PNC Bank, National Association; Notice of Application, 65175-65178 [E9-29321]
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Federal Register / Vol. 74, No. 235 / Wednesday, December 9, 2009 / Notices
papers be given the opportunity to
comment or provide feedback?
Dated: December 3, 2009.
M. David Hodge,
Operations Manager.
[FR Doc. E9–29322 Filed 12–8–09; 8:45 am]
BILLING CODE 3170–W7–P
SECURITIES AND EXCHANGE
COMMISSION
Applicant’s Representations
[Investment Company Act Release No.
29066; File No. 812–13640]
PNC Bank, National Association;
Notice of Application
December 3, 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
(‘‘Act’’) granting an exemption from
section 18(f)(1) of the Act.
PNC Bank, National
Association (‘‘PNC Bank’’).
SUMMARY OF THE APPLICATION: Applicant
requests an order that that would permit
certain registered open-end management
investment companies to participate as
borrowers in loan facilities to be
administered by PNC Bank.
FILING DATES: The application was filed
on March 11, 2009, and amended on
November 30, 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 28, 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 by
writing to the Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F
Street, NE., Washington, DC 20549–
1090. Applicant, PNC Bank, National
Association, One PNC Plaza, 21st Floor,
249 Fifth Avenue, Pittsburgh, PA 15222.
FOR FURTHER INFORMATION CONTACT:
Lewis B. Reich, Senior Counsel, at (202)
551–6919, or Mary Kay Frech, Branch
Chief, at (202) 551–6821 (Office of
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APPLICANT:
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Investment Company Regulation,
Division of Investment Management).
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 for an applicant using the
Company name box at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
1. PNC Bank, a wholly-owned indirect
subsidiary of The PNC Financial
Services Group, Inc. (‘‘PNC Financial’’),
is a national banking association with
its principal office in Pittsburgh,
Pennsylvania. PNC Financial is one of
the largest diversified financial services
companies in the United States based on
assets, with businesses engaged in retail
banking, corporate and institutional
banking, asset management, and global
fund processing services. PNC Bank has
extensive experience and expertise as an
administrator of asset-backed
commercial paper programs, having
administered the commercial paper
program of Market Street Funding LLC
(‘‘Market Street’’), a limited purpose
securitization entity, since 1995.
2. Market Street is organized as a
Delaware limited liability company and
is exempt from registration under the
Act in reliance on section 3(c)(7) of the
Act. All of the membership interests of
Market Street are owned by Market
Street Holding Corporation (‘‘MSHC’’).
All of the capital stock of MSHC is
owned by Amacar Investments, LLC, an
entity unaffiliated with PNC Financial.
As of September 30, 2009, Market
Street’s purchase commitments totaled
approximately $6.0 billion, and its
outstanding loans and other assets
totaled approximately $3.3 billion.
3. PNC Bank requests relief to permit
any registered open-end management
investment company or series thereof to
participate from time to time as a
borrower (‘‘Borrowing Fund’’) in a loan
facility to be administered by PNC Bank
(‘‘Loan Facility’’). Market Street, which
would be the principal source of
financing for each Loan Facility, will
issue commercial paper and will utilize
liquidity support provided by highly
rated financial institutions that are
‘‘banks’’ within the meaning of section
2(a)(5) of the Act (‘‘Liquidity
Providers’’). Market Street issues
unsecured commercial paper with
maturities of up to 270 days
(‘‘Promissory Notes’’) to fund
uncommitted purchases of and
uncommitted loans secured by various
types of financial assets.
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4. The Promissory Notes issued by
Market Street are sold only to
institutional investors that are
‘‘accredited investors’’ as defined in rule
501(a) of Regulation D under the
Securities Act of 1933 (the ‘‘Securities
Act’’) or to ‘‘qualified institutional
buyers’’ as defined in rule 144A under
the Securities Act. PNC Bank, which has
extensive experience as an
administrator of asset-backed
commercial paper programs, will
perform the administrative functions for
Market Street. PNC Bank will negotiate
the business arrangements on behalf of
Market Street, including loan amounts,
interest rates, and fees. PNC Bank will
act as agent for Market Street and the
related Liquidity Providers under the
agreements executed with each
Borrowing Fund and in such capacity
will exercise rights and enforce
remedies on behalf of Market Street and
Liquidity Providers.
5. As security for a loan, Borrowing
Funds will pledge assets (‘‘Pledged
Assets’’) for the benefit of Market Street
and the applicable Liquidity Provider.
The Pledged Assets will meet eligibility
criteria set by Market Street that will be
consistent with the Borrowing Fund’s
investment objectives and policies. For
each loan transaction, PNC Bank will
evaluate: (a) The type and nature of a
Borrowing Fund’s Pledged Assets to
determine whether they meet Market
Street’s standards for collateral; (b) the
operations and history of the Borrowing
Fund; and (c) the financial position and
operations of the Borrowing Fund’s
investment adviser.
6. Applicant states that Market Street
would make loans to a Borrowing Fund
on an uncommitted basis and the
applicable Liquidity Provider would be
obligated to make loans to the
Borrowing Fund in the event Market
Street was unable or unwilling to make
such loans. Market Street will have the
right in its sole discretion to require the
Liquidity Providers to acquire
outstanding loans made by Market
Street to a Borrowing Fund at an agreedupon amount determined pursuant to
the formula set forth in the related
agreements. Applicant states that these
liquidity support arrangements provide
additional assurances to the holders of
Promissory Notes that they will be paid
at maturity, as well as protection for
Borrowing Funds.
