ShariahShares Exchange-Traded Fund Trust, et al.; Notice of Application, 5814-5821 [2010-2381]
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Federal Register / Vol. 75, No. 23 / Thursday, February 4, 2010 / Notices
Applicant’s Address: 20550 Maxim
Parkway, Orlando, FL 32833.
Nuveen Washington Premium Income
Municipal Fund [File No. 811–7488]
Summary: Applicant, a closed-end
investment company, seeks an order
declaring that it has ceased to be an
investment company. On August 12,
1999, applicant transferred its assets to
Nuveen Premium Income Municipal
Fund 4, Inc., based on net asset value.
Applicant’s preferred shareholders
received one share of municipal auction
rate cumulative preferred shares
(‘‘preferred shares’’) of the acquiring
fund for each preferred share of
applicant. Expenses of $139,950
incurred in connection with the
reorganization were paid by applicant.
Filing Date: The application was filed
on December 16, 2009.
Applicant’s Address: 333 West
Wacker Dr., Chicago, IL 60606.
Scudder Municipal Bond Fund Inc.
[File No. 811–21255]; Scudder New
York Municipal Bond Fund Inc. [File
No. 811–21354]; Scudder California
Municipal Bond Fund Inc. [File No.
811–21355]; DWS Dreman Enhanced
Total Return Fund Inc. [File No. 811–
22100]
Summary: Each applicant, a closedend investment company, seeks an
order declaring that it has ceased to be
an investment company. Applicants
have never made a public offering of
their securities and do not propose to
make a public offering or engage in
business of any kind.
Filing Date: The applications were
filed on December 7, 2009.
Applicants’ Address: 345 Park Ave.,
New York, NY 10154.
Oppenheimer Dividend Growth Fund
[File No. 811–21718]
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Summary: Applicant seeks an order
declaring that it has ceased to be an
investment company. On November 13,
2008, applicant transferred its assets to
Oppenheimer Rising Dividends Fund,
based on net asset value. Expenses of
$57,964 incurred in connection with the
reorganization were paid by applicant.
Filing Date: The application was filed
on December 16, 2009.
Applicant’s Address: 6803 S. Tucson
Way, Centennial, CO 80112.
2009, each applicant made a liquidating
distribution to its shareholders, based
on net asset value. BlackRock Broad
Investment Grade 2009 Term Trust Inc.
paid expenses of approximately $21,612
incurred in connection with its
liquidation. BCT Subsidiary, Inc.
incurred no expenses in connection
with its liquidation.
Filing Date: The applications were
filed on January 5, 2010.
Applicants’ Address: 100 Bellevue
Parkway, Wilmington, DE 19809.
Calvert Municipal Fund, Inc. [File No.
811–6525]
Summary: Applicant seeks an order
declaring that it has ceased to be an
investment company. On July 31, 2009,
applicant transferred its assets to Calvert
Tax-Free Bond Fund, a series of Calvert
Tax-Free Reserves, based on net asset
value. Expenses of $3,114 incurred in
connection with the reorganization were
paid by applicant.
Filing Date: The application was filed
on January 5, 2010.
Applicant’s Address: 4550
Montgomery Ave., Suite 1000N,
Bethesda, MD 20814.
RidgeWorth Variable Trust [File No.
811–9032]
Summary: Applicant seeks an order
declaring that it has ceased to be an
investment company. On April 27,
2009, applicant made a liquidating
distribution to its shareholders, based
on net asset value. Expenses of
approximately $5,758 incurred in
connection with the liquidation were
paid by applicant.
Filing Dates: The application was
filed on August 31, 2009, and amended
on November 17, 2009.
Applicant’s Address: 3435 Stelzer
Road, Columbus, OH 43219.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. 2010–2380 Filed 2–3–10; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
29127; 812–13559]
BlackRock Broad Investment Grade
2009 Term Trust Inc. [File No. 811–
7250]; BCT Subsidiary, Inc. [File No.
811–9703]
ShariahShares Exchange-Traded Fund
Trust, et al.; Notice of Application
Summary: Each applicant, a closedend investment company, seeks an
order declaring that it has ceased to be
an investment company. On October 29,
AGENCY: Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 6(c) of the
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January 29, 2010.
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Investment Company Act of 1940 (the
‘‘Act’’) for an exemption from sections
2(a)(32), 5(a)(1), 22(d) and 22(e) of the
Act and rule 22c–1 under the Act, under
section 12(d)(1)(J) of the Act for an
exemption from sections 12(d)(1)(A) and
(B) of the Act, and under sections 6(c)
and 17(b) of the Act for an exemption
from sections 17(a)(1) and (a)(2) of the
Act.
SUMMARY OF APPLICATION: Applicants
request an order that would permit (a)
certain open-end management
investment companies and their series
to issue shares (‘‘Fund Shares’’) that can
be redeemed only in large aggregations
(‘‘Creation Unit Aggregations’’); (b)
secondary market transactions in Fund
Shares to occur at negotiated prices; (c)
certain series to pay redemption
proceeds, under certain circumstances,
more than seven days after the tender of
Fund Shares for redemption; (d) certain
affiliated persons of the series to deposit
securities into, and receive securities
from, the series in connection with the
purchase and redemption of Creation
Unit Aggregations; and (e) certain
registered management investment
companies and unit investment trusts
outside of the same group of investment
companies as the series to acquire Fund
Shares.
APPLICANTS: ShariahShares ExchangeTraded Fund Trust (the ‘‘Trust’’) and
Florentez Investment Management, Inc.
(the ‘‘Adviser’’).
FILING DATES: The application was filed
on July 31, 2008, and amended on
September 16, 2009, and January 29,
2010. Applicants have agreed to file an
amendment during the notice period,
the substance of which is reflected in
this notice.
HEARING OR NOTIFICATION OF HEARING: An
order granting the application will be
issued unless the Commission orders a
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on February 19, 2010 and
should be accompanied by proof of
service on applicants, in the form of an
affidavit, or for lawyers, a certificate of
service. Hearing requests should state
the nature of the writer’s interest, the
reason for the request, and the issues
contested. Persons who wish to be
notified of a hearing may request
notification by writing to the
Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F
Street, NE., Washington, DC 20549–
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1090; Applicants, 12 Brillantez, Irvine,
CA 92620.
FOR FURTHER INFORMATION CONTACT:
Bruce R. MacNeil, Senior Counsel at
(202) 551–6817, or Julia Kim Gilmer,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Applicants’ Representations
1. The Trust is registered as an openend management investment company
and is organized as a Delaware statutory
trust. The Trust will initially offer two
series (‘‘Initial Index Funds’’), each of
which will track an index of selected
equity securities.1 Applicants may
establish one or more registered
investment companies in addition to the
Trust that may be formed as a separate
trust or a separate series of the Trust, or
one or more trusts in the future (‘‘Future
Index Funds,’’ collectively with the
Initial Index Funds, the ‘‘Index Funds’’).
Each Future Index Fund will be advised
by the Adviser or an entity controlling,
controlled by, or under common control
with the Adviser, and comply with the
terms and conditions stated in the
application.2
2. The Adviser will serve as the
investment adviser to the Index Funds.
The Adviser will be registered as an
investment adviser under the
Investment Advisers Act of 1940
(‘‘Advisers Act’’) prior to the
commencement of investment
operations of any Index Fund. The
Adviser may enter into sub-advisory
agreements with one or more subadvisers with respect to the Index Funds
(the ‘‘Sub-Advisers’’). Each Sub-Adviser
will be registered under the Advisers
Act. A broker-dealer registered under
the Securities Exchange Act of 1934 (the
‘‘Exchange Act’’ and such broker-dealer,
a ‘‘Broker’’) will serve as the principal
underwriter and distributor for the
Creation Unit Aggregations of Fund
Shares (‘‘Distributor’’). The Distributor
will not be affiliated with the Adviser or
1 The Initial Index Funds are ShariahShares FTSE
USA Fund and ShariahShares FTSE Developed exU.S. Fund.
2 All existing entities that intend to rely on the
requested order have been named as applicants.
Any other existing or future entity that
subsequently relies on the order will comply with
the terms and conditions of the application.
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a national securities exchange as
defined in section 2(a)(26) of the Act
(‘‘Exchange’’).
3. Each Index Fund will hold certain
equity securities (‘‘Portfolio Securities’’)
selected to correspond generally to the
price and yield performance, before fees
and expenses, of a specified equity
securities index (an ‘‘Underlying
Index’’).3 Certain of the Underlying
Indicies will be comprised of equity
securities issued by domestic issuers
and non-domestic issuers meeting the
requirements for trading in U.S. markets
(‘‘Domestic Index’’). Other Underlying
Indicies may be comprised of foreign
equity securities or a combination of
domestic and foreign equity securities
(‘‘Foreign Index’’). Index Funds that
track Domestic Indices are referred to as
‘‘Domestic Funds’’ and Index Funds that
track Foreign Indices are referred to as
‘‘Foreign Funds.’’ No entity that creates,
compiles, sponsors or maintains an
Underlying Index (‘‘Index Provider’’) is
or will be an affiliated person, as
defined in section 2(a)(3) of the Act, or
an affiliated person of an affiliated
person, of the Trust, an Index Fund, the
Adviser, any Sub-Adviser to or
promoter of an Index Fund, or the
Distributor. The Index Provider to the
Initial Index Funds is FTSE Group.
4. The investment objective of each
Index Fund will be to provide
investment results, before fees and
expenses, that correspond generally to
the price and yield performance of its
Underlying Index.4 The value of each
Index Fund’s Underlying Index will be
disseminated every 15 seconds
throughout the trading day. An Index
Fund will utilize either a ‘‘replication’’
or ‘‘representative sampling’’ strategy
which will be disclosed with regard to
each Index Fund in its prospectus
(‘‘Prospectus’’).5 An Index Fund using a
3 The Underlying Indicies for the Initial Index
Funds are FTSE Shariah USA Index and FTSE
Shariah Developed ex U.S. Index.
4 Applicants represent that an Index Fund will
invest at least 80% of its total assets, exclusive of
securities lending collateral, in the component
securities that comprise its Underlying Index
(‘‘Component Securities’’) or, in the case of Foreign
Funds, Component Securities and depositary
receipts representing such securities. ‘‘Depositary
Receipts’’ will typically be American Depositary
Receipts but may include Global Depositary
Receipts and Euro Depositary Receipts. Each Index
Fund also may invest up to 20% of its assets in
certain futures, stock options, options on stock
index futures and swap contracts as related to its
respective Underlying Index and its Component
Securities, cash and cash equivalents, as well as in
stocks not included in its Underlying Index, but
which the Adviser or Sub-Adviser believes will
help the Index Fund track its Underlying Index.
5 All representations and conditions contained in
the application that require an Index Fund to
disclose particular information in the Index Fund’s
Prospectus and/or annual report shall be effective
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replication strategy will invest in the
Component Securities in its Underlying
Index in approximately the same
proportions as in the Underlying Index.
An Index Fund using a representative
sampling strategy will invest in some,
but not necessarily all of the Component
Securities.6 This may be the case, for
example, when there are practical
difficulties or substantial costs involved
in compiling an entire Underlying Index
basket that contains hundreds of
Component Securities, or in certain
instances, when a Component Security
is illiquid. Applicants anticipate that an
Index Fund that uses representative
sampling will not track the performance
of its Underlying Index with the same
degree of accuracy as an investment
vehicle that invests in every Component
Security of the Underlying Index with
the same weighting as the Underlying
Index. Applicants expect that each
Index Fund will have a tracking error
relative to the performance of its
Underlying Index of less than 5 percent.
5. Funds Shares will be sold at a price
between $40 and $250 in Creation Unit
Aggregations which will have an initial
price range of $1,000,000 to
$25,000,000. All orders to purchase
Creation Unit Aggregations must be
placed with the Distributor by or
through a party that has entered into an
agreement with the Distributor
(‘‘Authorized Participant’’). The
Distributor will be responsible for
transmitting the orders to the Index
Funds. An Authorized Participant must
be either: (a) A broker-dealer or other
participant in the continuous net
settlement system of the National
Securities Clearing Corporation, a
clearing agency registered with the
Commission, or (b) a participant in the
Depository Trust Company (‘‘DTC’’, and
such participant, ‘‘DTC Participant’’).
