Pax World Funds Trust II, et al.; Notice of Application, 37258-37265 [E9-17884]
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5. CFF states that it engages in several
banking activities, that it is controlled as
to financing it can undertake and loans
it can extend through French banking
laws and through oversight and
regulation implemented by the Banking
Commission. CFF asserts that as a SCF,
it is governed by a legal regime in many
respects stricter than the regime
applicable to commercial banks in
France. CFF further states that it fulfills
a public interest objective of providing
financial resources for the favored
sectors in France and the United States
and other developed nations, and that
its activities do not lend themselves to
the abuses against which the Act was
directed. Therefore, CFF states that it
satisfies the standards for relief under
section 6(c) of the Act.
Applicant’s Conditions
Applicant agrees that the order
granting the requested relief will be
subject to the following conditions:
1. In connection with any offering by
Applicant of its Privileged Debt
Securities in the United States,
Applicant will appoint an agent to
accept service of process in any suit,
action or proceeding brought on such
Privileged Debt Securities and instituted
in any State or Federal court presiding
in the City and County of New York by
any such holder of any such Privileged
Debt Securities. Applicant will
expressly submit to the jurisdiction of
the New York State and United States
Federal courts presiding in the City and
County of New York with respect to any
such suit, action or proceeding.
Applicant will also waive the defense of
forum non conveniens to the
maintenance of any such action or
proceeding in the New York State or
United States Federal courts presiding
in the City and County of New York.
Such appointment of an agent to accept
service of process and such submission
to jurisdiction shall be irrevocable until
all amounts due and to become due in
respect of such Privileged Debt
Securities have been paid. No such
submission to jurisdiction or
appointment of agent for service of
process will affect the right, if any, of a
holder of any such security to bring suit
in any court that will have jurisdiction
over Applicant by virtue of the offer and
sale of such Privileged Debt Securities
or otherwise.
2. Applicant’s activities will conform
in all material respects to the activities
described in the application.
3. Applicant is regulated as a SCF by
the French banking authorities, as
described in the application.
4. Applicant will only offer and sell
Privileged Debt Securities on a private
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basis in the United States to persons
reasonably believed by Applicant to be
(i) institutional accredited investors as
defined in paragraphs (1), (2), (3) and (7)
of Rule 501(a) under the 1933 Act, (ii)
any entity in which all of the equity
owners come within such paragraphs, or
(iii) qualified institutional buyers, as
defined in Rule 144A under the 1933
Act.
5. Applicant will not make public
offers or sales of equity or debt
securities in the United States and will
not make offers or sales of equity
securities on either a public or private
basis in the United States.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9–17892 Filed 7–27–09; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
28834; File No. 812–13503]
Pax World Funds Trust II, et al.; Notice
of Application
July 22, 2009.
AGENCY: Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 6(c) of the
Investment Company Act of 1940 (the
‘‘Act’’) for an exemption from sections
2(a)(32), 5(a)(1), 22(d), and 22(e) of the
Act and rule 22c–1 under the Act, under
sections 6(c) and 17(b) of the Act for an
exemption from sections 17(a)(1) and
17(a)(2) of the Act, and under section
12(d)(1)(J) of the Act for an exemption
from sections 12(d)(1)(A) and
12(d)(1)(B) of the Act.
SUMMARY OF APPLICATION: Applicants
request an order that would permit (a)
certain open-end management
investment companies and their series,
to issue shares (‘‘Fund Shares’’) that can
be redeemed only in large aggregations
(‘‘Creation Units’’); (b) secondary market
transactions in Fund Shares to occur at
negotiated prices; (c) certain series to
pay redemption proceeds, under certain
circumstances, more than seven days
after the tender of Fund Shares for
redemption; (d) certain affiliated
persons of the series to deposit
securities into, and receive securities
from, the series in connection with the
purchase and redemption of Creation
Units; and (e) certain registered
management investment companies and
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unit investment trusts outside of the
same group of investment companies as
the series to acquire Fund Shares.
APPLICANTS: Pax World Funds Trust II
(‘‘Trust’’), Pax World Management Corp.
(‘‘Advisor’’) and ALPS Distributors, Inc.
(‘‘Distributor’’).
DATES: Filing Dates: The application
was filed on February 29, 2008, and
amended on May 8, 2008, November 17,
2008, May 8, 2009, and July 7, 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 August 12, 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, Securities and
Exchange Commission, 100 F Street,
NE., Washington, DC 20549–1090;
Applicants: Pax World Management
Corp. and Pax World Funds Trust II, 30
Penhallow Street, Suite 400,
Portsmouth, NH 03801; ALPS
Distributors, Inc., 1290 Broadway, Suite
1100, Denver, CO 80203.
FOR FURTHER INFORMATION CONTACT:
Laura J. Riegel, Senior Counsel at (202)
551–6873, 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 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. The Trust is registered as an openend management investment company
and is organized as a Massachusetts
trust that will offer multiple series. The
Trust will initially offer Fund Shares of
two series (the ‘‘Initial Funds’’).
Applicants may offer additional
registered open-end investment
companies in the future as well as
additional series of the Trust and series
of any existing or future open-end
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investment companies registered under
the Act, which will be advised by the
Advisor or an entity controlling,
controlled by, or under common control
with the Advisor (‘‘Future Funds’’ and
together with the Initial Funds, the
‘‘Funds’’).1
2. The Advisor will serve as the
investment adviser to the Initial Funds.
The Advisor is registered as an
investment adviser under the
Investment Advisers Act of 1940, as
amended (the ‘‘Advisers Act’’). In the
future, the Advisor may enter into subadvisory agreements with one or more
additional investment advisers to act as
sub-advisors to particular Funds (‘‘SubAdvisors’’). Each Sub-Advisor will be
registered under the Advisers Act. The
Distributor is a broker-dealer registered
under the Securities Exchange Act of
1934 (the ‘‘Exchange Act’’) and will act
as the principal underwriter and
distributor for the Creation Units of
Fund Shares. The Distributor is not
affiliated with the Advisor or any SubAdvisor.
3. Each Fund will hold certain equity
securities (‘‘Portfolio Securities’’) and
financial instruments selected to
correspond, before fees and expenses,
generally to the price and yield
performance of a specified equity
securities index (each, an ‘‘Underlying
Index’’ and collectively, ‘‘Underlying
Indices’’).2 Certain of the Underlying
Indices are composed of equity
securities of domestic issuers and nondomestic issuers meeting the
requirements for trading in U.S. markets
(‘‘Domestic Indices’’). Other Underlying
Indices include equity securities trading
in non-U.S. markets or a combination of
such securities with domestic equity
securities (collectively ‘‘Foreign
Indices’’). Funds which track Domestic
Indices are referred to as ‘‘Domestic
Funds’’ and Funds which track Foreign
Indices are referred to as ‘‘Foreign
Funds.’’ No entity that compiles,
creates, sponsors or maintains an
Underlying Index (‘‘Index Provider’’) is
or will be an affiliated person, as
defined in section 2(a)(3) of the Act, or
an affiliated person of an affiliated
person, of the Trust or a Fund, of the
Advisor, of any Sub-Advisor to or
promoter of a Fund, or of the
Distributor.3
1 All existing entities that intend to rely on the
requested order have been named as applicants.
Any other existing or future entity that
subsequently relies on the order will comply with
the terms and conditions of the application.
2 The Underlying Indices for the Initial Funds are
KLD Europe Asia Pacific Sustainability SM Index
and KLD North America Sustainability SM Index.
3 The Index Provider to the Initial Funds is KLD
Research & Analytics, Inc.
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4. The investment objective of each
Fund will be to provide investment
results that correspond, before fees and
expenses, generally to the price and
yield performance of its Underlying
Index.4 The value of a Foreign Index
and the value of a Domestic Index will
be disseminated every 15 seconds,
throughout the trading day. A Fund will
utilize either a replication or
representative sampling strategy which
will be disclosed with regard to each
Fund in its statutory prospectus
(‘‘Prospectus’’).5 A Fund using a
replication strategy will invest in the
Component Securities in its Underlying
Index in approximately the same
proportions as in the Underlying Index.
In certain circumstances, such as when
there are practical difficulties or
substantial costs involved in holding
every security in an Underlying Index or
when a Component Security is less
liquid, illiquid or unavailable, a Fund
may use a representative sampling
strategy pursuant to which it will invest
in some, but not all of the Component
Securities of its Underlying Index.6
Applicants anticipate that a Fund that
utilizes a representative sampling
strategy will not track the performance
of its Underlying Index with the same
degree of accuracy as an investment
vehicle that invests in every Component
Security of the Underlying Index with
the same weighting as the Underlying
Index. Applicants expect that each Fund
will have a tracking error relative to the
performance of its Underlying Index of
less than 5 percent.
5. The Trust will issue Creation Units
in specified large aggregations of Fund
Shares (e.g., 25,000 Fund Shares for
4 Applicants represent that each Fund will invest
at least 80% of its total assets in the component
securities that comprise its Underlying Index
(‘‘Component Securities’’) or, in the case of Foreign
Funds, Component Securities and depositary
receipts representing such securities. ‘‘Depositary
Receipts’’ will typically be American Depositary
Receipts, but also include Global Depositary
Receipts and European Depositary Receipts. Each
Fund also may invest up to 20% of its assets in
certain futures, options and swap contracts, cash
and cash equivalents, as well as in stocks not
included in its Underlying Index, but which the
Advisor or Sub-Advisor believes will help the Fund
track its Underlying Index.
5 All representations and conditions contained in
the application that require a Fund to disclose
particular information in the Fund’s Prospectus
and/or annual report shall be effective with respect
to the Fund until the time that the Fund complies
with the disclosure requirements adopted by the
Commission in Investment Company Act Release
No. 28584 (Jan. 13, 2009).
6 Under the representative sampling strategy, the
Advisor or the Sub-Advisor will seek to construct
a Fund’s portfolio so that its market capitalization,
industry weightings, fundamental investment
characteristics (such as return variability, earnings
valuation and yield) and liquidity measures
perform like those of the Underlying Index.
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each Fund) as will be clearly stated in
the relevant Fund’s Prospectus.
Applicants expect that the initial price
of a Creation Unit will fall in the range
of $1,000,000 to $10,000,000. All orders
to purchase Creation Units must be
placed with the Distributor, by or
through a party that has entered into an
agreement with the Distributor
(‘‘Authorized Participant’’). The
Distributor will be responsible for
transmitting the orders to the Funds. An
Authorized Participant must be either:
(a) A broker-dealer or other participant
in the continuous net settlement system
of the National Securities Clearing
Corporation (‘‘NSCC’’), a clearing
agency registered with the Commission,
or (b) a participant in the Depository
Trust Company (‘‘DTC’’, and such
participant, ‘‘DTC Participant’’). Fund
Shares of each Fund generally will be
sold in Creation Units in exchange for
an in-kind deposit by the purchaser of
a portfolio of securities designated by
the Advisor or Sub-Advisor to
correspond generally to the price and
yield performance of the relevant
Underlying Index (the ‘‘Deposit
Securities’’), together with the deposit of
a specified cash payment (‘‘Balancing
Amount’’). The Balancing Amount is an
amount equal to the difference between
(a) the net asset value (‘‘NAV’’) (per
Creation Unit) of a Fund and (b) the
total aggregate market value (per
Creation Unit) of the Deposit
Securities.7 Each Fund may permit a
purchaser of Creation Units to substitute
cash in lieu of depositing some or all of
the Deposit Securities if the Advisor or
Sub-Advisor believes such method
would reduce the Fund’s transaction
costs or enhance the Fund’s operating
efficiency.8
7 Each Fund will sell and redeem Creation Units
only on a ‘‘Business Day’’ which includes any day
that a Fund is required to be open under section
22(e) of the Act. Each Business Day, prior to the
opening of trading on the Listing Exchange (defined
below), the list of names and amount of each
security constituting the current Deposit Securities
and the Balancing Amount will be made available.
Any national securities exchange (as defined in
section 2(a)(26) of the Act) (‘‘Exchange’’) on which
Fund Shares are primarily listed (‘‘Listing
Exchange’’) will disseminate, every 15 seconds
during its regular trading hours, through the
facilities of the Consolidated Tape Association, an
amount per individual Fund Shares representing
the sum of the estimated Balancing Amount and the
current value of the Deposit Securities.