7. Applicant states that Market Street
currently provides financing for assets
originated by customers of PNC Bank
and their affiliates as sellers of those
assets to Market Street. The assets
purchased by Market Street include
financial assets and securities backed by
financial assets. Some transactions are
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structured as loans to the sellers,
secured by the assets being financed, or
as agreements to acquire future cash
flows from asset interests. In addition to
purchasing interests in pools of assets
directly, Market Street has purchased
publicly registered, rule 144A eligible or
privately placed asset-backed securities
in open market or privately negotiated
transactions. Market Street finances its
purchase of asset pools primarily
through the issuance of its Promissory
Notes. All loans made by Market Street
to the Borrowing Funds are not
expected to be in the aggregate more
than 20% of Market Street’s outstanding
loans and other assets.
8. Applicant represents that the
revolving credit and security agreement
of a Loan Facility, which will be
negotiated by the parties, will contain
representations, warranties, covenants
and events of default that are customary
for secured loan transactions involving
registered open-end management
investment companies, as well as such
other terms that are specific to a
particular Borrowing Fund and the
conduct of its business. A Borrowing
Fund will have the right at any time to
prepay any outstanding loans under its
Loan Facility on certain monthly or
quarterly dates without any premium or
penalty. The Pledged Assets of a
Borrowing Fund will be available solely
to secure the repayment of the loans and
other outstanding obligations of that
Borrowing Fund under the Loan
Facility. Applicant further states that a
Borrowing Fund would have the same
rights and remedies under state and
federal law with respect to a Loan
Facility from Market Street that it would
have with respect to a comparable loan
from a bank. PNC Bank also states that
the arrangements with the Liquidity
Providers protect Borrowing Funds by
providing an alternative source of
financing in the event Market Street is
unable to continue lending funds.
9. Before a Loan Facility is
established, a Borrowing Fund must
represent, in writing, to PNC Bank,
Market Street and the Liquidity
Providers that: (a) Its policies permit
borrowing and, if applicable, the use of
leverage; (b) all borrowing transactions
pursuant to the Loan Facility will be
subject to the requirements of the Act,
the rules and regulations thereunder,
and any other applicable interpretations
or guidance from the Commission or its
staff; and (c) each borrowing transaction
will be conducted in accordance with
all applicable representations and
conditions of the application. Before a
Borrowing Fund may participate in a
Loan Facility, its board of directors or
trustees (‘‘Board’’), including a majority
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of the directors or trustees that are not
‘‘interested persons’’ within the
meaning of section 2(a)(19) of the Act
(‘‘Disinterested Directors’’), will
determine that its participation is
consistent with the Borrowing Fund’s
investment objectives and policies and
in the best interests of the Borrowing
Fund and its shareholders. Each
Borrowing Fund’s Board, including a
majority of the Disinterested Directors,
will also adopt procedures for
evaluating and making certain
determinations concerning the terms of
each loan transaction between the
Borrowing Fund and Market Street.
10. PNC Bank states that the proposed
Loan Facilities would enable Borrowing
Funds to borrow money from Market
Street at lower cost than obtaining
comparable loans from a bank. PNC
Bank states that Market Street’s cost of
funds is lower than that of banks, and
this advantage will be passed on to the
Borrowing Funds.1
Applicant’s Legal Analysis
1. Section 18(f)(1) of the Act prohibits
an open-end investment company from
issuing any senior security except that
a company is permitted to borrow from
any bank, if immediately after the
borrowing, there is an asset coverage of
at least 300% for all borrowings of the
company.2 Section 2(a)(5) defines
‘‘bank’’ as a depository institution, a
branch or agency of a foreign bank, a
member bank of the Federal Reserve
System, a banking institution or other
trust company that, as a substantial
portion of its business, receives deposits
or exercises fiduciary powers similar to
those permitted to national banks.
Applicant states that while Market
Street engages in many of the same
business activities as banks, it is not a
‘‘bank’’ under this definition.
2. Section 6(c) of the Act permits the
Commission to exempt any person or
transaction or any class or classes of
persons or transactions from any
provision or provisions 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. PNC Bank
1 The rate at which a Liquidity Provider would
make a loan to a Borrowing Fund would not be as
favorable as that of Market Street, but would be
comparable to the rates on secured lines of credit
from banks. PNC Bank anticipates that Market
Street, rather than a Liquidity Provider, will be the
lender to the Borrowing Funds under a Loan
Facility, absent extenuating circumstances.
2 Under section 18(g) of the Act, the term ‘‘senior
security’’ includes any bond, debenture, note, or
similar obligation or instrument constituting a
security and evidencing indebtedness.
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requests exemptive relief from section
18(f)(1) solely to the extent necessary to
allow a Borrowing Fund to borrow from
Market Street. PNC Bank believes that
permitting the Borrowing Funds to
borrow from Market Street is fully
consistent with the purposes and
policies of section 18(f)(1) and would
not implicate the concerns underlying
that provision.
3. PNC Bank states that section 18(f)
of the Act reflects Congressional
concern about excessive borrowing and
the issuance of senior securities by
open-end investment companies
because these practices could unduly
increase the speculative character and
investment risk of junior securities. PNC
Bank notes that Borrowing Funds would
remain subject to the 300% asset
coverage requirement in section 18(f)(1)
of the Act for all borrowings, including
those from Market Street. PNC Bank
further represents that Market Street’s
loans will not impose any restrictions
on a Borrowing Fund’s shareholders
that are different from those imposed by
a collateralized bank loan. Finally, PNC
Bank argues that permitting a Borrowing
Fund to borrow from Market Street
rather than a bank is expected to reduce
its costs of borrowing, which should
decrease the risk that a Borrowing
Fund’s borrowing costs will exceed the
return from securities purchased with
borrowed money and lessen any related
incentive to purchase more speculative
portfolio securities to cover those costs.