Fund Shares generally will be sold in
Creation Unit Aggregations in exchange
for an in-kind deposit by the purchaser
of a portfolio of securities designated by
the Adviser or the Sub-Adviser to
correspond generally to the price and
yield performance of the relevant
Underlying Index (the ‘‘Deposit
Securities’’), together with the deposit of
a specified cash payment (‘‘Balancing
Amount’’). The Balancing Amount is an
amount equal to the difference between
with respect to the Index Fund until the time that
the Index Fund complies with disclosure
requirements adopted by the Commission in
Investment Company Act Release No. 28584 (Jan.
13, 2009).
6 Under the representative sampling strategy,
stocks are selected for inclusion in an Index Fund
to have aggregate investment characteristics,
fundamental characteristics, and liquidity measures
similar to those of the Index Fund’s Underlying
Index taken in its entirety.
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(a) the net asset value (‘‘NAV’’) (per
Creation Unit Aggregation) of an Index
Fund and (b) the total aggregate market
value (per Creation Unit Aggregation) of
the Deposit Securities.7 An Index Fund
may permit a purchaser of Creation Unit
Aggregations to substitute cash in lieu of
depositing some or all of the requisite
Deposit Securities if the Adviser or SubAdviser believed such method would
reduce the Index Fund’s transaction
costs or enhance the Index Fund’s
operating efficiency.8
6. An investor purchasing or
redeeming a Creation Unit Aggregation
from an Index Fund will be charged a
fee (‘‘Transaction Fee’’) to prevent the
dilution of the interests of the remaining
shareholders resulting from costs in
connection with the purchase or
redemption of Creation Unit
Aggregations.9 The exact amounts of
Transaction Fees relevant to each Index
Fund (including the maximum
Transaction Fee) will be fully disclosed
in the Prospectus of such Index Fund.
The method for calculating the
Transaction Fees will be disclosed in
each Prospectus or statement of
additional information (‘‘SAI’’). The
Distributor will be responsible for
delivering a Prospectus to those persons
purchasing Creation Unit Aggregations,
and for maintaining records of both the
orders placed with it and the
confirmations of acceptance furnished.
In addition, the Distributor will
maintain a record of the instructions
7 Each Index Fund will sell and redeem Creation
Unit Aggregations on a ‘‘Business Day’’ which
includes any day that an Index Fund is required to
be open under Section 22(e) of the Act. Each
Business Day, prior to the opening of trading on the
primary listing Exchange, the list of names and
amount of each security constituting the current
Deposit Securities and the Balancing Amount,
effective as of the previous Business Day, will be
made available. Any Exchange on which Fund
Shares are listed will disseminate, every 15 seconds
during its regular trading hours, through the
facilities of the Consolidated Tape Association, an
amount per Fund Share representing the sum of the
estimated Balancing Amount and the current value
of the Deposit Securities.
8 Applicants state that in some circumstances or
in certain countries, it may not be practicable or
convenient, or permissible under the laws of certain
countries or the regulations of certain foreign stock
exchanges, for a Foreign Fund to operate
exclusively on an ‘‘in-kind’’ basis. Applicants also
note that when a substantial rebalancing of a
Foreign Fund’s portfolio is required, the Adviser or
Sub-Adviser might prefer to receive cash rather
than stocks so that the Foreign Fund may avoid
transaction costs involved in liquidating part of its
portfolio to achieve the rebalancing.
9 Where an Index Fund permits a purchaser to
substitute cash in lieu of depositing a portion of the
requisite Deposit Securities, the purchaser may be
assessed a higher Transaction Fee to cover the cost
of purchasing such Deposit Securities, including
operational, processing and brokerage costs, and
part or all of the spread between the expected bid
and the offer side of the market relating to such
Deposit Securities.
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given to the applicable Index Fund to
implement the delivery of Fund Shares.
7. Purchasers of Fund Shares in
Creation Unit Aggregations may hold
such Fund Shares or may sell such
Fund Shares into the secondary market.
Fund Shares will be listed and traded
on an Exchange. It is expected that one
or more member firms of a listing
Exchange will be designated to act as a
specialist or market maker and maintain
a market for Fund Shares trading on the
Exchange (each a ‘‘Market Maker’’).
Prices of Fund Shares trading on an
Exchange will be based on the current
bid/offer market. Fund Shares sold in
the secondary market will be subject to
customary brokerage commissions and
charges.
8. Applicants expect that purchasers
of Creation Unit Aggregations will
include institutional investors and
arbitrageurs (which could include
institutional investors). A Market
Maker, in providing a fair and orderly
secondary market for the Fund Shares,
also may purchase Creation Unit
Aggregations for use in its marketmaking activities. Applicants expect
that secondary market purchasers of
Fund Shares will include both
institutional investors and retail
investors.10 Applicants expect that the
price at which Fund Shares trade will
be disciplined by arbitrage
opportunities created by the ability to
continually purchase or redeem
Creation Unit Aggregations at their
NAV, which should ensure that Fund
Shares will not trade at a material
discount or premium.
9. Fund Shares will not be
individually redeemable, and owners of
Fund Shares may acquire those Fund
Shares from the Index Fund, or tender
such Fund Shares for redemption to the
Index Fund, in Creation Unit
Aggregations only. To redeem, an
investor will have to accumulate enough
Fund Shares to constitute a Creation
Unit Aggregation. Redemption orders
must be placed by or through an
Authorized Participant. An investor
redeeming a Creation Unit Aggregation
generally will receive (a) Portfolio
Securities designated to be delivered for
Creation Unit Aggregation redemptions
(‘‘Fund Securities’’) on the date that the
request for redemption is made11 and (b)
10 Fund Shares will be registered in book-entry
form only. DTC or its nominee will be the registered
owner of all outstanding Fund Shares. DTC or DTC
Participants will maintain records reflecting
beneficial owners of Fund Shares.
11 As a general matter, the Deposit Securities and
Fund Securities will correspond pro rata to the
securities held by each Index Fund, but Fund
Securities received on redemption may not always
be identical to Deposit Securities deposited in
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a ‘‘Cash Redemption Payment,’’
consisting of an amount calculated in
the same manner as the Balancing
Amount, although the actual amount of
the Cash Redemption Payment may
differ from the Balancing Amount if the
Fund Securities are not identical to the
Deposit Securities on that day. An
investor may receive the cash equivalent
of a Fund Security in certain
circumstances, such as if the investor is
constrained from effecting transactions
in the security by regulation or policy.
10. Neither the Trust nor any Index
Fund will be marketed or otherwise
held out as an ‘‘open-end investment
company’’ or a ‘‘mutual fund.’’ Instead,
each Index Fund will be marketed as an
‘‘exchange-traded fund,’’ an ‘‘investment
company,’’ a ‘‘fund,’’ or a ‘‘trust.’’ All
marketing materials that describe the
features or method of obtaining, buying
or selling Creation Unit Aggregations or
Fund Shares traded on an Exchange, or
refer to redeemability, will prominently
disclose that Fund Shares are not
individually redeemable and that the
owners of Fund Shares may purchase or
redeem Fund Shares from the Index
Fund in Creation Unit Aggregations
only. The same approach will be
followed in the SAI, shareholder reports
and investor educational materials
issued or circulated in connection with
the Fund Shares. The Index Funds will
provide copies of their annual and semiannual shareholder reports to DTC
Participants for distribution to
shareholders.
Applicants’ Legal Analysis
1. Applicants request an order under
section 6(c) of the Act for an exemption
from sections 2(a)(32), 5(a)(1), 22(d), and
22(e) of the Act and rule 22c-1 under the
Act, under sections 6(c) and 17(b) of the
Act for an exemption from sections
17(a)(1) and 17(a)(2) of the Act, and
under section 12(d)(1)(J) of the Act for
an exemption from sections 12(d)(1)(A)
and (B) of the Act.
2. Section 6(c) of the Act provides that
the Commission may exempt any
person, security or transaction, or any
class of persons, securities or
transactions, from any provision of the
Act, if and to the extent that such
exemption is necessary or appropriate
in the public interest and consistent
with the protection of investors and the
purposes fairly intended by the policy
connection with the purchase of Creation Unit
Aggregations for the same day. The Index Funds
will comply with the Federal securities laws in
accepting Deposit Securities and satisfying
redemptions with Fund Securities, including that
the Deposit Securities and Fund Securities are sold
in transactions that would be exempt from
registration under the Securities Act of 1933.
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and provisions of the Act. Section 17(b)
of the Act authorizes the Commission to
exempt a proposed transaction from
section 17(a) of the Act if evidence
establishes that the terms of the
transaction, including the consideration
to be paid or received, are reasonable
and fair and do not involve
overreaching on the part of any person
concerned, and the proposed
transaction is consistent with the
policies of the registered investment
company and the general provisions of
the Act. Section 12(d)(1)(J) of the Act
provides that the Commission may
exempt any person, security, or
transaction, or any class or classes of
persons, securities or transactions, from
any provisions of section 12(d)(1) if the
exemption is consistent with the public
interest and the protection of investors.
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Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an
‘‘open-end company’’ as a management
investment company that is offering for
sale or has outstanding any redeemable
security of which it is the issuer.
Section 2(a)(32) of the Act defines a
redeemable security as any security,
other than short-term paper, under the
terms of which the owner, upon its
presentation to the issuer, is entitled to
receive approximately his proportionate
share of the issuer’s current net assets,
or the cash equivalent. Because Fund
Shares will not be individually
redeemable, applicants request an order
that would permit the Index Funds to
register as open-end management
investment companies and issue Fund
Shares that are redeemable in Creation
Unit Aggregations only. Applicants state
that investors may purchase Fund
Shares in Creation Unit Aggregations
and redeem Creation Unit Aggregations
from each Index Fund. Applicants
further state that because Creation Unit
Aggregations may always be purchased
and redeemed at NAV, the market price
of the Fund Shares should not vary
substantially from their NAV.
Section 22(d) of the Act and Rule 22c1 under the Act
4. Section 22(d) of the Act, among
other things, prohibits a dealer from
selling a redeemable security, which is
currently being offered to the public by
or through a principal underwriter,
except at a current public offering price
described in the prospectus. Rule 22c-1
under the Act generally requires that a
dealer selling, redeeming or
repurchasing a redeemable security do
so only at a price based on its NAV.
Applicants state that secondary market
trading in Fund Shares will take place
at negotiated prices, not at a current
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offering price described in an Index
Fund’s Prospectus, and not at a price
based on NAV. Thus, purchases and
sales of Fund Shares in the secondary
market will not comply with section
22(d) of the Act and rule 22c-1 under
the Act. Applicants request an
exemption under section 6(c) from these
provisions.
5. Applicants assert that the concerns
sought to be addressed by section 22(d)
of the Act and rule 22c-1 under the Act
with respect to pricing are equally
satisfied by the proposed method of
pricing Fund Shares. Applicants
maintain that while there is little
legislative history regarding section
22(d), its provisions, as well as those of
rule 22c-1, appear to have been
designed to (a) prevent dilution caused
by certain riskless-trading schemes by
principal underwriters and contract
dealers, (b) prevent unjust
discrimination or preferential treatment
among buyers, and (c) ensure an orderly
distribution of investment company
shares by eliminating price competition
from dealers offering shares at less than
the published sales price and who could
pay investors a little more than the
published redemption price.
6. Applicants believe that none of
these purposes will be thwarted by
permitting Fund Shares to trade in the
secondary market at negotiated prices.
Applicants state that (a) secondary
market trading in Fund Shares does not
directly involve Index Fund assets and
will not result in dilution of an
investment in Fund Shares, and (b) to
the extent different prices exist during
a given trading day, or from day to day,
such variances occur as a result of thirdparty market forces, such as supply and
demand. Therefore, applicants assert
that secondary market transactions in
Fund Shares will not lead to
discrimination or preferential treatment
among purchasers. Finally, applicants
contend that the proposed distribution
system will be orderly because
competitive forces in the marketplace
will ensure that the difference between
the market price of Fund Shares and
their NAV remains narrow.
