Deutsche Bank Securities Inc., et al.; Notice of Application and Temporary Order, 28288-28290 [E9-13981]
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28288
Federal Register / Vol. 74, No. 113 / Monday, June 15, 2009 / Notices
All funds are required to conduct an
annual review of the adequacy of their
existing policies and procedures and the
policies and procedures of each
investment adviser, principal
underwriter, administrator, and transfer
agent of the fund, and the effectiveness
of their implementation. In addition,
each fund chief compliance officer is
required to prepare an annual report
that addresses the operation of the
policies and procedures of the fund and
the policies and procedures of each
investment adviser, principal
underwriter, administrator, and transfer
agent of the fund, any material changes
made to those policies and procedures
since the date of the last report, any
material changes to the policies and
procedures recommended as a result of
the annual review, and certain
compliance matters that occurred since
the date of the last report. The staff
estimates that each fund spends 42
hours per year, on average, conducting
the annual review and preparing the
annual report to the board of directors.
Thus, we estimate that the aggregate
annual burden hours associated with
the annual review and annual report
requirement is 194,796 hours.
Finally, the staff estimates that each
fund spends 11 hours annually, on
average, maintaining the records
required by proposed Rule 38a–1. Thus,
the aggregate annual burden hours
associated with the recordkeeping
requirement is 51,018 hours.
In total, the staff estimates that the
aggregate annual information collection
burden of Rule 38a–1 is 254,214 hours.
The estimate of burden hours is made
solely for the purposes of the Paperwork
Reduction Act. The estimate is not
derived from a comprehensive or even
a representative survey or study of the
costs of Commission rules. Complying
with this collection of information
requirement is mandatory. Responses
will not be kept confidential. An agency
may not conduct or sponsor, and a
person is not required to respond to, a
collection of information unless it
displays a currently valid control
number.
Written comments are invited on: (a)
Whether the proposed collection of
information is necessary for the proper
performance of the functions of the
agency, including whether the
information will have practical utility;
(b) the accuracy of the agency’s estimate
of the burden of the collection of
information; (c) ways to enhance the
quality, utility, and clarity of the
information collected; and (d) ways to
minimize the burden of the collection of
information on respondents, including
through the use of automated collection
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16:47 Jun 12, 2009
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techniques or other forms of information
technology. Consideration will be given
to comments and suggestions submitted
in writing within 60 days of this
publication.
Please direct your written comments
to Charles Boucher, Director/CIO,
Securities and Exchange Commission,
C/O Shirley Martinson, 6432 General
Green Way, Alexandria, VA 22312; or
send an e-mail to:
PRA_Mailbox@sec.gov.
Dated: June 9, 2009.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9–14007 Filed 6–12–09; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–28763; File No. 812–13664]
Deutsche Bank Securities Inc., et al.;
Notice of Application and Temporary
Order
June 9, 2009.
AGENCY: Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Temporary order and notice of
application for a permanent order under
section 9(c) of the Investment Company
Act of 1940 (‘‘Act’’).
SUMMARY OF APPLICATION: Applicants
have received a temporary order
exempting them from section 9(a) of the
Act, with respect to an injunction
entered against Deutsche Bank
Securities Inc. (‘‘DBSI’’) on June 9, 2009
by the United States District Court for
the Southern District of New York
(‘‘Injunction’’), until the Commission
takes final action on an application for
a permanent order. Applicants also have
applied for a permanent order.
APPLICANTS: DBSI, Deutsche Investment
Management Americas, Inc. (‘‘DIMA’’),
Deutsche Asset Management (Hong
Kong) Limited (‘‘DeAM (HK)’’),
Deutsche Asset Management
International GmbH (‘‘DeAMI’’),
Deutsche Asset Management (Japan)
Limited (‘‘DeAMJ’’), Deutsche
Investments Australia Limited
(‘‘DIAL’’), RREEF America LLC
(‘‘RREEF’’), RREEF Global Advisors
Limited (‘‘RREEF (G)’’), and DWS
Investments Distributors, Inc. (‘‘DIDI’’)
(collectively, other than DBSI, the
‘‘Fund Servicing Applicants’’ and
together with DBSI, the ‘‘Applicants’’).1
1 Applicants request that any relief granted
pursuant to the application also apply to any other
company of which DBSI is or may become an
affiliated person (together with the Applicants, the
‘‘Covered Persons’’).
