Kohlberg Capital Corporation; Notice of Application, 47860-47863 [2010-19527]
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Federal Register / Vol. 75, No. 152 / Monday, August 9, 2010 / Notices
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20416.
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Government Performance and Results
Act requires that each Federal agency
update their strategic plan every three
years, (5 U.S.C. 306), and submit their
plan to the Congress. This draft Strategic
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It is the policy of the Agency to
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Authority: 5 U.S.C. 306.
John Kushman,
Chief Financial Officer (Acting).
[FR Doc. 2010–19507 Filed 8–6–10; 8:45 am]
BILLING CODE 8025–01–P
SECURITIES AND EXCHANGE
COMMISSION
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[Investment Company Act Release No.
29376; File No. 812–13623]
Kohlberg Capital Corporation; Notice
of Application
August 3, 2010.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 6(c) of the
AGENCY:
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Investment Company Act of 1940
(‘‘Act’’) for an exemption from sections
23(a), 23(b) and 63 of the Act, and under
sections 57(a)(4) and 57(i) of the Act and
rule 17d–1 under the Act permitting
certain joint transactions otherwise
prohibited by section 57(a)(4) of the Act.
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Applicant’s Representations
1. Kohlberg Capital, a Delaware
corporation, is an internally managed,
non-diversified, closed-end investment
SUMMARY: Summary of the Application:
company that has elected to be
Kohlberg Capital Corporation
regulated as a business development
(‘‘Kohlberg Capital’’) requests an order to company (‘‘BDC’’) under the Act.1
permit it to issue restricted shares of its
Kohlberg Capital provides debt and
common stock (i.e., stock that, at the
equity growth capital to privately-held
time of issuance, is subject to certain
middle market companies and its
forfeiture restrictions, and thus is
investment objective is to generate
restricted as to its transferability until
current income and capital appreciation
such forfeiture restrictions have lapsed) from investments in senior secured term
(‘‘Restricted Stock’’) to its directors who
loans, mezzanine debt and selected
are not also employees or officers of
equity investments in such companies.
Kohlberg Capital (‘‘Non-Employee
Kohlberg Capital may also invest in
Directors’’) under the terms of its 2010
loans to larger, publicly traded
Amended and Restated Non-Employee
companies, high-yield bonds, distressed
Director Plan (together with any
debt securities and debt and equity
Kohlberg Capital executive
securities issued by collateralized debt
compensation plan that did, does, or
obligation funds. As of June 30, 2010,
may in the future, exist, ‘‘Plans’’).
there were 22,549,235 shares of
DATES: Filing Dates: The application was Kohlberg Capital’s common stock
filed on January 20, 2009, and amended outstanding.
2. Kohlberg Capital currently has
on July 9, 2009, and on July 29, 2010.
Hearing or Notification of Hearing: An seven directors serving on its board of
directors (‘‘Board’’) of whom four are
order granting the application will be
Non-Employee Directors. Currently,
issued unless the Commission orders a
hearing. Interested persons may request none of Kohlberg Capital’s NonEmployee Directors is an ‘‘interested
a hearing by writing to the
person’’ of Kohlberg Capital within the
Commission’s Secretary and serving
meaning of section 2(a)(19) of the Act,
applicant with a copy of the request,
but it is possible that Kohlberg Capital
personally or by mail. Hearing requests
may have Non-Employee Directors in
should be received by the Commission
the future who are interested persons of
by 5:30 p.m. on August 30, 2010, and
Kohlberg Capital.
should be accompanied by proof of
3. Kohlberg Capital believes that,
service on applicant, in the form of an
because the market for qualified director
affidavit or, for lawyers, a certificate of
candidates is highly competitive, its
service. Hearing requests should state
successful performance depends on its
the nature of the writer’s interest, the
ability to offer compensation packages
reason for the request, and the issues
to its directors that are competitive with
contested. Persons who wish to be
those offered by other investment
notified of a hearing may request
management businesses. Kohlberg
notification by writing to the
Capital states that granting Restricted
Commission’s Secretary.
Stock to Non-Employee Directors under
ADDRESSES: Secretary, U.S. Securities
the 2010 Amended and Restated Nonand Exchange Commission, 100 F
Employee Director Plan is fair and
Street, NE., Washington, DC 20549–
1090. Kohlberg Capital Corporation, 295 reasonable and would be competitive
with compensation packages offered by
Madison Avenue, 6th Floor, New York,
other investment management
NY 10017.
businesses.
