
Ivan L. Strasfeld,
Director of Exemption Determinations, Employee Benefits Security
Administration, U.S. Department of Labor.
[FR Doc. E9-10362 Filed 5-5-09; 8:45 am]
BILLING CODE 4510-29-P