Members Mutual Funds, et al.; Notice of Application, 62610-62612 [E9-28560]
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62610
Federal Register / Vol. 74, No. 228 / Monday, November 30, 2009 / Notices
amount of $1,000,000 and further issue
a Confirmatory Order modifying FPL’s
operating licenses DPR–31 and DPR–41
for the Turkey Point Nuclear Generating
Units 3 and 4, Docket Nos. 50–250 and
50–251. The Order would include
requiring an independent assessment of
FPL’s Employee Concerns Program and
management implementation of the
program in addition to providing
training on the program and
advertisement of the program to the
employees.
As the basis for this request, the
petitioner restates the concerns
identified in FPL’s self-assessment of
their Employee Concerns Program
(ECP):
WReier-Aviles on DSKGBLS3C1PROD with NOTICES
Management attention to the ECP did not
meet expectations and management’s
awareness of the ECP was superficial and
program values had not been emphasized
with employees.
The ECP facility was of low quality and did
not give the impression of being important to
management.
There is a perception problem with the
ECP in the areas of confidentiality and
potential retribution. The perception remains
as evidenced by surveys, interviews and the
high percentage of anonymous concerns.
Previous surveys and assessments identified
this perception, but little or no progress has
been made in reversing this perception.
The ECP was most frequently thought to be
a mechanism to use in addition to discussing
concerns with the NRC and not as the first
alternative to the Correction Action Program
‘‘CAP.’’
While meeting most of the program
requirements and having a technically
qualified individual in the ECP coordinator
position, the overall effectiveness of the
program was marginal.
The ECP representative has very low
visibility or recognition in the plant and has
not been integrated into the management
team or plant activities.
The large percentage of concerns submitted
anonymously hampers feedback to concerned
individuals. The written feedback process to
non-anonymous individuals is impersonal
and lacks feedback mechanisms for the ECP
coordinator to judge the program’s
effectiveness.
The ECP process also does not provide
assurance that conditions adverse to quality
identified in the ECP review process would
get entered into CAP, creating potential to
miss correction and trending opportunities.
The request is being treated pursuant
to Title 10 of the Code of Federal
Regulations (10 CFR) Section 2.206 of
the Commission’s regulations. The
request has been referred to the Director
of the Office of Nuclear Reactor
Regulation. As provided by Section
2.206, appropriate action will be taken
on this petition within a reasonable
time. The petitioner met with the Office
of Nuclear Reactor Regulation petition
review board on March 19 and May 7,
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14:58 Nov 27, 2009
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2009, to discuss the petition. The results
of that discussion were considered in
the board’s determination regarding the
schedule for the review of the petition.
A copy of the petition is available for
inspection at the Commission’s Public
Document Room (PDR), located at One
White Flint North, Public File Area O1
F21, 11555 Rockville Pike (first floor),
Rockville, Maryland. Publicly available
records will be accessible from the
Agencywide Documents Access and
Management System (ADAMS) Public
Electronic Reading Room on the Internet
at the NRC Web site, https://
www.nrc.gov/reading-rm/adams.html.
Persons who do not have access to
ADAMS or who encounter problems in
accessing the documents located in
ADAMS should contact the NRC PDR
Reference staff by telephone at 1–800–
397–4209 or 301–415–4737, or by e-mail
to pdr.Resource@nrc.gov.
Dated at Rockville, Maryland, this 19th day
of November 2009.
For the Nuclear Regulatory Commission.
Eric J. Leeds,
Director, Office of Nuclear Reactor
Regulation.
[FR Doc. E9–28510 Filed 11–27–09; 8:45 am]
BILLING CODE 7590–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
29062; File No. 812–13654]
Members Mutual Funds, et al.; Notice
of Application
November 23, 2009.
AGENCY: Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application under
section 6(c) of the Investment Company
Act of 1940 (the ‘‘Act’’) for an
exemption from section 15(a) of the Act
and rule 18f–2 under the Act.
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 December 18, 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
reasons for the request, and the issues
contested. Persons who wish to be
notified of a hearing may request
notification by writing to the
Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F
Street, NE., Washington, DC 20549–
1090. Applicants, W. Richard Mason,
Esq., Corporate Counsel and CCO,
Madison Asset Management, LLC c/o
Madison/Mosaic Legal and Compliance
Department, 8777 N. Gainey Center
Drive, Suite 220, Scottsdale, AZ 85258.
