Goldman, Sachs & Co., et al.; Notice of Application and Temporary Order, 44031-44033 [2010-18313]
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Federal Register / Vol. 75, No. 143 / Tuesday, July 27, 2010 / Notices
Type of request: Extension of a
currently approved collection.
Affected public: Individuals or
households, Business or other for-profit,
Non-profit institutions, State, Local or
Tribal Government.
Abstract: The information collection
has two purposes. When RRB records
that railroad service and/or
compensation is insufficient to qualify a
claimant for unemployment or sickness
benefits, the RRB obtains information
needed to reconcile the compensation
and/or service on record with that
claimed by the employee. Other forms
in the collection allow the RRB to
determine whether unemployment or
sickness benefits were properly
obtained.
Changes Proposed: The RRB proposes
no changes to any of the forms in the
collection.
The proposed burden estimate for this
ICR is as follows:
Estimated annual number of
respondents: 10,700.
Total annual responses: 10,700.
Total annual reporting hours: 2,512.
FOR FURTHER INFORMATION CONTACT:
Copies of the form and supporting
documents can be obtained from
Charles Mierzwa, the agency clearance
officer at (312–751–3363) or
Charles.Mierzwa@RRB.gov.
Comments regarding the information
collection should be addressed to
Patricia A. Henaghan, Railroad
Retirement Board, 844 North Rush
Street, Chicago, Illinois 60611–2092 or
e-mailed to
Patricia.Henaghan@RRB.GOV and to
the OMB Desk Officer for the RRB, at
the Office of Management and Budget,
Room 10230, New Executive Office
Building, Washington, DC 20503.
Charles Mierzwa,
Clearance Officer.
[FR Doc. 2010–18271 Filed 7–26–10; 8:45 am]
BILLING CODE 7905–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–29366; 812–13796]
Goldman, Sachs & Co., et al.; Notice of
Application and Temporary Order
July 21, 2010.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Temporary order and notice of
application for a permanent order under
section 9(c) of the Investment Company
Act of 1940 (‘‘Act’’).
sroberts on DSKD5P82C1PROD with NOTICES
AGENCY:
Applicants
have received a temporary order
SUMMARY OF APPLICATION:
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16:30 Jul 26, 2010
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exempting them from section 9(a) of the
Act, with respect to an injunction
entered against Goldman, Sachs & Co.
(‘‘Goldman Sachs’’) on July 20, 2010 by
the United States District Court for the
Southern District of New York (the
‘‘Injunction’’), until the Commission
takes final action on an application for
a permanent order. Applicants also have
applied for a permanent order.
APPLICANTS: Goldman Sachs, Goldman
Sachs Asset Management, L.P. (‘‘GSAM,
L.P.’’), Goldman Sachs Asset
Management International (‘‘GSAMI’’),
Goldman Sachs Hedge Fund Strategies
LLC (‘‘GSHFS’’), Commonwealth
Annuity and Life Insurance Company
(‘‘Commonwealth’’), First Allmerica
Financial Life Insurance Company
(‘‘FAFLIC’’) and Epoch Securities, Inc.
(‘‘Epoch,’’ together, the ‘‘Applicants’’).1
FILING DATES: The application was filed
on July 16, 2010, and amended on July
21, 2010.
HEARING OR NOTIFICATION OF HEARING: An
order granting the application will be
issued unless the Commission orders a
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
Applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on August 16, 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 &
Exchange Commission, 100 F Street,
NE., Washington, DC 20549–1090.
Applicants: Goldman Sachs, GSAM,
L.P. and GSHFS, 200 West Street, New
York, NY 10282; GSAMI, Christchurch
Court, 10–15 Newgate Street, London,
England EC1A7HD; and
Commonwealth, FAFLIC and Epoch,
132 Turnpike Road, Southborough, MA
01772.
FOR FURTHER INFORMATION CONTACT: Jaea
F. Hahn, Senior Counsel, at (202) 551–
6870 or Janet M. Grossnickle, Assistant
Director, at 202–551–6821 (Division of
Investment Management, Office of
Investment Company Regulation).