Section 22(e)
7. Section 22(e) generally prohibits a
registered investment company from
suspending the right of redemption or
postponing the date of payment of
redemption proceeds for more than
seven days after the tender of a security
for redemption. Applicants state that
settlement of redemptions for a Foreign
Fund will be contingent not only on the
securities settlement cycle of the United
States market, but also on the delivery
cycles in local markets for the
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5817
underlying foreign securities held by a
Foreign Fund. Applicants state that
delivery cycles for transferring Portfolio
Securities to redeeming investors,
coupled with local market holiday
schedules, may require a delivery
process longer than seven calendar days
for the Foreign Funds. Applicants
request relief under section 6(c) of the
Act from section 22(e) to allow the
Foreign Funds to pay redemption
proceeds up to fourteen calendar days
after the tender of a Creation Unit
Aggregation for redemption. Except as
disclosed in the relevant Foreign Fund’s
Prospectus and/or SAI, applicants
expect that each Foreign Fund will be
able to deliver redemption proceeds
within seven days.12 With respect to
future Foreign Funds, applicants seek
the same relief from section 22(e) only
to the extent that circumstances similar
to those described in the application
exist.
8. Applicants state that section 22(e)
was designed to prevent unreasonable,
undisclosed and unforeseen delays in
the payment of redemption proceeds.
Applicants assert that the requested
relief will not lead to the problems that
section 22(e) was designed to prevent.
Applicants state that the SAI will
disclose those local holidays (over the
period of at least one year following the
date of the SAI), if any, that are
expected to prevent the delivery of
redemption proceeds in seven calendar
days, and the maximum number of
days, up to fourteen calendar days,
needed to deliver the proceeds for each
Foreign Fund. Applicants are not
seeking relief from section 22(e) with
respect to Foreign Funds that will not
effect in-kind purchases and
redemptions of Creation Unit
Aggregations.
Section 12(d)(1)
9. Section 12(d)(1)(A) of the Act, in
relevant part, prohibits a registered
investment company from acquiring
securities of an investment company if
such securities represent more than 3%
of the total outstanding voting stock of
the acquired company, more than 5% of
the total assets of the acquiring
company, or, together with the
securities of any other investment
companies, more than 10% of the total
assets of the acquiring company. Section
12(d)(1)(B) of the Act prohibits a
registered open-end investment
12 Rule 15c6–1 under the Exchange Act requires
that most securities transactions be settled within
three business days of the trade. Applicants
acknowledge that no relief obtained from the
requirements of section 22(e) will affect any
obligations applicants may have under rule
15c6–1.
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company, its principal underwriter and
any other broker-dealer from selling the
investment company’s shares to another
investment company if the sale will
cause the acquiring company to own
more than 3% of the acquired
company’s voting stock, or if the sale
will cause more than 10% of the
acquired company’s voting stock to be
owned by investment companies
generally.
10. Applicants request an exemption
to permit management investment
companies (‘‘Purchasing Management
Companies’’) and unit investment trusts
(‘‘Purchasing Trusts’’) registered under
the Act that are not sponsored or
advised by the Adviser or any entity
controlling, controlled by, or under
common control with the Adviser and
are not part of the same ‘‘group of
investment companies,’’ as defined in
section 12(d)(1)(G)(ii) of the Act, as the
Index Funds (collectively, ‘‘Purchasing
Funds’’) to acquire Fund Shares beyond
the limits of section 12(d)(1)(A).
Purchasing Funds do not include the
Index Funds. In addition, applicants
seek relief to permit the Index Funds or
any Broker to sell Fund Shares to a
Purchasing Fund in excess of the limits
of section 12(d)(1)(B).
11. Each Purchasing Management
Company will be advised by an
investment adviser within the meaning
of section 2(a)(20)(A) of the Act (the
‘‘Purchasing Fund Adviser’’) and may be
sub-advised by an adviser(s) within the
meaning of section 2(a)(20)(B) of the Act
(‘‘Purchasing Fund Sub-Adviser’’). Any
investment adviser to a Purchasing
Fund will be registered under the
Advisers Act. Each Purchasing Trust
will be sponsored by a sponsor
(‘‘Sponsor’’).
12. Applicants submit that the
proposed conditions to the relief
requested, including the requirement
that Purchasing Funds enter into an
agreement with an Index Fund for the
purchase of Fund Shares (a ‘‘Purchasing
Fund Agreement’’), adequately address
the concerns underlying the limits in
section 12(d)(1)(A) and (B), which
include concerns about undue influence
by a fund of funds over underlying
funds, excessive layering of fees and
overly complex structures. Applicants
believe that the requested exemption is
consistent with the public interest and
the protection of investors.
13. Applicants believe that neither the
Purchasing Funds nor a Purchasing
Fund Affiliate would be able to exert
undue influence over the Index
Funds.13 To limit the control that a
13 A ‘‘Purchasing Fund Affiliate’’ is a Purchasing
Fund Adviser, Purchasing Fund Sub-Adviser,
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17:31 Feb 03, 2010
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Purchasing Fund may have over an
Index Fund, applicants propose a
condition prohibiting a Purchasing
Fund Adviser or a Sponsor, any person
controlling, controlled by, or under
common control with a Purchasing
Fund Adviser or Sponsor, and any
investment company or issuer that
would be an investment company but
for sections 3(c)(1) or 3(c)(7) of the Act
that is advised or sponsored by a
Purchasing Fund Adviser or Sponsor, or
any person controlling, controlled by, or
under common control with a
Purchasing Fund Adviser or Sponsor
(‘‘Purchasing Fund Advisory Group’’)
from controlling (individually or in the
aggregate) an Index Fund within the
meaning of section 2(a)(9) of the Act.
The same prohibition would apply to
any Purchasing Fund Sub-Adviser, any
person controlling, controlled by or
under common control with the
Purchasing Fund Sub-Adviser, and any
investment company or issuer that
would be an investment company but
for sections 3(c)(1) or 3(c)(7) of the Act
(or portion of such investment company
or issuer) advised or sponsored by the
Purchasing Fund Sub-Adviser or any
person controlling, controlled by or
under common control with the
Purchasing Fund Sub-Adviser
(‘‘Purchasing Fund Sub-Advisory
Group’’).
14. Applicants propose other
conditions to limit the potential for
undue influence over the Index Funds,
including that no Purchasing Fund or
Purchasing Fund Affiliate (except to the
extent it is acting in its capacity as an
investment adviser to an Index Fund)
will cause an Index Fund to purchase a
security in any offering of securities
during the existence of any
underwriting or selling syndicate of
which a principal underwriter is an
Underwriting Affiliate (‘‘Affiliated
Underwriting’’). An ‘‘Underwriting
Affiliate’’ is a principal underwriter in
any underwriting or selling syndicate
that is an officer, director, member of an
advisory board, Purchasing Fund
Adviser, Purchasing Fund Sub-Adviser,
employee or Sponsor of the Purchasing
Fund, or a person of which any such
officer, director, member of an advisory
board, Purchasing Fund Adviser,
Purchasing Fund Sub-Adviser,
employee, or Sponsor is an affiliated
person (except that any person whose
Sponsor, promoter, and principal underwriter of a
Purchasing Fund, and any person controlling,
controlled by, or under common control with any
of those entities. A ‘‘Fund Affiliate’’ is an investment
adviser, promoter, or principal underwriter of an
Index Fund and any person controlling, controlled
by, or under common control with any of these
entities.
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Frm 00063
Fmt 4703
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relationship to the Index Fund is
covered by section 10(f) of the Act is not
an Underwriting Affiliate).
15. Applicants assert that the
proposed conditions address any
concerns regarding excessive layering of
fees. The board of directors or trustees
of any Purchasing Management
Company, including a majority of the
directors or trustees who are not
‘‘interested persons’’ within the meaning
of section 2(a)(19) of the Act
(‘‘disinterested directors or trustees’’),
will find that the advisory fees charged
to the Purchasing Management
Company are based on services
provided that will be in addition to,
rather than duplicative of, services
provided under the advisory contract(s)
of any Index Fund in which the
Purchasing Management Company may
invest. In addition, except as provided
by condition 12, a Purchasing Fund
Adviser or a trustee (‘‘Trustee’’) or
Sponsor of a Purchasing Trust will, as
applicable, waive fees otherwise
payable to it by the Purchasing Fund in
an amount at least equal to any
compensation (including fees received
pursuant to any plan adopted by an
Index Fund under rule 12b–1 under the
Act) received by the Purchasing Fund
Adviser or Trustee or Sponsor or an
affiliated person of the Purchasing Fund
Adviser, Trustee or Sponsor, from the
Index Fund in connection with the
investment by the Purchasing Fund in
the Index Fund. Applicants state that
any sales charges or service fees charged
with respect to shares of a Purchasing
Fund will not exceed the limits
applicable to a fund of funds set forth
in National Association of Securities
Dealers (‘‘NASD’’) Conduct Rule 2830.14
16. Applicants submit that the
proposed arrangement will not create an
overly complex fund structure.
Applicants note that no Index Fund may
acquire securities of any investment
company or company relying on
sections 3(c)(1) or 3(c)(7) of the Act in
excess of the limits contained in section
12(d)(1)(A) of the Act, except to the
extent permitted by exemptive relief
from the Commission permitting the
Index Fund to purchase shares of other
investment companies for short-term
cash management purposes. To ensure
that Purchasing Funds comply with the
terms and conditions of the requested
relief from section 12(d)(1), any
Purchasing Fund that intends to invest
in an Index Fund in reliance on the
requested order will be required to enter
14 All references to NASD Conduct Rule 2830 also
includes any successor or replacement rule that
may be adopted by the Financial Industry
Regulatory Authority.
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into a Purchasing Fund Agreement
between the Index Fund and the
Purchasing Fund requiring the
Purchasing Fund to adhere to the terms
and conditions of the requested relief.
The Purchasing Fund Agreement also
will include an acknowledgement from
the Purchasing Fund that it may rely on
the requested order only to invest in the
Index Funds and not in any other
investment company.
17. Applicants also note that an Index
Fund may choose to reject a direct
purchase of Fund Shares in Creation
Unit Aggregations by a Purchasing
Fund. To the extent that a Purchasing
Fund purchases Fund Shares in the
secondary market, an Index Fund would
still retain its ability to reject initial
purchases of Fund Shares made in
reliance on the requested order by
declining to enter into the Purchasing
Fund Agreement prior to any
investment by a Purchasing Fund in
excess of the limits of section
12(d)(1)(A).
Section 17(a)(1) and (2) of the Act
18. Section 17(a) of the Act generally
prohibits an affiliated person of a
registered investment company, or an
affiliated person of such a person
(‘‘second tier affiliates’’), from selling
any security to or purchasing any
security from the company. Section
2(a)(3) of the Act defines ‘‘affiliated
person’’ to include (a) any person
directly or indirectly owning,
controlling or holding with power to
vote 5% or more of the outstanding
voting securities of the other person, (b)
any person 5% or more of whose
outstanding voting securities are
directly or indirectly owned, controlled
or held with the power to vote by the
other person, and (c) any person directly
or indirectly controlling, controlled by
or under common control with the other
person. Section 2(a)(9) of the Act
provides that a control relationship will
be presumed where one person owns
more than 25% of another person’s
voting securities.
19. Applicants request an exemption
from section 17(a) of the Act pursuant
to sections 17(b) and 6(c) of the Act to
permit persons to effectuate in-kind
purchases and redemptions with an
Index Fund when they are affiliated
persons, or second-tier affiliates of an
Index Fund solely by virtue of one or
more of the following: (a) Holding 5%
or more, or in excess of 25%, of the
outstanding Fund Shares of one or more
Index Funds; (b) having an affiliation
with a person with an ownership
interest described in (a); or (c) holding
5% or more, or more than 25%, of the
Fund Shares of one or more other
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17:31 Feb 03, 2010
Jkt 220001
registered investment companies (or
series thereof) advised by the Adviser,
or an entity controlling, controlled by,
or under common control with the
Adviser.
20. Applicants assert that no useful
purpose would be served by prohibiting
these types of affiliated persons from
purchasing or redeeming Creation Unit
Aggregations through ‘‘in-kind’’
transactions. The deposit procedures for
both in-kind purchases and in-kind
redemptions of Creation Unit
Aggregations will be the same for all
purchases and redemptions. Deposit
Securities and Fund Securities will be
valued in the same manner as Portfolio
Securities. Therefore, applicants state
that in-kind purchases and redemptions
will afford no opportunity for the
specified affiliated persons, or secondtier affiliates, of an Index Fund, to effect
a transaction detrimental to other
holders of Fund Shares. Applicants also
believe that in-kind purchases and
redemptions will not result in selfdealing or overreaching of the Index
Funds.