4. PNC Bank states that section 18(f)
of the Act also limited open-end
investment companies to borrowing
from traditional institutional lending
sources out of a Congressional concern
that public holders of senior securities
might be unaware that they were much
riskier instruments than senior
securities issued by operating
companies. Senior securities of
investment companies typically were
secured by assets that were subject to
wide fluctuations in value. Further,
common shareholders could redeem at
any time, which also might affect an
open-end investment company’s ability
to repay its outstanding debt.
5. PNC Bank argues that the Loan
Facilities do not involve the type of
senior security holder that section
18(f)(1) of the Act was designed to
protect and that the structure of the
Loan Facilities and Market Street
provide sufficient protection to the
parties that face any risk of loss by
lending to an open-end investment
company. Market Street is administered
by PNC Bank, which applicant states
has expertise in administering loans
collateralized by financial instruments
that equals or exceeds the expertise of
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most banks. The Liquidity Providers are
banks as defined by the Act and thus
not the type of potential senior security
holder that Congress believed needed
protection. PNC Bank states that the
Promissory Notes are general obligations
of Market Street and loans to Borrowing
Funds are not expected to exceed 20%
of Market Street’s outstanding assets
and loans to any individual Borrowing
Fund are not expected to exceed 10% of
Market Street’s assets. Any risk of loss
on the Promissory Notes posed by loans
to registered open-end investment
companies is further reduced by PNC
Bank’s expertise, Market Street’s ability
to sell the loans under the Loan
Facilities to the Liquidity Providers,
Market Street’s external liquidity and
credit enhancement sources and the
capital of Market Street.
6. Applicant states that section 18(f)
also reflects a concern that complex
capital structures may permit insiders to
manipulate the allocation of expenses
and profits; facilitate control of the
investment company by junior security
shareholders with little investment; and
make it difficult for investors in the
investment company to understand
what their stock is worth. PNC Bank
states that borrowing from Market Street
would not facilitate pyramiding of
control or manipulative reallocation of
expenses and profits. Further, PNC Bank
believes that borrowings from Market
Street would not be any more difficult
for shareholders of a Borrowing Fund to
understand than bank borrowings.
7. Applicant also states that section
18(f) reflects a concern that existed
when the Act was adopted that
borrowings by open-end investment
companies could be used to invest in
securities without being subject to
limitations of the Board of Governors of
the Federal Reserve System (the ‘‘FRB’’)
on the amount of credit that could be
used for these purposes (‘‘margin
requirements’’). Under Regulations U
and T under the Securities Exchange
Act of 1934, in effect prior to enactment
of the Act, only borrowings for such
purposes made by a domestic bank or
broker-dealer were subject to margin
requirements. Regulation U as currently
in effect imposes restrictions on banks
and lenders other than broker-dealers
that extend credit to borrowers for the
purpose of purchasing or carrying
margin stock. If Market Street makes
loans to a Borrowing Fund in excess of
the threshold amounts under Regulation
U, Market Street will register with the
FRB as a nonbank lender and would be
subject to the same credit restrictions as
a bank under Regulation U.
8. Finally, applicant believes the
requested relief will benefit Borrowing
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Funds by providing them with an
alternative, lower-cost source of
financing. For all of these reasons and
in light of the protections afforded by
the conditions set forth below, PNC
Bank believes that permitting Borrowing
Funds to borrow from Market Street
would be in the best interests of the
Borrowing Funds and their
shareholders, 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.
Applicant’s Conditions
The applicant agrees that any order
granting the requested relief will be
subject to the following conditions:
1. All Borrowing Funds will comply
with the asset coverage requirements in
section 18(f)(1) of the Act, including
with respect to all borrowings from
Market Street.
2. A loan by Market Street to a
Borrowing Fund will be at an interest
rate equal to Market Street’s cost of
funds (i.e., the weighted average
Promissory Note rate plus dealer
commissions).
3. Before a Borrowing Fund may
participate in a Loan Facility, the
Borrowing Fund’s Board, including a
majority of the Disinterested Directors,
will determine that participation in the
Loan Facility is consistent with the
Borrowing Fund’s investment objectives
and policies and is in the best interests
of the Borrowing Fund and its
shareholders. In addition, a Borrowing
Fund will disclose in its statement of
additional information all material facts
about its participation in the Loan
Facility.
4. Before a Borrowing Fund may
participate in a Loan Facility, its Board,
including a majority of the Disinterested
Directors, will adopt procedures
governing the Borrowing Fund’s
participation in the Loan Facility
(‘‘Procedures’’). In addition to any other
provisions the Board may find necessary
or appropriate to be included in the
Procedures, the Procedures will require
that, before a Borrowing Fund may enter
into loan transactions with Market
Street, the Board, including a majority
of the Disinterested Directors, will
determine that:
a. The borrowing is in the best
interests of the Borrowing Fund and its
shareholders;
b. The borrowing and pledge of assets
are consistent with the Borrowing
Fund’s investment objectives and
policies;
c. The total anticipated cost of the
Loan Facility (including fees and
interest) does not exceed the total
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65177
anticipated costs of comparable
financing alternatives that are available
to the Borrowing Fund;
d. The asset eligibility criteria for the
Loan Facility are consistent with the
Borrowing Fund’s investment objectives
and policies; and
e. The Borrowing Fund’s investments,
consistent with the asset eligibility
criteria and any other requirements of
participating in the Loan Facility, will
be in the best interests of the Borrowing
Fund and its shareholders.