FOR FURTHER INFORMATION CONTACT:
4. Except to the extent restricted
Steven I. Amchan, Senior Counsel, at
under the terms of the 2010 Amended
(202) 551–6826, or Jennifer L. Sawin,
and Restated Non-Employee Director
Branch Chief, at (202) 551–6821
Plan, a Non-Employee Director granted
(Division of Investment Management,
Restricted Stock will have all the rights
Office of Investment Company
of any other shareholder, including the
Regulation).
SUPPLEMENTARY INFORMATION: The
1 Section 2(a)(48) defines a BDC to be any closedend investment company that operates for the
following is a summary of the
purpose of making investments in securities
application. The complete application
described in sections 55(a)(1) through 55(a)(3) of the
may be obtained via the Commission’s
Act and makes available significant managerial
Web site by searching for the file
assistance with respect to the issuers of such
securities.
number, or an applicant using the
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right to vote the Restricted Stock and
the right to receive dividends. During
the restriction period, the Restricted
Stock generally may not be sold,
transferred, pledged, hypothecated,
margined, or otherwise encumbered by
the Non-Employee Director. Except as
the Board otherwise determines, upon
termination of a Non-Employee
Director’s service on the Board,
Restricted Stock for which forfeiture
restrictions have not lapsed at the time
of such termination shall generally be
forfeited.
5. The maximum amount of Restricted
Stock that may be issued under the
Plans will be 10% of the outstanding
shares of Kohlberg Capital’s common
stock on the effective date of the 2010
Amended and Restated Non-Employee
Director Plan plus 10% of the number
of shares of Kohlberg Capital’s common
stock issued or delivered by Kohlberg
Capital (other than pursuant to
compensation plans) during the term of
the 2010 Amended and Restated NonEmployee Director Plan.2 No NonEmployee Director may be granted more
than 25% of the shares reserved for
issuance under the 2010 Amended and
Restated Non-Employee Director Plan.
6. Under the 2010 Amended and
Restated Non-Employee Director Plan,
Non-Employee Directors automatically
would be granted 1,000 shares of
Restricted Stock each year on the date
of the annual meeting of shareholders
(or meeting in lieu of the annual
meeting of shareholders). Half of the
Restricted Stock grant would vest
immediately, and the remaining half
would vest on the earlier of (i) the first
anniversary of such grant, or (ii) the date
immediately preceding the next annual
meeting of shareholders (or meeting in
lieu of the annual meeting of
shareholders). Pro rata grants of
Restricted Stock would be made to NonEmployee Directors appointed outside
the annual election cycle. The grants of
Restricted Stock to Non-Employee
Directors under the 2010 Amended and
Restated Non-Employee Director Plan
will be automatic (subject to the
authority of the Board set forth in
Section 9(b) of the 2010 Amended and
Restated Non-Employee Director Plan to
prevent or limit the granting of
Restricted Stock) and will not be
changed without Commission approval.
7. The 2010 Amended and Restated
Non-Employee Director Plan will be
submitted to Kohlberg Capital’s
2 For purposes of calculating compliance with
this limit, Kohlberg Capital will count as Restricted
Stock all shares of its common stock that are issued
pursuant to the Plan less any shares that are
forfeited back to Kohlberg Capital and cancelled as
a result of forfeiture restrictions not lapsing.
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shareholders for their approval
following the issuance of the order and
will not become effective unless and
until shareholders approve it.
Applicant’s Legal Analysis
Sections 23(a) and (b), Section 63
1. Under section 63 of the Act, the
provisions of section 23(a) of the Act
generally prohibiting a registered
closed-end investment company from
issuing securities for services or for
property other than cash or securities
are made applicable to BDCs. This
provision would prohibit the issuance
of Restricted Stock as a part of the 2010
Amended and Restated Non-Employee
Director Plan.
2. Section 23(b) generally prohibits a
closed-end management investment
company from selling its common stock
at a price below its current net asset
value (‘‘NAV’’). Section 63(2) makes
section 23(b) applicable to BDCs unless
certain conditions are met. Because
Restricted Stock that would be granted
under the 2010 Amended and Restated
Non-Employee Director Plan would not
meet the terms of section 63(2), sections
23(b) and 63 prohibit the issuance of the
Restricted Stock.