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Fmt 4703
Sfmt 4703
DATES: Filing Date: The application was
filed on June 9, 2009.
HEARING OR NOTIFICATION OF HEARING: An
order granting the application will be
issued unless the Commission orders a
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
Applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on July 6, 2009, and should
be accompanied by proof of service on
Applicants, in the form of an affidavit,
or for lawyers, a certificate of service.
Hearing requests should state the nature
of the writer’s interest, the reason for the
request, and the issues contested.
Persons who wish to be notified of a
hearing may request notification by
writing to the Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F
Street, NE., Washington, DC 20549–
1090; Applicants: DBSI, 60 Wall Street,
New York, NY 10005; DIMA, 345 Park
Avenue, New York, NY 10154; DeAM
(HK), 48/F Cheung Kong Centre, 2
Queen’s Road Central, Hong Kong,
China; DeAMI, Mainzer Landstrasse
178–190, Frankfurt am Main, 60327;
DeAMJ, Sanno Park Tower, 2–11–1,
Nagata-Cho, Chiyoda-Ku, Tokyo, 100–
6173; DIAL, Deutsche Bank Place, Level
16, CNR Hunter and Phillip Streets,
Sydney, NSW 2000; RREEF, 875 N.
Michigan Avenue, 41st Floor, Chicago,
IL 60611; RREEF (G), Winchester House,
1 Great Winchester Street, London,
United Kingdom EC2N 2DB; and DIDI,
222 South Riverside Plaza, Chicago, IL
60606.
FOR FURTHER INFORMATION CONTACT:
Steven I. Amchan, Senior Counsel, at
(202) 551–6826, or Julia Kim Gilmer,
Branch Chief, at (202) 551–6821,
(Division of Investment Management,
Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The
following is a temporary order and a
summary of the application. The
complete application may be obtained
via the Commission’s Web site by
searching for the file number, or an
applicant using the Company name box,
at https://www.sec.gov/search/
search.htm or by calling (202) 551–
8090.
Applicants’ Representations
1. Deutsche Bank AG (‘‘DB’’) is a stock
corporation organized under the laws of
the Federal Republic of Germany. DBSI
is an indirect wholly-owned subsidiary
of DB, and an affiliated person of each
Fund Servicing Applicant within the
meaning of section 2(a)(3) of the Act (by
E:\FR\FM\15JNN1.SGM
15JNN1
Federal Register / Vol. 74, No. 113 / Monday, June 15, 2009 / Notices
virtue of being under common control
with the Fund Servicing Applicants).
DBSI provides securities brokerage and
investment advisory services to private
clients and institutions and
correspondent clearing services to
broker-dealers. DBSI also provides a
variety of capital raising, market
making, and brokerage services for its
government, financial institution, and
corporate clients, including fixed
income and equity sales and trading,
emerging markets activities, and equity
market research and investment
banking.
2. DIMA, DeAM (HK), DeAMI,
DeAMJ, DIAL, RREEF, and RREEF (G)
are registered as investment advisers
under the Investment Advisers Act of
1940, as amended (‘‘Advisers Act’’) and
provide investment advisory or
subadvisory services to registered
investment companies (‘‘Funds’’). DIDI
is a broker-dealer registered under the
Securities Exchange Act of 1934
(‘‘Exchange Act’’) and serves as
principal underwriter to Funds.
3. On June 9, 2009, the United States
District Court for the Southern District
of New York entered a judgment against
DBSI (‘‘Judgment’’) in a matter brought
by the Commission.2 The Commission
alleged in the complaint (‘‘Complaint’’)
that DBSI violated section 15(c) of the
Exchange Act by marketing auction rate
securities as highly liquid investments
comparable to cash or money market
instruments and by selling auction rate
securities to its customers without
adequately disclosing the risks involved
in purchasing such securities. Without
admitting or denying the allegations in
the Complaint, except as to jurisdiction,
DBSI consented to the entry of the
Judgment that included, among other
things, the entry of the Injunction and
other equitable relief including
undertakings to take various remedial
actions for the benefit of purchasers of
certain auction rate securities.
pwalker on PROD1PC71 with NOTICES
Applicants’ Legal Analysis
1. Section 9(a)(2) of the Act, in
relevant part, prohibits a person who
has been enjoined from, among other
things, engaging in or continuing any
conduct or practice in connection with
the purchase or sale of a security, or in
connection with activities as an
underwriter, broker or dealer, from
acting, among other things, as an
investment adviser or depositor of any
registered investment company or a
principal underwriter for any registered
2 Securities and Exchange Commission v.
Deutsche Bank Securities Inc., Judgment on
Consent Against Defendant Deutsche Bank
Securities Inc., 09 Civ. 5174 (S.D.N.Y. June 9, 2009).