5. If Market Street determines (a) to
require the Liquidity Providers to
acquire from Market Street outstanding
loans made to a Borrowing Fund, or (b)
not to extend additional loans to a
Borrowing Fund, the Board of the
Borrowing Fund, including a majority of
the Disinterested Directors, will be
notified promptly. As soon as
practicable, the Board, including a
majority of the Disinterested Directors,
must determine whether it is in the best
interests of the Borrowing Fund and its
shareholders to continue to participate
in the Loan Facility or to terminate the
Borrowing Fund’s participation in the
Loan Facility in accordance with its
terms.
6. At each regular quarterly meeting,
the Board, including a majority of the
Disinterested Directors, will (a) review a
Borrowing Fund’s loan transactions
under its Loan Facility during the
preceding quarter, including the terms
of each transaction, and (b) determine
whether the transactions were effected
in compliance with the Procedures and
the terms and conditions of the order.
At least annually, the Board, including
a majority of the Disinterested Directors,
will (a) with respect to a Borrowing
Fund’s continued participation in a
Loan Facility, make the determinations
required in condition 3 above, and (b)
approve such changes to the Procedures
as it deems necessary or appropriate.
7. A Borrowing Fund will maintain
and preserve permanently in an easily
accessible place a written copy of the
Procedures and any modifications to the
Procedures. The Borrowing Fund will
maintain and preserve for a period of
not less than six years from the end of
the fiscal year in which any transaction
with a Loan Facility occurred, the first
two years in an easily accessible place,
a written record of each transaction
setting forth a description of the terms
of the transaction, including the
amount, maturity, and the rate of
interest on the loan, and all information
upon which the determinations required
by these conditions were made.
8. The applicant will not enter into a
Loan Facility with any Borrowing Fund
if, at the time of such transaction, the
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applicant, Market Street or any
Liquidity Provider is an affiliated
person of that Borrowing Fund, within
the meaning of section 2(a)(3) of the Act,
or an affiliated person of any affiliated
person of that Borrowing Fund.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9–29321 Filed 12–8–09; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–61100; File No. SR–ISE–
2009–100]
Self-Regulatory Organizations;
International Securities Exchange,
LLC; Notice of Filing and Order
Granting Accelerated Approval to a
Proposed Rule Change Relating to the
Amounts that Direct Edge ECN, in Its
Capacity as an Introducing Broker for
Non-ISE Members, Passes Through to
Such Non-ISE Members
December 2, 2009.
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
30, 2009, the International Securities
Exchange, LLC (the ‘‘Exchange’’ or the
‘‘ISE’’) filed with the Securities and
Exchange Commission (‘‘Commission’’)
the proposed rule change as described
in Items I and II below, which Items
have been prepared by ISE. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons, and is
approving the proposal on an
accelerated basis.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
WReier-Aviles on DSKGBLS3C1PROD with NOTICES
The Exchange proposes to modify the
amounts that Direct Edge ECN
(‘‘DECN’’), in its capacity as an
introducing broker for non-ISE
Members, passes through to such nonISE Members.
The text of the proposed rule change
is available on the Exchange’s Internet
Web site at https://www.ise.com.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
1 15
2 17
U.S.C. 78s(b)(1).
CFR 240.19b–4.
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and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
of these statements may be examined at
the places specified in Item III below.
The self-regulatory organization has
prepared summaries, set forth in
sections A, B and C below, of the most
significant aspects of such statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
DECN, a facility of ISE, operates two
trading platforms, EDGX and EDGA. On
November 30, 2009, the ISE filed for
immediate effectiveness a proposed rule
change to: (i) Amend DECN’s fee
schedule for ISE Members 3 to reflect
pass through charges of other market
centers; 4 and (ii) make technical
3 References to ISE Members in this filing refer to
DECN Subscribers who are ISE Members.
4 On October 1, 2009, the Exchange added new
fee categories for the INET order type. When a
member routes to Nasdaq using the INET order type
and removes liquidity on Tapes A or C, the member
incurs a fee of $0.0030 on either EDGA or EDGX.
Such situation yields Flag ‘‘L’’. The INET order type
sweeps the EDGA or EDGX book, and routes the
remainder to Nasdaq. If the order is marketable, it
removes liquidity from the EDGA or EDGX book, as
applicable, first. If the order is non-marketable, the
order posts on Nasdaq. With regards to a Member’s
use of the INET order type for Tapes A or C
securities, Members routing an ADV: (i) Less than
5,000,000 shares are currently charged $0.0030 per
share, as described in the schedule; (ii) equal to or
greater than 5,000,000 shares but less than
20,000,000 shares are currently charged $0.0027 per
share; (iii) equal to or greater than 20,000,000 shares
but less than 30,000,001 shares are currently
charged $0.0026 per share; and (iv) equal to or
greater than 30,000,001 shares are currently charged
$0.0025 per share. The rates, in all cases, are
calculated for shares removed from Nasdaq. The
Exchange believes that these tier-based rates incent
Members to sweep the EDGA or EDGX book first
and then offer a discounted rate to Nasdaq’s rates
if the remainder of the order is routed to Nasdaq.