1 Applicants request that any relief granted
pursuant to the application also apply to any
existing company of which Goldman Sachs is an
affiliated person and to any other company of
which Goldman Sachs may become an affiliated
person in the future (together with Applicants,
‘‘Covered Persons’’).
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Fmt 4703
Sfmt 4703
44031
The
following is a temporary order and 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.
SUPPLEMENTARY INFORMATION:
Applicants’ Representations
1. Goldman Sachs, a New York
limited partnership, is a global
investment banking and securities firm.
Goldman Sachs is registered as an
investment adviser with the
Commission pursuant to section 203 of
the Investment Advisers Act of 1940
(‘‘Advisers Act’’). Goldman Sachs is also
registered as a broker-dealer under the
Securities Exchange Act of 1934 (the
‘‘Exchange Act’’) and acts as a principal
underwriter of certain registered
investment companies. GSAM, L.P.,
GSAMI and GSHFS are each registered
under the Advisers Act as investment
advisors and provide investment
advisory or subadvisory services to
Funds.2 Commonwealth and FAFLIC
are insurance companies domiciled in
Massachusetts and each acts as
depositor for certain separate accounts
that are registered as UITs under the
Act. Epoch is a registered broker-dealer
that acts as principal underwriter for the
UITs of Commonwealth and FAFLIC.
Each of Goldman Sachs, GSAM, L.P.,
GSAMI and GSHFS provide investment
advisory services to ESCs, as defined in
section 2(a)(13) of the Act, which
provide investment opportunities for
partners of Goldman Sachs (prior to its
initial public offering) and certain
employees and consultants of Goldman
Sachs and its affiliates. GSHFS does not
currently provide investment advisory
services to registered investment
companies.
2. On July 20, 2010, the United States
District Court for the Southern District
of New York entered a final judgment,
which included the Injunction against
Goldman Sachs in a matter brought by
the Commission (‘‘Final Judgment’’).3
The Commission alleged in the
complaint (‘‘Complaint’’) that offering
materials related to a transaction in
2 ‘‘Funds’’ refer to any registered investment
company or employees’ securities company (‘‘ESC’’)
for which a Covered Person serves as an investment
adviser, subadviser or depositor, or any registered
open-end investment company, registered unit
investment trust (‘‘UIT’’) or registered face amount
certificate company for which a Covered Person
serves as principal underwriter (such activities,
collectively, ‘‘Fund Servicing Activities’’).
3 Securities and Exchange Commission v.
Goldman, Sachs & Co. and Fabrice Tourre, 10–CV–
03229 (S.D.N.Y. July 20, 2010).
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44032
Federal Register / Vol. 75, No. 143 / Tuesday, July 27, 2010 / Notices
which Goldman Sachs or its affiliates
sold synthetic collateralized debt
obligations, which referenced a portfolio
of synthetic mortgage-backed securities,
to two institutional investors in early
2007 (‘‘Transaction’’), should have
disclosed that the hedge fund assuming
the short side of the Transaction had
played a role in the selection process.
As part of an agreement to settle the
action, Goldman Sachs entered into a
consent in which it acknowledged that
it was a mistake not to disclose the role
of the hedge fund in the Transaction
and consented to the entry of the Final
Judgment, including the Injunction. The
Final Judgment will also decree that
Goldman Sachs is liable for
disgorgement of $15 million and a civil
penalty of $535 million.4
sroberts on DSKD5P82C1PROD with NOTICES
Applicants’ Legal Analysis
1. Section 9(a)(2) of the Act, in
relevant part, prohibits a person who
has been enjoined from engaging in or
continuing any conduct or practice in
connection with the purchase or sale of
a security from acting, among other
things, as an investment adviser or
depositor of any registered investment
company or a principal underwriter for
any registered open-end investment
company, registered UITs or registered
face-amount certificate company.
Section 9(a)(3) of the Act makes the
prohibition in section 9(a)(2) applicable
to a company any affiliated person of
which has been disqualified under the
provisions of section 9(a)(2). Section
2(a)(3) of the Act defines ‘‘affiliated
person’’ to include any person directly
or indirectly controlling, controlled by,
or under common control with, the
other person. Applicants state that
Goldman Sachs is an affiliated person of
each of the other Applicants within the
meaning of section 2(a)(3) of the Act
because they are under common control.