3. Section 6(c) provides that the
Commission may, by order upon
application, conditionally or
unconditionally exempt any person,
security, or transaction, or any class or
classes of persons, securities or
transactions, from any provision of the
Act, if and to the extent that the
exemption is necessary or appropriate
in the public interest and consistent
with the protection of investors and the
purposes fairly intended by the policy
and provisions of the Act.
4. Kohlberg Capital requests an order
pursuant to section 6(c) of the Act
granting an exemption from the
provisions of sections 23(a) and (b) and
section 63 of the Act. Kohlberg Capital
states that the concerns underlying
those sections include: (a) preferential
treatment of investment company
insiders and the use of options and
other rights by insiders to obtain control
of the investment company; (b)
complication of the investment
company’s structure that makes it
difficult to determine the value of the
company’s shares; and (c) dilution of
shareholders’ equity in the investment
company. Kohlberg Capital states that
the 2010 Amended and Restated NonEmployee Director Plan does not raise
the concern about preferential treatment
of Kohlberg Capital’s insiders because
the 2010 Amended and Restated NonEmployee Director Plan is bona fide
compensation plan of the type that is
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common among corporations generally.
In addition, section 61(a)(3)(B) of the
Act permits a BDC to issue to its
officers, directors and employees,
pursuant to an executive compensation
plan, warrants, options and rights to
purchase the BDC’s voting securities,
subject to certain requirements.
Kohlberg Capital states that it is not
aware of any specific discussion in
Section 61 and its legislative history
regarding the use of direct grants of
stock as incentive compensation.
Kohlberg Capital states, however, that
the issuance of Restricted Stock is
substantially similar, for purposes of
investor protection under the Act, to the
issuance of warrants, options, and rights
as contemplated by section 61. Kohlberg
Capital also asserts that the 2010
Amended and Restated Non-Employee
Director Plan would not become a
means for insiders to obtain control of
Kohlberg Capital because the number of
shares of Kohlberg Capital issuable
under the 2010 Amended and Restated
Non-Employee Director Plan, and the
number of shares issuable to an
individual Non-Employee Director,
would be limited as set forth in the
conditions.
5. Kohlberg Capital further states that
the 2010 Amended and Restated NonEmployee Director Plan will not unduly
complicate Kohlberg Capital’s capital
structure because equity-based
compensation arrangements are widely
used among corporations and
commonly known to investors. Kohlberg
Capital notes that the 2010 Amended
and Restated Non-Employee Director
Plan will be submitted to its
shareholders for their approval or
disapproval after the issuance of any
order. Kohlberg Capital represents that a
concise, ‘‘plain English’’ description of
the 2010 Amended and Restated NonEmployee Director Plan, including its
potential dilutive effect, will be
provided in the proxy materials that
will be submitted to Kohlberg Capital’s
shareholders. Kohlberg Capital also
states that it will comply with the proxy
disclosure requirements in Item 10 of
Schedule 14A under the Securities
Exchange Act of 1934 (‘‘Exchange Act’’).
Kohlberg Capital further notes that the
2010 Amended and Restated NonEmployee Director Plan will be
disclosed to investors in accordance
with the requirements of the Form N–
2 registration statement for closed-end
investment companies, and pursuant to
the standards and guidelines adopted by
the Financial Accounting Standards
Board for operating companies. In
addition, Kohlberg Capital will comply
with the disclosure requirements for
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executive compensation plans
applicable to operating companies
under the Exchange Act.3 Kohlberg
Capital thus concludes that the 2010
Amended and Restated Non-Employee
Director Plan will be adequately
disclosed to investors and appropriately
reflected in the market value of
Kohlberg Capital’s common stock.
6. Kohlberg Capital acknowledges
that, while awards granted under the
2010 Amended and Restated NonEmployee Director Plan would have a
dilutive effect on the shareholders’
equity in Kohlberg Capital, that effect
would be outweighed by the anticipated
benefits of the 2010 Amended and
Restated Non-Employee Director Plan to
Kohlberg Capital and its shareholders.