21. Applicants also seek relief from
section 17(a) to permit an Index Fund
that is an affiliated person of a
Purchasing Fund to sell its Fund Shares
to and redeem its Fund Shares from a
Purchasing Fund and to engage in the
accompanying in-kind transactions with
the Purchasing Fund.15 Applicants state
that the terms of the transaction are fair
and reasonable. Applicants note that
any consideration paid by a Purchasing
Fund for the purchase or redemption of
Fund Shares directly from an Index
Fund will be based on the NAV of the
Index Fund.16 Applicants believe that
any proposed transactions directly
between the Index Funds and
Purchasing Funds will be consistent
with the policies of each Purchasing
Fund. The purchase of Creation Unit
Aggregations by a Purchasing Fund
directly from an Index Fund will be
accomplished in accordance with the
investment restrictions of any such
Purchasing Fund and will be consistent
15 Applicants acknowledge that receipt of
compensation by (a) an affiliated person of a
Purchasing Fund, or an affiliated person of such
person, for the purchase by the Purchasing Fund of
Fund Shares or (b) an affiliated person of an Index
Fund, or an affiliated person of such person, for the
sale by the Index Fund of its Fund Shares to a
Purchasing Fund may be prohibited by section
17(e)(1) of the Act. The Purchasing Fund Agreement
also will include this acknowledgement.
16 Applicants believe that a Purchasing Fund will
purchase Fund Shares in the secondary market and
will not purchase or redeem Creation Unit
Aggregations directly from an Index Fund.
However, the requested relief would apply to direct
sales of Creation Unit Aggregations by an Index
Fund to a Purchasing Fund and direct redemptions
of Fund Shares.
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5819
with the investment policies set forth in
the Purchasing Fund’s registration
statement. The Purchasing Fund
Agreement will require any Purchasing
Fund that purchases Creation Unit
Aggregations directly from an Index
Fund to represent that the purchase of
Creation Unit Aggregations from an
Index Fund by a Purchasing Fund will
be accomplished in compliance with the
investment restrictions of the
Purchasing Fund and will be consistent
with the investment policies set forth in
the Purchasing Fund’s registration
statement.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:17
ETF Relief
1. As long as the Index Funds operate
in reliance on the requested order, the
Fund Shares will be listed on an
Exchange.
2. Neither the Trust nor any Index
Fund will be advertised or marketed as
an open-end investment company or a
mutual fund. Each Index Fund’s
Prospectus will prominently disclose
that Fund Shares are not individually
redeemable shares and will disclose that
the owners of Fund Shares may acquire
those Fund Shares from such Index
Fund and tender those Fund Shares for
redemption to the Index Fund in
Creation Unit Aggregations only. Any
advertising material that describes the
purchase or sale of Creation Unit
Aggregations or refers to redeemability
will prominently disclose that Fund
Shares are not individually redeemable
and that owners of Fund Shares may
acquire those Fund Shares from an
Index Fund and tender those Fund
Shares for redemption to such Index
Fund in Creation Unit Aggregations
only.
3. The Web site maintained for the
Index Funds, which will be publicly
accessible at no charge, will contain the
following information, on a per Fund
Share basis, for each Index Fund: (a)
The prior Business Day’s NAV and the
mid-point of the bid-ask spread at the
time of the calculation of NAV (‘‘Bid/
Ask Price’’), and a calculation of the
premium or discount of the Bid/Ask
Price at the time of calculation of the
NAV against such NAV; and (b) data in
chart format displaying the frequency
distribution of discounts and premiums
of the daily Bid/Ask Price against the
NAV, within appropriate ranges, for
each of the four previous calendar
quarters.
17 See
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4. Each Index Fund’s Prospectus and
annual report will also include: (a) The
information listed in condition 3(b), (i)
in the case of the Index Fund’s
Prospectus, for the most recently
completed year (and the most recently
completed quarter or quarters, as
applicable) and (ii) in the case of the
annual report, for the immediately
preceding five years, as applicable; and
(b) the following data, calculated on a
per Fund Share basis for one, five and
ten year periods (or life of the Index
Fund), (i) the cumulative total return
and the average annual total return
based on NAV and Bid/Ask Price, and
(ii) the cumulative total return of the
relevant Underlying Index.
5. Each Index Fund’s Prospectus will
clearly disclose that, for purposes of the
Act, Fund Shares are issued by such
Index Fund, which is a registered
investment company, and that the
acquisition of Fund Shares by
investment companies is subject to the
restrictions of section 12(d)(1) of the
Act, except as permitted by an
exemptive order that permits registered
investment companies to invest in an
Index Fund beyond the limits in section
12(d)(1), subject to certain terms and
conditions, including that the registered
investment company enter into a
Purchasing Fund Agreement with the
Index Fund regarding the terms of the
investment.
6. The requested relief to permit ETF
operations will expire on the effective
date of any Commission rule under the
Act that provides relief permitting the
operation of index-based exchangetraded funds.
Section 12(d)(1) Relief
7. The members of a Purchasing
Fund’s Advisory Group will not control
(individually or in the aggregate) an
Index Fund within the meaning of
section 2(a)(9) of the Act. The members
of a Purchasing Fund’s Sub-Advisory
Group will not control (individually or
in the aggregate) an Index Fund within
the meaning of section 2(a)(9) of the Act.
If, as a result of a decrease in the
outstanding Fund Shares of an Index
Fund, a Purchasing Fund’s Advisory
Group or a Purchasing Fund’s SubAdvisory Group, each in the aggregate,
becomes a holder of more than 25% of
the outstanding Fund Shares of an Index
Fund, it will vote its Fund Shares in the
same proportion as the vote of all other
holders of the Fund Shares. This
condition does not apply to the
Purchasing Fund’s Sub-Advisory Group
with respect to an Index Fund for which
the Purchasing Fund’s Sub-Adviser or a
person controlling, controlled by, or
under common control with the
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17:31 Feb 03, 2010
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Purchasing Fund Sub-Adviser acts as
the investment adviser within the
meaning of section 2(a)(20)(A) of the
Act.
8. No Purchasing Fund or Purchasing
Fund Affiliate will cause any existing or
potential investment by the Purchasing
Fund in an Index Fund to influence the
terms of any services or transactions
between the Purchasing Fund or
Purchasing Fund Affiliate and the Index
Fund or a Fund Affiliate.
9. The board of directors or trustees of
a Purchasing Management Company,
including a majority of the disinterested
directors or trustees, will adopt
procedures reasonably designed to
ensure that the Purchasing Fund
Adviser and Purchasing Fund SubAdviser are conducting the investment
program of the Purchasing Management
Company without taking into account
any consideration received by the
Purchasing Management Company or a
Purchasing Fund Affiliate from an Index
Fund or a Fund Affiliate in connection
with any services or transactions.
10. No Purchasing Fund or
Purchasing Fund Affiliate (except to the
extent it is acting in its capacity as an
investment adviser to an Index Fund)
will cause an Index Fund to purchase a
security in any Affiliated Underwriting.
11. Before investing in an Index Fund
in excess of the limits in section
12(d)(1)(A), each Purchasing Fund and
the Index Fund will execute a
Purchasing Fund Agreement stating,
without limitation, that their boards of
directors or trustees and their
investment advisers or Sponsors and
Trustees, as applicable, understand the
terms and conditions of the order, and
agree to fulfill their responsibilities
under the order. At the time of its
investment in Fund Shares in excess of
the limit in section 12(d)(1)(A)(i), a
Purchasing Fund will notify the Index
Fund of the investment. At such time,
the Purchasing Fund will also transmit
to the Index Fund a list of the names of
each Purchasing Fund Affiliate and
Underwriting Affiliate. The Purchasing
Fund will notify the Index Fund of any
changes to the list of names as soon as
reasonably practicable after a change
occurs. The relevant Index Fund and the
Purchasing Fund will maintain and
preserve a copy of the order, the
Purchasing Fund Agreement, and the
list with any updated information for
the duration of the investment and for
a period of not less than six years
thereafter, the first two years in an
easily accessible place.
12. The Purchasing Fund Adviser,
Trustee or Sponsor, as applicable, will
waive fees otherwise payable to it by the
Purchasing Fund in an amount at least
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Fmt 4703
Sfmt 4703
equal to any compensation (including
fees received under any plan adopted by
an Index Fund under rule 12b–1 under
the Act) received from an Index Fund by
the Purchasing Fund Adviser, Trustee or
Sponsor, or an affiliated person of the
Purchasing Fund Adviser, Trustee or
Sponsor, other than any advisory fees
paid to the Purchasing Fund Adviser,
Trustee or Sponsor, or its affiliated
person by an Index Fund, in connection
with the investment by the Purchasing
Fund in the Index Fund. Any
Purchasing Fund Sub-Adviser will
waive fees otherwise payable to the
Purchasing Fund Sub-Adviser, directly
or indirectly, by the Purchasing
Management Company in an amount at
least equal to any compensation
received from an Index Fund by the
Purchasing Fund Sub-Adviser, or an
affiliated person of the Purchasing Fund
Sub-Adviser, other than any advisory
fees paid to the Purchasing Fund SubAdviser or its affiliated person by the
Index Fund, in connection with any
investment by the Purchasing
Management Company in an Index
Fund made at the direction of the
Purchasing Fund Sub-Adviser. In the
event that the Purchasing Fund SubAdviser waives fees, the benefit of the
waiver will be passed through to the
Purchasing Management Company.
13. Any sales charges and/or service
fees charged with respect to shares of a
Purchasing Fund will not exceed the
limits applicable to a fund of funds as
set forth in NASD Conduct Rule 2830.
14. Once an investment by a
Purchasing Fund in Fund Shares
exceeds the limits of section
12(d)(1)(A)(i) of the Act, the board of
directors/trustees of an Index Fund
(‘‘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 Board members’’), will
determine that any consideration paid
by the Index Fund to a Purchasing Fund
or a Purchasing Fund Affiliate in
connection with any services or
transactions (a) is fair and reasonable in
relation to the nature and quality of the
services and benefits received by such
Index Fund; (b) is within the range of
consideration that the Index Fund
would be required to pay to another
unaffiliated entity in connection with
the same services or transactions; and
(c) does not involve overreaching on the
part of any person concerned. This
condition does not apply with respect to
any services or transactions between an
Index Fund and its investment
adviser(s), or any person controlling,
controlled by, or under common control
with such investment adviser(s).
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15. The Board, including a majority of
the disinterested Board members, will
adopt procedures reasonably designed
to monitor any purchases of securities
by an Index Fund in an Affiliated
Underwriting once the investment by a
Purchasing Fund in an Index Fund
exceeds the limit of section
12(d)(1)(A)(i) of the Act, including any
purchases made directly from an
Underwriting Affiliate. The Board will
review these purchases periodically, but
no less frequently than annually, to
determine whether the purchases were
influenced by the investment by the
Purchasing Fund in an Index Fund. The
Board will consider, among other
things: (a) Whether the purchases were
consistent with the investment
objectives and policies of the Index
Fund; (b) how the performance of
securities purchased in an Affiliated
Underwriting compares to the
performance of comparable securities
purchased during a comparable period
of time in underwritings other than
Affiliated Underwritings or to a
benchmark such as a comparable market
index; and (c) whether the amount of
securities purchased by the Index Fund
in Affiliated Underwritings and the
amount purchased directly from an
Underwriting Affiliate have changed
significantly from prior years. The
Board will take any appropriate actions
based on its review, including, if
appropriate, the institution of
procedures designed to assure that
purchases of securities in Affiliated
Underwritings are in the best interest of
shareholders of the Index Fund.
16. Each Index Fund will maintain
and preserve permanently in an easily
accessible place a written copy of the
procedures described in the preceding
condition, and any modifications to
such procedures, and will maintain and
preserve for a period of not less than six
years from the end of the fiscal year in
which any purchase in an Affiliated
Underwriting occurred, the first two
years in an easily accessible place, a
written record of each purchase of
securities in Affiliated Underwritings,
once an investment by a Purchasing
Fund in shares of the Index Fund
exceeds the limit of section
12(d)(1)(A)(i) of the Act, setting forth
from whom the securities were
acquired, the identity of the
underwriting syndicate’s members, the
terms of the purchase, and the
information or materials upon which
the Board’s determinations were made.