8 Applicants state that in some circumstances or
in certain countries, it may not be practicable or
convenient, or permissible under the laws of certain
countries or the regulations of certain foreign stock
exchanges, for a Foreign Fund to operate
exclusively on an ‘‘in-kind’’ basis. Applicants also
note that when a substantial rebalancing of a Fund’s
portfolio is required, the Advisor or Sub-Advisor
might prefer to receive cash rather than stocks so
that the Fund may avoid transaction costs involved
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6. An investor purchasing or
redeeming a Creation Unit from a Fund
will be charged a fee (‘‘Transaction
Fee’’) to prevent the dilution of the
interests of the remaining shareholders
resulting from costs in connection with
the purchase or redemption of Creation
Units.9 The maximum Transaction Fees
relevant to each Fund and the method
of calculating such Transaction Fees
will be fully disclosed in the Prospectus
of such Fund or statement of additional
information (‘‘SAI’’). The Distributor
will be responsible for delivering the
Fund’s Prospectus to those persons
purchasing Creation Units, and for
maintaining records of both the orders
placed with it and the confirmations of
acceptance furnished by it. In addition,
the Distributor will maintain a record of
the instructions given to the applicable
Fund to implement the delivery of its
Fund Shares.
7. Purchasers of Fund Shares in
Creation Units may hold such Fund
Shares or may sell such Fund Shares
into the secondary market. Fund Shares
will be listed and traded on an
Exchange. It is expected that one or
more member firms of a Listing
Exchange will be designated to act as a
specialist or a market maker and
maintain a market for Fund Shares
trading on the Listing Exchange. Prices
of Fund Shares trading on an Exchange
will be based on the current bid/ask
market. Fund Shares sold in the
secondary market will be subject to
customary brokerage commissions and
charges.
8. Applicants expect that purchasers
of Creation Units will include
institutional investors and arbitrageurs
(which could include institutional
investors). A specialist or market maker,
in providing a fair and orderly
secondary market for the Fund Shares,
also may purchase Creation Units for
use in its market-making activities.
Applicants expect that secondary
market purchasers of Fund Shares will
include both institutional investors and
retail investors.10 Applicants expect that
the price at which Fund Shares trade
will be disciplined by arbitrage
in liquidating part of its portfolio to achieve the
rebalancing.
9 Where a Fund permits a purchaser to substitute
cash in lieu of depositing a portion of the requisite
Deposit Securities, the purchaser may be assessed
a higher Transaction Fee to cover the cost of
purchasing such Deposit Securities, including
operational processing and brokerage costs, and
part or all of the spread between the expected bid
and the offer side of the market relating to such
Deposit Securities.
10 Fund Shares will be registered in book-entry
form only. DTC or its nominee will be the registered
owner of all outstanding Fund Shares. DTC or DTC
Participants will maintain records reflecting
beneficial owners of Fund Shares.
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opportunities created by the option to
continually purchase or redeem
Creation Units at their NAV, which
should ensure that Fund Shares will not
trade at a material discount or premium
in relation to their NAV.
9. Fund Shares will not be
individually redeemable, and owners of
Fund Shares may acquire those Fund
Shares from the Fund, or tender such
Fund Shares for redemption to the
Fund, in Creation Units only. To
redeem, an investor will have to
accumulate enough Fund Shares to
constitute a Creation Unit. Redemption
orders must be placed by or through an
Authorized Participant. An investor
redeeming a Creation Unit generally
will receive (a) Portfolio Securities
designated to be delivered for Creation
Unit redemptions (‘‘Fund Securities’’)
on the date that the request for
redemption is submitted 11 and (b) a
‘‘Cash Redemption Payment,’’
consisting of an amount calculated in
the same manner as the Balancing
Amount, although the actual amount of
the Cash Redemption Payment may
differ if the Fund Securities are not
identical to the Deposit Securities on
that day. An investor may receive the
cash equivalent of a Fund Security in
certain circumstances, such as if the
investor is constrained from effecting
transactions in the security by
regulation or policy.
10. No Fund will be marketed or
otherwise held out as a traditional openend investment company or a mutual
fund. Instead, each Fund will be
marketed as an ‘‘ETF,’’ an ‘‘investment
company,’’ a ‘‘fund,’’ or a ‘‘trust.’’ All
marketing materials that describe the
features or method of obtaining, buying
or selling Creation Units or Fund Shares
traded on an Exchange, or refer to
redeemability, will prominently
disclose that Fund Shares are not
individually redeemable and that the
owners of Fund Shares may purchase or
redeem Fund Shares from the Fund in
Creation Units only. The same approach
will be followed in the SAI, shareholder
reports and investor educational
materials issued or circulated in
connection with the Fund Shares. The
Funds will provide copies of their
11 As a general matter, the Deposit Securities and
Fund Securities will correspond pro rata to the
Portfolio Securities held by each Fund, but Fund
Securities received on redemption may not always
be identical to Deposit Securities deposited in
connection with the purchase of Creation Units for
the same day. The Funds will comply with the
Federal securities laws in accepting Deposit
Securities and satisfying redemptions with Fund
Securities, including that the Deposit Securities and
Fund Securities are sold in transactions that would
be exempt from registration under the Securities
Act.
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annual and semi-annual shareholder
reports to DTC Participants for
distribution to shareholders.
Applicants’ Legal Analysis
1. Applicants request an order under
section 6(c) of the Act for an exemption
from sections 2(a)(32), 5(a)(1), 22(d), and
22(e) of the Act and rule 22c–1 under
the Act, under sections 6(c) and 17(b) of
the Act for an exemption from sections
17(a)(1) and 17(a)(2) of the Act, and
under section 12(d)(1)(J) of the Act for
an exemption from sections 12(d)(1)(A)
and (B) of the Act.
2. Section 6(c) of the Act provides that
the Commission may exempt any
person, security or transaction, or any
class of persons, securities or
transactions, from any provision of the
Act, if and to the extent that such
exemption is necessary or appropriate
in the public interest and consistent
with the protection of investors and the
purposes fairly intended by the policy
and provisions of the Act. Section 17(b)
of the Act authorizes the Commission to
exempt a proposed transaction from
section 17(a) of the Act if evidence
establishes that the terms of the
transaction, including the consideration
to be paid or received, are reasonable
and fair and do not involve
overreaching on the part of any person
concerned, and the proposed
transaction is consistent with the
policies of the registered investment
company and the general provisions of
the Act. Section 12(d)(1)(J) of the Act
provides that the Commission may
exempt any person, security, or
transaction, or any class or classes of
persons, securities or transactions, from
any provisions of section 12(d)(1) if the
exemption is consistent with the public
interest and the protection of investors.
Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an
‘‘open-end company’’ as a management
investment company that is offering for
sale or has outstanding any redeemable
security of which it is the issuer.
Section 2(a)(32) of the Act defines a
redeemable security as any security,
other than short-term paper, under the
terms of which the owner, upon its
presentation to the issuer, is entitled to
receive approximately his proportionate
share of the issuer’s current net assets,
or the cash equivalent. Because Fund
Shares will not be individually
redeemable, applicants request an order
that would permit the Funds to register
as open-end management investment
companies and issue Fund Shares that
are redeemable in Creation Units only.
Applicants state that investors may
purchase Fund Shares in Creation Units
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and redeem Creation Units from each
Fund. Applicants state that because
Creation Units may always be
purchased and redeemed at NAV, the
market price of the Fund Shares should
not vary substantially from their NAV.
Section 22(d) of the Act and Rule 22c–
1 Under the Act
4. Section 22(d) of the Act, among
other things, prohibits a dealer from
selling a redeemable security, which is
currently being offered to the public by
or through a principal underwriter,
except at a current public offering price
described in the prospectus. Rule 22c–
1 under the Act generally requires that
a dealer selling, redeeming or
repurchasing a redeemable security do
so only at a price based on its NAV.
Applicants state that secondary market
trading in Fund Shares will take place
at negotiated prices, not at a current
offering price described in a Fund’s
Prospectus, and not at a price based on
NAV. Thus, purchases and sales of
Fund Shares in the secondary market
will not comply with section 22(d) of
the Act and rule 22c–1 under the Act.
Applicants request an exemption under
section 6(c) from these provisions.
5. Applicants assert that the concerns
sought to be addressed by section 22(d)
of the Act and rule 22c–1 under the Act
with respect to pricing are equally
satisfied by the proposed method of
pricing Fund Shares. Applicants
maintain that while there is little
legislative history regarding section
22(d), its provisions, as well as those of
rule 22c–1, appear to have been
designed to (a) prevent dilution caused
by certain riskless-trading schemes by
principal underwriters and contract
dealers, (b) prevent unjust
discrimination or preferential treatment
among buyers, and (c) ensure an orderly
distribution of investment company
shares by eliminating price competition
from dealers offering shares at less than
the published sales price and
repurchasing shares at more than the
published redemption price.
6. Applicants believe that none of
these purposes will be thwarted by
permitting Fund Shares to trade in the
secondary market at negotiated prices.
Applicants state that (a) secondary
market trading in Fund Shares does not
involve a Fund as a party and will not
result in dilution of an investment in
Fund Shares, and (b) to the extent
different prices exist during a given
trading day, or from day to day, such
variances occur as a result of third-party
market forces, such as supply and
demand. Therefore, applicants assert
that secondary market transactions in
Fund Shares will not lead to
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discrimination or preferential treatment
among purchasers. Finally, applicants
contend that the proposed distribution
system will be orderly because
competitive forces will ensure that the
difference between the market price of
Fund Shares and their NAV remains
narrow.
Section 22(e)
7. Section 22(e) of the Act generally
prohibits a registered investment
company from suspending the right of
redemption or postponing the date of
payment of redemption proceeds for
more than seven days after the tender of
a security for redemption. Applicants
state that settlement of redemptions for
the Foreign Funds is contingent not
only on the settlement cycle of the
United States market, but also on
currently practicable delivery cycles in
local markets for underlying foreign
securities held by the Foreign Funds.
Applicants state that local market
delivery cycles for transferring Fund
Securities to redeeming investors,
coupled with local market holiday
schedules, will, under certain
circumstances, require a delivery
process longer than seven calendar days
for Foreign Funds. Applicants request
relief under section 6(c) of the Act from
section 22(e) to allow the Foreign Funds
to pay redemption proceeds up to
fourteen calendar days after the tender
of any Creation Units for redemption.
Except as disclosed in the relevant
Foreign Fund’s Prospectus and/or SAI,
applicants expect that each Foreign
Fund will be able to deliver redemption
proceeds within seven days.12 With
respect to Future Funds that are Foreign
Funds, applicants seek the same relief
from section 22(e) only to the extent that
circumstances similar to those described
in the application exist.
8. Applicants state that section 22(e)
was designed to prevent unreasonable,
undisclosed and unforeseen delays in
the payment of redemption proceeds.
Applicants assert that the requested
relief will not lead to the problems that
section 22(e) was designed to prevent.
Applicants state that the SAI will
disclose those local holidays (over the
period of at least one year following the
date of the SAI), if any, that are
expected to prevent the delivery of
redemption proceeds in seven calendar
days, and the maximum number of
days, up to fourteen calendar days,
12 Rule 15c6–1 under the Exchange Act requires
that most securities transactions be settled within
three business days of the trade. Applicants
acknowledge that no relief obtained from the
requirements of section 22(e) will affect any
obligations applicants may have under rule
15c6–1.
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37261
needed to deliver the proceeds for the
relevant Foreign Fund. Applicants are
not seeking relief from section 22(e)
with respect to Foreign Funds that do
not effect creations and redemptions of
Creation Units in-kind.
Section 12(d)(1)
9. Section 12(d)(1)(A) of the Act, in
relevant part, prohibits a registered
investment company from acquiring
securities of an investment company if
such securities represent more than 3%
of the total outstanding voting stock of
the acquired company, more than 5% of
the total assets of the acquiring
company, or, together with the
securities of any other investment
companies, more than 10% of the total
assets of the acquiring company. Section
12(d)(1)(B) of the Act prohibits a
registered open-end investment
company, its principal underwriter and
any other broker-dealer from selling the
investment company’s shares to another
investment company if the sale will
cause the acquiring company to own
more than 3% of the acquired
company’s voting stock, or if the sale
will cause more than 10% of the
acquired company’s voting stock to be
owned by investment companies
generally.