Applicants state that entry of the Final
Judgment would result in the
disqualification of Goldman Sachs
under section 9(a)(2) and the other
Applicants under section 9(a)(3) of the
Act.
4 The Final Judgment will also require Goldman
Sachs to comply with certain undertakings relating
to (i) the vetting and approval process for offerings
of residential mortgage-related securities products
by its firmwide Capital Committee, (ii) review of
marketing materials used in connection with
residential mortgage-related securities offerings by
Goldman Sachs’ Legal Department and Compliance
Department, (iii) annual internal audits of the
review of such marketing materials, (iv) where
Goldman Sachs is the lead underwriter of an
offering of residential mortgage-related securities
and retains outside counsel to advise on the
offering, review of the related offering materials by
outside counsel and (v) education and training of
persons involved in the structuring or marketing of
residential mortgage-related securities offerings.
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16:30 Jul 26, 2010
Jkt 220001
2. Section 9(c) of the Act provides that
the Commission shall grant an
application for exemption from the
disqualification provisions of section
9(a) if it is established that these
provisions, as applied to Applicants, are
unduly or disproportionately severe or
that Applicants’ conduct has been such
as not to make it against the public
interest or the protection of investors to
grant the application. Applicants have
filed an application pursuant to section
9(c) seeking a temporary and permanent
order exempting them from the
disqualification provisions of section
9(a) of the Act.
3. Applicants believe they meet the
standards for exemption specified in
section 9(c). Applicants state that the
prohibitions of section 9(a) as applied to
them would be unduly and
disproportionately severe and that the
conduct of Applicants has been such as
not to make it against the public interest
or the protection of investors to grant
the exemption from section 9(a).
4. Applicants state that the violations
alleged in the Complaint did not involve
Fund Servicing Activities or the current
or former Goldman Sachs employees
who are or were involved in Fund
Servicing Activities. Applicants also
state that no current or former director,
officer, or employee of Goldman Sachs
or the other Applicants—who is
involved in providing Fund Servicing
Activities to Funds—had any
knowledge of, or was involved in, the
conduct that forms the basis of the
Complaint. Applicants further state that
the individual defendant named in the
Complaint and the other personnel at
Goldman Sachs who were involved in
the violations alleged in the Complaint
have had no and will not have any
future involvement in providing Fund
Servicing Activities to Funds.
Applicants represent that the alleged
conduct giving rise to the Final
Judgment did not involve any Fund or
the assets of any Fund for which an
Applicant provided Fund Servicing
Activities.
5. Applicants state that the inability of
the Applicants to engage in Fund
Servicing Activities would result in
potentially severe hardships for the
Funds (including the UITs) and their
shareholders or contract holders.
Applicants state that they will
distribute, as soon as reasonably
practicable, written materials, including
an offer to meet in person to discuss the
materials, to the boards of directors or
trustees of the Funds (excluding for this
purpose, the ESCs) (the ‘‘Boards’’),
including the directors who are not
‘‘interested persons,’’ as defined in
section 2(a)(19) of the Act, of such
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Frm 00118
Fmt 4703
Sfmt 4703
Funds and their independent legal
counsel, as defined in rule 0–1(a)(6)
under the Act, if any, regarding the
Injunction, any impact on the Funds,
and the application. Applicants have
provided and will continue to provide
the Funds with all information
concerning the Final Judgment and the
application that is necessary for the
Funds to fulfill their disclosure and
other obligations under the Federal
securities laws.
6. Applicants also assert that, if they
were barred from providing Fund
Servicing Activities to the Funds and
ESCs, the effect on their businesses and
employees would be severe. Applicants
state that they have committed
substantial resources to establish an
expertise in Fund Servicing Activities.
