Compagnie de Financement Foncier; Notice of Application, 37256-37258 [E9-17892]
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37256
Federal Register / Vol. 74, No. 143 / Tuesday, July 28, 2009 / Notices
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Rule 17f–1(b), OMB Control No. 3235–
0032, SEC File No. 270–28.
Notice is hereby given that pursuant
to the Paperwork Reduction Act of 1995
(44 U.S.C. 3501 et seq.) the Securities
and Exchange Commission
(‘‘Commission’’) is soliciting comments
on the existing collection of information
provided for in the following rule: Rule
17f–1(b)—Requirements for reporting
and inquiry with respect to missing,
lost, counterfeit, or stolen securities (17
CFR 240.17f–1(b)) under the Securities
Exchange Act of 1934 (15 U.S.C. 78a et
seq.) (the ‘‘Exchange Act’’). The
Commission plans to submit this
existing collection of information to the
Office of Management and Budget
(‘‘OMB’’) for extension and approval.
Rule 17f–1(b) (17 CFR 240.17f–1(b))
under the Exchange Act requires
approximately 26,000 entities in the
securities industry to register in the Lost
and Stolen Securities Program
(‘‘Program’’). Registration fulfills a
statutory requirement that entities
report and inquire about missing, lost,
counterfeit, or stolen securities.
Registration also allows entities in the
securities industry to gain access to a
confidential database that stores
information for the Program.
We estimate that 1,000 new entities
will register in the Program each year.
The staff estimates that the average
number of hours necessary to comply
with the Rule 17f–1(b) is one-half hour.
The total burden is therefore 500 hours
(1,000 times one-half) annually for all
participants.
Written comments are invited on: (a)
Whether the proposed collection of
information is necessary for the proper
performance of the functions of the
Commission, including whether the
information shall have practical utility;
(b) the accuracy of the Commission’s
estimates of the burden of the proposed
collection of information; (c) ways to
enhance the quality, utility, and clarity
of the information to be collected; and
(d) ways to minimize the burden of the
collection of information on
respondents, including through the use
of automated collection techniques or
other forms of information technology.
Consideration will be given to
comments and suggestions submitted in
writing within 60 days of this
publication.
Comments should be directed to
Charles Boucher, Director/Chief
Information Officer, Securities and
Exchange Commission, c/o Shirley
Martinson, 6432 General Green Way,
Alexandria, Virginia 22312 or send an email to:
PRA_Mailbox@sec.gov.
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Dated: July 21, 2009.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9–17859 Filed 7–27–09; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
28835; 812–13573]
Compagnie de Financement Foncier;
Notice of Application
July 22, 2009.
AGENCY: Securities and Exchange
Commission (the ‘‘Commission’’).
ACTION: Notice of application for an
order under section 6(c) of the
Investment Company Act of 1940
(‘‘Act’’) for an exemption from all
provisions of the Act.
SUMMARY OF APPLICATION: Applicant
Compagnie de Financement Foncier
(‘‘CFF’’), a specialized credit institution,
requests an order exempting it from all
provisions of the Act in connection with
the offer and sale of its securities in the
United States.
FILING DATES: The application was filed
on September 17, 2008, and amended
on June 22, 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, U.S. Securities
and Exchange Commission, 100 F
Street, NE., Washington, DC 20549–
1090. Applicant, c/o John D. Watson, Jr.,
Latham & Watkins LLP, 53, quai
d’Orsay, 75007 Paris, France.
FOR FURTHER INFORMATION CONTACT:
Bruce R. MacNeil, Senior Counsel, at
(202) 551–6817, or Janet M. Grossnickle,
Assistant Director, at (202) 551–6821
(Division of Investment Management,
Office of Investment Company
Regulation).
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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.
Applicant’s Representations:
1. CFF, a limited liability company
organized under the laws of the
´ ´
Republic of France, is a Societe de
´
Credit Foncier (‘‘SCF’’), a specialized
credit institution authorized and
licensed under French law and
regulated and supervised by French
banking authorities. Applicant
represents that the sole permitted
business of a SCF is to provide
financing to the housing and public
sectors in France and a limited number
of other developed countries. Applicant
further states that, subject to a
comprehensive statutory and regulatory
framework, a SCF conducts this
business by (a) making or acquiring
mortgage loans (which include loans
incurred to acquire real property and
secured by a mortgage or, in certain
limited circumstances, other highquality credit support); (b) extending
financing to public sector entities by
making public sector loans or acquiring
public sector obligations; and (c)
acquiring debt securities backed by
mortgage loans or public sector
obligations (collectively, ‘‘Eligible
Assets’’). Equity securities or other
equity interests are not treated as
Eligible Assets and are not permitted to
be held by a SCF.