These discounted rates arise in part from reduced
administrative costs associated with certain volume
levels. See Securities Exchange Act Release No.
60769 (October 2, 2009), 74 FR 51903 (October 8,
2009) (SR–ISE–2009–68).
In SR–ISE–2009–99, the Exchange amended its
fees in order to reflect changes to the actual
transaction fees assessed by away markets.
Specifically, the Exchange amended its fees
schedule to reflect changes to Nasdaq’s best
removal tier rate. For example, on November 1,
2009, the best removal tier rate increased on Nasdaq
from $0.0027 per share executed to $0.0028 per
share executed for Tape A & C securities. See
Securities Exchange Act Release No. 60959
(November 6, 2009), 74 FR 58672 (November 13,
2009)(SR–NASDAQ–2009–096). The Exchange
amended its fee schedule so that when Nasdaq’s
best removal tier rate changes, EDGA and EDGX’s
fees change as well, in lock step. The new language
reads as follows:
Subscribers routing an average daily volume
(‘‘ADV’’): (i) Less than 5,000,000 shares will be
charged $0.0030 per share, as described in the
schedule; (ii) equal to or greater than 5,000,000
shares but less than 20,000,000 shares will be
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changes to the fee schedule.5 The
changes made pursuant to SR–ISE–
2009–99 became operative on December
1, 2009.
In its capacity as a member of ISE,
DECN currently serves as an introducing
broker for the non-ISE Member
subscribers of DECN to access EDGX
and EDGA. DECN, as an ISE Member
and introducing broker, receives rebates
and is assessed charges from DECN for
transactions it executes on EDGX or
EDGA in its capacity as introducing
broker for non-ISE Members. Since the
amounts of such rebates and charges
were changed pursuant to SR–ISE–
2009–99, DECN wishes to make
corresponding changes to the amounts it
passes through to non-ISE Member
subscribers of DECN for which it acts as
introducing broker. As a result, the per
share amounts that non-ISE Member
subscribers receive and are charged will
be the same as the amounts that ISE
Members receive and are charged.
ISE is seeking accelerated approval of
this proposed rule change, as well an
effective date of December 1, 2009. ISE
represents that this proposal will ensure
that both ISE Members and non-ISE
Members (by virtue of the pass-through
described above) will in effect receive
and be charged equivalent amounts and
that the imposition of such amounts
will begin on the same December 1,
2009 start date.
2. Statutory Basis
The Exchange believes that the
proposed rule change is consistent with
charged Nasdaq’s best removal tier rate per share;
(iii) equal to or greater than 20,000,000 shares but
less than 30,000,001 shares will be charged
Nasdaq’s best removal tier rate—$0.0001 per share;
and (iv) equal to or greater than 30,000,001 shares
will be charged Nasdaq’s best removal tier rate—
$0.0002 per share. The rates, in all cases, are
calculated for shares removed from Nasdaq.
(emphasis added)
For the month of December this equates to
$0.0028 per share for (ii), above, $0.0027 per share
for (iii), above, and $0.0026 per share for (iv), as
described above.
5 In SR–ISE–2009–99, the Exchange made
technical changes to the fee schedule. Effective
December 1, 2009, the Exchange amended the
meaning of several flags. In particular, the N and
W flags are no longer used to reflect activity outside
of regular market hours. The Exchange adopted
flags 3–7 to reflect pre- and post-market activity.
See Securities Exchange Act Release No. 60914
(November 2, 2009), 74 FR 57726 (November 9,
2009)(SR–ISE–2009–88). In SR–ISE–2009–99, the
Exchange corrected a reference in footnote 1 to the
fee schedule to reflect this change. The new
language reads as follows:
In addition, subscribers can also qualify for a
rebate of $0.0032 per share for all liquidity posted
on EDGX if they add or route at least 10,000,000
shares of average daily volume prior to 9:30 AM or
after 4:00 PM (includes all flags except 6) AND add
a minimum of 75,000,000 shares of average daily
volume on EDGX in total, including during both
market hours and pre and post-trading hours.
(emphasis added)
E:\FR\FM\09DEN1.SGM
09DEN1
Agencies
[Federal Register Volume 74, Number 235 (Wednesday, December 9, 2009)]
[Notices]
[Pages 65175-65178]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E9-29321]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 29066; File No. 812-13640]
PNC Bank, National Association; Notice of Application
December 3, 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 (``Act'') granting an exemption from
section 18(f)(1) of the Act.
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Applicant: PNC Bank, National Association (``PNC Bank'').
Summary of the Application: Applicant requests an order that that would
permit certain registered open-end management investment companies to
participate as borrowers in loan facilities to be administered by PNC
Bank.
Filing Dates: The application was filed on March 11, 2009, and amended
on November 30, 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 28, 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 by
writing to the Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street, NE., Washington, DC 20549-1090. Applicant, PNC Bank, National
Association, One PNC Plaza, 21st Floor, 249 Fifth Avenue, Pittsburgh,
PA 15222.
FOR FURTHER INFORMATION CONTACT: Lewis B. Reich, Senior Counsel, at
(202) 551-6919, or Mary Kay Frech, Branch Chief, at (202) 551-6821
(Office of Investment Company Regulation, Division of Investment
Management).