10. Applicants request an exemption
to permit management investment
companies (‘‘Purchasing Management
Companies’’) and unit investment trusts
(‘‘Purchasing Trusts’’) registered under
the Act that are not sponsored or
advised by the Advisor or any entity
controlling, controlled by, or under
common control with the Advisor and
are not part of the same ‘‘group of
investment companies,’’ as defined in
section 12(d)(1)(G)(ii) of the Act, as the
Trust (collectively, ‘‘Purchasing Funds’’)
to acquire shares of a Fund beyond the
limits of section 12(d)(1)(A). Purchasing
Funds do not include the Funds. In
addition, applicants seek relief to permit
a Fund or broker-dealer (‘‘Broker’’) that
is registered under the Exchange Act to
sell Fund Shares to a Purchasing Fund
in excess of the limits of section
12(d)(1)(B).
11. Each Purchasing Management
Company will be advised by an
investment adviser within the meaning
of section 2(a)(20)(A) of the Act (the
‘‘Purchasing Fund Advisor’’) and may
be sub-advised by one or more
investment advisers within the meaning
of section 2(a)(20)(B) of the Act (each a
‘‘Purchasing Fund Sub-Advisor’’). Any
investment adviser to a Purchasing
Management Company will be
registered under the Advisers Act. Each
Purchasing Trust will be sponsored by
a sponsor (‘‘Sponsor’’).
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12. Applicants submit that the
proposed conditions to the requested
relief adequately address the concerns
underlying the limits in sections
12(d)(1)(A) and (B), which include
concerns about undue influence by a
fund of funds over underlying funds,
excessive layering of fees and overly
complex fund structures. Applicants
believe that the requested exemption is
consistent with the public interest and
the protection of investors.
13. Applicants believe that neither the
Purchasing Funds nor a Purchasing
Fund Affiliate would be able to exert
undue influence over the Funds.13 To
limit the control that a Purchasing Fund
may have over a Fund, applicants
propose a condition prohibiting a
Purchasing Fund Advisor or a Sponsor,
any person controlling, controlled by, or
under common control with a
Purchasing Fund Advisor or Sponsor,
and any investment company and any
issuer that would be an investment
company but for sections 3(c)(1) or
3(c)(7) of the Act that is advised or
sponsored by a Purchasing Fund
Advisor or Sponsor, or any person
controlling, controlled by, or under
common control with a Purchasing
Fund Advisor or Sponsor (‘‘Purchasing
Fund’s Advisory Group’’) from
controlling (individually or in the
aggregate) a Fund within the meaning of
section 2(a)(9) of the Act. The same
prohibition would apply to any
Purchasing Fund Sub-Advisor, any
person controlling, controlled by or
under common control with the
Purchasing Fund Sub-Advisor, and any
investment company or issuer that
would be an investment company but
for sections 3(c)(1) or 3(c)(7) of the Act
(or portion of such investment company
or issuer) advised or sponsored by the
Purchasing Fund Sub-Advisor or any
person controlling, controlled by or
under common control with the
Purchasing Fund Sub-Advisor
(‘‘Purchasing Fund’s Sub-Advisory
Group’’). Applicants propose other
conditions to limit the potential for
undue influence over the Funds,
including that no Purchasing Fund or
Purchasing Fund Affiliate (except to the
extent it is acting in its capacity as an
investment adviser to a Fund) will cause
a Fund to purchase a security in any
13 A ‘‘Purchasing Fund Affiliate’’ is a Purchasing
Fund Advisor, Purchasing Fund Sub-Advisor,
Sponsor, promoter, and principal underwriter of a
Purchasing Fund, and any person controlling,
controlled by, or under common control with any
of these entities. A ‘‘Fund Affiliate’’ is an
investment adviser, promoter, or principal
underwriter of a Fund and any person controlling,
controlled by or under common control with any
of these entities.
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offering of securities during the
existence of any underwriting or selling
syndicate of which a principal
underwriter is an Underwriting Affiliate
(‘‘Affiliated Underwriting’’). An
‘‘Underwriting Affiliate’’ is a principal
underwriter in any underwriting or
selling syndicate that is an officer,
director, member of an advisory board,
Purchasing Fund Advisor, Purchasing
Fund Sub-Advisor, employee or
Sponsor of a Purchasing Fund, or a
person of which any such officer,
director, member of an advisory board,
Purchasing Fund Advisor, Purchasing
Fund Sub-Advisor, employee, or
Sponsor is an affiliated person (except
that any person whose relationship to
the Fund is covered by section 10(f) of
the Act is not an Underwriting
Affiliate).
14. Applicants assert that the
proposed conditions address any
concerns regarding excessive layering of
fees. The board of directors or trustees
of any Purchasing Management
Company, including a majority of the
directors or trustees who are not
‘‘interested persons’’ within the
meaning of section 2(a)(19) of the Act
(‘‘disinterested directors or trustees’’),
will find that the advisory fees charged
to the Purchasing Management
Company are based on services
provided that will be in addition to,
rather than duplicative of, services
provided under the advisory contract(s)
of any Fund in which the Purchasing
Management Company may invest. In
addition, except as provided in
condition 12, a Purchasing Fund
Advisor or a trustee (‘‘Trustee’’) or
Sponsor of a Purchasing Trust will, as
applicable, waive fees otherwise
payable to it by the Purchasing Fund in
an amount at least equal to any
compensation (including fees received
pursuant to any plan adopted by a Fund
under rule 12b–1 under the Act)
received by the Purchasing Fund
Advisor or Trustee or Sponsor or an
affiliated person of the Purchasing Fund
Advisor, Trustee or Sponsor, from the
Fund in connection with the investment
by the Purchasing Fund in the Fund.
Applicants state that any sales loads or
service fees charged with respect to
shares of a Purchasing Fund will not
exceed the limits applicable to a fund of
funds set forth in Conduct Rule 2830 of
the National Association of Securities
Dealers (‘‘NASD’’).14
15. Applicants submit that the
proposed arrangement will not create an
14 Any references to NASD Conduct Rule 2830
include any successor or replacement rule to NASD
Conduct Rule 2830 that may be adopted by the
Financial Industry Regulatory Association.
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Frm 00076
Fmt 4703
Sfmt 4703
overly complex fund structure.
Applicants note that no Fund may
acquire securities of any investment
company or company relying on
sections 3(c)(1) or 3(c)(7) of the Act in
excess of the limits contained in section
12(d)(1)(A) of the Act, except to the
extent permitted by exemptive relief
from the Commission permitting the
Fund to purchase shares of a money
market fund for short-term cash
management purposes. To ensure that
Purchasing Funds comply with the
terms and conditions of the requested
relief from section 12(d)(1), any
Purchasing Fund that intends to invest
in a Fund in reliance on the requested
order will enter into a Purchasing Fund
Agreement between the Fund and the
Purchasing Fund requiring the
Purchasing Fund to adhere to the terms
and conditions of the requested order.
The Purchasing Fund Agreement also
will include an acknowledgement from
the Purchasing Fund that it may rely on
the requested order only to invest in the
Funds and not in any other investment
company.
16. Applicants also note that a Fund
may choose to reject a direct purchase
of Fund Shares in Creation Units by a
Purchasing Fund. To the extent that a
Purchasing Fund purchases Fund
Shares in the secondary market, a Fund
would still retain its ability to reject
initial purchases of Fund Shares made
in reliance on the requested order by
declining to enter into the Purchasing
Fund Agreement prior to any
investment by a Purchasing Fund in
excess of the limits of section
12(d)(1)(A).
Sections 17(a)(1) and (2) of the Act
17. Section 17(a) of the Act generally
prohibits an affiliated person of a
registered investment company, or an
affiliated person of such a person
(‘‘Second-Tier Affiliate’’), from selling
any security to or purchasing any
security from the company. Section
2(a)(3) of the Act defines ‘‘affiliated
person’’ to include (a) any person
directly or indirectly owning,
controlling or holding with power to
vote 5% or more of the outstanding
voting securities of the other person, (b)
any person 5% or more of whose
outstanding voting securities are
directly or indirectly owned, controlled
or held with the power to vote by the
other person, and (c) any person directly
or indirectly controlling, controlled by
or under common control with the other
person. Section 2(a)(9) of the Act
provides that a control relationship will
be presumed where one person owns
more than 25% of another person’s
voting securities.
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18. Applicants request an exemption
from section 17(a) of the Act pursuant
to sections 17(b) and 6(c) of the Act to
permit persons to effectuate in-kind
purchases and redemptions with a Fund
when they are affiliated persons of the
Fund or Second-Tier Affiliates solely by
virtue of one or more of the following:
(a) Holding 5% or more, or in excess of
25%, of the outstanding Fund Shares of
one or more Funds; (b) having an
affiliation with a person with an
ownership interest described in (a); or
(c) holding 5% or more, or more than
25%, of the shares of one or more other
registered investment companies (or
series thereof) advised by the Advisor.
19. Applicants assert that no useful
purpose would be served by prohibiting
these types of affiliated persons from
purchasing or redeeming Creation Units
through ‘‘in-kind’’ transactions. The
deposit procedures for both in-kind
purchases and in-kind redemptions of
Creation Units will be the same for all
purchases and redemptions. Deposit
Securities and Fund Securities will be
valued in the same manner as Portfolio
Securities. Therefore, applicants state
that in-kind purchases and redemptions
will afford no opportunity for the
specified affiliated persons, or SecondTier Affiliates, of a Fund to effect a
transaction detrimental to other holders
of Fund Shares. Applicants also believe
that in-kind purchases and redemptions
will not result in self-dealing or
overreaching of the Fund.
20. Applicants also seek relief from
section 17(a) to permit a Fund that is an
affiliated person of a Purchasing Fund
to sell its Fund Shares to and redeem its
Fund Shares from a Purchasing Fund,
and to engage in the accompanying inkind transactions with the Purchasing
Fund.15 Applicants state that the terms
of the transactions are fair and
reasonable and do not involve
overreaching. Applicants note that any
consideration paid by a Purchasing
Fund for the purchase or redemption of
Fund Shares directly from a Fund will
be based on the NAV of the Fund.16
Applicants believe that any proposed
15 Applicants acknowledge that the receipt of
compensation by (a) an affiliated person of a
Purchasing Fund, or an affiliated person of such
person, for the purchase by the Purchasing Fund of
Fund Shares of a Fund or (b) an affiliated person
of a Fund, or an affiliated person of such person,
for the sale by the Fund of its Fund Shares to a
Purchasing Fund, may be prohibited by section
17(e)(1) of the Act. The Purchasing Fund Agreement
also will include this acknowledgment.
16 Applicants believe that a Purchasing Fund will
purchase Fund Shares in the secondary market and
will not purchase or redeem Creation Units directly
from a Fund. However, the requested relief would
apply to direct sales of Creation Units by a Fund
to a Purchasing Fund and redemptions of those
Fund Shares.
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19:36 Jul 27, 2009
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transactions directly between the Funds
and Purchasing Funds will be consistent
with the policies of each Purchasing
Fund. The purchase of Creation Units
by a Purchasing Fund directly from a
Fund will be accomplished in
accordance with the investment
restrictions of any such Purchasing
Fund and will be consistent with the
investment policies set forth in the
Purchasing Fund’s registration
statement. The Purchasing Fund
Agreement will require any Purchasing
Fund that purchases Creation Units
directly from a Fund to represent that
the purchase of Creation Units from a
Fund by a Purchasing Fund will be
accomplished in compliance with the
investment restrictions of the
Purchasing Fund and will be consistent
with the investment policies set forth in
the Purchasing Fund’s registration
statement.
Applicants’ Conditions
Applicants agree that any order of
granting the requested relief will be
subject to the following conditions: 17
ETF Relief
1. As long as the Funds operate in
reliance on the requested order, Fund
Shares will be listed on an Exchange.