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16:47 Jun 12, 2009
Jkt 217001
open-end investment company,
registered unit investment trust or
registered face-amount certificate
company. Section 9(a)(3) of the Act
makes the prohibition in section 9(a)(2)
applicable to a company, any affiliated
person of which has been disqualified
under the provisions of section 9(a)(2).
Section 2(a)(3) of the Act defines
‘‘affiliated person’’ to include, among
others, any person directly or indirectly
controlling, controlled by, or under
common control with, the other person.
Applicants state that DBSI is an
affiliated person of each of the other
Applicants within the meaning of
section 2(a)(3) of the Act. Applicants
state that the entry of the Injunction
results in Applicants being subject to
the disqualification provisions of
section 9(a) of the Act.
2. Section 9(c) of the Act provides that
the Commission shall grant an
application for exemption from the
disqualification provisions of section
9(a) if it is established that these
provisions, as applied to the Applicants,
are unduly or disproportionately severe
or that the Applicants’ conduct has been
such as not to make it against the public
interest or the protection of investors to
grant the exemption. Applicants have
filed an application pursuant to section
9(c) seeking a temporary and permanent
order exempting them and Covered
Persons from the disqualification
provisions of section 9(a) of the Act.
3. Applicants believe they meet the
standard for exemption specified in
section 9(c). Applicants state that the
prohibitions of section 9(a) as applied to
them would be unduly and
disproportionately severe and that the
conduct of the Applicants has been such
as not to make it against the public
interest or the protection of investors to
grant the exemption from section 9(a).
4. Applicants state that the alleged
conduct giving rise to the Injunction did
not involve any of the Applicants acting
in the capacity of investment adviser,
subadviser or depositor to any Fund or
in the capacity of principal underwriter
for any open-end Fund, UIT, or
registered face-amount certificate
company. Applicants also state that
none of the current or former directors,
officers, or employees of the Fund
Servicing Applicants had any
responsibility for, or had any
involvement in, the conduct alleged in
the Complaint. Applicants further state
that the personnel at DBSI who were
involved in the violations alleged in the
Complaint have had no and will not
have any future involvement in
providing investment advisory,
subadvisory, depository or underwriting
services to Funds.
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Fmt 4703
Sfmt 4703
28289
5. Applicants state that their inability
to continue to provide investment
advisory, subadvisory and underwriting
services to Funds would result in
potential hardship for the Funds and
their shareholders. Applicants state that
they will, as soon as reasonably
practicable, distribute written materials,
including an offer to meet in person to
discuss the materials, to the boards of
directors (‘‘Boards’’) of the Funds for
which the Applicants serve as
investment adviser, investment
subadviser or principal underwriter,
including the directors who are not
‘‘interested persons,’’ as defined in
section 2(a)(19) of the Act, of such
Funds, and their independent legal
counsel as defined in rule 0–1(a)(6)
under the Act, relating to the
circumstances that led to the Injunction,
any impact on the Funds, and the
application. Applicants state they will
provide the Boards of the Funds with all
information concerning the Injunction
and the application that is necessary for
the Funds to fulfill their disclosure and
other obligations under the Federal
securities laws.
6. Applicants also state that, if the
Fund Servicing Applicants were barred
from providing services to the Funds,
the effect on their businesses and
employees would be severe. Applicants
state that they have committed
substantial resources to establish an
expertise in providing advisory and
principal underwriting services to
Funds. Applicants further state that
prohibiting the Fund Servicing
Applicants from providing such services
would not only adversely affect their
businesses, but would also adversely
affect over 500 employees who are
involved in those activities.
7. Applicants previously have
received exemptions under section 9(c)
as the result of conduct that triggered
section 9(a) as described in greater
detail in the application.