FOR FURTHER INFORMATION CONTACT:
Laura L. Solomon, Senior Counsel at
(202) 551–6915, 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. MMF and USF are open-end
management investment companies
registered under the Act. MMF is
organized as a Delaware business trust.
USF is organized as a Massachusetts
business trust. MMF is currently
Summary of Application: The
comprised of 14 separate series and USF
requested order would permit certain
is currently comprised of 18 separate
registered open-end management
series each of which has its own
investment companies to enter into and investment objectives and policies (such
materially amend subadvisory
series, together with the future series of
agreements without shareholder
MMF and USF, the ‘‘Funds,’’ and each
approval.
a ‘‘Fund’’). Applicants also request relief
Applicants: Members Mutual Funds
with respect to current and future series
(‘‘MMF’’), Ultra Series Fund (‘‘USF’’)
of all registered open-end management
and Madison Asset Management, LLC
investment companies and their series
(‘‘MAM’’).
that are now, or in the future, advised
DATES: Filing Dates: The application was by MAM or any entity controlling,
filed on April 16, 2009, and amended on controlled by or under common control
(within the meaning of section 2(a)(9) of
September 23, 2009 and November 23,
the Act) with MAM, or any successor to
2009.
Hearing or Notification of Hearing: An MAM (collectively, the ‘‘Adviser’’) that
comply with the terms and conditions
order granting the application will be
as set forth in the application and that
issued unless the Commission orders a
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uses the services of one or more
subadvisors to manage all or a portion
of their investment portfolios (the
‘‘Management Structure,’’ and such
companies and their series included in
the term ‘‘Funds’’), as described more
fully in the application.1
2. MAM, a Wisconsin limited liability
corporation, is registered as an
investment adviser under the
Investment Advisers Act of 1940
(‘‘Advisers Act’’). MAM provides overall
investment management to MMF, USF
and each Fund, subject to the
supervision of the board of directors or
trustees of each Fund (‘‘Board’’)
pursuant to written agreements
(‘‘Management Agreements’’).2
3. The Management Agreements have
been approved by a majority of the
trustees who are not ‘‘interested
persons,’’ as defined in section 2(a)(19)
of the Act, of the Board (the
‘‘Independent Trustees’’) and Fund
shareholders in the manner required by
sections 15(a) and (c) of the Act and rule
18f–2 under the Act. The Adviser will
provide general management services to
each Fund, including overall
supervisory responsibility for the
general management and investment of
each Fund’s assets subject to review and
approval of the Board. For the
investment management services the
Adviser provides to the Funds, the
Adviser will receive fees at an annual
rate based on each Fund’s average net
assets. Each investment subadvisor will
be recommended by the Adviser and
selected and approved by the Board,
including a majority of the Independent
Trustees, and is (or will be) registered as
an investment adviser under the
Advisers Act. Each investment
subadvisor has discretionary authority
to invest all or a portion of the assets of
a particular Fund pursuant to a written
investment subadvisory agreement
between the investment subadvisor and
the Adviser. The fees of the investment
subadvisors are paid by the Adviser at
rates negotiated with the investment
subadvisors by the Adviser and
evaluated by the Board. The Adviser
will monitor the performance of each
investment subadvisor and of the
Fund’s portfolio and reallocate Fund
assets among individual investment
subadvisors, or recommend to the Board
that the Fund employ or terminate
particular investment subadvisors, to
the extent the Adviser deems
appropriate to achieve the Fund’s
overall investment objectives.
4. Applicants request an order to
eliminate the need for Funds to submit
new investment subadvisory
agreements, and material amendments
to existing investment subadvisory
agreements, to shareholders for their
approval. The requested relief will not
extend to any investment subadvisor
who is an ‘‘affiliated person,’’ as defined
in section 2(a)(3) of the Act, of the
Funds or the Adviser (other than by
reason of serving as investment
subadvisor to one or more Funds)
(‘‘affiliated investment subadvisor’’).
Shareholder approval will continue to
be required for each investment
subadvisory agreement with an
affiliated investment subadvisor.