17. Before approving any advisory
contract under section 15 of the Act, the
board of directors or trustees of each
Purchasing Management Company,
including a majority of the disinterested
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17:31 Feb 03, 2010
Jkt 220001
directors or trustees, will find that the
advisory fees charged under such
contract are based on services provided
that will be in addition to, rather than
duplicative of, the services provided
under the advisory contract(s) of any
Index Fund in which the Purchasing
Management Company may invest.
These findings and their basis will be
recorded fully in the minute books of
the appropriate Purchasing Management
Company.
18. No Index Fund will acquire
securities of any other investment
company or companies relying on
sections 3(c)(1) or 3(c)(7) of the Act in
excess of the limits contained in section
12(d)(1)(A) of the Act, except to the
extent permitted by exemptive relief
from the Commission permitting the
Index Fund to purchase shares of other
investment companies for short-term
cash management purposes.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. 2010–2381 Filed 2–3–10; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–61416; File No. SR–
NASDAQ–2010–010]
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Notice of
Filing and Immediate Effectiveness of
a Proposed Rule Change To Clarify
Nasdaq Rule 7023
January 25, 2010.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1, and Rule 19b–4 2 thereunder,
notice is hereby given that on January
21, 2010, The NASDAQ Stock Market
LLC (‘‘Nasdaq’’) filed with the Securities
and Exchange Commission (‘‘SEC’’ or
‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III, below, which Items have been
prepared by Nasdaq. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to clarify
Nasdaq Rule 7023 to make clear that
Historical ModelView information will
be available via NasdaqTrader.com and
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
Frm 00066
Fmt 4703
7023. NASDAQ TotalView
(a)–(c) No change.
(d) Historical ModelView [TotalView]
Information [—ModelView] Nasdaq will
make historical [TotalView information,
under the] ModelView [entitlement package]
information[,] available via
NasdaqTrader.com. ModelView shall contain
historical [TotalView] information regarding
aggregate displayed and reserve liquidity at
each price level directly from [in] the Nasdaq
Market Center. ModelView shall be available
for a subscription fee of $2,000 per month.
*
*
*
*
*
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
Nasdaq included statements concerning
the purpose of 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 IV below. Nasdaq 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
The Exchange proposes to clarify
Nasdaq Rule 7023(d) to make clear that
Historical ModelView information will
be available via NasdaqTrader.com and
will contain historical information
regarding aggregate displayed and
reserve liquidity at each price level
directly from the Nasdaq Market Center.
Additionally, references to the
Historical TotalView data product will
be deleted from Nasdaq Rule 7023(d)
since it is offered through a technology
subsidiary of the Exchange rather than
the Exchange itself. Historical
3 Changes are marked to the rules of The
NASDAQ Stock Market LLC found at https://
nasdaqomx.cchwallstreet.com.
1 15
PO 00000
that references to the Historical
TotalView data product will be deleted
since it is offered through a technology
subsidiary of the Exchange rather than
the Exchange itself. The text of the
proposed rule change is available from
Nasdaq’s Web site at https://
nasdaq.cchwallstreet.com, at Nasdaq’s
principal office, and at the
Commission’s Public Reference Room.
The text of the proposed rule change
is below. Proposed new language is
italicized; proposed deletions are in
brackets.3
*
*
*
*
*
Sfmt 4703
E:\FR\FM\04FEN1.SGM
04FEN1
Agencies
[Federal Register Volume 75, Number 23 (Thursday, February 4, 2010)]
[Notices]
[Pages 5814-5821]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-2381]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 29127; 812-13559]
ShariahShares Exchange-Traded Fund Trust, et al.; Notice of
Application
January 29, 2010.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under section 6(c) of the
Investment Company Act of 1940 (the ``Act'') for an exemption from
sections 2(a)(32), 5(a)(1), 22(d) and 22(e) of the Act and rule 22c-1
under the Act, under section 12(d)(1)(J) of the Act for an exemption
from sections 12(d)(1)(A) and (B) of the Act, and under sections 6(c)
and 17(b) of the Act for an exemption from sections 17(a)(1) and (a)(2)
of the Act.
-----------------------------------------------------------------------
Summary of Application: Applicants request an order that would permit
(a) certain open-end management investment companies and their series
to issue shares (``Fund Shares'') that can be redeemed only in large
aggregations (``Creation Unit Aggregations''); (b) secondary market
transactions in Fund Shares to occur at negotiated prices; (c) certain
series to pay redemption proceeds, under certain circumstances, more
than seven days after the tender of Fund Shares for redemption; (d)
certain affiliated persons of the series to deposit securities into,
and receive securities from, the series in connection with the purchase
and redemption of Creation Unit Aggregations; and (e) certain
registered management investment companies and unit investment trusts
outside of the same group of investment companies as the series to
acquire Fund Shares.
Applicants: ShariahShares Exchange-Traded Fund Trust (the ``Trust'')
and Florentez Investment Management, Inc. (the ``Adviser'').
Filing Dates: The application was filed on July 31, 2008, and amended
on September 16, 2009, and January 29, 2010. Applicants have agreed to
file an amendment during the notice period, the substance of which is
reflected in this notice.
Hearing or Notification of Hearing: An order granting the application
will be issued unless the Commission orders a hearing. Interested
persons may request a hearing by writing to the Commission's Secretary
and serving applicants with a copy of the request, personally or by
mail. Hearing requests should be received by the Commission by 5:30
p.m. on February 19, 2010 and should be accompanied by proof of service
on applicants, in the form of an affidavit, or for lawyers, a
certificate of service. Hearing requests should state the nature of the
writer's interest, the reason for the request, and the issues
contested. Persons who wish to be notified of a hearing may request
notification by writing to the Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street, NE., Washington, DC 20549-
[[Page 5815]]
1090; Applicants, 12 Brillantez, Irvine, CA 92620.
FOR FURTHER INFORMATION CONTACT: Bruce R. MacNeil, Senior Counsel at
(202) 551-6817, or Julia Kim Gilmer, Branch Chief, at (202) 551-6821
(Division of Investment Management, Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or an applicant
using the Company name box, at https://www.sec.gov/search/search.htm or
by calling (202) 551-8090.
Applicants' Representations
1. The Trust is registered as an open-end management investment
company and is organized as a Delaware statutory trust. The Trust will
initially offer two series (``Initial Index Funds''), each of which
will track an index of selected equity securities.\1\ Applicants may
establish one or more registered investment companies in addition to
the Trust that may be formed as a separate trust or a separate series
of the Trust, or one or more trusts in the future (``Future Index
Funds,'' collectively with the Initial Index Funds, the ``Index
Funds''). Each Future Index Fund will be advised by the Adviser or an
entity controlling, controlled by, or under common control with the
Adviser, and comply with the terms and conditions stated in the
application.\2\
---------------------------------------------------------------------------
\1\ The Initial Index Funds are ShariahShares FTSE USA Fund and
ShariahShares FTSE Developed ex-U.S. Fund.
\2\ All existing entities that intend to rely on the requested
order have been named as applicants. Any other existing or future
entity that subsequently relies on the order will comply with the
terms and conditions of the application.
---------------------------------------------------------------------------
2. The Adviser will serve as the investment adviser to the Index
Funds. The Adviser will be registered as an investment adviser under
the Investment Advisers Act of 1940 (``Advisers Act'') prior to the
commencement of investment operations of any Index Fund. The Adviser
may enter into sub-advisory agreements with one or more sub-advisers
with respect to the Index Funds (the ``Sub-Advisers''). Each Sub-
Adviser will be registered under the Advisers Act. A broker-dealer
registered under the Securities Exchange Act of 1934 (the ``Exchange
Act'' and such broker-dealer, a ``Broker'') will serve as the principal
underwriter and distributor for the Creation Unit Aggregations of Fund
Shares (``Distributor''). The Distributor will not be affiliated with
the Adviser or a national securities exchange as defined in section
2(a)(26) of the Act (``Exchange'').
3. Each Index Fund will hold certain equity securities (``Portfolio
Securities'') selected to correspond generally to the price and yield
performance, before fees and expenses, of a specified equity securities
index (an ``Underlying Index'').\3\ Certain of the Underlying Indicies
will be comprised of equity securities issued by domestic issuers and
non-domestic issuers meeting the requirements for trading in U.S.
markets (``Domestic Index''). Other Underlying Indicies may be
comprised of foreign equity securities or a combination of domestic and
foreign equity securities (``Foreign Index''). Index Funds that track
Domestic Indices are referred to as ``Domestic Funds'' and Index Funds
that track Foreign Indices are referred to as ``Foreign Funds.'' No
entity that creates, compiles, sponsors or maintains an Underlying
Index (``Index Provider'') is or will be an affiliated person, as
defined in section 2(a)(3) of the Act, or an affiliated person of an
affiliated person, of the Trust, an Index Fund, the Adviser, any Sub-
Adviser to or promoter of an Index Fund, or the Distributor. The Index
Provider to the Initial Index Funds is FTSE Group.
---------------------------------------------------------------------------
\3\ The Underlying Indicies for the Initial Index Funds are FTSE
Shariah USA Index and FTSE Shariah Developed ex U.S. Index.
---------------------------------------------------------------------------
4. The investment objective of each Index Fund will be to provide
investment results, before fees and expenses, that correspond generally
to the price and yield performance of its Underlying Index.\4\ The
value of each Index Fund's Underlying Index will be disseminated every
15 seconds throughout the trading day. An Index Fund will utilize
either a ``replication'' or ``representative sampling'' strategy which
will be disclosed with regard to each Index Fund in its prospectus
(``Prospectus'').\5\ An Index Fund using a replication strategy will
invest in the Component Securities in its Underlying Index in
approximately the same proportions as in the Underlying Index. An Index
Fund using a representative sampling strategy will invest in some, but
not necessarily all of the Component Securities.\6\ This may be the
case, for example, when there are practical difficulties or substantial
costs involved in compiling an entire Underlying Index basket that
contains hundreds of Component Securities, or in certain instances,
when a Component Security is illiquid. Applicants anticipate that an
Index Fund that uses representative sampling will not track the
performance of its Underlying Index with the same degree of accuracy as
an investment vehicle that invests in every Component Security of the
Underlying Index with the same weighting as the Underlying Index.
Applicants expect that each Index Fund will have a tracking error
relative to the performance of its Underlying Index of less than 5
percent.
---------------------------------------------------------------------------
\4\ Applicants represent that an Index Fund will invest at least
80% of its total assets, exclusive of securities lending collateral,
in the component securities that comprise its Underlying Index
(``Component Securities'') or, in the case of Foreign Funds,
Component Securities and depositary receipts representing such
securities. ``Depositary Receipts'' will typically be American
Depositary Receipts but may include Global Depositary Receipts and
Euro Depositary Receipts. Each Index Fund also may invest up to 20%
of its assets in certain futures, stock options, options on stock
index futures and swap contracts as related to its respective
Underlying Index and its Component Securities, cash and cash
equivalents, as well as in stocks not included in its Underlying
Index, but which the Adviser or Sub-Adviser believes will help the
Index Fund track its Underlying Index.
\5\ All representations and conditions contained in the
application that require an Index Fund to disclose particular
information in the Index Fund's Prospectus and/or annual report
shall be effective with respect to the Index Fund until the time
that the Index Fund complies with disclosure requirements adopted by
the Commission in Investment Company Act Release No. 28584 (Jan. 13,
2009).
\6\ Under the representative sampling strategy, stocks are
selected for inclusion in an Index Fund to have aggregate investment
characteristics, fundamental characteristics, and liquidity measures
similar to those of the Index Fund's Underlying Index taken in its
entirety.