Kohlberg Capital asserts that it needs
the flexibility to provide the requested
equity-based compensation in order to
be able to compete effectively with other
financial services firms for talented
directors. Kohlberg Capital states that its
Non-Employee Directors make a
significant contribution to the
management of its business and to the
analysis and supervision of its portfolio
investments, by providing guidance
regarding, among other things,
operational matters and strategic
direction, as well as by serving on the
Board’s three committees. Kohlberg
Capital believes that its ability to make
Restricted Stock grants under the 2010
Amended and Restated Non-Employee
Director Plan to Non-Employee
Directors provides a means of retaining
the services of current Non-Employee
Directors and of attracting qualified
persons to serve as Non-Employee
Directors in the future. Kohlberg Capital
believes that the Restricted Stock grants
will provide significant incentives to the
Non-Employee Directors to devote their
best efforts to the success of Kohlberg
Capital’s business and the enhancement
of shareholder value in the future.
Kohlberg Capital also states that the
Restricted Stock will provide a means
for the Non-Employee Directors to
increase their ownership interests in
Kohlberg Capital, thereby ensuring close
identification of their interests with
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3 Kohlberg
Capital will comply with the
amendments to the disclosure requirements for
executive and director compensation, related party
transactions, director independence and other
corporate governance matters, and security
ownership of officers and directors to the extent
adopted and applicable to BDCs. See Executive
Compensation and Related Party Disclosure,
Securities Act Release No. 8655 (Jan. 27, 2006)
(proposed rule); Executive Compensation and
Related Party Disclosure, Securities Act Release No.
8732A (Aug. 29, 2006) (final rule and proposed
rule), as amended by Executive Compensation
Disclosure, Securities Act Release No. 8765 (Dec.
22, 2006) (adopted as interim final rules with
request for comments).
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those of Kohlberg Capital and its
shareholders.
Section 57(a)(4), Rule 17d–1
7. Section 57(a) proscribes certain
transactions between a BDC and persons
related to the BDC in the manner
described in section 57(b) (‘‘57(b)
persons’’), absent a Commission order.
Section 57(a)(4) generally prohibits a
57(b) person from effecting a transaction
in which the BDC is a joint participant
absent such an order. Rule 17d–1, made
applicable to BDCs by section 57(i),
proscribes participation in a ‘‘joint
enterprise or other joint arrangement or
profit-sharing plan,’’ which includes a
stock option or purchase plan. Nonemployee directors of a BDC are 57(b)
persons. Thus, the issuance of shares of
Restricted Stock could be deemed to
involve a joint transaction involving a
BDC and a 57(b) person in
contravention of section 57(a)(4). Rule
17d–1(b) provides that, in considering
relief pursuant to the rule, the
Commission will consider (i) whether
the participation of the company in a
joint enterprise is consistent with the
Act’s policies and purposes and (ii) the
extent to which that participation is on
a basis different from or less
advantageous than that of other
participants.
8. Kohlberg Capital requests an order
pursuant to section 57(a)(4) and rule
17d–1 to permit Kohlberg Capital to
issue Restricted Stock to Non-Employee
Directors pursuant to the 2010
Amended and Restated Non-Employee
Director Plan. Kohlberg Capital states
that the 2010 Amended and Restated
Non-Employee Director Plan is in the
interests of Kohlberg Capital’s
shareholders because the 2010
Amended and Restated Non-Employee
Director Plan will help Kohlberg Capital
attract and retain highly qualified
directors, help align the interests of
Kohlberg Capital’s Non-Employee
Directors with those of its shareholders,
and is designed to produce a better
return for Kohlberg Capital’s
shareholders.
Applicant’s Conditions
Applicant agrees that the order
granting the requested relief will be
subject to the following conditions:
1. The 2010 Amended and Restated
Non-Employee Director Plan will be
authorized by Kohlberg Capital’s
shareholders.
2. The amount of voting securities
that would result from the exercise of all
of Kohlberg Capital’s outstanding
warrants, options, and rights, together
with any Restricted Stock issued
pursuant to the Plans, at the time of
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issuance shall not exceed 25% of the
outstanding voting securities of
Kohlberg Capital (excluding Restricted
Stock), except that if the amount of
voting securities that would result from
the exercise of all of Kohlberg Capital’s
outstanding warrants, options, and
rights issued to Kohlberg Capital’s
directors, officers, and employees,
together with any Restricted Stock
issued pursuant to the Plans, would
exceed 15% of the outstanding voting
securities of Kohlberg Capital
(excluding Restricted Stock), then the
total amount of voting securities that
would result from the exercise of all
outstanding warrants, options, and
rights, together with any Restricted
Stock issued pursuant to the Plans, at
the time of issuance shall not exceed
20% of the outstanding voting securities
of Kohlberg Capital (excluding
Restricted Stock).