2. Neither the Trust nor any Fund will
be advertised or marketed as an openend investment company or a mutual
fund. Each Fund’s Prospectus will
prominently disclose that Fund Shares
are not individually redeemable shares
and will disclose that the owners of
Fund Shares may acquire those Fund
Shares from the Fund and tender those
Fund Shares for redemption to the Fund
in Creation Units only. Any advertising
material that describes the purchase or
sale of Creation Units or refers to
redeemability will prominently disclose
that Fund Shares are not individually
redeemable, and that owners of Fund
Shares may acquire those Fund Shares
from the Fund and tender those Fund
Shares for redemption to the Fund in
Creation Units only.
3. The Web site maintained for each
Fund, which will be publicly accessible
at no charge, will contain the following
information, on a per individual Fund
Share basis, for each Fund: (a) The prior
Business Day’s NAV and the mid-point
of the bid-ask spread at the time of the
calculation of the NAV (‘‘Bid/Ask
Price’’), and a calculation of the
premium or discount of the Bid/Ask
Price at the time of calculation of the
NAV against such NAV; and (b) data in
chart format displaying the frequency
distribution of discounts and premiums
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17 See
note 5, supra.
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37263
of the daily Bid/Ask Price against the
NAV, within appropriate ranges, for
each of the four previous calendar
quarters.
4. The Prospectus and annual report
for each Fund also will include: (a) The
information listed in condition 3(b), (i)
in the case of the Fund’s Prospectus, for
the most recently completed year (and
the most recently completed quarter or
quarters, as applicable) and (ii) in the
case of the annual report, for the
immediately preceding five years, as
applicable; and (b) the following data,
calculated on a per individual Fund
Share basis for one, five and ten year
periods (or life of the Fund), (i) the
cumulative total return and the average
annual total return based on NAV and
Bid/Ask Price, and (ii) the cumulative
total return of the relevant Underlying
Index.
5. Each Fund’s Prospectus will clearly
disclose that, for purposes of the Act,
Fund Shares are issued by the Fund,
which is a registered investment
company, and that the acquisition of
Fund Shares by investment companies
is subject to the restrictions of section
12(d)(1) of the Act, except as permitted
by an exemptive order that permits
registered investment companies to
invest in a Fund beyond the limits in
section 12(d)(1), subject to certain terms
and conditions, including that the
registered investment company enter
into a Purchasing Fund Agreement with
the Fund regarding the terms of the
investment.
6. The requested relief to permit ETF
operations will expire on the effective
date of any Commission rule under the
Act that provides relief permitting the
operation of index-based exchangetraded funds.
Section 12(d)(1) Relief
7. The members of a Purchasing
Fund’s Advisory Group will not control
(individually or in the aggregate) a Fund
within the meaning of section 2(a)(9) of
the Act. The members of a Purchasing
Fund’s Sub-Advisory Group will not
control (individually or in the aggregate)
a Fund within the meaning of section
2(a)(9) of the Act. If as a result of a
decrease in the outstanding Fund Shares
of a Fund, a Purchasing Fund’s
Advisory Group or a Purchasing Fund’s
Sub-Advisory Group, each in the
aggregate, becomes a holder of more
than 25 percent of the outstanding Fund
Shares of a Fund, it will vote its Fund
Shares in the same proportion as the
vote of all other holders of the Fund
Shares. This condition does not apply to
the Purchasing Fund’s Sub-Advisory
Group with respect to a Fund for which
the Purchasing Fund’s Sub-Advisor or a
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person controlling, controlled by, or
under common control with the
Purchasing Fund Sub-Advisor acts as
the investment adviser within the
meaning of section 2(a)(20)(A) of the
Act.
8. No Purchasing Fund or Purchasing
Fund Affiliate will cause any existing or
potential investment by the Purchasing
Fund in a Fund to influence the terms
of any services or transactions between
the Purchasing Fund or Purchasing
Fund Affiliate and the Fund or a Fund
Affiliate.
9. The board of directors or trustees of
a Purchasing Management Company,
including a majority of the disinterested
directors or trustees, will adopt
procedures reasonably designed to
ensure that the Purchasing Fund
Advisor and Purchasing Fund SubAdvisor are conducting the investment
program of the Purchasing Management
Company without taking into account
any consideration received by the
Purchasing Management Company or a
Purchasing Fund Affiliate from a Fund
or a Fund Affiliate in connection with
any services or transactions.
10. No Purchasing Fund or
Purchasing Fund Affiliate (except to the
extent it is acting in its capacity as an
investment adviser to a Fund) will cause
a Fund to purchase a security in any
Affiliated Underwriting.
11. Before investing in the Fund
Shares of a Fund in excess of the limits
in section 12(d)(1)(A), each Purchasing
Fund and the Fund will execute a
Purchasing Fund Agreement stating,
without limitation, that their boards of
directors or trustees and their
investment advisers or Sponsors and
Trustees, as applicable, understand the
terms and conditions of the order, and
agree to fulfill their responsibilities
under the order. At the time of its
investment in Fund Shares of a Fund in
excess of the limit in section
12(d)(1)(A)(i), a Purchasing Fund will
notify such Fund of the investment. At
such time, the Purchasing Fund will
also transmit to the Fund a list of names
of each Purchasing Fund Affiliate and
Underwriting Affiliate. The Purchasing
Fund will notify the Fund of any
changes to the list of the names as soon
as reasonably practicable after a change
occurs. The relevant Fund and the
Purchasing Fund will maintain and
preserve a copy of the order, the
Purchasing Fund Agreement, and the
list with any updated information for
the duration of the investment and for
a period of not less than six years
thereafter, the first two years in an
easily accessible place.
12. The Purchasing Fund Advisor,
Trustee or Sponsor, as applicable, will
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waive fees otherwise payable to it by the
Purchasing Fund in an amount at least
equal to any compensation (including
fees received under any plan adopted by
a Fund under rule 12b–1 under the Act)
received from a Fund by the Purchasing
Fund Advisor, Trustee or Sponsor, or an
affiliated person of the Purchasing Fund
Advisor, Trustee or Sponsor, other than
any advisory fees paid to the Purchasing
Fund Advisor, Trustee or Sponsor, or its
affiliated person by a Fund, in
connection with the investment by the
Purchasing Fund in the Fund. Any
Purchasing Fund Sub-Advisor will
waive fees otherwise payable to the
Purchasing Fund Sub-Advisor, directly
or indirectly, by the Purchasing
Management Company in an amount at
least equal to any compensation
received from a Fund by the Purchasing
Fund Sub-Advisor, or an affiliated
person of the Purchasing Fund SubAdvisor, other than any advisory fees
paid to the Purchasing Fund SubAdvisor or its affiliated person by a
Fund, in connection with any
investment by the Purchasing
Management Company in a Fund made
at the direction of the Purchasing Fund
Sub-Advisor. In the event that the
Purchasing Fund Sub-Advisor waives
fees, the benefit of the waiver will be
passed through to the Purchasing
Management Company.
13. Any sales charges and/or service
fees charged with respect to shares of a
Purchasing Fund will not exceed the
limits applicable to a fund of funds as
set forth in NASD Conduct Rule 2830.
14. Once an investment by a
Purchasing Fund in the Fund Shares of
a Fund exceeds the limit in section
12(d)(1)(A)(i) of the Act, the Board of a
Fund, including a majority of the
directors or trustees that are not
‘‘interested persons’’ within the
meaning of section 2(a)(19) of the Act
(‘‘disinterested Board members’’), will
determine that any consideration paid
by the Fund to a Purchasing Fund or
Purchasing Fund Affiliate in connection
with any services or transactions: (a) Is
fair and reasonable in relation to the
nature and quality of the services and
benefits received by the Fund; (b) is
within the range of consideration that
the Fund would be required to pay to
another unaffiliated entity in connection
with the same services or transactions;
and (c) does not involve overreaching
on the part of any person concerned.
This condition does not apply with
respect to any services or transactions
between a Fund and its investment
adviser(s), or any person controlling,
controlled by, or under common control
with such investment adviser(s).
PO 00000
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15. The Board, including a majority of
the disinterested Board members, will
adopt procedures reasonably designed
to monitor any purchases of securities
by a Fund in an Affiliated Underwriting
once an investment by the Purchasing
Fund in the securities of the Fund
exceeds the limit of section
12(d)(1)(A)(i) of the Act, including any
purchases made directly from an
Underwriting Affiliate. The Board will
review these purchases periodically, but
no less frequently than annually, to
determine whether the purchases were
influenced by the investment by the
Purchasing Fund in a Fund. The Board
will consider, among other things: (a)
Whether the purchases were consistent
with the investment objectives and
policies of the Fund; (b) how the
performance of securities purchased in
an Affiliated Underwriting compares to
the performance of comparable
securities purchased during a
comparable period of time in
underwritings other than Affiliated
Underwritings or to a benchmark such
as a comparable market index; and (c)
whether the amount of securities
purchased by a Fund in Affiliated
Underwritings and the amount
purchased directly from an
Underwriting Affiliate have changed
significantly from prior years. The
Board will take any appropriate actions
based on its review, including, if
appropriate, the institution of
procedures designed to assure that
purchases of securities in Affiliated
Underwritings are in the best interest of
shareholders of the Fund.
16. Each Fund will maintain and
preserve permanently in an easily
accessible place a written copy of the
procedures described in the preceding
condition, and any modifications to
such procedures, and will maintain and
preserve for a period not less than six
years from the end of the fiscal year in
which any purchase in an Affiliated
Underwriting occurred, the first two
years in an easily accessible place, a
written record of each purchase of
securities in Affiliated Underwritings,
once an investment by a Purchasing
Fund in the Fund Shares of the Fund
exceeds the limit of section
12(d)(1)(A)(i) of the Act, setting forth
from whom the securities were
acquired, the identity of the
underwriting syndicate’s members, the
terms of the purchase, and the
information or materials upon which
the Board’s determinations were made.
17. Before approving any advisory
contract under section 15 of the Act, the
board of directors or trustees of each
Purchasing Management Company,
including a majority of the disinterested
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directors or trustees, will find that the
advisory fees charged under such
contract are based on services provided
that will be in addition to, rather than
duplicative of, the services provided
under the advisory contract(s) of any
Fund in which the Purchasing
Management Company may invest.
These findings and their basis will be
recorded fully in the minute books of
the appropriate Purchasing Management
Company.
18. No Fund will acquire securities of
any investment company or companies
relying on sections 3(c)(1) or 3(c)(7) of
the Act in excess of the limits contained
in section 12(d)(1)(A) of the Act, except
to the extent permitted by exemptive
relief from the Commission permitting
the Fund to purchase shares of a money
market fund for short-term cash
management purposes.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9–17884 Filed 7–27–09; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–60360; File No. 4–429]
Joint Industry Plan; Chicago Board
Options Exchange, Incorporated,
International Securities Exchange,
LLC, The NASDAQ Stock Market LLC,
NASDAQ OMX BX, Inc., NASDAQ OMX
PHLX, Inc., NYSE Amex LLC, and
NYSE Arca, Inc.; Notice of Filing of
Amendments to the Intermarket
Options Linkage Plan To Withdraw
From the Plan
July 21, 2009.
mstockstill on DSKH9S0YB1PROD with NOTICES
I. Introduction
Pursuant to Section 11A of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 1 and Rule 608 of Regulation
NMS thereunder (‘‘Rule 608’’),2 notice is
hereby given that on June 25, 2009, June
25, 3009, July 2, 2009, July 2, 2009, July
7, 2009, July 17, 2009, July 20, 2009,
NYSE Arca, Inc. (‘‘NYSE Arca’’), NYSE
Amex, LLC (‘‘NYSE Amex’’),
International Securities Exchange, LLC
(‘‘ISE’’), Chicago Board Options
Exchange, Incorporated (‘‘CBOE’’),
NASDAQ OMX BX, Inc. (‘‘BX’’),
NASDAQ OMX PHLX, Inc. (‘‘Phlx’’),
and The NASDAQ Stock Market LLC
(‘‘Nasdaq’’) (collectively,
1 15
2 17
U.S.C. 78k-1(a).