---------------------------------------------------------------------------
5. Funds Shares will be sold at a price between $40 and $250 in
Creation Unit Aggregations which will have an initial price range of
$1,000,000 to $25,000,000. All orders to purchase Creation Unit
Aggregations must be placed with the Distributor by or through a party
that has entered into an agreement with the Distributor (``Authorized
Participant''). The Distributor will be responsible for transmitting
the orders to the Index Funds. An Authorized Participant must be
either: (a) A broker-dealer or other participant in the continuous net
settlement system of the National Securities Clearing Corporation, a
clearing agency registered with the Commission, or (b) a participant in
the Depository Trust Company (``DTC'', and such participant, ``DTC
Participant''). Fund Shares generally will be sold in Creation Unit
Aggregations in exchange for an in-kind deposit by the purchaser of a
portfolio of securities designated by the Adviser or the Sub-Adviser to
correspond generally to the price and yield performance of the relevant
Underlying Index (the ``Deposit Securities''), together with the
deposit of a specified cash payment (``Balancing Amount''). The
Balancing Amount is an amount equal to the difference between
[[Page 5816]]
(a) the net asset value (``NAV'') (per Creation Unit Aggregation) of an
Index Fund and (b) the total aggregate market value (per Creation Unit
Aggregation) of the Deposit Securities.\7\ An Index Fund may permit a
purchaser of Creation Unit Aggregations to substitute cash in lieu of
depositing some or all of the requisite Deposit Securities if the
Adviser or Sub-Adviser believed such method would reduce the Index
Fund's transaction costs or enhance the Index Fund's operating
efficiency.\8\
---------------------------------------------------------------------------
\7\ Each Index Fund will sell and redeem Creation Unit
Aggregations on a ``Business Day'' which includes any day that an
Index Fund is required to be open under Section 22(e) of the Act.
Each Business Day, prior to the opening of trading on the primary
listing Exchange, the list of names and amount of each security
constituting the current Deposit Securities and the Balancing
Amount, effective as of the previous Business Day, will be made
available. Any Exchange on which Fund Shares are listed will
disseminate, every 15 seconds during its regular trading hours,
through the facilities of the Consolidated Tape Association, an
amount per Fund Share representing the sum of the estimated
Balancing Amount and the current value of the Deposit Securities.
\8\ Applicants state that in some circumstances or in certain
countries, it may not be practicable or convenient, or permissible
under the laws of certain countries or the regulations of certain
foreign stock exchanges, for a Foreign Fund to operate exclusively
on an ``in-kind'' basis. Applicants also note that when a
substantial rebalancing of a Foreign Fund's portfolio is required,
the Adviser or Sub-Adviser might prefer to receive cash rather than
stocks so that the Foreign Fund may avoid transaction costs involved
in liquidating part of its portfolio to achieve the rebalancing.
---------------------------------------------------------------------------
6. An investor purchasing or redeeming a Creation Unit Aggregation
from an Index Fund will be charged a fee (``Transaction Fee'') to
prevent the dilution of the interests of the remaining shareholders
resulting from costs in connection with the purchase or redemption of
Creation Unit Aggregations.\9\ The exact amounts of Transaction Fees
relevant to each Index Fund (including the maximum Transaction Fee)
will be fully disclosed in the Prospectus of such Index Fund. The
method for calculating the Transaction Fees will be disclosed in each
Prospectus or statement of additional information (``SAI''). The
Distributor will be responsible for delivering a Prospectus to those
persons purchasing Creation Unit Aggregations, and for maintaining
records of both the orders placed with it and the confirmations of
acceptance furnished. In addition, the Distributor will maintain a
record of the instructions given to the applicable Index Fund to
implement the delivery of Fund Shares.
---------------------------------------------------------------------------
\9\ Where an Index Fund permits a purchaser to substitute cash
in lieu of depositing a portion of the requisite Deposit Securities,
the purchaser may be assessed a higher Transaction Fee to cover the
cost of purchasing such Deposit Securities, including operational,
processing and brokerage costs, and part or all of the spread
between the expected bid and the offer side of the market relating
to such Deposit Securities.
---------------------------------------------------------------------------
7. Purchasers of Fund Shares in Creation Unit Aggregations may hold
such Fund Shares or may sell such Fund Shares into the secondary
market. Fund Shares will be listed and traded on an Exchange. It is
expected that one or more member firms of a listing Exchange will be
designated to act as a specialist or market maker and maintain a market
for Fund Shares trading on the Exchange (each a ``Market Maker'').
Prices of Fund Shares trading on an Exchange will be based on the
current bid/offer market. Fund Shares sold in the secondary market will
be subject to customary brokerage commissions and charges.
8. Applicants expect that purchasers of Creation Unit Aggregations
will include institutional investors and arbitrageurs (which could
include institutional investors). A Market Maker, in providing a fair
and orderly secondary market for the Fund Shares, also may purchase
Creation Unit Aggregations for use in its market-making activities.
Applicants expect that secondary market purchasers of Fund Shares will
include both institutional investors and retail investors.\10\
Applicants expect that the price at which Fund Shares trade will be
disciplined by arbitrage opportunities created by the ability to
continually purchase or redeem Creation Unit Aggregations at their NAV,
which should ensure that Fund Shares will not trade at a material
discount or premium.
---------------------------------------------------------------------------
\10\ Fund Shares will be registered in book-entry form only. DTC
or its nominee will be the registered owner of all outstanding Fund
Shares. DTC or DTC Participants will maintain records reflecting
beneficial owners of Fund Shares.
---------------------------------------------------------------------------
9. Fund Shares will not be individually redeemable, and owners of
Fund Shares may acquire those Fund Shares from the Index Fund, or
tender such Fund Shares for redemption to the Index Fund, in Creation
Unit Aggregations only. To redeem, an investor will have to accumulate
enough Fund Shares to constitute a Creation Unit Aggregation.
Redemption orders must be placed by or through an Authorized
Participant. An investor redeeming a Creation Unit Aggregation
generally will receive (a) Portfolio Securities designated to be
delivered for Creation Unit Aggregation redemptions (``Fund
Securities'') on the date that the request for redemption is made\11\
and (b) a ``Cash Redemption Payment,'' consisting of an amount
calculated in the same manner as the Balancing Amount, although the
actual amount of the Cash Redemption Payment may differ from the
Balancing Amount if the Fund Securities are not identical to the
Deposit Securities on that day. An investor may receive the cash
equivalent of a Fund Security in certain circumstances, such as if the
investor is constrained from effecting transactions in the security by
regulation or policy.
---------------------------------------------------------------------------
\11\ As a general matter, the Deposit Securities and Fund
Securities will correspond pro rata to the securities held by each
Index Fund, but Fund Securities received on redemption may not
always be identical to Deposit Securities deposited in connection
with the purchase of Creation Unit Aggregations for the same day.
The Index Funds will comply with the Federal securities laws in
accepting Deposit Securities and satisfying redemptions with Fund
Securities, including that the Deposit Securities and Fund
Securities are sold in transactions that would be exempt from
registration under the Securities Act of 1933.
---------------------------------------------------------------------------
10. Neither the Trust nor any Index Fund will be marketed or
otherwise held out as an ``open-end investment company'' or a ``mutual
fund.'' Instead, each Index Fund will be marketed as an ``exchange-
traded fund,'' an ``investment company,'' a ``fund,'' or a ``trust.''
All marketing materials that describe the features or method of
obtaining, buying or selling Creation Unit Aggregations or Fund Shares
traded on an Exchange, or refer to redeemability, will prominently
disclose that Fund Shares are not individually redeemable and that the
owners of Fund Shares may purchase or redeem Fund Shares from the Index
Fund in Creation Unit Aggregations only. The same approach will be
followed in the SAI, shareholder reports and investor educational
materials issued or circulated in connection with the Fund Shares. The
Index Funds will provide copies of their annual and semi-annual
shareholder reports to DTC Participants for distribution to
shareholders.
Applicants' Legal Analysis
1. Applicants request an order under section 6(c) of the Act for an
exemption from sections 2(a)(32), 5(a)(1), 22(d), and 22(e) of the Act
and rule 22c-1 under the Act, under sections 6(c) and 17(b) of the Act
for an exemption from sections 17(a)(1) and 17(a)(2) of the Act, and
under section 12(d)(1)(J) of the Act for an exemption from sections
12(d)(1)(A) and (B) of the Act.
2. Section 6(c) of the Act provides that the Commission may exempt
any person, security or transaction, or any class of persons,
securities or transactions, from any provision of the Act, if and to
the extent that such exemption is necessary or appropriate in the
public interest and consistent with the protection of investors and the
purposes fairly intended by the policy
[[Page 5817]]
and provisions of the Act. Section 17(b) of the Act authorizes the
Commission to exempt a proposed transaction from section 17(a) of the
Act if evidence establishes that the terms of the transaction,
including the consideration to be paid or received, are reasonable and
fair and do not involve overreaching on the part of any person
concerned, and the proposed transaction is consistent with the policies
of the registered investment company and the general provisions of the
Act. Section 12(d)(1)(J) of the Act provides that the Commission may
exempt any person, security, or transaction, or any class or classes of
persons, securities or transactions, from any provisions of section
12(d)(1) if the exemption is consistent with the public interest and
the protection of investors.
Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an ``open-end company'' as a
management investment company that is offering for sale or has
outstanding any redeemable security of which it is the issuer. Section
2(a)(32) of the Act defines a redeemable security as any security,
other than short-term paper, under the terms of which the owner, upon
its presentation to the issuer, is entitled to receive approximately
his proportionate share of the issuer's current net assets, or the cash
equivalent. Because Fund Shares will not be individually redeemable,
applicants request an order that would permit the Index Funds to
register as open-end management investment companies and issue Fund
Shares that are redeemable in Creation Unit Aggregations only.
Applicants state that investors may purchase Fund Shares in Creation
Unit Aggregations and redeem Creation Unit Aggregations from each Index
Fund. Applicants further state that because Creation Unit Aggregations
may always be purchased and redeemed at NAV, the market price of the
Fund Shares should not vary substantially from their NAV.
Section 22(d) of the Act and Rule 22c-1 under the Act
4. Section 22(d) of the Act, among other things, prohibits a dealer
from selling a redeemable security, which is currently being offered to
the public by or through a principal underwriter, except at a current
public offering price described in the prospectus. Rule 22c-1 under the
Act generally requires that a dealer selling, redeeming or repurchasing
a redeemable security do so only at a price based on its NAV.
Applicants state that secondary market trading in Fund Shares will take
place at negotiated prices, not at a current offering price described
in an Index Fund's Prospectus, and not at a price based on NAV. Thus,
purchases and sales of Fund Shares in the secondary market will not
comply with section 22(d) of the Act and rule 22c-1 under the Act.
Applicants request an exemption under section 6(c) from these
provisions.
5. Applicants assert that the concerns sought to be addressed by
section 22(d) of the Act and rule 22c-1 under the Act with respect to
pricing are equally satisfied by the proposed method of pricing Fund
Shares. Applicants maintain that while there is little legislative
history regarding section 22(d), its provisions, as well as those of
rule 22c-1, appear to have been designed to (a) prevent dilution caused
by certain riskless-trading schemes by principal underwriters and
contract dealers, (b) prevent unjust discrimination or preferential
treatment among buyers, and (c) ensure an orderly distribution of
investment company shares by eliminating price competition from dealers
offering shares at less than the published sales price and who could
pay investors a little more than the published redemption price.
6. Applicants believe that none of these purposes will be thwarted
by permitting Fund Shares to trade in the secondary market at
negotiated prices. Applicants state that (a) secondary market trading
in Fund Shares does not directly involve Index Fund assets and will not
result in dilution of an investment in Fund Shares, and (b) to the
extent different prices exist during a given trading day, or from day
to day, such variances occur as a result of third-party market forces,
such as supply and demand. Therefore, applicants assert that secondary
market transactions in Fund Shares will not lead to discrimination or
preferential treatment among purchasers. Finally, applicants contend
that the proposed distribution system will be orderly because
competitive forces in the marketplace will ensure that the difference
between the market price of Fund Shares and their NAV remains narrow.
Section 22(e)
7. Section 22(e) generally prohibits a registered investment
company from suspending the right of redemption or postponing the date
of payment of redemption proceeds for more than seven days after the
tender of a security for redemption. Applicants state that settlement
of redemptions for a Foreign Fund will be contingent not only on the
securities settlement cycle of the United States market, but also on
the delivery cycles in local markets for the underlying foreign
securities held by a Foreign Fund. Applicants state that delivery
cycles for transferring Portfolio Securities to redeeming investors,
coupled with local market holiday schedules, may require a delivery
process longer than seven calendar days for the Foreign Funds.