3. The maximum amount of Restricted
Stock that may be issued under the
Plans will be 10% of the outstanding
shares of common stock of Kohlberg
Capital on the effective date of the 2010
Amended and Restated Non-Employee
Director Plan plus 10% of the number
of shares of Kohlberg Capital’s common
stock issued or delivered by Kohlberg
Capital (other than pursuant to
compensation plans) during the term of
the 2010 Amended and Restated NonEmployee Director Plan.
4. The Board will review the 2010
Amended and Restated Non-Employee
Director Plan at least annually. In
addition, the Board will review
periodically the potential impact that
the issuance of Restricted Stock under
the 2010 Amended and Restated NonEmployee Director Plan could have on
Kohlberg Capital’s earnings and NAV
per share, such review to take place
prior to any decisions to grant Restricted
Stock under the 2010 Amended and
Restated Non-Employee Director Plan,
but in no event less frequently than
annually. Adequate procedures and
records will be maintained to permit
such review. The Board will be
authorized to take appropriate steps to
ensure that the grant of Restricted Stock
under the 2010 Amended and Restated
Non-Employee Director Plan would not
have an effect contrary to the interests
of Kohlberg Capital’s shareholders. This
authority will include the authority to
prevent or limit the granting of
additional Restricted Stock under the
2010 Amended and Restated NonEmployee Director Plan. All records
maintained pursuant to this condition
will be subject to examination by the
Commission and its staff.
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For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Florence E. Harmon,
Deputy Secretary.
SECURITIES AND EXCHANGE
COMMISSION
[FR Doc. 2010–19527 Filed 8–6–10; 8:45 am]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of
Proposed Rule Change To Adopt
FINRA Rule 4530 (Reporting
Requirements) in the Consolidated
FINRA Rulebook
[Release No. 34–62621 File No. SR–FINRA–
2010–034]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
Sunshine Act Meeting
July 30, 2010.
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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 a Closed Meeting
on Thursday, August 12, 2010 at 2 p.m.
Commissioners, Counsel to the
Commissioners, the Secretary to the
Commission, and recording secretaries
will attend the Closed Meeting. 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 Meeting in a closed session.
The subject matter of the Closed
Meeting scheduled for Thursday,
August 12, 2010 will be:
Institution and settlement of
injunctive actions;
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.
Dated: August 5, 2010.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2010–19713 Filed 8–5–10; 4:15 pm]
BILLING CODE 8010–01–P
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (‘‘Act’’)1
and Rule 19b–4 thereunder,2 notice is
hereby given that on July 30, 2010,
Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’) (f/k/a
National Association of Securities
Dealers, Inc. (‘‘NASD’’)) 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 FINRA. 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
FINRA is proposing to adopt NASD
Rule 3070 (Reporting Requirements) as
FINRA Rule 4530 (Reporting
Requirements) in the consolidated
FINRA rulebook, subject to certain
amendments, and to delete paragraphs
(a) through (d) of Incorporated NYSE
Rule 351 (Reporting Requirements) and
Incorporated NYSE Rules 351.10 and
351.13. The proposed rule change also
would add a supplementary material
section to proposed FINRA Rule 4530.
The text of the proposed rule change
is available on FINRA’s Web site at
https://www.finra.org, on the
Commission’s Web site at https://
www.sec.gov, at the principal office of
FINRA, and at the Commission’s Public
Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
FINRA 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. FINRA has prepared
1 15
2 17
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U.S.C. 78s(b)(1).
CFR 240.19b–4.
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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
As part of the process of developing
a new consolidated rulebook
(‘‘Consolidated FINRA Rulebook’’),3
FINRA is proposing to adopt NASD
Rule 3070 as FINRA Rule 4530 in the
Consolidated FINRA Rulebook, subject
to certain amendments as described
below. The proposed rule change also
would delete paragraphs (a) through (d)
of Incorporated NYSE Rule 3514 and
NYSE Rules 351.10 and 351.13 from the
Transitional Rulebook.5 Further, the
proposed rule change would add a
supplementary material section to
proposed FINRA Rule 4530 as detailed
below.