Applicants further state that prohibiting
them from Fund Servicing Activities
would not only adversely affect their
businesses, but would also adversely
affect over 600 employees at GSAM, L.P.
alone that are involved in those
activities. Applicants also state that
disqualifying Goldman Sachs, GSAM,
L.P., GSAMI and GSHFS from
continuing to provide investment
advisory services to ESCs is not in the
public interest or in furtherance of the
protection of investors. Applicants
assert that it would not be consistent
with the purposes of the ESC provisions
of the Act or the representations made
in the application for the ESC order to
require another entity not affiliated with
Goldman Sachs to manage the ESCs. In
addition, participants in the ESCs have
subscribed for interests in the ESCs with
the expectation that the ESCs would be
managed by Goldman Sachs or one of its
affiliates.
7. Applicants state that Goldman
Sachs has previously sought and
received exemptions under section 9(c)
of the Act on four occasions, as
described in the application.
Applicants’ Condition
Applicants agree that any order
granting the requested relief will be
subject to the following condition:
Any temporary exemption granted
pursuant to the application shall be
without prejudice to, and shall not limit
the Commission’s rights in any manner
with respect to, any Commission
investigation of, or administrative
proceedings involving or against, the
Covered Persons, including without
limitation, the consideration by the
Commission of a permanent exemption
from section 9(a) of the Act requested
pursuant to the application or the
revocation or removal of any temporary
exemptions granted under the Act in
connection with the application.
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Federal Register / Vol. 75, No. 143 / Tuesday, July 27, 2010 / Notices
Temporary Order
The Commission has considered the
matter and finds that Applicants have
made the necessary showing to justify
granting a temporary exemption.
Accordingly,
It is hereby ordered, pursuant to
section 9(c) of the Act, that Covered
Persons are granted a temporary
exemption from the provisions of
section 9(a), effective as of the date of
the Injunction, solely with respect to the
Injunction, subject to the condition in
the application, until the date the
Commission takes final action on an
application for a permanent order.
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[FR Doc. 2010–18313 Filed 7–26–10; 8:45 am]
BILLING CODE 8010–01–P
[Release No. 34–62539; File No. SR–FINRA–
2010–029]
SECURITIES AND EXCHANGE
COMMISSION
sroberts on DSKD5P82C1PROD with NOTICES
Sunshine Act Meetings
Notice is hereby given, pursuant to
the provisions of the Government in the
Sunshine Act, Public Law 94–409, that
the Securities and Exchange
Commission will hold Closed Meetings
on Wednesday, July 28, 2010 at 2:30
p.m. and on Thursday, July 29, 2010 at
2 p.m.
Commissioners, Counsel to the
Commissioners, the Secretary to the
Commission, and recording secretaries
will attend the Closed Meetings. Certain
staff members who have an interest in
the matters also may be present.
The General Counsel of the
Commission, or his designee, has
certified that, in his opinion, one or
more of the exemptions set forth in 5
U.S.C. 552b(c)(3), (5), (7), 9(B) and (10)
and 17 CFR 200.402(a)(3), (5), (7), 9(ii)
and (10), permit consideration of the
scheduled matters at the Closed
Meeting.
Commissioner Casey, as duty officer,
voted to consider the items listed for the
Closed Meetings in closed session, and
determined that no earlier notice thereof
was possible.
The subject matter of the Closed
Meeting scheduled for Wednesday, July
28, 2010 will be:
Institution and settlement of an
injunctive action; and
Institution and settlement of
administrative proceedings.
The subject matter of the Closed
Meeting scheduled for Thursday, July
29, 2010 will be:
Institution and settlement of
injunctive actions;
16:30 Jul 26, 2010
Dated: July 22, 2010.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2010–18451 Filed 7–23–10; 11:15 am]
By the Commission.
Elizabeth M. Murphy,
Secretary.
VerDate Mar<15>2010
Institution and settlement of
administrative proceedings; and
Other matters relating to enforcement
proceedings.
At times, changes in Commission
priorities require alterations in the
scheduling of meeting items.
For further information and to
ascertain what, if any, matters have been
added, deleted or postponed, please
contact:
The Office of the Secretary at (202)
551–5400.