Applicants request relief under section 6(c) of the Act from section
22(e) to allow the Foreign Funds to pay redemption proceeds up to
fourteen calendar days after the tender of a Creation Unit Aggregation
for redemption. Except as disclosed in the relevant Foreign Fund's
Prospectus and/or SAI, applicants expect that each Foreign Fund will be
able to deliver redemption proceeds within seven days.\12\ With respect
to future Foreign Funds, applicants seek the same relief from section
22(e) only to the extent that circumstances similar to those described
in the application exist.
---------------------------------------------------------------------------
\12\ Rule 15c6-1 under the Exchange Act requires that most
securities transactions be settled within three business days of the
trade. Applicants acknowledge that no relief obtained from the
requirements of section 22(e) will affect any obligations applicants
may have under rule 15c6-1.
---------------------------------------------------------------------------
8. Applicants state that section 22(e) was designed to prevent
unreasonable, undisclosed and unforeseen delays in the payment of
redemption proceeds. Applicants assert that the requested relief will
not lead to the problems that section 22(e) was designed to prevent.
Applicants state that the SAI will disclose those local holidays (over
the period of at least one year following the date of the SAI), if any,
that are expected to prevent the delivery of redemption proceeds in
seven calendar days, and the maximum number of days, up to fourteen
calendar days, needed to deliver the proceeds for each Foreign Fund.
Applicants are not seeking relief from section 22(e) with respect to
Foreign Funds that will not effect in-kind purchases and redemptions of
Creation Unit Aggregations.
Section 12(d)(1)
9. Section 12(d)(1)(A) of the Act, in relevant part, prohibits a
registered investment company from acquiring securities of an
investment company if such securities represent more than 3% of the
total outstanding voting stock of the acquired company, more than 5% of
the total assets of the acquiring company, or, together with the
securities of any other investment companies, more than 10% of the
total assets of the acquiring company. Section 12(d)(1)(B) of the Act
prohibits a registered open-end investment
[[Page 5818]]
company, its principal underwriter and any other broker-dealer from
selling the investment company's shares to another investment company
if the sale will cause the acquiring company to own more than 3% of the
acquired company's voting stock, or if the sale will cause more than
10% of the acquired company's voting stock to be owned by investment
companies generally.
10. Applicants request an exemption to permit management investment
companies (``Purchasing Management Companies'') and unit investment
trusts (``Purchasing Trusts'') registered under the Act that are not
sponsored or advised by the Adviser or any entity controlling,
controlled by, or under common control with the Adviser and are not
part of the same ``group of investment companies,'' as defined in
section 12(d)(1)(G)(ii) of the Act, as the Index Funds (collectively,
``Purchasing Funds'') to acquire Fund Shares beyond the limits of
section 12(d)(1)(A). Purchasing Funds do not include the Index Funds.
In addition, applicants seek relief to permit the Index Funds or any
Broker to sell Fund Shares to a Purchasing Fund in excess of the limits
of section 12(d)(1)(B).
11. Each Purchasing Management Company will be advised by an
investment adviser within the meaning of section 2(a)(20)(A) of the Act
(the ``Purchasing Fund Adviser'') and may be sub-advised by an
adviser(s) within the meaning of section 2(a)(20)(B) of the Act
(``Purchasing Fund Sub-Adviser''). Any investment adviser to a
Purchasing Fund will be registered under the Advisers Act. Each
Purchasing Trust will be sponsored by a sponsor (``Sponsor'').
12. Applicants submit that the proposed conditions to the relief
requested, including the requirement that Purchasing Funds enter into
an agreement with an Index Fund for the purchase of Fund Shares (a
``Purchasing Fund Agreement''), adequately address the concerns
underlying the limits in section 12(d)(1)(A) and (B), which include
concerns about undue influence by a fund of funds over underlying
funds, excessive layering of fees and overly complex structures.
Applicants believe that the requested exemption is consistent with the
public interest and the protection of investors.
13. Applicants believe that neither the Purchasing Funds nor a
Purchasing Fund Affiliate would be able to exert undue influence over
the Index Funds.\13\ To limit the control that a Purchasing Fund may
have over an Index Fund, applicants propose a condition prohibiting a
Purchasing Fund Adviser or a Sponsor, any person controlling,
controlled by, or under common control with a Purchasing Fund Adviser
or Sponsor, and any investment company or issuer that would be an
investment company but for sections 3(c)(1) or 3(c)(7) of the Act that
is advised or sponsored by a Purchasing Fund Adviser or Sponsor, or any
person controlling, controlled by, or under common control with a
Purchasing Fund Adviser or Sponsor (``Purchasing Fund Advisory Group'')
from controlling (individually or in the aggregate) an Index Fund
within the meaning of section 2(a)(9) of the Act. The same prohibition
would apply to any Purchasing Fund Sub-Adviser, any person controlling,
controlled by or under common control with the Purchasing Fund Sub-
Adviser, and any investment company or issuer that would be an
investment company but for sections 3(c)(1) or 3(c)(7) of the Act (or
portion of such investment company or issuer) advised or sponsored by
the Purchasing Fund Sub-Adviser or any person controlling, controlled
by or under common control with the Purchasing Fund Sub-Adviser
(``Purchasing Fund Sub-Advisory Group'').
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\13\ A ``Purchasing Fund Affiliate'' is a Purchasing Fund
Adviser, Purchasing Fund Sub-Adviser, Sponsor, promoter, and
principal underwriter of a Purchasing Fund, and any person
controlling, controlled by, or under common control with any of
those entities. A ``Fund Affiliate'' is an investment adviser,
promoter, or principal underwriter of an Index Fund and any person
controlling, controlled by, or under common control with any of
these entities.
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14. Applicants propose other conditions to limit the potential for
undue influence over the Index Funds, including that no Purchasing Fund
or Purchasing Fund Affiliate (except to the extent it is acting in its
capacity as an investment adviser to an Index Fund) will cause an Index
Fund to purchase a security in any offering of securities during the
existence of any underwriting or selling syndicate of which a principal
underwriter is an Underwriting Affiliate (``Affiliated Underwriting'').
An ``Underwriting Affiliate'' is a principal underwriter in any
underwriting or selling syndicate that is an officer, director, member
of an advisory board, Purchasing Fund Adviser, Purchasing Fund Sub-
Adviser, employee or Sponsor of the Purchasing Fund, or a person of
which any such officer, director, member of an advisory board,
Purchasing Fund Adviser, Purchasing Fund Sub-Adviser, employee, or
Sponsor is an affiliated person (except that any person whose
relationship to the Index Fund is covered by section 10(f) of the Act
is not an Underwriting Affiliate).
15. Applicants assert that the proposed conditions address any
concerns regarding excessive layering of fees. The board of directors
or trustees of any Purchasing Management Company, including a majority
of the directors or trustees who are not ``interested persons'' within
the meaning of section 2(a)(19) of the Act (``disinterested directors
or trustees''), will find that the advisory fees charged to the
Purchasing Management Company are based on services provided that will
be in addition to, rather than duplicative of, services provided under
the advisory contract(s) of any Index Fund in which the Purchasing
Management Company may invest. In addition, except as provided by
condition 12, a Purchasing Fund Adviser or a trustee (``Trustee'') or
Sponsor of a Purchasing Trust will, as applicable, waive fees otherwise
payable to it by the Purchasing Fund in an amount at least equal to any
compensation (including fees received pursuant to any plan adopted by
an Index Fund under rule 12b-1 under the Act) received by the
Purchasing Fund Adviser or Trustee or Sponsor or an affiliated person
of the Purchasing Fund Adviser, Trustee or Sponsor, from the Index Fund
in connection with the investment by the Purchasing Fund in the Index
Fund. Applicants state that any sales charges or service fees charged
with respect to shares of a Purchasing Fund will not exceed the limits
applicable to a fund of funds set forth in National Association of
Securities Dealers (``NASD'') Conduct Rule 2830.\14\
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\14\ All references to NASD Conduct Rule 2830 also includes any
successor or replacement rule that may be adopted by the Financial
Industry Regulatory Authority.
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16. Applicants submit that the proposed arrangement will not create
an overly complex fund structure. Applicants note that no Index Fund
may acquire securities of any investment company or company relying on
sections 3(c)(1) or 3(c)(7) of the Act in excess of the limits
contained in section 12(d)(1)(A) of the Act, except to the extent
permitted by exemptive relief from the Commission permitting the Index
Fund to purchase shares of other investment companies for short-term
cash management purposes. To ensure that Purchasing Funds comply with
the terms and conditions of the requested relief from section 12(d)(1),
any Purchasing Fund that intends to invest in an Index Fund in reliance
on the requested order will be required to enter
[[Page 5819]]
into a Purchasing Fund Agreement between the Index Fund and the
Purchasing Fund requiring the Purchasing Fund to adhere to the terms
and conditions of the requested relief. The Purchasing Fund Agreement
also will include an acknowledgement from the Purchasing Fund that it
may rely on the requested order only to invest in the Index Funds and
not in any other investment company.
17. Applicants also note that an Index Fund may choose to reject a
direct purchase of Fund Shares in Creation Unit Aggregations by a
Purchasing Fund. To the extent that a Purchasing Fund purchases Fund
Shares in the secondary market, an Index Fund would still retain its
ability to reject initial purchases of Fund Shares made in reliance on
the requested order by declining to enter into the Purchasing Fund
Agreement prior to any investment by a Purchasing Fund in excess of the
limits of section 12(d)(1)(A).
Section 17(a)(1) and (2) of the Act
18. Section 17(a) of the Act generally prohibits an affiliated
person of a registered investment company, or an affiliated person of
such a person (``second tier affiliates''), from selling any security
to or purchasing any security from the company. Section 2(a)(3) of the
Act defines ``affiliated person'' to include (a) any person directly or
indirectly owning, controlling or holding with power to vote 5% or more
of the outstanding voting securities of the other person, (b) any
person 5% or more of whose outstanding voting securities are directly
or indirectly owned, controlled or held with the power to vote by the
other person, and (c) any person directly or indirectly controlling,
controlled by or under common control with the other person. Section
2(a)(9) of the Act provides that a control relationship will be
presumed where one person owns more than 25% of another person's voting
securities.
19. Applicants request an exemption from section 17(a) of the Act
pursuant to sections 17(b) and 6(c) of the Act to permit persons to
effectuate in-kind purchases and redemptions with an Index Fund when
they are affiliated persons, or second-tier affiliates of an Index Fund
solely by virtue of one or more of the following: (a) Holding 5% or
more, or in excess of 25%, of the outstanding Fund Shares of one or
more Index Funds; (b) having an affiliation with a person with an
ownership interest described in (a); or (c) holding 5% or more, or more
than 25%, of the Fund Shares of one or more other registered investment
companies (or series thereof) advised by the Adviser, or an entity
controlling, controlled by, or under common control with the Adviser.
20. Applicants assert that no useful purpose would be served by
prohibiting these types of affiliated persons from purchasing or
redeeming Creation Unit Aggregations through ``in-kind'' transactions.
The deposit procedures for both in-kind purchases and in-kind
redemptions of Creation Unit Aggregations will be the same for all
purchases and redemptions. Deposit Securities and Fund Securities will
be valued in the same manner as Portfolio Securities. Therefore,
applicants state that in-kind purchases and redemptions will afford no
opportunity for the specified affiliated persons, or second-tier
affiliates, of an Index Fund, to effect a transaction detrimental to
other holders of Fund Shares. Applicants also believe that in-kind
purchases and redemptions will not result in self-dealing or
overreaching of the Index Funds.