Background
NASD Rule 3070 and NYSE Rule 351
require members to report to FINRA
certain specified events (e.g., regulatory
actions) and quarterly statistical and
summary information regarding written
customer complaints. FINRA uses the
reported information for regulatory
purposes. Among other things, the
information assists FINRA to identify
and investigate firms, offices and
associated persons that may pose a
regulatory risk.
Proposal
FINRA proposes replacing NASD Rule
3070 and NYSE Rule 351 with a single
3 The current FINRA rulebook consists of (1)
FINRA Rules; (2) NASD Rules; and (3) rules
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).
4 For convenience, the Incorporated NYSE Rules
are referred to as the NYSE Rules.
5 NYSE Rule 351(e) and NYSE Rule Interpretation
351(e)/01 (Reports of Investigation) govern trade
investigation reporting requirements. NYSE Rules
351(f), 351.11 and 351.12 govern the annual
attestation requirement of the research analyst
conflict of interest rules. These provisions will be
addressed as part of the supervision rules and
research analyst conflict of interest rules,
respectively. See Regulatory Notice 08–24 (May
2008) (Proposed Consolidated FINRA Rules
Governing Supervision and Supervisory Controls)
and Regulatory Notice 08–55 (October 2008)
(FINRA Requests Comment on Proposed Research
Registration and Conflict of Interest Rules).
E:\FR\FM\09AUN1.SGM
09AUN1
Agencies
[Federal Register Volume 75, Number 152 (Monday, August 9, 2010)]
[Notices]
[Pages 47860-47863]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-19527]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 29376; File No. 812-13623]
Kohlberg Capital Corporation; Notice of Application
August 3, 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 (``Act'') for an exemption from sections
23(a), 23(b) and 63 of the Act, and under sections 57(a)(4) and 57(i)
of the Act and rule 17d-1 under the Act permitting certain joint
transactions otherwise prohibited by section 57(a)(4) of the Act.
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SUMMARY: Summary of the Application: Kohlberg Capital Corporation
(``Kohlberg Capital'') requests an order to permit it to issue
restricted shares of its common stock (i.e., stock that, at the time of
issuance, is subject to certain forfeiture restrictions, and thus is
restricted as to its transferability until such forfeiture restrictions
have lapsed) (``Restricted Stock'') to its directors who are not also
employees or officers of Kohlberg Capital (``Non-Employee Directors'')
under the terms of its 2010 Amended and Restated Non-Employee Director
Plan (together with any Kohlberg Capital executive compensation plan
that did, does, or may in the future, exist, ``Plans'').
DATES: Filing Dates: The application was filed on January 20, 2009, and
amended on July 9, 2009, and on July 29, 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 applicant 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 30, 2010, and should be accompanied by proof of
service on applicant, in the form of an affidavit or, for lawyers, a
certificate of service. Hearing requests should state the nature of the
writer's interest, the reason for the request, and the issues
contested. Persons who wish to be notified of a hearing may request
notification by writing to the Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street, NE., Washington, DC 20549-1090. Kohlberg Capital Corporation,
295 Madison Avenue, 6th Floor, New York, NY 10017.
FOR FURTHER INFORMATION CONTACT: Steven I. Amchan, Senior Counsel, at
(202) 551-6826, or Jennifer L. Sawin, 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.
Applicant's Representations
1. Kohlberg Capital, a Delaware corporation, is an internally
managed, non-diversified, closed-end investment company that has
elected to be regulated as a business development company (``BDC'')
under the Act.\1\ Kohlberg Capital provides debt and equity growth
capital to privately-held middle market companies and its investment
objective is to generate current income and capital appreciation from
investments in senior secured term loans, mezzanine debt and selected
equity investments in such companies. Kohlberg Capital may also invest
in loans to larger, publicly traded companies, high-yield bonds,
distressed debt securities and debt and equity securities issued by
collateralized debt obligation funds. As of June 30, 2010, there were
22,549,235 shares of Kohlberg Capital's common stock outstanding.