Jkt 220001
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Order Approving the
Proposed Rule Change To Adopt
FINRA Rule 5141 (Sale of Securities in
a Fixed Price Offering) in the
Consolidated FINRA Rulebook
July 21, 2010.
I. Introduction
On May 27, 2010, the Financial
Industry Regulatory Authority, Inc.
(‘‘FINRA’’) (f/k/a National Association of
Securities Dealers, Inc. (‘‘NASD’’)) filed
with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposal to adopt
FINRA Rule 5141 (Sale of Securities in
a Fixed Price Offering) in the
consolidated FINRA rulebook and to
delete NASD Rules 0120(h), 2730, 2740
and 2750, and NASD IM–2730, IM–2740
and IM–2750. This proposal was
published for comment in the Federal
Register on June 21, 2010.3 The
Commission received no comments
regarding the proposal. This order
approves this proposed rule change.
II. Description of the Proposed Rule
Change
As part of the process of developing
a new consolidated rulebook
(‘‘Consolidated FINRA Rulebook’’),4
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 Securities Exchange Act Release No. 62299
(June 16, 2010), 75 FR 35105 (June 21, 2010) (SR–
FINRA–2010–029) (‘‘Notice’’).
4 The current FINRA rulebook consists of: (1)
FINRA Rules; (2) NASD Rules; and (3) rules
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1 15
2 17
Frm 00119
Fmt 4703
Sfmt 4703
44033
FINRA proposed to adopt FINRA Rule
5141 (Sale of Securities in a Fixed Price
Offering) in the Consolidated FINRA
Rulebook and to delete NASD Rules
0120(h), 2730, 2740 and 2750, and
NASD IM–2730, IM–2740 and IM–2750.
Proposed FINRA Rule 5141 would be
a new, consolidated rule intended to
protect the integrity of fixed price
offerings 5 by ensuring that securities in
such offerings are sold to the public at
the stated public offering price or prices,
thereby preventing an undisclosed
better price. The proposed rule is based
in part on, and would replace, the
current fixed price offering rules (NASD
Rules 0120(h), 2730, 2740 and 2750 and
associated Interpretive Materials (‘‘IMs’’)
2730, 2740 and 2750).6 Like the current
fixed price offering rules, the proposed
rule would prohibit the grant of certain
preferences (e.g., selling concessions,
discounts, other allowances or various
economic equivalents) in connection
with fixed price offerings of securities.
A. Proposed FINRA Rule 5141
Paragraph (a) of the proposed rule
would provide that no member or
person associated with a member that
participates in a selling syndicate or
incorporated from NYSE (‘‘Incorporated NYSE
Rules’’) (together, the NASD Rules and Incorporated
NYSE Rules are referred to as the ‘‘Transitional
Rulebook’’). While the NASD Rules generally apply
to all FINRA members, the Incorporated NYSE
Rules apply only to those members of FINRA that
are also members of the NYSE (‘‘Dual Members’’).
The FINRA Rules apply to all FINRA members,
unless such rules have a more limited application
by their terms. For more information about the
rulebook consolidation process, see Information
Notice, March 12, 2008 (Rulebook Consolidation
Process).
5 NASD Rule 0120(h) defines the term ‘‘fixed price
offering’’ to mean the offering of securities at a
stated public offering price or prices, all or part of
which securities are publicly offered in the United
States or any territory thereof, whether or not
registered under the Securities Act of 1933. The
term does not include offerings of ‘‘exempted
securities’’ or ‘‘municipal securities’’ as those terms
are defined in Sections 3(a)(12) and 3(a)(29),
respectively, of the Securities Exchange Act or
offerings of redeemable securities of investment
companies registered pursuant to the Investment
Company Act of 1940 which are offered at prices
determined by the net asset value of the securities.
The proposed rule change would incorporate the
definition of ‘‘fixed price offering’’ into the proposed
rule in substantially identical form. See proposed
FINRA Rule 5141.04. See also Section II.B infra and
Section (C) under Item II.C in the Notice.
6 The current fixed price offering rules are also
known as the Papilsky rules because of the court
decision with which they are commonly associated.