Applicants’ Condition
Applicants agree that any order
granting the requested relief will be
subject to the following condition:
Any temporary exemption granted
pursuant to the application shall be
without prejudice to, and shall not limit
the Commission’s rights in any manner
with respect to, any Commission
investigation of, or administrative
proceedings involving or against,
Covered Persons, including, without
limitation, the consideration by the
Commission of a permanent exemption
from section 9(a) of the Act requested
pursuant to the application or the
revocation or removal of any temporary
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28290
Federal Register / Vol. 74, No. 113 / Monday, June 15, 2009 / Notices
exemptions granted under the Act in
connection with the application.
Temporary Order
The Commission has considered the
matter and finds that Applicants have
made the necessary showing to justify
granting a temporary exemption.
Accordingly,
It is hereby ordered, pursuant to
section 9(c) of the Act, that Applicants
and any other Covered Persons are
granted a temporary exemption from the
provisions of section 9(a), solely with
respect to the Injunction, subject to the
condition in the application, from June
9, 2009, until the Commission takes
final action on their application for a
permanent order.
By the Commission.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9–13981 Filed 6–12–09; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–28762; File No. 812–13663]
RBC Capital Markets Corporation, et
al.; Notice of Application and
Temporary Order
June 9, 2009.
pwalker on PROD1PC71 with NOTICES
AGENCY: Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Temporary order and notice of
application for a permanent order under
section 9(c) of the Investment Company
Act of 1940 (‘‘Act’’).
SUMMARY OF APPLICATION: Applicants
have received a temporary order
exempting them from section 9(a) of the
Act, with respect to an injunction
entered against RBC Capital Markets
Corporation (‘‘RBC’’) on June 9, 2009 by
the United States District Court for the
Southern District of New York
(‘‘Injunction’’), until the Commission
takes final action on an application for
a permanent order. Applicants also have
applied for a permanent order.
APPLICANTS: RBC, Voyageur Asset
Management Inc. (‘‘Voyageur’’),
Tamarack Distributors Inc.
(‘‘Tamarack’’), and Sky Investment
Counsel Inc. (‘‘Sky’’) (collectively, other
than RBC, the ‘‘Fund Servicing
Applicants’’ and together with RBC, the
‘‘Applicants’’).1
1 Applicants request that any relief granted
pursuant to the application also apply to any other
company of which RBC is or may become an
affiliated person (together with the Applicants, the
‘‘Covered Persons’’).
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16:47 Jun 12, 2009
Jkt 217001
FILING DATE: The application was filed
on June 3, 2009. Applicants have agreed
to file an amendment during the notice
period, the substance of which is
reflected in this notice.
HEARING OR NOTIFICATION OF HEARING: An
order granting the application will be
issued unless the Commission orders a
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
Applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on July 6, 2009, and should
be accompanied by proof of service on
Applicants, in the form of an affidavit,
or for lawyers, a certificate of service.
Hearing requests should state the nature
of the writer’s interest, the reason for the
request, and the issues contested.
Persons who wish to be notified of a
hearing may request notification by
writing to the Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F
Street, NE., Washington, DC 20549–
1090; Applicants: RBC, One Liberty
Plaza, 165 Broadway, New York, NY
10006; Voyageur and Tamarack, 100
South Fifth Street, Suite 2300,
Minneapolis, MN 55402; and Sky, 1
Adelaide Street East, Suite 2310,
Toronto, ON, Canada M5C 2V9.
FOR FURTHER INFORMATION CONTACT: Jaea
F. Hahn, Senior Counsel, at (202) 551–
6870, or Julia Kim Gilmer, Branch Chief,
at (202) 551–6821, (Division of
Investment Management, Office of
Investment Company Regulation).
SUPPLEMENTARY INFORMATION: The
following is a temporary order and a
summary of the application. The
complete application may be obtained
via the Commission’s Web site by
searching for the file number, or an
applicant using the Company name box,
at https://www.sec.gov/search/
search.htm or by calling (202) 551–
8090.
Applicants’ Representations
1. RBC is a full service investment
banking firm engaged in securities
underwriting, sales and trading,
investment banking, financial advisory
services and investment research
services. RBC is registered with the
Commission as a broker-dealer under
the Securities Exchange Act of 1934, as
amended (‘‘Exchange Act’’) and as an
investment adviser under the
Investment Advisers Act of 1940, as
amended (‘‘Advisers Act’’). RBC is an
indirect, wholly owned subsidiary of
Royal Bank of Canada (‘‘Royal Bank’’),
a Canada-based global financial services
firm.