CFR 242.608.
VerDate Nov<24>2008
19:36 Jul 27, 2009
Jkt 217001
‘‘Participants’’) 3 respectively submitted
to the Securities and Exchange
Commission (‘‘Commission’’)
amendments to the Plan for the Purpose
of Creating and Operating an
Intermarket Option Linkage (‘‘Linkage
Plan’’) (‘‘Amendments’’).4 Each
Amendment proposes to modify Section
4(a) of the Linkage Plan to delete the
name of the submitting Participant. The
Commission is publishing this notice to
solicit comments from interested
persons on the proposed Amendments
to the Linkage Plan.
II. Description of the Proposed
Amendments
The purpose of each Amendment is
for the Participant submitting such
Amendment to withdraw from the
Linkage Plan. Pursuant to Section 4(d)
of the Linkage Plan, a Participant may
withdraw by: (i) Providing not less than
30 days’ prior written notice to each of
the other Participants and to The
Options Clearing Corporation (‘‘OCC,’’
the facilities manager) of such intent to
withdraw; and (ii) effecting an
amendment to the Linkage Plan as
specified in Section 5(c)(iii) of the
Linkage Plan. In turn, Section 5(c)(iii) of
the Linkage Plan states that a Participant
can withdraw from the Linkage Plan by
filing an amendment deleting its name
in Section 4(a) of the Linkage Plan and
submitting such amendment to the
Commission for approval. The
submitting Participant must state how it
plans to accomplish, by alternate means,
the goals of the Linkage Plan regarding
letter from Peter G. Armstrong, NYSE Arca,
to Elizabeth Murphy, Secretary, Commission, dated
June 24, 2009; letter from Michael Babel, NYSE
Amex, to Elizabeth Murphy, Secretary,
Commission, dated June 24, 2009; letter from
Michael J. Simon, ISE, to Elizabeth Murphy,
Secretary, Commission, dated July 1, 2009; letter
from Edward J. Joyce, CBOE, to Elizabeth Murphy,
Secretary, Commission, dated July 1, 2009; letter
from Maura A. Looney, Associate Vice President,
BX, to Elizabeth Murphy, Secretary, Commission,
dated July 6, 2009; letter from letter from Richard
S. Rudolph, Assistant General Counsel, Phlx, to
Elizabeth Murphy, Secretary, Commission, dated
July 16, 2009; and letter from Jeffrey S. Davis, Vice
President and Deputy General Counsel, Nasdaq, to
Elizabeth Murphy, Secretary, Commission, dated
July 17, 2009.
4 On July 28, 2000, the Commission approved a
national market system plan for the purpose of
creating and operating an intermarket options
market linkage proposed by the American Stock
Exchange LLC (n/k/a Amex), CBOE, and ISE. See
Securities Exchange Act Release No. 43086 (July 28,
2000), 65 FR 48023 (August 4, 2000). Subsequently,
Philadelphia Stock Exchange, Inc. (n/k/a Phlx),
Pacific Exchange, Inc. (n/k/a NYSE Arca), Boston
Stock Exchange, Inc. (n/k/a BX), and Nasdaq joined
the Linkage Plan. See Securities Exchange Act
Release Nos. 43573 (November 16, 2000), 65 FR
70851 (November 28, 2000); 43574 (November 16,
2000), 65 FR 70850 (November 28, 2000); 49198
(February 5, 2004), 69 FR 7029 (February 12, 2004);
and 57545 (March 21, 2008), 73 FR 16394 (March
27, 2008).
PO 00000
3 See
Frm 00079
Fmt 4703
Sfmt 4703
37265
limiting Trade-Throughs. The
amendment is effective upon
Commission approval.
The Participants plan to accomplish
the Linkage Plan’s goals through
membership in the Options Order
Protection and Locked/Crossed Market
Plan (‘‘New Plan’’). The Commission
has published the New Plan for
comment.5 The participants to the New
Plan currently plan to begin
implementing that plan on August 31st,
subject to Commission approval. The
New Plan contains a requirement that
each participant establish, maintain and
enforce written procedures and policies
that are reasonably designed to prevent
Trade-Throughs.6 The New Plan will
accomplish this in a more efficient
manner than the Linkage Plan.
Specifically, the New Plan eliminates a
central hub and addresses TradeThrough compliance through the use of
intermarket sweep orders. This is based
on the concepts of Regulation NMS,
which, among other things, addresses
trade-throughs in the equity market. The
New Plan also requires its participants
to conduct surveillance of their markets
to ascertain the effectiveness of these
policies and procedures.7 Finally, the
New Plan contains provisions requiring
its participants to establish, maintain
and enforce written rules addressing
locked and crossed markets.8 The
Participants believe that the New Plan
will fully accomplish the same goals of
the Plan, including imposing limits on
Trade-Throughs.
III. Implementation of the Plan
Amendment
The proposed Amendments to the
Linkage Plan will be effective upon
approval by the Commission pursuant
to Rule 608.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the Amendments to
the Linkage Plan are consistent with the
Act. Comments may be submitted by
any of the following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number 4–429 on the subject line.
5 See Securities Exchange Act Release No. 59647
(March 30, 2009), 74 FR 15010 (April 2, 2009).
6 Section 5(a)(i) of the New Plan.
7 Section 5(a)(ii) of the New Plan.
8 Section 6 of the New Plan.
E:\FR\FM\28JYN1.SGM
28JYN1
Agencies
[Federal Register Volume 74, Number 143 (Tuesday, July 28, 2009)]
[Notices]
[Pages 37258-37265]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-17884]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 28834; File No. 812-13503]
Pax World Funds Trust II, et al.; Notice of Application
July 22, 2009.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under section 6(c) of the
Investment Company Act of 1940 (the ``Act'') for an exemption from
sections 2(a)(32), 5(a)(1), 22(d), and 22(e) of the Act and rule 22c-1
under the Act, under sections 6(c) and 17(b) of the Act for an
exemption from sections 17(a)(1) and 17(a)(2) of the Act, and under
section 12(d)(1)(J) of the Act for an exemption from sections
12(d)(1)(A) and 12(d)(1)(B) of the Act.
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Summary of Application: Applicants request an order that would permit
(a) certain open-end management investment companies and their series,
to issue shares (``Fund Shares'') that can be redeemed only in large
aggregations (``Creation Units''); (b) secondary market transactions in
Fund Shares to occur at negotiated prices; (c) certain series to pay
redemption proceeds, under certain circumstances, more than seven days
after the tender of Fund Shares for redemption; (d) certain affiliated
persons of the series to deposit securities into, and receive
securities from, the series in connection with the purchase and
redemption of Creation Units; and (e) certain registered management
investment companies and unit investment trusts outside of the same
group of investment companies as the series to acquire Fund Shares.
Applicants: Pax World Funds Trust II (``Trust''), Pax World Management
Corp. (``Advisor'') and ALPS Distributors, Inc. (``Distributor'').
DATES: Filing Dates: The application was filed on February 29, 2008,
and amended on May 8, 2008, November 17, 2008, May 8, 2009, and July 7,
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 August 12, 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, Securities and Exchange Commission, 100 F Street,
NE., Washington, DC 20549-1090; Applicants: Pax World Management Corp.
and Pax World Funds Trust II, 30 Penhallow Street, Suite 400,
Portsmouth, NH 03801; ALPS Distributors, Inc., 1290 Broadway, Suite
1100, Denver, CO 80203.
FOR FURTHER INFORMATION CONTACT: Laura J. Riegel, Senior Counsel at
(202) 551-6873, 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 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. The Trust is registered as an open-end management investment
company and is organized as a Massachusetts trust that will offer
multiple series. The Trust will initially offer Fund Shares of two
series (the ``Initial Funds''). Applicants may offer additional
registered open-end investment companies in the future as well as
additional series of the Trust and series of any existing or future
open-end
[[Page 37259]]
investment companies registered under the Act, which will be advised by
the Advisor or an entity controlling, controlled by, or under common
control with the Advisor (``Future Funds'' and together with the
Initial Funds, the ``Funds'').\1\
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\1\ All existing entities that intend to rely on the requested
order have been named as applicants. Any other existing or future
entity that subsequently relies on the order will comply with the
terms and conditions of the application.
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2. The Advisor will serve as the investment adviser to the Initial
Funds. The Advisor is registered as an investment adviser under the
Investment Advisers Act of 1940, as amended (the ``Advisers Act''). In
the future, the Advisor may enter into sub-advisory agreements with one
or more additional investment advisers to act as sub-advisors to
particular Funds (``Sub-Advisors''). Each Sub-Advisor will be
registered under the Advisers Act. The Distributor is a broker-dealer
registered under the Securities Exchange Act of 1934 (the ``Exchange
Act'') and will act as the principal underwriter and distributor for
the Creation Units of Fund Shares. The Distributor is not affiliated
with the Advisor or any Sub-Advisor.
3. Each Fund will hold certain equity securities (``Portfolio
Securities'') and financial instruments selected to correspond, before
fees and expenses, generally to the price and yield performance of a
specified equity securities index (each, an ``Underlying Index'' and
collectively, ``Underlying Indices'').\2\ Certain of the Underlying
Indices are composed of equity securities of domestic issuers and non-
domestic issuers meeting the requirements for trading in U.S. markets
(``Domestic Indices''). Other Underlying Indices include equity
securities trading in non-U.S. markets or a combination of such
securities with domestic equity securities (collectively ``Foreign
Indices''). Funds which track Domestic Indices are referred to as
``Domestic Funds'' and Funds which track Foreign Indices are referred
to as ``Foreign Funds.'' No entity that compiles, creates, sponsors or
maintains an Underlying Index (``Index Provider'') is or will be an
affiliated person, as defined in section 2(a)(3) of the Act, or an
affiliated person of an affiliated person, of the Trust or a Fund, of
the Advisor, of any Sub-Advisor to or promoter of a Fund, or of the
Distributor.\3\
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\2\ The Underlying Indices for the Initial Funds are KLD Europe
Asia Pacific Sustainability \SM\ Index and KLD North America
Sustainability \SM\ Index.
\3\ The Index Provider to the Initial Funds is KLD Research &
Analytics, Inc.
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4. The investment objective of each Fund will be to provide
investment results that correspond, before fees and expenses, generally
to the price and yield performance of its Underlying Index.\4\ The
value of a Foreign Index and the value of a Domestic Index will be
disseminated every 15 seconds, throughout the trading day. A Fund will
utilize either a replication or representative sampling strategy which
will be disclosed with regard to each Fund in its statutory prospectus
(``Prospectus'').\5\ A Fund using a replication strategy will invest in
the Component Securities in its Underlying Index in approximately the
same proportions as in the Underlying Index. In certain circumstances,
such as when there are practical difficulties or substantial costs
involved in holding every security in an Underlying Index or when a
Component Security is less liquid, illiquid or unavailable, a Fund may
use a representative sampling strategy pursuant to which it will invest
in some, but not all of the Component Securities of its Underlying
Index.\6\ Applicants anticipate that a Fund that utilizes a
representative sampling strategy will not track the performance of its
Underlying Index with the same degree of accuracy as an investment
vehicle that invests in every Component Security of the Underlying
Index with the same weighting as the Underlying Index. Applicants
expect that each Fund will have a tracking error relative to the
performance of its Underlying Index of less than 5 percent.
---------------------------------------------------------------------------
\4\ Applicants represent that each Fund will invest at least 80%
of its total assets in the component securities that comprise its
Underlying Index (``Component Securities'') or, in the case of
Foreign Funds, Component Securities and depositary receipts
representing such securities. ``Depositary Receipts'' will typically
be American Depositary Receipts, but also include Global Depositary
Receipts and European Depositary Receipts. Each Fund also may invest
up to 20% of its assets in certain futures, options and swap
contracts, cash and cash equivalents, as well as in stocks not
included in its Underlying Index, but which the Advisor or Sub-
Advisor believes will help the Fund track its Underlying Index.
\5\ All representations and conditions contained in the
application that require a Fund to disclose particular information
in the Fund's Prospectus and/or annual report shall be effective
with respect to the Fund until the time that the Fund complies with
the disclosure requirements adopted by the Commission in Investment
Company Act Release No. 28584 (Jan. 13, 2009).