See Papilsky v. Berndt, Fed. Sec. L. Rep (CCH) ¶
95,627 (S.D.N.Y. June 24, 1976). For more
information regarding the background of NASD
Rules 0120(h), 2730, 2740 and 2750 and the
associated IMs, see Notice to Members 81–3
(February 1981) (Adoption of New Rules
Concerning Securities Distribution Practices)
(‘‘Notice to Members 81–3’’); see also Securities
Exchange Act Release No. 17371 (December 12,
1980), 45 FR 83707 (December 19, 1980) (File No.
SR–NASD–78–3).
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Agencies
[Federal Register Volume 75, Number 143 (Tuesday, July 27, 2010)]
[Notices]
[Pages 44031-44033]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-18313]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-29366; 812-13796]
Goldman, Sachs & Co., et al.; Notice of Application and Temporary
Order
July 21, 2010.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Temporary order and notice of application for a permanent order
under section 9(c) of the Investment Company Act of 1940 (``Act'').
-----------------------------------------------------------------------
Summary of Application: Applicants have received a temporary order
exempting them from section 9(a) of the Act, with respect to an
injunction entered against Goldman, Sachs & Co. (``Goldman Sachs'') on
July 20, 2010 by the United States District Court for the Southern
District of New York (the ``Injunction''), until the Commission takes
final action on an application for a permanent order. Applicants also
have applied for a permanent order.
Applicants: Goldman Sachs, Goldman Sachs Asset Management, L.P.
(``GSAM, L.P.''), Goldman Sachs Asset Management International
(``GSAMI''), Goldman Sachs Hedge Fund Strategies LLC (``GSHFS''),
Commonwealth Annuity and Life Insurance Company (``Commonwealth''),
First Allmerica Financial Life Insurance Company (``FAFLIC'') and Epoch
Securities, Inc. (``Epoch,'' together, the ``Applicants'').\1\
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\1\ Applicants request that any relief granted pursuant to the
application also apply to any existing company of which Goldman
Sachs is an affiliated person and to any other company of which
Goldman Sachs may become an affiliated person in the future
(together with Applicants, ``Covered Persons'').
Filing Dates: The application was filed on July 16, 2010, and amended
---------------------------------------------------------------------------
on July 21, 2010.
HEARING OR NOTIFICATION OF HEARING: An order granting the application
will be issued unless the Commission orders a hearing. Interested
persons may request a hearing by writing to the Commission's Secretary
and serving Applicants with a copy of the request, personally or by
mail. Hearing requests should be received by the Commission by 5:30
p.m. on August 16, 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 & Exchange Commission, 100 F
Street, NE., Washington, DC 20549-1090. Applicants: Goldman Sachs,
GSAM, L.P. and GSHFS, 200 West Street, New York, NY 10282; GSAMI,
Christchurch Court, 10-15 Newgate Street, London, England EC1A7HD; and
Commonwealth, FAFLIC and Epoch, 132 Turnpike Road, Southborough, MA
01772.
FOR FURTHER INFORMATION CONTACT: Jaea F. Hahn, Senior Counsel, at (202)
551-6870 or Janet M. Grossnickle, Assistant Director, at 202-551-6821
(Division of Investment Management, Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The following is a temporary order and 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. Goldman Sachs, a New York limited partnership, is a global
investment banking and securities firm. Goldman Sachs is registered as
an investment adviser with the Commission pursuant to section 203 of
the Investment Advisers Act of 1940 (``Advisers Act''). Goldman Sachs
is also registered as a broker-dealer under the Securities Exchange Act
of 1934 (the ``Exchange Act'') and acts as a principal underwriter of
certain registered investment companies. GSAM, L.P., GSAMI and GSHFS
are each registered under the Advisers Act as investment advisors and
provide investment advisory or subadvisory services to Funds.\2\
Commonwealth and FAFLIC are insurance companies domiciled in
Massachusetts and each acts as depositor for certain separate accounts
that are registered as UITs under the Act. Epoch is a registered
broker-dealer that acts as principal underwriter for the UITs of
Commonwealth and FAFLIC. Each of Goldman Sachs, GSAM, L.P., GSAMI and
GSHFS provide investment advisory services to ESCs, as defined in
section 2(a)(13) of the Act, which provide investment opportunities for
partners of Goldman Sachs (prior to its initial public offering) and
certain employees and consultants of Goldman Sachs and its affiliates.