PO 00000
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Fmt 4703
Sfmt 4703
2. Voyaguer and Sky are registered as
investment advisers under the Advisers
Act and provide investment advisory or
subadvisory services to registered
investment companies (‘‘Funds’’).
Voyageur is an indirect, wholly owned
subsidiary of Royal Bank. Royal Bank
indirectly owns a controlling interest in
Sky. Tamarack is a broker-dealer
registered under the Exchange Act and
serves as principal underwriter to openend Funds. None of the Applicants
serve as depositor to any Fund.
3. On June 9, 2009, the United States
District Court for the Southern District
of New York entered a judgment against
RBC (‘‘Judgment’’) in a matter brought
by the Commission.2 The Commission
alleged in the complaint (‘‘Complaint’’)
that RBC violated section 15(c) of the
Exchange Act by misrepresenting to
many of its customers that auction rate
securities were safe, highly liquid
investments that were substitutes for
cash or money market funds. The
Complaint further alleges that on
February 11, 2008, RBC determined not
to place bids in most of its auctions, as
it had historically done, resulting in
failed auctions. Without admitting or
denying the allegations in the
Complaint, except as to jurisdiction,
RBC consented to the entry of the
Injunction and other equitable relief
including undertakings to take various
remedial actions for the benefit of
purchasers of certain auction rate
securities.
Applicants’ Legal Analysis
1. Section 9(a)(2) of the Act, in
relevant part, prohibits a person who
has been enjoined from, among other
things, engaging in or continuing any
conduct or practice in connection with
the purchase or sale of a security, or in
connection with activities as an
underwriter, broker or dealer, from
acting, among other things, as an
investment adviser or depositor of any
registered investment company or a
principal underwriter for any registered
open-end investment company,
registered unit investment trust or
registered face-amount certificate
company. Section 9(a)(3) of the Act
makes the prohibition in section 9(a)(2)
applicable to a company, any affiliated
person of which has been disqualified
under the provisions of section 9(a)(2).
Section 2(a)(3) of the Act defines
‘‘affiliated person’’ to include, among
others, any person directly or indirectly
controlling, controlled by, or under
2 Securities and Exchange Commission v. RBC
Capital Markets Corporation, Judgment as to
Defendant RBC Capital Markets Corporation, 09–
cv–5172 (S.D.N.Y., June 9, 2009).
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Agencies
[Federal Register Volume 74, Number 113 (Monday, June 15, 2009)]
[Notices]
[Pages 28288-28290]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-13981]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-28763; File No. 812-13664]
Deutsche Bank Securities Inc., et al.; Notice of Application and
Temporary Order
June 9, 2009.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Temporary order and notice of application for a permanent order
under section 9(c) of the Investment Company Act of 1940 (``Act'').
-----------------------------------------------------------------------
Summary of Application: Applicants have received a temporary order
exempting them from section 9(a) of the Act, with respect to an
injunction entered against Deutsche Bank Securities Inc. (``DBSI'') on
June 9, 2009 by the United States District Court for the Southern
District of New York (``Injunction''), until the Commission takes final
action on an application for a permanent order. Applicants also have
applied for a permanent order.
Applicants: DBSI, Deutsche Investment Management Americas, Inc.
(``DIMA''), Deutsche Asset Management (Hong Kong) Limited (``DeAM
(HK)''), Deutsche Asset Management International GmbH (``DeAMI''),
Deutsche Asset Management (Japan) Limited (``DeAMJ''), Deutsche
Investments Australia Limited (``DIAL''), RREEF America LLC
(``RREEF''), RREEF Global Advisors Limited (``RREEF (G)''), and DWS
Investments Distributors, Inc. (``DIDI'') (collectively, other than
DBSI, the ``Fund Servicing Applicants'' and together with DBSI, the
``Applicants'').\1\
---------------------------------------------------------------------------
\1\ Applicants request that any relief granted pursuant to the
application also apply to any other company of which DBSI is or may
become an affiliated person (together with the Applicants, the
``Covered Persons'').
---------------------------------------------------------------------------
DATES: Filing Date: The application was filed on June 9, 2009.