1 The term ‘‘successor’’ is limited to an entity or
entities that result from a reorganization into
another jurisdiction or a change in the type of
business organization. Any existing entity that
currently intends to rely on the requested relief is
named as an applicant. If a Fund has the name of
any investment subadvisor in the Fund’s name, the
investment subadvisor’s name will be preceded by
the name of the Adviser.
2 Under a prior order, the Commission granted
relief to Members Capital Advisors, Inc. (‘‘MCA’’)
(f/k/a CIMCO, Inc.) and MMF from the provisions
of section 15(a) of the Act and rule 18f–2 under the
Act, pursuant to which MCA retained investment
subadvisors for certain of the Funds. Members
Mutual Funds and CIMCO, Inc., Investment
Company Act Release Nos. 23365 (July 29, 1998)
(notice) and 23400 (August 25, 1998) (order)
(‘‘Existing Order’’). On April 15, 2009, MCA, an
indirectly wholly owned subsidiary of CUNA
Mutual Insurance Society (‘‘CMIS’’) and CMIS
entered into an agreement under which MAM
would become the investment adviser to the Funds
(the ‘‘Transaction’’). The Transaction was approved
by Fund shareholders and MAM now serves as the
Funds’ investment adviser. The Funds wish to
continue to operate in a manner consistent with the
Existing Order. On June 30, 2009, MAM received
a no-action letter (Ref. No. 2009–3–1CR), permitting
MAM to rely on the Existing Order until the earlier
of the receipt of any order granted by the
Commission on the application or December 30,
2009.
Applicants’ Legal Analysis
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14:58 Nov 27, 2009
Jkt 220001
1. Section 15(a) of the Act provides,
in relevant part, that it is unlawful for
any person to act as an investment
adviser to a registered investment
company except pursuant to a written
contract that has been approved by the
vote of a majority of the company’s
outstanding voting securities. Rule 18f–
2 under the Act provides that each
series or class of stock in a series
company affected by a matter must
approve such matter if the Act requires
shareholder approval.
2. Section 6(c) 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 provision of the
Act, or from any rule thereunder, 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. Applicants
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62611
believe that the requested relief meets
this standard.
3. Applicants state that investors in
any subadvised Fund are, in effect,
electing to have the Adviser select one
or more investment subadvisors best
suited to achieve a Fund’s investment
objectives. Applicants assert that, the
role of the investment subadvisor, from
the perspective of the investor, is
comparable to that of individual
portfolio managers employed by other
investment company investment
advisory firms. Applicants contend that
requiring shareholder approval of
investment subadvisory agreements
would not serve the purpose intended
by the Act. Such requirements would
place costs and burdens on the Funds
and their shareholders that would not
advance such shareholders’ interests
and would merely increase the Fund’s
expenses and delay the prompt
implementation of actions deemed
advisable by the Adviser and the Board.
Applicants also note that the
Management Agreement between the
Adviser and each of the Funds will be
subject to the shareholder approval
requirements in section 15(a) and 15(c)
of the Act and rule 18f–2 under the Act.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief shall be
subject to the following conditions:
1. The Adviser will provide general
management services to each Fund,
including overall supervisory
responsibility for the general
management and investment of each
Fund’s assets, and, subject to the review
and approval of the Board, will: (i) Set
the overall investment strategies of the
Funds; (ii) evaluate, select and
recommend investment subadvisors to
manage all or part of a Fund’s assets;
(iii) allocate and, when appropriate,
reallocate the assets of the Funds among
investment subadvisors in those cases
where a Fund has more than one
investment subadvisor; (iv) monitor and
evaluate the investment performance of
the investment subadvisors, including
their compliance with the investment
objectives, policies and restrictions of
the Funds; and (v) implement
procedures reasonably designed to
ensure that the investment subadvisors
comply with the relevant Fund’s
investment objective, policies and
restrictions.
2. Before any Fund may rely on the
order requested in the application, the
operation of the Fund in the manner
described in the application will be
approved by a majority of its
outstanding voting securities, as defined
in the Act, or, in the case of a Fund
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Federal Register / Vol. 74, No. 228 / Monday, November 30, 2009 / Notices
whose public shareholders purchase
shares on the basis of a prospectus
containing the disclosure contemplated
by condition 4 below, by the initial
shareholder(s) before offering shares of
such Fund to the public.