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 for 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. PNC Bank, a wholly-owned indirect subsidiary of The PNC
Financial Services Group, Inc. (``PNC Financial''), is a national
banking association with its principal office in Pittsburgh,
Pennsylvania. PNC Financial is one of the largest diversified financial
services companies in the United States based on assets, with
businesses engaged in retail banking, corporate and institutional
banking, asset management, and global fund processing services. PNC
Bank has extensive experience and expertise as an administrator of
asset-backed commercial paper programs, having administered the
commercial paper program of Market Street Funding LLC (``Market
Street''), a limited purpose securitization entity, since 1995.
2. Market Street is organized as a Delaware limited liability
company and is exempt from registration under the Act in reliance on
section 3(c)(7) of the Act. All of the membership interests of Market
Street are owned by Market Street Holding Corporation (``MSHC''). All
of the capital stock of MSHC is owned by Amacar Investments, LLC, an
entity unaffiliated with PNC Financial. As of September 30, 2009,
Market Street's purchase commitments totaled approximately $6.0
billion, and its outstanding loans and other assets totaled
approximately $3.3 billion.
3. PNC Bank requests relief to permit any registered open-end
management investment company or series thereof to participate from
time to time as a borrower (``Borrowing Fund'') in a loan facility to
be administered by PNC Bank (``Loan Facility''). Market Street, which
would be the principal source of financing for each Loan Facility, will
issue commercial paper and will utilize liquidity support provided by
highly rated financial institutions that are ``banks'' within the
meaning of section 2(a)(5) of the Act (``Liquidity Providers''). Market
Street issues unsecured commercial paper with maturities of up to 270
days (``Promissory Notes'') to fund uncommitted purchases of and
uncommitted loans secured by various types of financial assets.
4. The Promissory Notes issued by Market Street are sold only to
institutional investors that are ``accredited investors'' as defined in
rule 501(a) of Regulation D under the Securities Act of 1933 (the
``Securities Act'') or to ``qualified institutional buyers'' as defined
in rule 144A under the Securities Act. PNC Bank, which has extensive
experience as an administrator of asset-backed commercial paper
programs, will perform the administrative functions for Market Street.
PNC Bank will negotiate the business arrangements on behalf of Market
Street, including loan amounts, interest rates, and fees. PNC Bank will
act as agent for Market Street and the related Liquidity Providers
under the agreements executed with each Borrowing Fund and in such
capacity will exercise rights and enforce remedies on behalf of Market
Street and Liquidity Providers.
5. As security for a loan, Borrowing Funds will pledge assets
(``Pledged Assets'') for the benefit of Market Street and the
applicable Liquidity Provider. The Pledged Assets will meet eligibility
criteria set by Market Street that will be consistent with the
Borrowing Fund's investment objectives and policies. For each loan
transaction, PNC Bank will evaluate: (a) The type and nature of a
Borrowing Fund's Pledged Assets to determine whether they meet Market
Street's standards for collateral; (b) the operations and history of
the Borrowing Fund; and (c) the financial position and operations of
the Borrowing Fund's investment adviser.
6. Applicant states that Market Street would make loans to a
Borrowing Fund on an uncommitted basis and the applicable Liquidity
Provider would be obligated to make loans to the Borrowing Fund in the
event Market Street was unable or unwilling to make such loans. Market
Street will have the right in its sole discretion to require the
Liquidity Providers to acquire outstanding loans made by Market Street
to a Borrowing Fund at an agreed-upon amount determined pursuant to the
formula set forth in the related agreements. Applicant states that
these liquidity support arrangements provide additional assurances to
the holders of Promissory Notes that they will be paid at maturity, as
well as protection for Borrowing Funds.
7. Applicant states that Market Street currently provides financing
for assets originated by customers of PNC Bank and their affiliates as
sellers of those assets to Market Street. The assets purchased by
Market Street include financial assets and securities backed by
financial assets. Some transactions are
[[Page 65176]]
structured as loans to the sellers, secured by the assets being
financed, or as agreements to acquire future cash flows from asset
interests. In addition to purchasing interests in pools of assets
directly, Market Street has purchased publicly registered, rule 144A
eligible or privately placed asset-backed securities in open market or
privately negotiated transactions. Market Street finances its purchase
of asset pools primarily through the issuance of its Promissory Notes.
All loans made by Market Street to the Borrowing Funds are not expected
to be in the aggregate more than 20% of Market Street's outstanding
loans and other assets.
8. Applicant represents that the revolving credit and security
agreement of a Loan Facility, which will be negotiated by the parties,
will contain representations, warranties, covenants and events of
default that are customary for secured loan transactions involving
registered open-end management investment companies, as well as such
other terms that are specific to a particular Borrowing Fund and the
conduct of its business. A Borrowing Fund will have the right at any
time to prepay any outstanding loans under its Loan Facility on certain
monthly or quarterly dates without any premium or penalty. The Pledged
Assets of a Borrowing Fund will be available solely to secure the
repayment of the loans and other outstanding obligations of that
Borrowing Fund under the Loan Facility. Applicant further states that a
Borrowing Fund would have the same rights and remedies under state and
federal law with respect to a Loan Facility from Market Street that it
would have with respect to a comparable loan from a bank. PNC Bank also
states that the arrangements with the Liquidity Providers protect
Borrowing Funds by providing an alternative source of financing in the
event Market Street is unable to continue lending funds.