Hearing or Notification of Hearing: An order granting the application
will be issued unless the Commission orders a hearing. Interested
persons may request a hearing by writing to the Commission's Secretary
and serving Applicants with a copy of the request, personally or by
mail. Hearing requests should be received by the Commission by 5:30
p.m. on July 6, 2009, and should be accompanied by proof of service on
Applicants, in the form of an affidavit, or for lawyers, a certificate
of service. Hearing requests should state the nature of the writer's
interest, the reason for the request, and the issues contested. Persons
who wish to be notified of a hearing may request notification by
writing to the Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street, NE., Washington, DC 20549-1090; Applicants: DBSI, 60 Wall
Street, New York, NY 10005; DIMA, 345 Park Avenue, New York, NY 10154;
DeAM (HK), 48/F Cheung Kong Centre, 2 Queen's Road Central, Hong Kong,
China; DeAMI, Mainzer Landstrasse 178-190, Frankfurt am Main, 60327;
DeAMJ, Sanno Park Tower, 2-11-1, Nagata-Cho, Chiyoda-Ku, Tokyo, 100-
6173; DIAL, Deutsche Bank Place, Level 16, CNR Hunter and Phillip
Streets, Sydney, NSW 2000; RREEF, 875 N. Michigan Avenue, 41st Floor,
Chicago, IL 60611; RREEF (G), Winchester House, 1 Great Winchester
Street, London, United Kingdom EC2N 2DB; and DIDI, 222 South Riverside
Plaza, Chicago, IL 60606.
FOR FURTHER INFORMATION CONTACT: Steven I. Amchan, Senior Counsel, at
(202) 551-6826, or Julia Kim Gilmer, Branch Chief, at (202) 551-6821,
(Division of Investment Management, Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The following is a temporary order and a
summary of the application. The complete application may be obtained
via the Commission's Web site by searching for the file number, or an
applicant using the Company name box, at https://www.sec.gov/search/search.htm or by calling (202) 551-8090.
Applicants' Representations
1. Deutsche Bank AG (``DB'') is a stock corporation organized under
the laws of the Federal Republic of Germany. DBSI is an indirect
wholly-owned subsidiary of DB, and an affiliated person of each Fund
Servicing Applicant within the meaning of section 2(a)(3) of the Act
(by
[[Page 28289]]
virtue of being under common control with the Fund Servicing
Applicants). DBSI provides securities brokerage and investment advisory
services to private clients and institutions and correspondent clearing
services to broker-dealers. DBSI also provides a variety of capital
raising, market making, and brokerage services for its government,
financial institution, and corporate clients, including fixed income
and equity sales and trading, emerging markets activities, and equity
market research and investment banking.
2. DIMA, DeAM (HK), DeAMI, DeAMJ, DIAL, RREEF, and RREEF (G) are
registered as investment advisers under the Investment Advisers Act of
1940, as amended (``Advisers Act'') and provide investment advisory or
subadvisory services to registered investment companies (``Funds'').
DIDI is a broker-dealer registered under the Securities Exchange Act of
1934 (``Exchange Act'') and serves as principal underwriter to Funds.
3. On June 9, 2009, the United States District Court for the
Southern District of New York entered a judgment against DBSI
(``Judgment'') in a matter brought by the Commission.\2\ The Commission
alleged in the complaint (``Complaint'') that DBSI violated section
15(c) of the Exchange Act by marketing auction rate securities as
highly liquid investments comparable to cash or money market
instruments and by selling auction rate securities to its customers
without adequately disclosing the risks involved in purchasing such
securities. Without admitting or denying the allegations in the
Complaint, except as to jurisdiction, DBSI consented to the entry of
the Judgment that included, among other things, the entry of the
Injunction and other equitable relief including undertakings to take
various remedial actions for the benefit of purchasers of certain
auction rate securities.
---------------------------------------------------------------------------
\2\ Securities and Exchange Commission v. Deutsche Bank
Securities Inc., Judgment on Consent Against Defendant Deutsche Bank
Securities Inc., 09 Civ. 5174 (S.D.N.Y. June 9, 2009).
---------------------------------------------------------------------------
Applicants' Legal Analysis
1. Section 9(a)(2) of the Act, in relevant part, prohibits a person
who has been enjoined from, among other things, engaging in or
continuing any conduct or practice in connection with the purchase or
sale of a security, or in connection with activities as an underwriter,
broker or dealer, from acting, among other things, as an investment
adviser or depositor of any registered investment company or a
principal underwriter for any registered open-end investment company,
registered unit investment trust or registered face-amount certificate
company. Section 9(a)(3) of the Act makes the prohibition in section
9(a)(2) applicable to a company, any affiliated person of which has
been disqualified under the provisions of section 9(a)(2). Section
2(a)(3) of the Act defines ``affiliated person'' to include, among
others, any person directly or indirectly controlling, controlled by,
or under common control with, the other person. Applicants state that
DBSI is an affiliated person of each of the other Applicants within the
meaning of section 2(a)(3) of the Act. Applicants state that the entry
of the Injunction results in Applicants being subject to the
disqualification provisions of section 9(a) of the Act.