3. Within 90 days of the hiring of any
new investment subadvisor, the Adviser
will furnish shareholders of the affected
Fund with all information about such
investment subadvisor that would be
included in a proxy statement,
including any change in such disclosure
caused by the addition of the new
investment subadvisor. To meet this
condition, the Funds will provide
shareholders with an information
statement meeting the requirements of
Regulation 14C, Schedule 14C, and Item
22 of Schedule 14A under the Securities
Exchange Act of 1934.
4. Each Fund will disclose in its
prospectus the existence, substance, and
effect of any order granted pursuant to
the application. In addition, each Fund
will hold itself out to the public as
employing the Management Structure
described in the application. The
prospectus will prominently disclose
that the Adviser has ultimate
responsibility (subject to oversight by
the Board) to oversee investment
subadvisors and recommend their
hiring, termination and replacement.
5. No trustee or officer of any Fund,
or director or officer of the Adviser will
own directly or indirectly (other than
through a pooled investment vehicle
that is not controlled by any such
director, trustee, or officer) any interest
in an investment subadvisor except for:
(i) Ownership of interests in the Adviser
or any entity that controls, is controlled
by, or under common control with the
Adviser; or (ii) ownership of less than
1% of the outstanding securities of any
class of equity or debt securities of any
publicly-traded company that is either
an investment subadvisor or an entity
that controls, is controlled by or is
under common control with an
investment subadvisor.
6. The Adviser will not enter into
investment subadvisory agreements on
behalf of a Fund with any affiliated
investment subadvisor without such
agreement, including the compensation
to be paid under the agreement, being
approved by the shareholders of the
applicable Fund.
7. At all times, at least a majority of
the Board will be Independent Trustees,
and the nomination of new or additional
Independent Trustees will be placed
within the discretion of the thenexisting Independent Trustees.
8. When a change of investment
subadvisor is proposed for a Fund with
an affiliated investment subadvisor, the
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14:58 Nov 27, 2009
Jkt 220001
Board, including a majority of the
Independent Trustees, will make a
separate finding, reflected in the
minutes of meetings of the Board, that
any such change of investment
subadvisors is in the best interest of the
Fund and its shareholders and does not
involve a conflict of interest from which
the Adviser or the affiliated investment
subadvisor derives an inappropriate
advantage.
9. In the event the Commission adopts
a rule under the Act providing
substantially similar relief to that in the
requested order, the requested order
will expire on the effective date of that
rule.
lack of current and accurate information
concerning the securities of USA
Biomass Corp. because it has not filed
any periodic reports since the period
ended December 31, 2002.
The Commission is of the opinion that
the public interest and the protection of
investors require a suspension of trading
in the securities of the above-listed
companies. Therefore, it is ordered,
pursuant to Section 12(k) of the
Securities Exchange Act of 1934, that
trading in the securities of the abovelisted companies is suspended for the
period from 9:30 a.m. EST on November
25, 2009, through 11:59 p.m. EST on
December 9, 2009.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Elizabeth M. Murphy,
Secretary.
[FR Doc. E9–28560 Filed 11–27–09; 8:45 am]
By the Commission.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. E9–28639 Filed 11–25–09; 11:15
am]
BILLING CODE 8011–01–P
BILLING CODE P
SECURITIES AND EXCHANGE
COMMISSION
SECURITIES AND EXCHANGE
COMMISSION
[File No. 500–1]
[Release No. 34–61043; File No. SR–NYSE–
2009–116]
In the Matter of Customer Sports, Inc.,
Leonidas Films, Inc. (n/k/a
Consolidated Pictures Group, Inc.),
Sportsprize Entertainment, Inc., U.S.
Interactive, Inc., and USA Biomass
Corp.; Order of Suspension of Trading
Self-Regulatory Organizations; New
York Stock Exchange LLC; Notice of
Filing of Proposed Rule Change to
Increase the Ceiling on Its Equity
Ownership Interest in BIDS Holdings
L.P. to Less Than 10%
November 25, 2009.
November 20, 2009.
It appears to the Securities and
Exchange Commission that there is a
lack of current and accurate information
concerning the securities of Customer
Sports, Inc. because it has not filed any
periodic reports since the period ended
April 30, 2000.