\6\ Under the representative sampling strategy, the Advisor or
the Sub-Advisor will seek to construct a Fund's portfolio so that
its market capitalization, industry weightings, fundamental
investment characteristics (such as return variability, earnings
valuation and yield) and liquidity measures perform like those of
the Underlying Index.
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5. The Trust will issue Creation Units in specified large
aggregations of Fund Shares (e.g., 25,000 Fund Shares for each Fund) as
will be clearly stated in the relevant Fund's Prospectus. Applicants
expect that the initial price of a Creation Unit will fall in the range
of $1,000,000 to $10,000,000. All orders to purchase Creation Units
must be placed with the Distributor, by or through a party that has
entered into an agreement with the Distributor (``Authorized
Participant''). The Distributor will be responsible for transmitting
the orders to the Funds. An Authorized Participant must be either: (a)
A broker-dealer or other participant in the continuous net settlement
system of the National Securities Clearing Corporation (``NSCC''), a
clearing agency registered with the Commission, or (b) a participant in
the Depository Trust Company (``DTC'', and such participant, ``DTC
Participant''). Fund Shares of each Fund generally will be sold in
Creation Units in exchange for an in-kind deposit by the purchaser of a
portfolio of securities designated by the Advisor or Sub-Advisor to
correspond generally to the price and yield performance of the relevant
Underlying Index (the ``Deposit Securities''), together with the
deposit of a specified cash payment (``Balancing Amount''). The
Balancing Amount is an amount equal to the difference between (a) the
net asset value (``NAV'') (per Creation Unit) of a Fund and (b) the
total aggregate market value (per Creation Unit) of the Deposit
Securities.\7\ Each Fund may permit a purchaser of Creation Units to
substitute cash in lieu of depositing some or all of the Deposit
Securities if the Advisor or Sub-Advisor believes such method would
reduce the Fund's transaction costs or enhance the Fund's operating
efficiency.\8\
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\7\ Each Fund will sell and redeem Creation Units only on a
``Business Day'' which includes any day that a Fund is required to
be open under section 22(e) of the Act. Each Business Day, prior to
the opening of trading on the Listing Exchange (defined below), the
list of names and amount of each security constituting the current
Deposit Securities and the Balancing Amount will be made available.
Any national securities exchange (as defined in section 2(a)(26) of
the Act) (``Exchange'') on which Fund Shares are primarily listed
(``Listing Exchange'') will disseminate, every 15 seconds during its
regular trading hours, through the facilities of the Consolidated
Tape Association, an amount per individual Fund Shares representing
the sum of the estimated Balancing Amount and the current value of
the Deposit Securities.
\8\ Applicants state that in some circumstances or in certain
countries, it may not be practicable or convenient, or permissible
under the laws of certain countries or the regulations of certain
foreign stock exchanges, for a Foreign Fund to operate exclusively
on an ``in-kind'' basis. Applicants also note that when a
substantial rebalancing of a Fund's portfolio is required, the
Advisor or Sub-Advisor might prefer to receive cash rather than
stocks so that the Fund may avoid transaction costs involved in
liquidating part of its portfolio to achieve the rebalancing.
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[[Page 37260]]
6. An investor purchasing or redeeming a Creation Unit from a Fund
will be charged a fee (``Transaction Fee'') to prevent the dilution of
the interests of the remaining shareholders resulting from costs in
connection with the purchase or redemption of Creation Units.\9\ The
maximum Transaction Fees relevant to each Fund and the method of
calculating such Transaction Fees will be fully disclosed in the
Prospectus of such Fund or statement of additional information
(``SAI''). The Distributor will be responsible for delivering the
Fund's Prospectus to those persons purchasing Creation Units, and for
maintaining records of both the orders placed with it and the
confirmations of acceptance furnished by it. In addition, the
Distributor will maintain a record of the instructions given to the
applicable Fund to implement the delivery of its Fund Shares.
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\9\ Where a Fund permits a purchaser to substitute cash in lieu
of depositing a portion of the requisite Deposit Securities, the
purchaser may be assessed a higher Transaction Fee to cover the cost
of purchasing such Deposit Securities, including operational
processing and brokerage costs, and part or all of the spread
between the expected bid and the offer side of the market relating
to such Deposit Securities.
---------------------------------------------------------------------------
7. Purchasers of Fund Shares in Creation Units may hold such Fund
Shares or may sell such Fund Shares into the secondary market. Fund
Shares will be listed and traded on an Exchange. It is expected that
one or more member firms of a Listing Exchange will be designated to
act as a specialist or a market maker and maintain a market for Fund
Shares trading on the Listing Exchange. Prices of Fund Shares trading
on an Exchange will be based on the current bid/ask market. Fund Shares
sold in the secondary market will be subject to customary brokerage
commissions and charges.
8. Applicants expect that purchasers of Creation Units will include
institutional investors and arbitrageurs (which could include
institutional investors). A specialist or market maker, in providing a
fair and orderly secondary market for the Fund Shares, also may
purchase Creation Units for use in its market-making activities.
Applicants expect that secondary market purchasers of Fund Shares will
include both institutional investors and retail investors.\10\
Applicants expect that the price at which Fund Shares trade will be
disciplined by arbitrage opportunities created by the option to
continually purchase or redeem Creation Units at their NAV, which
should ensure that Fund Shares will not trade at a material discount or
premium in relation to their NAV.
---------------------------------------------------------------------------
\10\ Fund Shares will be registered in book-entry form only. DTC
or its nominee will be the registered owner of all outstanding Fund
Shares. DTC or DTC Participants will maintain records reflecting
beneficial owners of Fund Shares.
---------------------------------------------------------------------------
9. Fund Shares will not be individually redeemable, and owners of
Fund Shares may acquire those Fund Shares from the Fund, or tender such
Fund Shares for redemption to the Fund, in Creation Units only. To
redeem, an investor will have to accumulate enough Fund Shares to
constitute a Creation Unit. Redemption orders must be placed by or
through an Authorized Participant. An investor redeeming a Creation
Unit generally will receive (a) Portfolio Securities designated to be
delivered for Creation Unit redemptions (``Fund Securities'') on the
date that the request for redemption is submitted \11\ and (b) a ``Cash
Redemption Payment,'' consisting of an amount calculated in the same
manner as the Balancing Amount, although the actual amount of the Cash
Redemption Payment may differ if the Fund Securities are not identical
to the Deposit Securities on that day. An investor may receive the cash
equivalent of a Fund Security in certain circumstances, such as if the
investor is constrained from effecting transactions in the security by
regulation or policy.
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\11\ As a general matter, the Deposit Securities and Fund
Securities will correspond pro rata to the Portfolio Securities held
by each Fund, but Fund Securities received on redemption may not
always be identical to Deposit Securities deposited in connection
with the purchase of Creation Units for the same day. The Funds will
comply with the Federal securities laws in accepting Deposit
Securities and satisfying redemptions with Fund Securities,
including that the Deposit Securities and Fund Securities are sold
in transactions that would be exempt from registration under the
Securities Act.
---------------------------------------------------------------------------
10. No Fund will be marketed or otherwise held out as a traditional
open-end investment company or a mutual fund. Instead, each Fund will
be marketed as an ``ETF,'' an ``investment company,'' a ``fund,'' or a
``trust.'' All marketing materials that describe the features or method
of obtaining, buying or selling Creation Units or Fund Shares traded on
an Exchange, or refer to redeemability, will prominently disclose that
Fund Shares are not individually redeemable and that the owners of Fund
Shares may purchase or redeem Fund Shares from the Fund in Creation
Units only. The same approach will be followed in the SAI, shareholder
reports and investor educational materials issued or circulated in
connection with the Fund Shares. The Funds will provide copies of their
annual and semi-annual shareholder reports to DTC Participants for
distribution to shareholders.
Applicants' Legal Analysis
1. Applicants request an order under section 6(c) of the Act for an
exemption from sections 2(a)(32), 5(a)(1), 22(d), and 22(e) of the Act
and rule 22c-1 under the Act, under sections 6(c) and 17(b) of the Act
for an exemption from sections 17(a)(1) and 17(a)(2) of the Act, and
under section 12(d)(1)(J) of the Act for an exemption from sections
12(d)(1)(A) and (B) of the Act.
2. Section 6(c) of the Act provides that the Commission may exempt
any person, security or transaction, or any class of persons,
securities or transactions, from any provision of the Act, if and to
the extent that such exemption is necessary or appropriate in the
public interest and consistent with the protection of investors and the
purposes fairly intended by the policy and provisions of the Act.
Section 17(b) of the Act authorizes the Commission to exempt a proposed
transaction from section 17(a) of the Act if evidence establishes that
the terms of the transaction, including the consideration to be paid or
received, are reasonable and fair and do not involve overreaching on
the part of any person concerned, and the proposed transaction is
consistent with the policies of the registered investment company and
the general provisions of the Act. Section 12(d)(1)(J) of the Act
provides that the Commission may exempt any person, security, or
transaction, or any class or classes of persons, securities or
transactions, from any provisions of section 12(d)(1) if the exemption
is consistent with the public interest and the protection of investors.
Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an ``open-end company'' as a
management investment company that is offering for sale or has
outstanding any redeemable security of which it is the issuer. Section
2(a)(32) of the Act defines a redeemable security as any security,
other than short-term paper, under the terms of which the owner, upon
its presentation to the issuer, is entitled to receive approximately
his proportionate share of the issuer's current net assets, or the cash
equivalent. Because Fund Shares will not be individually redeemable,
applicants request an order that would permit the Funds to register as
open-end management investment companies and issue Fund Shares that are
redeemable in Creation Units only. Applicants state that investors may
purchase Fund Shares in Creation Units
[[Page 37261]]
and redeem Creation Units from each Fund. Applicants state that because
Creation Units may always be purchased and redeemed at NAV, the market
price of the Fund Shares should not vary substantially from their NAV.
Section 22(d) of the Act and Rule 22c-1 Under the Act
4. Section 22(d) of the Act, among other things, prohibits a dealer
from selling a redeemable security, which is currently being offered to
the public by or through a principal underwriter, except at a current
public offering price described in the prospectus. Rule 22c-1 under the
Act generally requires that a dealer selling, redeeming or repurchasing
a redeemable security do so only at a price based on its NAV.
Applicants state that secondary market trading in Fund Shares will take
place at negotiated prices, not at a current offering price described
in a Fund's Prospectus, and not at a price based on NAV. Thus,
purchases and sales of Fund Shares in the secondary market will not
comply with section 22(d) of the Act and rule 22c-1 under the Act.
Applicants request an exemption under section 6(c) from these
provisions.
5. Applicants assert that the concerns sought to be addressed by
section 22(d) of the Act and rule 22c-1 under the Act with respect to
pricing are equally satisfied by the proposed method of pricing Fund
Shares. Applicants maintain that while there is little legislative
history regarding section 22(d), its provisions, as well as those of
rule 22c-1, appear to have been designed to (a) prevent dilution caused
by certain riskless-trading schemes by principal underwriters and
contract dealers, (b) prevent unjust discrimination or preferential
treatment among buyers, and (c) ensure an orderly distribution of
investment company shares by eliminating price competition from dealers
offering shares at less than the published sales price and repurchasing
shares at more than the published redemption price.
6. Applicants believe that none of these purposes will be thwarted
by permitting Fund Shares to trade in the secondary market at
negotiated prices. Applicants state that (a) secondary market trading
in Fund Shares does not involve a Fund as a party and will not result
in dilution of an investment in Fund Shares, and (b) to the extent
different prices exist during a given trading day, or from day to day,
such variances occur as a result of third-party market forces, such as
supply and demand. Therefore, applicants assert that secondary market
transactions in Fund Shares will not lead to discrimination or
preferential treatment among purchasers. Finally, applicants contend
that the proposed distribution system will be orderly because
competitive forces will ensure that the difference between the market
price of Fund Shares and their NAV remains narrow.
Section 22(e)
7. Section 22(e) of the Act generally prohibits a registered
investment company from suspending the right of redemption or
postponing the date of payment of redemption proceeds for more than
seven days after the tender of a security for redemption. Applicants
state that settlement of redemptions for the Foreign Funds is
contingent not only on the settlement cycle of the United States
market, but also on currently practicable delivery cycles in local
markets for underlying foreign securities held by the Foreign Funds.