9. Before a Loan Facility is established, a Borrowing Fund must
represent, in writing, to PNC Bank, Market Street and the Liquidity
Providers that: (a) Its policies permit borrowing and, if applicable,
the use of leverage; (b) all borrowing transactions pursuant to the
Loan Facility will be subject to the requirements of the Act, the rules
and regulations thereunder, and any other applicable interpretations or
guidance from the Commission or its staff; and (c) each borrowing
transaction will be conducted in accordance with all applicable
representations and conditions of the application. Before a Borrowing
Fund may participate in a Loan Facility, its board of directors or
trustees (``Board''), 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 Directors''), will determine that
its participation is consistent with the Borrowing Fund's investment
objectives and policies and in the best interests of the Borrowing Fund
and its shareholders. Each Borrowing Fund's Board, including a majority
of the Disinterested Directors, will also adopt procedures for
evaluating and making certain determinations concerning the terms of
each loan transaction between the Borrowing Fund and Market Street.
10. PNC Bank states that the proposed Loan Facilities would enable
Borrowing Funds to borrow money from Market Street at lower cost than
obtaining comparable loans from a bank. PNC Bank states that Market
Street's cost of funds is lower than that of banks, and this advantage
will be passed on to the Borrowing Funds.\1\
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\1\ The rate at which a Liquidity Provider would make a loan to
a Borrowing Fund would not be as favorable as that of Market Street,
but would be comparable to the rates on secured lines of credit from
banks. PNC Bank anticipates that Market Street, rather than a
Liquidity Provider, will be the lender to the Borrowing Funds under
a Loan Facility, absent extenuating circumstances.
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Applicant's Legal Analysis
1. Section 18(f)(1) of the Act prohibits an open-end investment
company from issuing any senior security except that a company is
permitted to borrow from any bank, if immediately after the borrowing,
there is an asset coverage of at least 300% for all borrowings of the
company.\2\ Section 2(a)(5) defines ``bank'' as a depository
institution, a branch or agency of a foreign bank, a member bank of the
Federal Reserve System, a banking institution or other trust company
that, as a substantial portion of its business, receives deposits or
exercises fiduciary powers similar to those permitted to national
banks. Applicant states that while Market Street engages in many of the
same business activities as banks, it is not a ``bank'' under this
definition.
---------------------------------------------------------------------------
\2\ Under section 18(g) of the Act, the term ``senior security''
includes any bond, debenture, note, or similar obligation or
instrument constituting a security and evidencing indebtedness.
---------------------------------------------------------------------------
2. Section 6(c) of the Act permits the Commission to exempt any
person or transaction or any class or classes of persons or
transactions from any provision or provisions 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. PNC
Bank requests exemptive relief from section 18(f)(1) solely to the
extent necessary to allow a Borrowing Fund to borrow from Market
Street. PNC Bank believes that permitting the Borrowing Funds to borrow
from Market Street is fully consistent with the purposes and policies
of section 18(f)(1) and would not implicate the concerns underlying
that provision.
3. PNC Bank states that section 18(f) of the Act reflects
Congressional concern about excessive borrowing and the issuance of
senior securities by open-end investment companies because these
practices could unduly increase the speculative character and
investment risk of junior securities. PNC Bank notes that Borrowing
Funds would remain subject to the 300% asset coverage requirement in
section 18(f)(1) of the Act for all borrowings, including those from
Market Street. PNC Bank further represents that Market Street's loans
will not impose any restrictions on a Borrowing Fund's shareholders
that are different from those imposed by a collateralized bank loan.
Finally, PNC Bank argues that permitting a Borrowing Fund to borrow
from Market Street rather than a bank is expected to reduce its costs
of borrowing, which should decrease the risk that a Borrowing Fund's
borrowing costs will exceed the return from securities purchased with
borrowed money and lessen any related incentive to purchase more
speculative portfolio securities to cover those costs.
4. PNC Bank states that section 18(f) of the Act also limited open-
end investment companies to borrowing from traditional institutional
lending sources out of a Congressional concern that public holders of
senior securities might be unaware that they were much riskier
instruments than senior securities issued by operating companies.
Senior securities of investment companies typically were secured by
assets that were subject to wide fluctuations in value. Further, common
shareholders could redeem at any time, which also might affect an open-
end investment company's ability to repay its outstanding debt.
5. PNC Bank argues that the Loan Facilities do not involve the type
of senior security holder that section 18(f)(1) of the Act was designed
to protect and that the structure of the Loan Facilities and Market
Street provide sufficient protection to the parties that face any risk
of loss by lending to an open-end investment company. Market Street is
administered by PNC Bank, which applicant states has expertise in
administering loans collateralized by financial instruments that equals
or exceeds the expertise of
[[Page 65177]]
most banks. The Liquidity Providers are banks as defined by the Act and
thus not the type of potential senior security holder that Congress
believed needed protection. PNC Bank states that the Promissory Notes
are general obligations of Market Street and loans to Borrowing Funds
are not expected to exceed 20% of Market Street's outstanding assets
and loans to any individual Borrowing Fund are not expected to exceed
10% of Market Street's assets. Any risk of loss on the Promissory Notes
posed by loans to registered open-end investment companies is further
reduced by PNC Bank's expertise, Market Street's ability to sell the
loans under the Loan Facilities to the Liquidity Providers, Market
Street's external liquidity and credit enhancement sources and the
capital of Market Street.
6. Applicant states that section 18(f) also reflects a concern that
complex capital structures may permit insiders to manipulate the
allocation of expenses and profits; facilitate control of the
investment company by junior security shareholders with little
investment; and make it difficult for investors in the investment
company to understand what their stock is worth. PNC Bank states that
borrowing from Market Street would not facilitate pyramiding of control
or manipulative reallocation of expenses and profits. Further, PNC Bank
believes that borrowings from Market Street would not be any more
difficult for shareholders of a Borrowing Fund to understand than bank
borrowings.