It appears to the Securities and
Exchange Commission that there is a
lack of current and accurate information
concerning the securities of Leonidas
Films, Inc. (n/k/a Consolidated Pictures
Group, Inc.) because it has not filed any
periodic reports since the period ended
March 31, 2001.
It appears to the Securities and
Exchange Commission that there is a
lack of current and accurate information
concerning the securities of Sportsprize
Entertainment, Inc. because it has not
filed any periodic reports since the
period ended August 31, 2000.
It appears to the Securities and
Exchange Commission that there is a
lack of current and accurate information
concerning the securities of U.S.
Interactive, Inc. because it has not filed
any periodic reports since the period
ended September 30, 2000.
It appears to the Securities and
Exchange Commission that there is a
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that, on
November 18, 2009, New York Stock
Exchange LLC (‘‘NYSE’’ or the
‘‘Exchange’’) filed with the Securities
and Exchange Commission (the
‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III below, which Items have been
prepared by the Exchange. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
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I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to increase
the ceiling on the Exchange’s equity
ownership interest in BIDS Holdings
L.P. (‘‘BIDS’’), a member of the
Exchange, to less than 10% from the
current level of less than 9%, pursuant
to the pilot program that provides an
exception to NYSE Rule 2B by
permitting such equity ownership as
1 15
2 17
U.S.C. 78s(b)(1).
CFR 240.19b–4.
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Agencies
[Federal Register Volume 74, Number 228 (Monday, November 30, 2009)]
[Notices]
[Pages 62610-62612]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-28560]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 29062; File No. 812-13654]
Members Mutual Funds, et al.; Notice of Application
November 23, 2009.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application under section 6(c) of the Investment
Company Act of 1940 (the ``Act'') for an exemption from section 15(a)
of the Act and rule 18f-2 under the Act.
-----------------------------------------------------------------------
Summary of Application: The requested order would permit certain
registered open-end management investment companies to enter into and
materially amend subadvisory agreements without shareholder approval.
Applicants: Members Mutual Funds (``MMF''), Ultra Series Fund
(``USF'') and Madison Asset Management, LLC (``MAM'').
DATES: Filing Dates: The application was filed on April 16, 2009, and
amended on September 23, 2009 and November 23, 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 December 18, 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 reasons for the request, and the issues
contested. Persons who wish to be notified of a hearing may request
notification by writing to the Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street, NE., Washington, DC 20549-1090. Applicants, W. Richard Mason,
Esq., Corporate Counsel and CCO, Madison Asset Management, LLC c/o
Madison/Mosaic Legal and Compliance Department, 8777 N. Gainey Center
Drive, Suite 220, Scottsdale, AZ 85258.
FOR FURTHER INFORMATION CONTACT: Laura L. Solomon, Senior Counsel at
(202) 551-6915, 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. MMF and USF are open-end management investment companies
registered under the Act. MMF is organized as a Delaware business
trust. USF is organized as a Massachusetts business trust. MMF is
currently comprised of 14 separate series and USF is currently
comprised of 18 separate series each of which has its own investment
objectives and policies (such series, together with the future series
of MMF and USF, the ``Funds,'' and each a ``Fund''). Applicants also
request relief with respect to current and future series of all
registered open-end management investment companies and their series
that are now, or in the future, advised by MAM or any entity
controlling, controlled by or under common control (within the meaning
of section 2(a)(9) of the Act) with MAM, or any successor to MAM
(collectively, the ``Adviser'') that comply with the terms and
conditions as set forth in the application and that
[[Page 62611]]
uses the services of one or more subadvisors to manage all or a portion
of their investment portfolios (the ``Management Structure,'' and such
companies and their series included in the term ``Funds''), as
described more fully in the application.\1\
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\1\ The term ``successor'' is limited to an entity or entities
that result from a reorganization into another jurisdiction or a
change in the type of business organization. Any existing entity
that currently intends to rely on the requested relief is named as
an applicant. If a Fund has the name of any investment subadvisor in
the Fund's name, the investment subadvisor's name will be preceded
by the name of the Adviser.