2. As a SCF, CFF states that it finances
its business through the issuance of
covered bonds, a type of debt security
governed by French law. French
covered bonds, known as obligations
`
foncieres, and the SCFs that issue them
are governed by the Savings and
Financial Security Act of 1999 (the
‘‘SFSA Law’’).1 Applicant states that
under the SFSA law, only credit
institutions licensed and regulated in
France as a SCF may issue obligations
`
foncieres. However, CFF is not
permitted under the SFSA Law to
accept demand deposits and may only
carry out the specific banking activities
that are consistent with its purpose as
a SCF, which is to acquire Eligible
Assets and to issue covered bonds (or
SUPPLEMENTARY INFORMATION:
1 Applicant represents that the French public law
`
regime governing obligations foncieres, in which
the issuing entity is strictly regulated by banking
authorities as a credit institution and in which the
priority of investors’ claims is guaranteed as a
matter of law, differs significantly from the private
contractually-based covered bond regimes found in
certain other countries (such as the United States).
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other debt securities) in order to finance
the acquistion of Eligible Assets.
3. CFF is a direct, wholly-owned
´
subsidiary of Credit Foncier de France
(‘‘Credit Foncier’’), which is licensed
and regulated under French law as a
commercial bank. Applicant states that
Credit Foncier was the first French
issuer of covered bonds and an active
participant in the covered bond market
until 1999, when in connection with the
adoption of the SFSA Law, Credit
Foncier formed CFF and transferred its
covered bond business to it. CFF states
that since its formation, it has issued
over $147.5 billion in covered bonds in
the international capital markets.
4. Applicant represents that the SFSA
Law gives the holders of CFF’s covered
bonds the benefit of a statutory priority
in right of payment (the ‘‘Privilege’’) on
all assets and cash flows of CFF.
According to CFF, the Privilege
constitutes a legal safeguard for holders
of covered bonds in that no creditors of
a SCF, including the French State, can
claim cash flows generated by Eligible
Assets until the SCF’s obligations in
respect of its covered bonds are
discharged in full. The SFSA Law
establishes a principle of overcollateralization, which provides that
the total amount of the assets of a SCF
must exceed the global amount of
liabilities benefiting from the Privilege
at all times, thereby limiting risk
exposure. CFF states that in addition to
the Privilege, as an additional investor
protection safeguard, the SFSA Law
creates important exceptions to the
claw-back rules that would otherwise
apply under the French insolvency
laws.
5. CFF states that, as a licensed credit
institution, it is subject to extensive
legal and regulatory obligations under
French banking regulations and is
supervised by the French Banking
Commission (‘‘Banking Commission’’), a
body within the Banque de France. CFF
further states that it is not only subject
to the general regulatory supervision
applicable to all licensed credit
institutions, including banks, but also to
additional control mechanisms that are
specific to its status as a SCF. CFF states
that it is subject to continuous off-site
monitoring and routine on-site
inspections by the Banking
Commission, which consists of
examination of CFF’s prudential and
accounting records, regular contacts
with CFF’s senior management and
statutory auditors, and ascertainment
that the information disclosed by CFF
accurately reflects its financial
condition. In addition, CFF states that as
an issuer of listed debt securities sold to
the general public in France, it is also
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subject to the rules and regulations of
the Financial Markets Authority (the
‘‘AMF’’), the French financial market
regulator responsible for ensuring
investors’ protection.
6. Applicant represents that under
French banking regulations, CFF must
appoint a specific controller (the
‘‘Specific Controller’’) as a result of its
status as a SCF. The Specific Controller
is appointed by CFF’s management
board with the approval of the Banking
Commission. CFF states that the
Specific Controller monitors compliance
with the legal and regulatory provisions
applicable to SCFs, monitors CFF’s
management of its assets and liabilities
and ensures that CFF only undertakes
transactions that are consistent with its
specific purpose as a SCF. The Specific
Controller verifies that the assets held
by CFF are Eligible Assets and certifies
compliance with collateralization
requirements.