GSHFS does not currently provide investment advisory services to
registered investment companies.
---------------------------------------------------------------------------
\2\ ``Funds'' refer to any registered investment company or
employees' securities company (``ESC'') for which a Covered Person
serves as an investment adviser, subadviser or depositor, or any
registered open-end investment company, registered unit investment
trust (``UIT'') or registered face amount certificate company for
which a Covered Person serves as principal underwriter (such
activities, collectively, ``Fund Servicing Activities'').
---------------------------------------------------------------------------
2. On July 20, 2010, the United States District Court for the
Southern District of New York entered a final judgment, which included
the Injunction against Goldman Sachs in a matter brought by the
Commission (``Final Judgment'').\3\ The Commission alleged in the
complaint (``Complaint'') that offering materials related to a
transaction in
[[Page 44032]]
which Goldman Sachs or its affiliates sold synthetic collateralized
debt obligations, which referenced a portfolio of synthetic mortgage-
backed securities, to two institutional investors in early 2007
(``Transaction''), should have disclosed that the hedge fund assuming
the short side of the Transaction had played a role in the selection
process. As part of an agreement to settle the action, Goldman Sachs
entered into a consent in which it acknowledged that it was a mistake
not to disclose the role of the hedge fund in the Transaction and
consented to the entry of the Final Judgment, including the Injunction.
The Final Judgment will also decree that Goldman Sachs is liable for
disgorgement of $15 million and a civil penalty of $535 million.\4\
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\3\ Securities and Exchange Commission v. Goldman, Sachs & Co.
and Fabrice Tourre, 10-CV-03229 (S.D.N.Y. July 20, 2010).
\4\ The Final Judgment will also require Goldman Sachs to comply
with certain undertakings relating to (i) the vetting and approval
process for offerings of residential mortgage-related securities
products by its firmwide Capital Committee, (ii) review of marketing
materials used in connection with residential mortgage-related
securities offerings by Goldman Sachs' Legal Department and
Compliance Department, (iii) annual internal audits of the review of
such marketing materials, (iv) where Goldman Sachs is the lead
underwriter of an offering of residential mortgage-related
securities and retains outside counsel to advise on the offering,
review of the related offering materials by outside counsel and (v)
education and training of persons involved in the structuring or
marketing of residential mortgage-related securities offerings.
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Applicants' Legal Analysis
1. Section 9(a)(2) of the Act, in relevant part, prohibits a person
who has been enjoined from engaging in or continuing any conduct or
practice in connection with the purchase or sale of a security from
acting, among other things, as an investment adviser or depositor of
any registered investment company or a principal underwriter for any
registered open-end investment company, registered UITs or registered
face-amount certificate company. Section 9(a)(3) of the Act makes the
prohibition in section 9(a)(2) applicable to a company any affiliated
person of which has been disqualified under the provisions of section
9(a)(2). Section 2(a)(3) of the Act defines ``affiliated person'' to
include any person directly or indirectly controlling, controlled by,
or under common control with, the other person. Applicants state that
Goldman Sachs is an affiliated person of each of the other Applicants
within the meaning of section 2(a)(3) of the Act because they are under
common control. Applicants state that entry of the Final Judgment would
result in the disqualification of Goldman Sachs under section 9(a)(2)
and the other Applicants under section 9(a)(3) of the Act.
2. Section 9(c) of the Act provides that the Commission shall grant
an application for exemption from the disqualification provisions of
section 9(a) if it is established that these provisions, as applied to
Applicants, are unduly or disproportionately severe or that Applicants'
conduct has been such as not to make it against the public interest or
the protection of investors to grant the application. Applicants have
filed an application pursuant to section 9(c) seeking a temporary and
permanent order exempting them from the disqualification provisions of
section 9(a) of the Act.