---------------------------------------------------------------------------
2. MAM, a Wisconsin limited liability corporation, is registered as
an investment adviser under the Investment Advisers Act of 1940
(``Advisers Act''). MAM provides overall investment management to MMF,
USF and each Fund, subject to the supervision of the board of directors
or trustees of each Fund (``Board'') pursuant to written agreements
(``Management Agreements'').\2\
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\2\ Under a prior order, the Commission granted relief to
Members Capital Advisors, Inc. (``MCA'') (f/k/a CIMCO, Inc.) and MMF
from the provisions of section 15(a) of the Act and rule 18f-2 under
the Act, pursuant to which MCA retained investment subadvisors for
certain of the Funds. Members Mutual Funds and CIMCO, Inc.,
Investment Company Act Release Nos. 23365 (July 29, 1998) (notice)
and 23400 (August 25, 1998) (order) (``Existing Order''). On April
15, 2009, MCA, an indirectly wholly owned subsidiary of CUNA Mutual
Insurance Society (``CMIS'') and CMIS entered into an agreement
under which MAM would become the investment adviser to the Funds
(the ``Transaction''). The Transaction was approved by Fund
shareholders and MAM now serves as the Funds' investment adviser.
The Funds wish to continue to operate in a manner consistent with
the Existing Order. On June 30, 2009, MAM received a no-action
letter (Ref. No. 2009-3-1CR), permitting MAM to rely on the Existing
Order until the earlier of the receipt of any order granted by the
Commission on the application or December 30, 2009.
---------------------------------------------------------------------------
3. The Management Agreements have been approved by a majority of
the trustees who are not ``interested persons,'' as defined in section
2(a)(19) of the Act, of the Board (the ``Independent Trustees'') and
Fund shareholders in the manner required by sections 15(a) and (c) of
the Act and rule 18f-2 under the Act. The Adviser will provide general
management services to each Fund, including overall supervisory
responsibility for the general management and investment of each Fund's
assets subject to review and approval of the Board. For the investment
management services the Adviser provides to the Funds, the Adviser will
receive fees at an annual rate based on each Fund's average net assets.
Each investment subadvisor will be recommended by the Adviser and
selected and approved by the Board, including a majority of the
Independent Trustees, and is (or will be) registered as an investment
adviser under the Advisers Act. Each investment subadvisor has
discretionary authority to invest all or a portion of the assets of a
particular Fund pursuant to a written investment subadvisory agreement
between the investment subadvisor and the Adviser. The fees of the
investment subadvisors are paid by the Adviser at rates negotiated with
the investment subadvisors by the Adviser and evaluated by the Board.
The Adviser will monitor the performance of each investment subadvisor
and of the Fund's portfolio and reallocate Fund assets among individual
investment subadvisors, or recommend to the Board that the Fund employ
or terminate particular investment subadvisors, to the extent the
Adviser deems appropriate to achieve the Fund's overall investment
objectives.
4. Applicants request an order to eliminate the need for Funds to
submit new investment subadvisory agreements, and material amendments
to existing investment subadvisory agreements, to shareholders for
their approval. The requested relief will not extend to any investment
subadvisor who is an ``affiliated person,'' as defined in section
2(a)(3) of the Act, of the Funds or the Adviser (other than by reason
of serving as investment subadvisor to one or more Funds) (``affiliated
investment subadvisor''). Shareholder approval will continue to be
required for each investment subadvisory agreement with an affiliated
investment subadvisor.
Applicants' Legal Analysis
1. Section 15(a) of the Act provides, in relevant part, that it is
unlawful for any person to act as an investment adviser to a registered
investment company except pursuant to a written contract that has been
approved by the vote of a majority of the company's outstanding voting
securities. Rule 18f-2 under the Act provides that each series or class
of stock in a series company affected by a matter must approve such
matter if the Act requires shareholder approval.
2. Section 6(c) 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 provision of the Act, or
from any rule thereunder, 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. Applicants believe that the requested relief
meets this standard.
3. Applicants state that investors in any subadvised Fund are, in
effect, electing to have the Adviser select one or more investment
subadvisors best suited to achieve a Fund's investment objectives.