7. CFF states that it is also subject to
special internal control procedures. The
SFSA Law requires that the asset and
liabilities of a SCF be managed by a
credit institution pursuant to servicing
agreements. Because of this legal
requirement, CFF relies on Credit
Foncier to operate its business. Credit
Foncier, a licensed bank, administers
CFF in accordance with permanent and
periodic control procedures that are
centralized at the level of Credit
Foncier.
8. CFF proposes to offer and sell in
the United States its covered bonds and
other debt securities that benefit from
the Privilege as described in the
application (collectively, the ‘‘Privileged
Debt Securities’’). CFF states that any
such offer and sale shall occur only in
transactions exempt from registration
under the Securities Act of 1933 (‘‘1933
Act’’), including transactions effected as
traditional private placements with
institutional investors or in transactions
in which the securities may be resold to
‘‘qualified institutional buyers’’ as
contemplated by rule 144A under the
1933 Act. CFF believes that investors in
its Privileged Debt Securities would
have the protections provided by the
Privilege, the protections provided by
the French government’s regulation of
CFF and its operations, and the
protections of the laws in the United
States applicable to securities offered
and sold to qualified institutional
buyers and other institutional investors,
as well as the antifraud provisions of the
Securities Exchange Act of 1934. CFF
intends to use the proceeds from any
sale of its securities in the United States
as an additional source of financing for
the housing and public sectors in France
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37257
and other developed countries,
including the United States.
Applicant’s Legal Analysis
1. Section 3(a)(1)(C) of the Act defines
an investment company to include any
issuer engaged in the business of
investing, reinvesting, owning, holding
or trading in securities, and that owns
or proposes to acquire investment
securities having a value exceeding 40%
of the issuer’s total assets. Section
3(a)(2) of the Act defines ‘‘investment
securities’’ to include all securities
except Government securities, securities
issued by employees’ securities
companies, and securities issued by
majority-owned subsidiaries of the
owner which (a) are not investment
companies, and (b) are not relying on
the exclusions from the definition of
investment company in section 3(c)(1)
or 3(c)(7) of the Act.
2. CFF states that a majority of its
assets consist of loans, debt securities
and cash equivalents, and that these
assets could be considered ‘‘investment
securities’’ within the meaning of
section 3(a)(2) of the Act. As a result,
CFF states that it could be deemed to be
an ‘‘investment company’’ under section
3(a)(1)(C) of the Act.
3. Section 6(c) of the Act provides, in
relevant part, that the Commission, by
order upon application, may
conditionally or unconditionally
exempt any person, security, or
transaction from any provision of the
Act, if and to the extent 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.
4. Rule 3a–6 under the Act excludes
foreign banks from the definition of an
investment company under the Act. A
‘‘foreign bank’’ is defined in the rule to
include a banking institution ‘‘engaged
substantially in commercial banking
activity’’ which in turn is defined to
include ‘‘extending commercial and
other types of credit, and accepting
demand and other types of deposits.’’
CFF states that while a large part of its
business activity is to extend
commercial credit such as mortgage
loans and loans to public sector entities
and it is subject to extensive supervision
and regulation by French banking
authorities, it is not considered a
comercial bank under French law.
Further, Applicant states that as a credit
institution licensed as a SCF, it cannot
accept ‘‘demand and other types of
deposits.’’ Therefore, CFF states that it
is not eligible for the exclusion provided
by rule 3a-6 under the Act.
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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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Fmt 4703
Sfmt 4703
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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Agencies
[Federal Register Volume 74, Number 143 (Tuesday, July 28, 2009)]
[Notices]
[Pages 37256-37258]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-17892]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 28835; 812-13573]
Compagnie de Financement Foncier; Notice of Application
July 22, 2009.
AGENCY: Securities and Exchange Commission (the ``Commission'').
ACTION: Notice of application for an order under section 6(c) of the
Investment Company Act of 1940 (``Act'') for an exemption from all
provisions of the Act.
-----------------------------------------------------------------------
Summary of Application: Applicant Compagnie de Financement Foncier
(``CFF''), a specialized credit institution, requests an order
exempting it from all provisions of the Act in connection with the
offer and sale of its securities in the United States.