21. Applicants also seek relief from section 17(a) to permit an
Index Fund that is an affiliated person of a Purchasing Fund to sell
its Fund Shares to and redeem its Fund Shares from a Purchasing Fund
and to engage in the accompanying in-kind transactions with the
Purchasing Fund.\15\ Applicants state that the terms of the transaction
are fair and reasonable. Applicants note that any consideration paid by
a Purchasing Fund for the purchase or redemption of Fund Shares
directly from an Index Fund will be based on the NAV of the Index
Fund.\16\ Applicants believe that any proposed transactions directly
between the Index Funds and Purchasing Funds will be consistent with
the policies of each Purchasing Fund. The purchase of Creation Unit
Aggregations by a Purchasing Fund directly from an Index Fund will be
accomplished in accordance with the investment restrictions of any such
Purchasing Fund and will be consistent with the investment policies set
forth in the Purchasing Fund's registration statement. The Purchasing
Fund Agreement will require any Purchasing Fund that purchases Creation
Unit Aggregations directly from an Index Fund to represent that the
purchase of Creation Unit Aggregations from an Index Fund by a
Purchasing Fund will be accomplished in compliance with the investment
restrictions of the Purchasing Fund and will be consistent with the
investment policies set forth in the Purchasing Fund's registration
statement.
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\15\ Applicants acknowledge that receipt of compensation by (a)
an affiliated person of a Purchasing Fund, or an affiliated person
of such person, for the purchase by the Purchasing Fund of Fund
Shares or (b) an affiliated person of an Index Fund, or an
affiliated person of such person, for the sale by the Index Fund of
its Fund Shares to a Purchasing Fund may be prohibited by section
17(e)(1) of the Act. The Purchasing Fund Agreement also will include
this acknowledgement.
\16\ Applicants believe that a Purchasing Fund will purchase
Fund Shares in the secondary market and will not purchase or redeem
Creation Unit Aggregations directly from an Index Fund. However, the
requested relief would apply to direct sales of Creation Unit
Aggregations by an Index Fund to a Purchasing Fund and direct
redemptions of Fund Shares.
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Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:\17\
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\17\ See note 5, supra.
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ETF Relief
1. As long as the Index Funds operate in reliance on the requested
order, the Fund Shares will be listed on an Exchange.
2. Neither the Trust nor any Index Fund will be advertised or
marketed as an open-end investment company or a mutual fund. Each Index
Fund's Prospectus will prominently disclose that Fund Shares are not
individually redeemable shares and will disclose that the owners of
Fund Shares may acquire those Fund Shares from such Index Fund and
tender those Fund Shares for redemption to the Index Fund in Creation
Unit Aggregations only. Any advertising material that describes the
purchase or sale of Creation Unit Aggregations or refers to
redeemability will prominently disclose that Fund Shares are not
individually redeemable and that owners of Fund Shares may acquire
those Fund Shares from an Index Fund and tender those Fund Shares for
redemption to such Index Fund in Creation Unit Aggregations only.
3. The Web site maintained for the Index Funds, which will be
publicly accessible at no charge, will contain the following
information, on a per Fund Share basis, for each Index Fund: (a) The
prior Business Day's NAV and the mid-point of the bid-ask spread at the
time of the calculation of NAV (``Bid/Ask Price''), and a calculation
of the premium or discount of the Bid/Ask Price at the time of
calculation of the NAV against such NAV; and (b) data in chart format
displaying the frequency distribution of discounts and premiums of the
daily Bid/Ask Price against the NAV, within appropriate ranges, for
each of the four previous calendar quarters.
[[Page 5820]]
4. Each Index Fund's Prospectus and annual report will also
include: (a) The information listed in condition 3(b), (i) in the case
of the Index Fund's Prospectus, for the most recently completed year
(and the most recently completed quarter or quarters, as applicable)
and (ii) in the case of the annual report, for the immediately
preceding five years, as applicable; and (b) the following data,
calculated on a per Fund Share basis for one, five and ten year periods
(or life of the Index Fund), (i) the cumulative total return and the
average annual total return based on NAV and Bid/Ask Price, and (ii)
the cumulative total return of the relevant Underlying Index.
5. Each Index Fund's Prospectus will clearly disclose that, for
purposes of the Act, Fund Shares are issued by such Index Fund, which
is a registered investment company, and that the acquisition of Fund
Shares by investment companies is subject to the restrictions of
section 12(d)(1) of the Act, except as permitted by an exemptive order
that permits registered investment companies to invest in an Index Fund
beyond the limits in section 12(d)(1), subject to certain terms and
conditions, including that the registered investment company enter into
a Purchasing Fund Agreement with the Index Fund regarding the terms of
the investment.
6. The requested relief to permit ETF operations will expire on the
effective date of any Commission rule under the Act that provides
relief permitting the operation of index-based exchange-traded funds.
Section 12(d)(1) Relief
7. The members of a Purchasing Fund's Advisory Group will not
control (individually or in the aggregate) an Index Fund within the
meaning of section 2(a)(9) of the Act. The members of a Purchasing
Fund's Sub-Advisory Group will not control (individually or in the
aggregate) an Index Fund within the meaning of section 2(a)(9) of the
Act. If, as a result of a decrease in the outstanding Fund Shares of an
Index Fund, a Purchasing Fund's Advisory Group or a Purchasing Fund's
Sub-Advisory Group, each in the aggregate, becomes a holder of more
than 25% of the outstanding Fund Shares of an Index Fund, it will vote
its Fund Shares in the same proportion as the vote of all other holders
of the Fund Shares. This condition does not apply to the Purchasing
Fund's Sub-Advisory Group with respect to an Index Fund for which the
Purchasing Fund's Sub-Adviser or a person controlling, controlled by,
or under common control with the Purchasing Fund Sub-Adviser acts as
the investment adviser within the meaning of section 2(a)(20)(A) of the
Act.
8. No Purchasing Fund or Purchasing Fund Affiliate will cause any
existing or potential investment by the Purchasing Fund in an Index
Fund to influence the terms of any services or transactions between the
Purchasing Fund or Purchasing Fund Affiliate and the Index Fund or a
Fund Affiliate.
9. The board of directors or trustees of a Purchasing Management
Company, including a majority of the disinterested directors or
trustees, will adopt procedures reasonably designed to ensure that the
Purchasing Fund Adviser and Purchasing Fund Sub-Adviser are conducting
the investment program of the Purchasing Management Company without
taking into account any consideration received by the Purchasing
Management Company or a Purchasing Fund Affiliate from an Index Fund or
a Fund Affiliate in connection with any services or transactions.
10. No Purchasing Fund or Purchasing Fund Affiliate (except to the
extent it is acting in its capacity as an investment adviser to an
Index Fund) will cause an Index Fund to purchase a security in any
Affiliated Underwriting.
11. Before investing in an Index Fund in excess of the limits in
section 12(d)(1)(A), each Purchasing Fund and the Index Fund will
execute a Purchasing Fund Agreement stating, without limitation, that
their boards of directors or trustees and their investment advisers or
Sponsors and Trustees, as applicable, understand the terms and
conditions of the order, and agree to fulfill their responsibilities
under the order. At the time of its investment in Fund Shares in excess
of the limit in section 12(d)(1)(A)(i), a Purchasing Fund will notify
the Index Fund of the investment. At such time, the Purchasing Fund
will also transmit to the Index Fund a list of the names of each
Purchasing Fund Affiliate and Underwriting Affiliate. The Purchasing
Fund will notify the Index Fund of any changes to the list of names as
soon as reasonably practicable after a change occurs. The relevant
Index Fund and the Purchasing Fund will maintain and preserve a copy of
the order, the Purchasing Fund Agreement, and the list with any updated
information for the duration of the investment and for a period of not
less than six years thereafter, the first two years in an easily
accessible place.
12. The Purchasing Fund Adviser, Trustee or Sponsor, as applicable,
will waive fees otherwise payable to it by the Purchasing Fund in an
amount at least equal to any compensation (including fees received
under any plan adopted by an Index Fund under rule 12b-1 under the Act)
received from an Index Fund by the Purchasing Fund Adviser, Trustee or
Sponsor, or an affiliated person of the Purchasing Fund Adviser,
Trustee or Sponsor, other than any advisory fees paid to the Purchasing
Fund Adviser, Trustee or Sponsor, or its affiliated person by an Index
Fund, in connection with the investment by the Purchasing Fund in the
Index Fund. Any Purchasing Fund Sub-Adviser will waive fees otherwise
payable to the Purchasing Fund Sub-Adviser, directly or indirectly, by
the Purchasing Management Company in an amount at least equal to any
compensation received from an Index Fund by the Purchasing Fund Sub-
Adviser, or an affiliated person of the Purchasing Fund Sub-Adviser,
other than any advisory fees paid to the Purchasing Fund Sub-Adviser or
its affiliated person by the Index Fund, in connection with any
investment by the Purchasing Management Company in an Index Fund made
at the direction of the Purchasing Fund Sub-Adviser. In the event that
the Purchasing Fund Sub-Adviser waives fees, the benefit of the waiver
will be passed through to the Purchasing Management Company.
13. Any sales charges and/or service fees charged with respect to
shares of a Purchasing Fund will not exceed the limits applicable to a
fund of funds as set forth in NASD Conduct Rule 2830.
14. Once an investment by a Purchasing Fund in Fund Shares exceeds
the limits of section 12(d)(1)(A)(i) of the Act, the board of
directors/trustees of an Index Fund (``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 Board
members''), will determine that any consideration paid by the Index
Fund to a Purchasing Fund or a Purchasing Fund Affiliate in connection
with any services or transactions (a) is fair and reasonable in
relation to the nature and quality of the services and benefits
received by such Index Fund; (b) is within the range of consideration
that the Index Fund would be required to pay to another unaffiliated
entity in connection with the same services or transactions; and (c)
does not involve overreaching on the part of any person concerned. This
condition does not apply with respect to any services or transactions
between an Index Fund and its investment adviser(s), or any person
controlling, controlled by, or under common control with such
investment adviser(s).
[[Page 5821]]
15. The Board, including a majority of the disinterested Board
members, will adopt procedures reasonably designed to monitor any
purchases of securities by an Index Fund in an Affiliated Underwriting
once the investment by a Purchasing Fund in an Index Fund exceeds the
limit of section 12(d)(1)(A)(i) of the Act, including any purchases
made directly from an Underwriting Affiliate. The Board will review
these purchases periodically, but no less frequently than annually, to
determine whether the purchases were influenced by the investment by
the Purchasing Fund in an Index Fund. The Board will consider, among
other things: (a) Whether the purchases were consistent with the
investment objectives and policies of the Index Fund; (b) how the
performance of securities purchased in an Affiliated Underwriting
compares to the performance of comparable securities purchased during a
comparable period of time in underwritings other than Affiliated
Underwritings or to a benchmark such as a comparable market index; and
(c) whether the amount of securities purchased by the Index Fund in
Affiliated Underwritings and the amount purchased directly from an
Underwriting Affiliate have changed significantly from prior years. The
Board will take any appropriate actions based on its review, including,
if appropriate, the institution of procedures designed to assure that
purchases of securities in Affiliated Underwritings are in the best
interest of shareholders of the Index Fund.
16. Each Index Fund will maintain and preserve permanently in an
easily accessible place a written copy of the procedures described in
the preceding condition, and any modifications to such procedures, and
will maintain and preserve for a period of not less than six years from
the end of the fiscal year in which any purchase in an Affiliated
Underwriting occurred, the first two years in an easily accessible
place, a written record of each purchase of securities in Affiliated
Underwritings, once an investment by a Purchasing Fund in shares of the
Index Fund exceeds the limit of section 12(d)(1)(A)(i) of the Act,
setting forth from whom the securities were acquired, the identity of
the underwriting syndicate's members, the terms of the purchase, and
the information or materials upon which the Board's determinations were
made.
17. Before approving any advisory contract under section 15 of the
Act, the board of directors or trustees of each Purchasing Management
Company, including a majority of the disinterested directors or
trustees, will find that the advisory fees charged under such contract
are based on services provided that will be in addition to, rather than
duplicative of, the services provided under the advisory contract(s) of
any Index Fund in which the Purchasing Management Company may invest.
These findings and their basis will be recorded fully in the minute
books of the appropriate Purchasing Management Company.
18. No Index Fund will acquire securities of any other investment
company or companies relying on sections 3(c)(1) or 3(c)(7) of the Act
in excess of the limits contained in section 12(d)(1)(A) of the Act,
except to the extent permitted by exemptive relief from the Commission
permitting the Index Fund to purchase shares of other investment
companies for short-term cash management purposes.
For the Commission, by the Division of Investment Management,
under delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. 2010-2381 Filed 2-3-10; 8:45 am]
BILLING CODE 8011-01-P