Applicants assert that, the role of the investment subadvisor, from the
perspective of the investor, is comparable to that of individual
portfolio managers employed by other investment company investment
advisory firms. Applicants contend that requiring shareholder approval
of investment subadvisory agreements would not serve the purpose
intended by the Act. Such requirements would place costs and burdens on
the Funds and their shareholders that would not advance such
shareholders' interests and would merely increase the Fund's expenses
and delay the prompt implementation of actions deemed advisable by the
Adviser and the Board. Applicants also note that the Management
Agreement between the Adviser and each of the Funds will be subject to
the shareholder approval requirements in section 15(a) and 15(c) of the
Act and rule 18f-2 under the Act.
Applicants' Conditions
Applicants agree that any order granting the requested relief shall
be subject to the following conditions:
1. The Adviser will provide general management services to each
Fund, including overall supervisory responsibility for the general
management and investment of each Fund's assets, and, subject to the
review and approval of the Board, will: (i) Set the overall investment
strategies of the Funds; (ii) evaluate, select and recommend investment
subadvisors to manage all or part of a Fund's assets; (iii) allocate
and, when appropriate, reallocate the assets of the Funds among
investment subadvisors in those cases where a Fund has more than one
investment subadvisor; (iv) monitor and evaluate the investment
performance of the investment subadvisors, including their compliance
with the investment objectives, policies and restrictions of the Funds;
and (v) implement procedures reasonably designed to ensure that the
investment subadvisors comply with the relevant Fund's investment
objective, policies and restrictions.
2. Before any Fund may rely on the order requested in the
application, the operation of the Fund in the manner described in the
application will be approved by a majority of its outstanding voting
securities, as defined in the Act, or, in the case of a Fund
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whose public shareholders purchase shares on the basis of a prospectus
containing the disclosure contemplated by condition 4 below, by the
initial shareholder(s) before offering shares of such Fund to the
public.
3. Within 90 days of the hiring of any new investment subadvisor,
the Adviser will furnish shareholders of the affected Fund with all
information about such investment subadvisor that would be included in
a proxy statement, including any change in such disclosure caused by
the addition of the new investment subadvisor. To meet this condition,
the Funds will provide shareholders with an information statement
meeting the requirements of Regulation 14C, Schedule 14C, and Item 22
of Schedule 14A under the Securities Exchange Act of 1934.
4. Each Fund will disclose in its prospectus the existence,
substance, and effect of any order granted pursuant to the application.
In addition, each Fund will hold itself out to the public as employing
the Management Structure described in the application. The prospectus
will prominently disclose that the Adviser has ultimate responsibility
(subject to oversight by the Board) to oversee investment subadvisors
and recommend their hiring, termination and replacement.
5. No trustee or officer of any Fund, or director or officer of the
Adviser will own directly or indirectly (other than through a pooled
investment vehicle that is not controlled by any such director,
trustee, or officer) any interest in an investment subadvisor except
for: (i) Ownership of interests in the Adviser or any entity that
controls, is controlled by, or under common control with the Adviser;
or (ii) ownership of less than 1% of the outstanding securities of any
class of equity or debt securities of any publicly-traded company that
is either an investment subadvisor or an entity that controls, is
controlled by or is under common control with an investment subadvisor.
6. The Adviser will not enter into investment subadvisory
agreements on behalf of a Fund with any affiliated investment
subadvisor without such agreement, including the compensation to be
paid under the agreement, being approved by the shareholders of the
applicable Fund.
7. At all times, at least a majority of the Board will be
Independent Trustees, and the nomination of new or additional
Independent Trustees will be placed within the discretion of the then-
existing Independent Trustees.
8. When a change of investment subadvisor is proposed for a Fund
with an affiliated investment subadvisor, the Board, including a
majority of the Independent Trustees, will make a separate finding,
reflected in the minutes of meetings of the Board, that any such change
of investment subadvisors is in the best interest of the Fund and its
shareholders and does not involve a conflict of interest from which the
Adviser or the affiliated investment subadvisor derives an
inappropriate advantage.
9. In the event the Commission adopts a rule under the Act
providing substantially similar relief to that in the requested order,
the requested order will expire on the effective date of that rule.
For the Commission, by the Division of Investment Management,
under delegated authority.
Elizabeth M. Murphy,
Secretary.
[FR Doc. E9-28560 Filed 11-27-09; 8:45 am]
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