Filing Dates: The application was filed on September 17, 2008, and
amended on June 22, 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, U.S. Securities and Exchange Commission, 100 F
Street, NE., Washington, DC 20549-1090. Applicant, c/o John D. Watson,
Jr., Latham & Watkins LLP, 53, quai d'Orsay, 75007 Paris, France.
FOR FURTHER INFORMATION CONTACT: Bruce R. MacNeil, Senior Counsel, at
(202) 551-6817, or Janet M. Grossnickle, Assistant Director, at (202)
551-6821 (Division of Investment Management, Office of Investment
Company Regulation).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained 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.
Applicant's Representations:
1. CFF, a limited liability company organized under the laws of the
Republic of France, is a Soci[eacute]t[eacute] de Cr[eacute]dit Foncier
(``SCF''), a specialized credit institution authorized and licensed
under French law and regulated and supervised by French banking
authorities. Applicant represents that the sole permitted business of a
SCF is to provide financing to the housing and public sectors in France
and a limited number of other developed countries. Applicant further
states that, subject to a comprehensive statutory and regulatory
framework, a SCF conducts this business by (a) making or acquiring
mortgage loans (which include loans incurred to acquire real property
and secured by a mortgage or, in certain limited circumstances, other
high-quality credit support); (b) extending financing to public sector
entities by making public sector loans or acquiring public sector
obligations; and (c) acquiring debt securities backed by mortgage loans
or public sector obligations (collectively, ``Eligible Assets'').
Equity securities or other equity interests are not treated as Eligible
Assets and are not permitted to be held by a SCF.
2. As a SCF, CFF states that it finances its business through the
issuance of covered bonds, a type of debt security governed by French
law. French covered bonds, known as obligations fonci[egrave]res, and
the SCFs that issue them are governed by the Savings and Financial
Security Act of 1999 (the ``SFSA Law'').\1\ Applicant states that under
the SFSA law, only credit institutions licensed and regulated in France
as a SCF may issue obligations fonci[egrave]res. However, CFF is not
permitted under the SFSA Law to accept demand deposits and may only
carry out the specific banking activities that are consistent with its
purpose as a SCF, which is to acquire Eligible Assets and to issue
covered bonds (or
[[Page 37257]]
other debt securities) in order to finance the acquistion of Eligible
Assets.
---------------------------------------------------------------------------
\1\ Applicant represents that the French public law regime
governing obligations fonci[egrave]res, in which the issuing entity
is strictly regulated by banking authorities as a credit institution
and in which the priority of investors' claims is guaranteed as a
matter of law, differs significantly from the private contractually-
based covered bond regimes found in certain other countries (such as
the United States).
---------------------------------------------------------------------------
3. CFF is a direct, wholly-owned subsidiary of Cr[eacute]dit
Foncier de France (``Credit Foncier''), which is licensed and regulated
under French law as a commercial bank. Applicant states that Credit
Foncier was the first French issuer of covered bonds and an active
participant in the covered bond market until 1999, when in connection
with the adoption of the SFSA Law, Credit Foncier formed CFF and
transferred its covered bond business to it. CFF states that since its
formation, it has issued over $147.5 billion in covered bonds in the
international capital markets.
4. Applicant represents that the SFSA Law gives the holders of
CFF's covered bonds the benefit of a statutory priority in right of
payment (the ``Privilege'') on all assets and cash flows of CFF.
According to CFF, the Privilege constitutes a legal safeguard for
holders of covered bonds in that no creditors of a SCF, including the
French State, can claim cash flows generated by Eligible Assets until
the SCF's obligations in respect of its covered bonds are discharged in
full. The SFSA Law establishes a principle of over-collateralization,
which provides that the total amount of the assets of a SCF must exceed
the global amount of liabilities benefiting from the Privilege at all
times, thereby limiting risk exposure. CFF states that in addition to
the Privilege, as an additional investor protection safeguard, the SFSA
Law creates important exceptions to the claw-back rules that would
otherwise apply under the French insolvency laws.