Applicants state that local market delivery cycles for transferring
Fund Securities to redeeming investors, coupled with local market
holiday schedules, will, under certain circumstances, require a
delivery process longer than seven calendar days for Foreign Funds.
Applicants request relief under section 6(c) of the Act from section
22(e) to allow the Foreign Funds to pay redemption proceeds up to
fourteen calendar days after the tender of any Creation Units for
redemption. Except as disclosed in the relevant Foreign Fund's
Prospectus and/or SAI, applicants expect that each Foreign Fund will be
able to deliver redemption proceeds within seven days.\12\ With respect
to Future Funds that are Foreign Funds, applicants seek the same relief
from section 22(e) only to the extent that circumstances similar to
those described in the application exist.
---------------------------------------------------------------------------
\12\ Rule 15c6-1 under the Exchange Act requires that most
securities transactions be settled within three business days of the
trade. Applicants acknowledge that no relief obtained from the
requirements of section 22(e) will affect any obligations applicants
may have under rule 15c6-1.
---------------------------------------------------------------------------
8. Applicants state that section 22(e) was designed to prevent
unreasonable, undisclosed and unforeseen delays in the payment of
redemption proceeds. Applicants assert that the requested relief will
not lead to the problems that section 22(e) was designed to prevent.
Applicants state that the SAI will disclose those local holidays (over
the period of at least one year following the date of the SAI), if any,
that are expected to prevent the delivery of redemption proceeds in
seven calendar days, and the maximum number of days, up to fourteen
calendar days, needed to deliver the proceeds for the relevant Foreign
Fund. Applicants are not seeking relief from section 22(e) with respect
to Foreign Funds that do not effect creations and redemptions of
Creation Units in-kind.
Section 12(d)(1)
9. Section 12(d)(1)(A) of the Act, in relevant part, prohibits a
registered investment company from acquiring securities of an
investment company if such securities represent more than 3% of the
total outstanding voting stock of the acquired company, more than 5% of
the total assets of the acquiring company, or, together with the
securities of any other investment companies, more than 10% of the
total assets of the acquiring company. Section 12(d)(1)(B) of the Act
prohibits a registered open-end investment company, its principal
underwriter and any other broker-dealer from selling the investment
company's shares to another investment company if the sale will cause
the acquiring company to own more than 3% of the acquired company's
voting stock, or if the sale will cause more than 10% of the acquired
company's voting stock to be owned by investment companies generally.
10. Applicants request an exemption to permit management investment
companies (``Purchasing Management Companies'') and unit investment
trusts (``Purchasing Trusts'') registered under the Act that are not
sponsored or advised by the Advisor or any entity controlling,
controlled by, or under common control with the Advisor and are not
part of the same ``group of investment companies,'' as defined in
section 12(d)(1)(G)(ii) of the Act, as the Trust (collectively,
``Purchasing Funds'') to acquire shares of a Fund beyond the limits of
section 12(d)(1)(A). Purchasing Funds do not include the Funds. In
addition, applicants seek relief to permit a Fund or broker-dealer
(``Broker'') that is registered under the Exchange Act to sell Fund
Shares to a Purchasing Fund in excess of the limits of section
12(d)(1)(B).
11. Each Purchasing Management Company will be advised by an
investment adviser within the meaning of section 2(a)(20)(A) of the Act
(the ``Purchasing Fund Advisor'') and may be sub-advised by one or more
investment advisers within the meaning of section 2(a)(20)(B) of the
Act (each a ``Purchasing Fund Sub-Advisor''). Any investment adviser to
a Purchasing Management Company will be registered under the Advisers
Act. Each Purchasing Trust will be sponsored by a sponsor
(``Sponsor'').
[[Page 37262]]
12. Applicants submit that the proposed conditions to the requested
relief adequately address the concerns underlying the limits in
sections 12(d)(1)(A) and (B), which include concerns about undue
influence by a fund of funds over underlying funds, excessive layering
of fees and overly complex fund structures. Applicants believe that the
requested exemption is consistent with the public interest and the
protection of investors.
13. Applicants believe that neither the Purchasing Funds nor a
Purchasing Fund Affiliate would be able to exert undue influence over
the Funds.\13\ To limit the control that a Purchasing Fund may have
over a Fund, applicants propose a condition prohibiting a Purchasing
Fund Advisor or a Sponsor, any person controlling, controlled by, or
under common control with a Purchasing Fund Advisor or Sponsor, and any
investment company and any issuer that would be an investment company
but for sections 3(c)(1) or 3(c)(7) of the Act that is advised or
sponsored by a Purchasing Fund Advisor or Sponsor, or any person
controlling, controlled by, or under common control with a Purchasing
Fund Advisor or Sponsor (``Purchasing Fund's Advisory Group'') from
controlling (individually or in the aggregate) a Fund within the
meaning of section 2(a)(9) of the Act. The same prohibition would apply
to any Purchasing Fund Sub-Advisor, any person controlling, controlled
by or under common control with the Purchasing Fund Sub-Advisor, and
any investment company or issuer that would be an investment company
but for sections 3(c)(1) or 3(c)(7) of the Act (or portion of such
investment company or issuer) advised or sponsored by the Purchasing
Fund Sub-Advisor or any person controlling, controlled by or under
common control with the Purchasing Fund Sub-Advisor (``Purchasing
Fund's Sub-Advisory Group''). Applicants propose other conditions to
limit the potential for undue influence over the Funds, including that
no Purchasing Fund or Purchasing Fund Affiliate (except to the extent
it is acting in its capacity as an investment adviser to a Fund) will
cause a Fund to purchase a security in any offering of securities
during the existence of any underwriting or selling syndicate of which
a principal underwriter is an Underwriting Affiliate (``Affiliated
Underwriting''). An ``Underwriting Affiliate'' is a principal
underwriter in any underwriting or selling syndicate that is an
officer, director, member of an advisory board, Purchasing Fund
Advisor, Purchasing Fund Sub-Advisor, employee or Sponsor of a
Purchasing Fund, or a person of which any such officer, director,
member of an advisory board, Purchasing Fund Advisor, Purchasing Fund
Sub-Advisor, employee, or Sponsor is an affiliated person (except that
any person whose relationship to the Fund is covered by section 10(f)
of the Act is not an Underwriting Affiliate).
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\13\ A ``Purchasing Fund Affiliate'' is a Purchasing Fund
Advisor, Purchasing Fund Sub-Advisor, Sponsor, promoter, and
principal underwriter of a Purchasing Fund, and any person
controlling, controlled by, or under common control with any of
these entities. A ``Fund Affiliate'' is an investment adviser,
promoter, or principal underwriter of a Fund and any person
controlling, controlled by or under common control with any of these
entities.
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14. Applicants assert that the proposed conditions address any
concerns regarding excessive layering of fees. The board of directors
or trustees of any Purchasing Management Company, including a majority
of the directors or trustees who are not ``interested persons'' within
the meaning of section 2(a)(19) of the Act (``disinterested directors
or trustees''), will find that the advisory fees charged to the
Purchasing Management Company are based on services provided that will
be in addition to, rather than duplicative of, services provided under
the advisory contract(s) of any Fund in which the Purchasing Management
Company may invest. In addition, except as provided in condition 12, a
Purchasing Fund Advisor or a trustee (``Trustee'') or Sponsor of a
Purchasing Trust will, as applicable, waive fees otherwise payable to
it by the Purchasing Fund in an amount at least equal to any
compensation (including fees received pursuant to any plan adopted by a
Fund under rule 12b-1 under the Act) received by the Purchasing Fund
Advisor or Trustee or Sponsor or an affiliated person of the Purchasing
Fund Advisor, Trustee or Sponsor, from the Fund in connection with the
investment by the Purchasing Fund in the Fund. Applicants state that
any sales loads or service fees charged with respect to shares of a
Purchasing Fund will not exceed the limits applicable to a fund of
funds set forth in Conduct Rule 2830 of the National Association of
Securities Dealers (``NASD'').\14\
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\14\ Any references to NASD Conduct Rule 2830 include any
successor or replacement rule to NASD Conduct Rule 2830 that may be
adopted by the Financial Industry Regulatory Association.
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15. Applicants submit that the proposed arrangement will not create
an overly complex fund structure. Applicants note that no Fund may
acquire securities of any investment company or company relying on
sections 3(c)(1) or 3(c)(7) of the Act in excess of the limits
contained in section 12(d)(1)(A) of the Act, except to the extent
permitted by exemptive relief from the Commission permitting the Fund
to purchase shares of a money market fund for short-term cash
management purposes. To ensure that Purchasing Funds comply with the
terms and conditions of the requested relief from section 12(d)(1), any
Purchasing Fund that intends to invest in a Fund in reliance on the
requested order will enter into a Purchasing Fund Agreement between the
Fund and the Purchasing Fund requiring the Purchasing Fund to adhere to
the terms and conditions of the requested order. The Purchasing Fund
Agreement also will include an acknowledgement from the Purchasing Fund
that it may rely on the requested order only to invest in the Funds and
not in any other investment company.
16. Applicants also note that a Fund may choose to reject a direct
purchase of Fund Shares in Creation Units by a Purchasing Fund. To the
extent that a Purchasing Fund purchases Fund Shares in the secondary
market, a Fund would still retain its ability to reject initial
purchases of Fund Shares made in reliance on the requested order by
declining to enter into the Purchasing Fund Agreement prior to any
investment by a Purchasing Fund in excess of the limits of section
12(d)(1)(A).
Sections 17(a)(1) and (2) of the Act
17. Section 17(a) of the Act generally prohibits an affiliated
person of a registered investment company, or an affiliated person of
such a person (``Second-Tier Affiliate''), from selling any security to
or purchasing any security from the company. Section 2(a)(3) of the Act
defines ``affiliated person'' to include (a) any person directly or
indirectly owning, controlling or holding with power to vote 5% or more
of the outstanding voting securities of the other person, (b) any
person 5% or more of whose outstanding voting securities are directly
or indirectly owned, controlled or held with the power to vote by the
other person, and (c) any person directly or indirectly controlling,
controlled by or under common control with the other person. Section
2(a)(9) of the Act provides that a control relationship will be
presumed where one person owns more than 25% of another person's voting
securities.
[[Page 37263]]
18. Applicants request an exemption from section 17(a) of the Act
pursuant to sections 17(b) and 6(c) of the Act to permit persons to
effectuate in-kind purchases and redemptions with a Fund when they are
affiliated persons of the Fund or Second-Tier Affiliates solely by
virtue of one or more of the following: (a) Holding 5% or more, or in
excess of 25%, of the outstanding Fund Shares of one or more Funds; (b)
having an affiliation with a person with an ownership interest
described in (a); or (c) holding 5% or more, or more than 25%, of the
shares of one or more other registered investment companies (or series
thereof) advised by the Advisor.
19. Applicants assert that no useful purpose would be served by
prohibiting these types of affiliated persons from purchasing or
redeeming Creation Units through ``in-kind'' transactions. The deposit
procedures for both in-kind purchases and in-kind redemptions of
Creation Units will be the same for all purchases and redemptions.
Deposit Securities and Fund Securities will be valued in the same
manner as Portfolio Securities. Therefore, applicants state that in-
kind purchases and redemptions will afford no opportunity for the
specified affiliated persons, or Second-Tier Affiliates, of a Fund to
effect a transaction detrimental to other holders of Fund Shares.
Applicants also believe that in-kind purchases and redemptions will not
result in self-dealing or overreaching of the Fund.