7. Applicant also states that section 18(f) reflects a concern that
existed when the Act was adopted that borrowings by open-end investment
companies could be used to invest in securities without being subject
to limitations of the Board of Governors of the Federal Reserve System
(the ``FRB'') on the amount of credit that could be used for these
purposes (``margin requirements''). Under Regulations U and T under the
Securities Exchange Act of 1934, in effect prior to enactment of the
Act, only borrowings for such purposes made by a domestic bank or
broker-dealer were subject to margin requirements. Regulation U as
currently in effect imposes restrictions on banks and lenders other
than broker-dealers that extend credit to borrowers for the purpose of
purchasing or carrying margin stock. If Market Street makes loans to a
Borrowing Fund in excess of the threshold amounts under Regulation U,
Market Street will register with the FRB as a nonbank lender and would
be subject to the same credit restrictions as a bank under Regulation
U.
8. Finally, applicant believes the requested relief will benefit
Borrowing Funds by providing them with an alternative, lower-cost
source of financing. For all of these reasons and in light of the
protections afforded by the conditions set forth below, PNC Bank
believes that permitting Borrowing Funds to borrow from Market Street
would be in the best interests of the Borrowing Funds and their
shareholders, 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.
Applicant's Conditions
The applicant agrees that any order granting the requested relief
will be subject to the following conditions:
1. All Borrowing Funds will comply with the asset coverage
requirements in section 18(f)(1) of the Act, including with respect to
all borrowings from Market Street.
2. A loan by Market Street to a Borrowing Fund will be at an
interest rate equal to Market Street's cost of funds (i.e., the
weighted average Promissory Note rate plus dealer commissions).
3. Before a Borrowing Fund may participate in a Loan Facility, the
Borrowing Fund's Board, including a majority of the Disinterested
Directors, will determine that participation in the Loan Facility is
consistent with the Borrowing Fund's investment objectives and policies
and is in the best interests of the Borrowing Fund and its
shareholders. In addition, a Borrowing Fund will disclose in its
statement of additional information all material facts about its
participation in the Loan Facility.
4. Before a Borrowing Fund may participate in a Loan Facility, its
Board, including a majority of the Disinterested Directors, will adopt
procedures governing the Borrowing Fund's participation in the Loan
Facility (``Procedures''). In addition to any other provisions the
Board may find necessary or appropriate to be included in the
Procedures, the Procedures will require that, before a Borrowing Fund
may enter into loan transactions with Market Street, the Board,
including a majority of the Disinterested Directors, will determine
that:
a. The borrowing is in the best interests of the Borrowing Fund and
its shareholders;
b. The borrowing and pledge of assets are consistent with the
Borrowing Fund's investment objectives and policies;
c. The total anticipated cost of the Loan Facility (including fees
and interest) does not exceed the total anticipated costs of comparable
financing alternatives that are available to the Borrowing Fund;
d. The asset eligibility criteria for the Loan Facility are
consistent with the Borrowing Fund's investment objectives and
policies; and
e. The Borrowing Fund's investments, consistent with the asset
eligibility criteria and any other requirements of participating in the
Loan Facility, will be in the best interests of the Borrowing Fund and
its shareholders.
5. If Market Street determines (a) to require the Liquidity
Providers to acquire from Market Street outstanding loans made to a
Borrowing Fund, or (b) not to extend additional loans to a Borrowing
Fund, the Board of the Borrowing Fund, including a majority of the
Disinterested Directors, will be notified promptly. As soon as
practicable, the Board, including a majority of the Disinterested
Directors, must determine whether it is in the best interests of the
Borrowing Fund and its shareholders to continue to participate in the
Loan Facility or to terminate the Borrowing Fund's participation in the
Loan Facility in accordance with its terms.
6. At each regular quarterly meeting, the Board, including a
majority of the Disinterested Directors, will (a) review a Borrowing
Fund's loan transactions under its Loan Facility during the preceding
quarter, including the terms of each transaction, and (b) determine
whether the transactions were effected in compliance with the
Procedures and the terms and conditions of the order. At least
annually, the Board, including a majority of the Disinterested
Directors, will (a) with respect to a Borrowing Fund's continued
participation in a Loan Facility, make the determinations required in
condition 3 above, and (b) approve such changes to the Procedures as it
deems necessary or appropriate.
7. A Borrowing Fund will maintain and preserve permanently in an
easily accessible place a written copy of the Procedures and any
modifications to the Procedures. The Borrowing Fund will maintain and
preserve for a period of not less than six years from the end of the
fiscal year in which any transaction with a Loan Facility occurred, the
first two years in an easily accessible place, a written record of each
transaction setting forth a description of the terms of the
transaction, including the amount, maturity, and the rate of interest
on the loan, and all information upon which the determinations required
by these conditions were made.
8. The applicant will not enter into a Loan Facility with any
Borrowing Fund if, at the time of such transaction, the
[[Page 65178]]
applicant, Market Street or any Liquidity Provider is an affiliated
person of that Borrowing Fund, within the meaning of section 2(a)(3) of
the Act, or an affiliated person of any affiliated person of that
Borrowing Fund.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E9-29321 Filed 12-8-09; 8:45 am]
BILLING CODE 8011-01-P