5. CFF states that, as a licensed credit institution, it is subject
to extensive legal and regulatory obligations under French banking
regulations and is supervised by the French Banking Commission
(``Banking Commission''), a body within the Banque de France. CFF
further states that it is not only subject to the general regulatory
supervision applicable to all licensed credit institutions, including
banks, but also to additional control mechanisms that are specific to
its status as a SCF. CFF states that it is subject to continuous off-
site monitoring and routine on-site inspections by the Banking
Commission, which consists of examination of CFF's prudential and
accounting records, regular contacts with CFF's senior management and
statutory auditors, and ascertainment that the information disclosed by
CFF accurately reflects its financial condition. In addition, CFF
states that as an issuer of listed debt securities sold to the general
public in France, it is also subject to the rules and regulations of
the Financial Markets Authority (the ``AMF''), the French financial
market regulator responsible for ensuring investors' protection.
6. Applicant represents that under French banking regulations, CFF
must appoint a specific controller (the ``Specific Controller'') as a
result of its status as a SCF. The Specific Controller is appointed by
CFF's management board with the approval of the Banking Commission. CFF
states that the Specific Controller monitors compliance with the legal
and regulatory provisions applicable to SCFs, monitors CFF's management
of its assets and liabilities and ensures that CFF only undertakes
transactions that are consistent with its specific purpose as a SCF.
The Specific Controller verifies that the assets held by CFF are
Eligible Assets and certifies compliance with collateralization
requirements.
7. CFF states that it is also subject to special internal control
procedures. The SFSA Law requires that the asset and liabilities of a
SCF be managed by a credit institution pursuant to servicing
agreements. Because of this legal requirement, CFF relies on Credit
Foncier to operate its business. Credit Foncier, a licensed bank,
administers CFF in accordance with permanent and periodic control
procedures that are centralized at the level of Credit Foncier.
8. CFF proposes to offer and sell in the United States its covered
bonds and other debt securities that benefit from the Privilege as
described in the application (collectively, the ``Privileged Debt
Securities''). CFF states that any such offer and sale shall occur only
in transactions exempt from registration under the Securities Act of
1933 (``1933 Act''), including transactions effected as traditional
private placements with institutional investors or in transactions in
which the securities may be resold to ``qualified institutional
buyers'' as contemplated by rule 144A under the 1933 Act. CFF believes
that investors in its Privileged Debt Securities would have the
protections provided by the Privilege, the protections provided by the
French government's regulation of CFF and its operations, and the
protections of the laws in the United States applicable to securities
offered and sold to qualified institutional buyers and other
institutional investors, as well as the antifraud provisions of the
Securities Exchange Act of 1934. CFF intends to use the proceeds from
any sale of its securities in the United States as an additional source
of financing for the housing and public sectors in France and other
developed countries, including the United States.
Applicant's Legal Analysis
1. Section 3(a)(1)(C) of the Act defines an investment company to
include any issuer engaged in the business of investing, reinvesting,
owning, holding or trading in securities, and that owns or proposes to
acquire investment securities having a value exceeding 40% of the
issuer's total assets. Section 3(a)(2) of the Act defines ``investment
securities'' to include all securities except Government securities,
securities issued by employees' securities companies, and securities
issued by majority-owned subsidiaries of the owner which (a) are not
investment companies, and (b) are not relying on the exclusions from
the definition of investment company in section 3(c)(1) or 3(c)(7) of
the Act.
2. CFF states that a majority of its assets consist of loans, debt
securities and cash equivalents, and that these assets could be
considered ``investment securities'' within the meaning of section
3(a)(2) of the Act. As a result, CFF states that it could be deemed to
be an ``investment company'' under section 3(a)(1)(C) of the Act.
3. Section 6(c) of the Act provides, in relevant part, that the
Commission, by order upon application, may conditionally or
unconditionally exempt any person, security, or transaction from any
provision of the Act, if and to the extent 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.
4. Rule 3a-6 under the Act excludes foreign banks from the
definition of an investment company under the Act. A ``foreign bank''
is defined in the rule to include a banking institution ``engaged
substantially in commercial banking activity'' which in turn is defined
to include ``extending commercial and other types of credit, and
accepting demand and other types of deposits.'' CFF states that while a
large part of its business activity is to extend commercial credit such
as mortgage loans and loans to public sector entities and it is subject
to extensive supervision and regulation by French banking authorities,
it is not considered a comercial bank under French law. Further,
Applicant states that as a credit institution licensed as a SCF, it
cannot accept ``demand and other types of deposits.'' Therefore, CFF
states that it is not eligible for the exclusion provided by rule 3a-6
under the Act.
[[Page 37258]]
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 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