2. Section 9(c) of the Act provides that the Commission shall grant
an application for exemption from the disqualification provisions of
section 9(a) if it is established that these provisions, as applied to
the Applicants, are unduly or disproportionately severe or that the
Applicants' conduct has been such as not to make it against the public
interest or the protection of investors to grant the exemption.
Applicants have filed an application pursuant to section 9(c) seeking a
temporary and permanent order exempting them and Covered Persons from
the disqualification provisions of section 9(a) of the Act.
3. Applicants believe they meet the standard for exemption
specified in section 9(c). Applicants state that the prohibitions of
section 9(a) as applied to them would be unduly and disproportionately
severe and that the conduct of the Applicants has been such as not to
make it against the public interest or the protection of investors to
grant the exemption from section 9(a).
4. Applicants state that the alleged conduct giving rise to the
Injunction did not involve any of the Applicants acting in the capacity
of investment adviser, subadviser or depositor to any Fund or in the
capacity of principal underwriter for any open-end Fund, UIT, or
registered face-amount certificate company. Applicants also state that
none of the current or former directors, officers, or employees of the
Fund Servicing Applicants had any responsibility for, or had any
involvement in, the conduct alleged in the Complaint. Applicants
further state that the personnel at DBSI who were involved in the
violations alleged in the Complaint have had no and will not have any
future involvement in providing investment advisory, subadvisory,
depository or underwriting services to Funds.
5. Applicants state that their inability to continue to provide
investment advisory, subadvisory and underwriting services to Funds
would result in potential hardship for the Funds and their
shareholders. Applicants state that they will, as soon as reasonably
practicable, distribute written materials, including an offer to meet
in person to discuss the materials, to the boards of directors
(``Boards'') of the Funds for which the Applicants serve as investment
adviser, investment subadviser or principal underwriter, including the
directors who are not ``interested persons,'' as defined in section
2(a)(19) of the Act, of such Funds, and their independent legal counsel
as defined in rule 0-1(a)(6) under the Act, relating to the
circumstances that led to the Injunction, any impact on the Funds, and
the application. Applicants state they will provide the Boards of the
Funds with all information concerning the Injunction and the
application that is necessary for the Funds to fulfill their disclosure
and other obligations under the Federal securities laws.
6. Applicants also state that, if the Fund Servicing Applicants
were barred from providing services to the Funds, the effect on their
businesses and employees would be severe. Applicants state that they
have committed substantial resources to establish an expertise in
providing advisory and principal underwriting services to Funds.
Applicants further state that prohibiting the Fund Servicing Applicants
from providing such services would not only adversely affect their
businesses, but would also adversely affect over 500 employees who are
involved in those activities.
7. Applicants previously have received exemptions under section
9(c) as the result of conduct that triggered section 9(a) as described
in greater detail in the application.
Applicants' Condition
Applicants agree that any order granting the requested relief will
be subject to the following condition:
Any temporary exemption granted pursuant to the application shall
be without prejudice to, and shall not limit the Commission's rights in
any manner with respect to, any Commission investigation of, or
administrative proceedings involving or against, Covered Persons,
including, without limitation, the consideration by the Commission of a
permanent exemption from section 9(a) of the Act requested pursuant to
the application or the revocation or removal of any temporary
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exemptions granted under the Act in connection with the application.
Temporary Order
The Commission has considered the matter and finds that Applicants
have made the necessary showing to justify granting a temporary
exemption.
Accordingly,
It is hereby ordered, pursuant to section 9(c) of the Act, that
Applicants and any other Covered Persons are granted a temporary
exemption from the provisions of section 9(a), solely with respect to
the Injunction, subject to the condition in the application, from June
9, 2009, until the Commission takes final action on their application
for a permanent order.
By the Commission.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9-13981 Filed 6-12-09; 8:45 am]
BILLING CODE 8010-01-P