20. Applicants also seek relief from section 17(a) to permit a Fund
that is an affiliated person of a Purchasing Fund to sell its Fund
Shares to and redeem its Fund Shares from a Purchasing Fund, and to
engage in the accompanying in-kind transactions with the Purchasing
Fund.\15\ Applicants state that the terms of the transactions are fair
and reasonable and do not involve overreaching. Applicants note that
any consideration paid by a Purchasing Fund for the purchase or
redemption of Fund Shares directly from a Fund will be based on the NAV
of the Fund.\16\ Applicants believe that any proposed transactions
directly between the Funds and Purchasing Funds will be consistent with
the policies of each Purchasing Fund. The purchase of Creation Units by
a Purchasing Fund directly from a Fund will be accomplished in
accordance with the investment restrictions of any such Purchasing Fund
and will be consistent with the investment policies set forth in the
Purchasing Fund's registration statement. The Purchasing Fund Agreement
will require any Purchasing Fund that purchases Creation Units directly
from a Fund to represent that the purchase of Creation Units from a
Fund by a Purchasing Fund will be accomplished in compliance with the
investment restrictions of the Purchasing Fund and will be consistent
with the investment policies set forth in the Purchasing Fund's
registration statement.
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\15\ Applicants acknowledge that the receipt of compensation by
(a) an affiliated person of a Purchasing Fund, or an affiliated
person of such person, for the purchase by the Purchasing Fund of
Fund Shares of a Fund or (b) an affiliated person of a Fund, or an
affiliated person of such person, for the sale by the Fund of its
Fund Shares to a Purchasing Fund, may be prohibited by section
17(e)(1) of the Act. The Purchasing Fund Agreement also will include
this acknowledgment.
\16\ Applicants believe that a Purchasing Fund will purchase
Fund Shares in the secondary market and will not purchase or redeem
Creation Units directly from a Fund. However, the requested relief
would apply to direct sales of Creation Units by a Fund to a
Purchasing Fund and redemptions of those Fund Shares.
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Applicants' Conditions
Applicants agree that any order of granting the requested relief
will be subject to the following conditions: \17\
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\17\ See note 5, supra.
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ETF Relief
1. As long as the Funds operate in reliance on the requested order,
Fund Shares will be listed on an Exchange.
2. Neither the Trust nor any Fund will be advertised or marketed as
an open-end investment company or a mutual fund. Each Fund's Prospectus
will prominently disclose that Fund Shares are not individually
redeemable shares and will disclose that the owners of Fund Shares may
acquire those Fund Shares from the Fund and tender those Fund Shares
for redemption to the Fund in Creation Units only. Any advertising
material that describes the purchase or sale of Creation Units or
refers to redeemability will prominently disclose that Fund Shares are
not individually redeemable, and that owners of Fund Shares may acquire
those Fund Shares from the Fund and tender those Fund Shares for
redemption to the Fund in Creation Units only.
3. The Web site maintained for each Fund, which will be publicly
accessible at no charge, will contain the following information, on a
per individual Fund Share basis, for each Fund: (a) The prior Business
Day's NAV and the mid-point of the bid-ask spread at the time of the
calculation of the NAV (``Bid/Ask Price''), and a calculation of the
premium or discount of the Bid/Ask Price at the time of calculation of
the NAV against such NAV; and (b) data in chart format displaying the
frequency distribution of discounts and premiums of the daily Bid/Ask
Price against the NAV, within appropriate ranges, for each of the four
previous calendar quarters.
4. The Prospectus and annual report for each Fund also will
include: (a) The information listed in condition 3(b), (i) in the case
of the Fund's Prospectus, for the most recently completed year (and the
most recently completed quarter or quarters, as applicable) and (ii) in
the case of the annual report, for the immediately preceding five
years, as applicable; and (b) the following data, calculated on a per
individual Fund Share basis for one, five and ten year periods (or life
of the Fund), (i) the cumulative total return and the average annual
total return based on NAV and Bid/Ask Price, and (ii) the cumulative
total return of the relevant Underlying Index.
5. Each Fund's Prospectus will clearly disclose that, for purposes
of the Act, Fund Shares are issued by the Fund, which is a registered
investment company, and that the acquisition of Fund Shares by
investment companies is subject to the restrictions of section 12(d)(1)
of the Act, except as permitted by an exemptive order that permits
registered investment companies to invest in a Fund beyond the limits
in section 12(d)(1), subject to certain terms and conditions, including
that the registered investment company enter into a Purchasing Fund
Agreement with the Fund regarding the terms of the investment.
6. The requested relief to permit ETF operations will expire on the
effective date of any Commission rule under the Act that provides
relief permitting the operation of index-based exchange-traded funds.
Section 12(d)(1) Relief
7. The members of a Purchasing Fund's Advisory Group will not
control (individually or in the aggregate) a Fund within the meaning of
section 2(a)(9) of the Act. The members of a Purchasing Fund's Sub-
Advisory Group will not control (individually or in the aggregate) a
Fund within the meaning of section 2(a)(9) of the Act. If as a result
of a decrease in the outstanding Fund Shares of a Fund, a Purchasing
Fund's Advisory Group or a Purchasing Fund's Sub-Advisory Group, each
in the aggregate, becomes a holder of more than 25 percent of the
outstanding Fund Shares of a Fund, it will vote its Fund Shares in the
same proportion as the vote of all other holders of the Fund Shares.
This condition does not apply to the Purchasing Fund's Sub-Advisory
Group with respect to a Fund for which the Purchasing Fund's Sub-
Advisor or a
[[Page 37264]]
person controlling, controlled by, or under common control with the
Purchasing Fund Sub-Advisor acts as the investment adviser within the
meaning of section 2(a)(20)(A) of the Act.
8. No Purchasing Fund or Purchasing Fund Affiliate will cause any
existing or potential investment by the Purchasing Fund in a Fund to
influence the terms of any services or transactions between the
Purchasing Fund or Purchasing Fund Affiliate and the Fund or a Fund
Affiliate.
9. The board of directors or trustees of a Purchasing Management
Company, including a majority of the disinterested directors or
trustees, will adopt procedures reasonably designed to ensure that the
Purchasing Fund Advisor and Purchasing Fund Sub-Advisor are conducting
the investment program of the Purchasing Management Company without
taking into account any consideration received by the Purchasing
Management Company or a Purchasing Fund Affiliate from a Fund or a Fund
Affiliate in connection with any services or transactions.
10. No Purchasing Fund or Purchasing Fund Affiliate (except to the
extent it is acting in its capacity as an investment adviser to a Fund)
will cause a Fund to purchase a security in any Affiliated
Underwriting.
11. Before investing in the Fund Shares of a Fund in excess of the
limits in section 12(d)(1)(A), each Purchasing Fund and the Fund will
execute a Purchasing Fund Agreement stating, without limitation, that
their boards of directors or trustees and their investment advisers or
Sponsors and Trustees, as applicable, understand the terms and
conditions of the order, and agree to fulfill their responsibilities
under the order. At the time of its investment in Fund Shares of a Fund
in excess of the limit in section 12(d)(1)(A)(i), a Purchasing Fund
will notify such Fund of the investment. At such time, the Purchasing
Fund will also transmit to the Fund a list of names of each Purchasing
Fund Affiliate and Underwriting Affiliate. The Purchasing Fund will
notify the Fund of any changes to the list of the names as soon as
reasonably practicable after a change occurs. The relevant Fund and the
Purchasing Fund will maintain and preserve a copy of the order, the
Purchasing Fund Agreement, and the list with any updated information
for the duration of the investment and for a period of not less than
six years thereafter, the first two years in an easily accessible
place.
12. The Purchasing Fund Advisor, Trustee or Sponsor, as applicable,
will waive fees otherwise payable to it by the Purchasing Fund in an
amount at least equal to any compensation (including fees received
under any plan adopted by a Fund under rule 12b-1 under the Act)
received from a Fund by the Purchasing Fund Advisor, Trustee or
Sponsor, or an affiliated person of the Purchasing Fund Advisor,
Trustee or Sponsor, other than any advisory fees paid to the Purchasing
Fund Advisor, Trustee or Sponsor, or its affiliated person by a Fund,
in connection with the investment by the Purchasing Fund in the Fund.
Any Purchasing Fund Sub-Advisor will waive fees otherwise payable to
the Purchasing Fund Sub-Advisor, directly or indirectly, by the
Purchasing Management Company in an amount at least equal to any
compensation received from a Fund by the Purchasing Fund Sub-Advisor,
or an affiliated person of the Purchasing Fund Sub-Advisor, other than
any advisory fees paid to the Purchasing Fund Sub-Advisor or its
affiliated person by a Fund, in connection with any investment by the
Purchasing Management Company in a Fund made at the direction of the
Purchasing Fund Sub-Advisor. In the event that the Purchasing Fund Sub-
Advisor waives fees, the benefit of the waiver will be passed through
to the Purchasing Management Company.
13. Any sales charges and/or service fees charged with respect to
shares of a Purchasing Fund will not exceed the limits applicable to a
fund of funds as set forth in NASD Conduct Rule 2830.
14. Once an investment by a Purchasing Fund in the Fund Shares of a
Fund exceeds the limit in section 12(d)(1)(A)(i) of the Act, the Board
of a Fund, including a majority of the directors or trustees that are
not ``interested persons'' within the meaning of section 2(a)(19) of
the Act (``disinterested Board members''), will determine that any
consideration paid by the Fund to a Purchasing Fund or Purchasing Fund
Affiliate in connection with any services or transactions: (a) Is fair
and reasonable in relation to the nature and quality of the services
and benefits received by the Fund; (b) is within the range of
consideration that the Fund would be required to pay to another
unaffiliated entity in connection with the same services or
transactions; and (c) does not involve overreaching on the part of any
person concerned. This condition does not apply with respect to any
services or transactions between a Fund and its investment adviser(s),
or any person controlling, controlled by, or under common control with
such investment adviser(s).
15. The Board, including a majority of the disinterested Board
members, will adopt procedures reasonably designed to monitor any
purchases of securities by a Fund in an Affiliated Underwriting once an
investment by the Purchasing Fund in the securities of the Fund exceeds
the limit of section 12(d)(1)(A)(i) of the Act, including any purchases
made directly from an Underwriting Affiliate. The Board will review
these purchases periodically, but no less frequently than annually, to
determine whether the purchases were influenced by the investment by
the Purchasing Fund in a Fund. The Board will consider, among other
things: (a) Whether the purchases were consistent with the investment
objectives and policies of the Fund; (b) how the performance of
securities purchased in an Affiliated Underwriting compares to the
performance of comparable securities purchased during a comparable
period of time in underwritings other than Affiliated Underwritings or
to a benchmark such as a comparable market index; and (c) whether the
amount of securities purchased by a Fund in Affiliated Underwritings
and the amount purchased directly from an Underwriting Affiliate have
changed significantly from prior years. The Board will take any
appropriate actions based on its review, including, if appropriate, the
institution of procedures designed to assure that purchases of
securities in Affiliated Underwritings are in the best interest of
shareholders of the Fund.
16. Each Fund will maintain and preserve permanently in an easily
accessible place a written copy of the procedures described in the
preceding condition, and any modifications to such procedures, and will
maintain and preserve for a period not less than six years from the end
of the fiscal year in which any purchase in an Affiliated Underwriting
occurred, the first two years in an easily accessible place, a written
record of each purchase of securities in Affiliated Underwritings, once
an investment by a Purchasing Fund in the Fund Shares of the Fund
exceeds the limit of section 12(d)(1)(A)(i) of the Act, setting forth
from whom the securities were acquired, the identity of the
underwriting syndicate's members, the terms of the purchase, and the
information or materials upon which the Board's determinations were
made.
17. Before approving any advisory contract under section 15 of the
Act, the board of directors or trustees of each Purchasing Management
Company, including a majority of the disinterested
[[Page 37265]]
directors or trustees, will find that the advisory fees charged under
such contract are based on services provided that will be in addition
to, rather than duplicative of, the services provided under the
advisory contract(s) of any Fund in which the Purchasing Management
Company may invest. These findings and their basis will be recorded
fully in the minute books of the appropriate Purchasing Management
Company.
18. No Fund will acquire securities of any investment company or
companies relying on sections 3(c)(1) or 3(c)(7) of the Act in excess
of the limits contained in section 12(d)(1)(A) of the Act, except to
the extent permitted by exemptive relief from the Commission permitting
the Fund to purchase shares of a money market fund for short-term cash
management purposes.
For the Commission, by the Division of Investment Management,
under delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9-17884 Filed 7-27-09; 8:45 am]
BILLING CODE 8010-01-P