3. Applicants believe they meet the standards for exemption
specified in section 9(c). Applicants state that the prohibitions of
section 9(a) as applied to them would be unduly and disproportionately
severe and that the conduct of Applicants has been such as not to make
it against the public interest or the protection of investors to grant
the exemption from section 9(a).
4. Applicants state that the violations alleged in the Complaint
did not involve Fund Servicing Activities or the current or former
Goldman Sachs employees who are or were involved in Fund Servicing
Activities. Applicants also state that no current or former director,
officer, or employee of Goldman Sachs or the other Applicants--who is
involved in providing Fund Servicing Activities to Funds--had any
knowledge of, or was involved in, the conduct that forms the basis of
the Complaint. Applicants further state that the individual defendant
named in the Complaint and the other personnel at Goldman Sachs who
were involved in the violations alleged in the Complaint have had no
and will not have any future involvement in providing Fund Servicing
Activities to Funds. Applicants represent that the alleged conduct
giving rise to the Final Judgment did not involve any Fund or the
assets of any Fund for which an Applicant provided Fund Servicing
Activities.
5. Applicants state that the inability of the Applicants to engage
in Fund Servicing Activities would result in potentially severe
hardships for the Funds (including the UITs) and their shareholders or
contract holders. Applicants state that they will distribute, as soon
as reasonably practicable, written materials, including an offer to
meet in person to discuss the materials, to the boards of directors or
trustees of the Funds (excluding for this purpose, the ESCs) (the
``Boards''), including the directors who are not ``interested
persons,'' as defined in section 2(a)(19) of the Act, of such Funds and
their independent legal counsel, as defined in rule 0-1(a)(6) under the
Act, if any, regarding the Injunction, any impact on the Funds, and the
application. Applicants have provided and will continue to provide the
Funds with all information concerning the Final Judgment and the
application that is necessary for the Funds to fulfill their disclosure
and other obligations under the Federal securities laws.
6. Applicants also assert that, if they were barred from providing
Fund Servicing Activities to the Funds and ESCs, the effect on their
businesses and employees would be severe. Applicants state that they
have committed substantial resources to establish an expertise in Fund
Servicing Activities. Applicants further state that prohibiting them
from Fund Servicing Activities would not only adversely affect their
businesses, but would also adversely affect over 600 employees at GSAM,
L.P. alone that are involved in those activities. Applicants also state
that disqualifying Goldman Sachs, GSAM, L.P., GSAMI and GSHFS from
continuing to provide investment advisory services to ESCs is not in
the public interest or in furtherance of the protection of investors.
Applicants assert that it would not be consistent with the purposes of
the ESC provisions of the Act or the representations made in the
application for the ESC order to require another entity not affiliated
with Goldman Sachs to manage the ESCs. In addition, participants in the
ESCs have subscribed for interests in the ESCs with the expectation
that the ESCs would be managed by Goldman Sachs or one of its
affiliates.
7. Applicants state that Goldman Sachs has previously sought and
received exemptions under section 9(c) of the Act on four occasions, as
described in the application.
Applicants' Condition
Applicants agree that any order granting the requested relief will
be subject to the following condition:
Any temporary exemption granted pursuant to the application shall
be without prejudice to, and shall not limit the Commission's rights in
any manner with respect to, any Commission investigation of, or
administrative proceedings involving or against, the Covered Persons,
including without limitation, the consideration by the Commission of a
permanent exemption from section 9(a) of the Act requested pursuant to
the application or the revocation or removal of any temporary
exemptions granted under the Act in connection with the application.
[[Page 44033]]
Temporary Order
The Commission has considered the matter and finds that Applicants
have made the necessary showing to justify granting a temporary
exemption.
Accordingly,
It is hereby ordered, pursuant to section 9(c) of the Act, that
Covered Persons are granted a temporary exemption from the provisions
of section 9(a), effective as of the date of the Injunction, solely
with respect to the Injunction, subject to the condition in the
application, until the date the Commission takes final action on an
application for a permanent order.
By the Commission.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2010-18313 Filed 7-26-10; 8:45 am]
BILLING CODE 8010-01-P