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\1\ Section 2(a)(48) defines a BDC to be any closed-end
investment company that operates for the purpose of making
investments in securities described in sections 55(a)(1) through
55(a)(3) of the Act and makes available significant managerial
assistance with respect to the issuers of such securities.
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2. Kohlberg Capital currently has seven directors serving on its
board of directors (``Board'') of whom four are Non-Employee Directors.
Currently, none of Kohlberg Capital's Non-Employee Directors is an
``interested person'' of Kohlberg Capital within the meaning of section
2(a)(19) of the Act, but it is possible that Kohlberg Capital may have
Non-Employee Directors in the future who are interested persons of
Kohlberg Capital.
3. Kohlberg Capital believes that, because the market for qualified
director candidates is highly competitive, its successful performance
depends on its ability to offer compensation packages to its directors
that are competitive with those offered by other investment management
businesses. Kohlberg Capital states that granting Restricted Stock to
Non-Employee Directors under the 2010 Amended and Restated Non-Employee
Director Plan is fair and reasonable and would be competitive with
compensation packages offered by other investment management
businesses.
4. Except to the extent restricted under the terms of the 2010
Amended and Restated Non-Employee Director Plan, a Non-Employee
Director granted Restricted Stock will have all the rights of any other
shareholder, including the
[[Page 47861]]
right to vote the Restricted Stock and the right to receive dividends.
During the restriction period, the Restricted Stock generally may not
be sold, transferred, pledged, hypothecated, margined, or otherwise
encumbered by the Non-Employee Director. Except as the Board otherwise
determines, upon termination of a Non-Employee Director's service on
the Board, Restricted Stock for which forfeiture restrictions have not
lapsed at the time of such termination shall generally be forfeited.
5. The maximum amount of Restricted Stock that may be issued under
the Plans will be 10% of the outstanding shares of Kohlberg Capital's
common stock on the effective date of the 2010 Amended and Restated
Non-Employee Director Plan plus 10% of the number of shares of Kohlberg
Capital's common stock issued or delivered by Kohlberg Capital (other
than pursuant to compensation plans) during the term of the 2010
Amended and Restated Non-Employee Director Plan.\2\ No Non-Employee
Director may be granted more than 25% of the shares reserved for
issuance under the 2010 Amended and Restated Non-Employee Director
Plan.
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\2\ For purposes of calculating compliance with this limit,
Kohlberg Capital will count as Restricted Stock all shares of its
common stock that are issued pursuant to the Plan less any shares
that are forfeited back to Kohlberg Capital and cancelled as a
result of forfeiture restrictions not lapsing.
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6. Under the 2010 Amended and Restated Non-Employee Director Plan,
Non-Employee Directors automatically would be granted 1,000 shares of
Restricted Stock each year on the date of the annual meeting of
shareholders (or meeting in lieu of the annual meeting of
shareholders). Half of the Restricted Stock grant would vest
immediately, and the remaining half would vest on the earlier of (i)
the first anniversary of such grant, or (ii) the date immediately
preceding the next annual meeting of shareholders (or meeting in lieu
of the annual meeting of shareholders). Pro rata grants of Restricted
Stock would be made to Non-Employee Directors appointed outside the
annual election cycle. The grants of Restricted Stock to Non-Employee
Directors under the 2010 Amended and Restated Non-Employee Director
Plan will be automatic (subject to the authority of the Board set forth
in Section 9(b) of the 2010 Amended and Restated Non-Employee Director
Plan to prevent or limit the granting of Restricted Stock) and will not
be changed without Commission approval.
7. The 2010 Amended and Restated Non-Employee Director Plan will be
submitted to Kohlberg Capital's shareholders for their approval
following the issuance of the order and will not become effective
unless and until shareholders approve it.
Applicant's Legal Analysis
Sections 23(a) and (b), Section 63
1. Under section 63 of the Act, the provisions of section 23(a) of
the Act generally prohibiting a registered closed-end investment
company from issuing securities for services or for property other than
cash or securities are made applicable to BDCs. This provision would
prohibit the issuance of Restricted Stock as a part of the 2010 Amended
and Restated Non-Employee Director Plan.
2. Section 23(b) generally prohibits a closed-end management
investment company from selling its common stock at a price below its
current net asset value (``NAV''). Section 63(2) makes section 23(b)
applicable to BDCs unless certain conditions are met. Because
Restricted Stock that would be granted under the 2010 Amended and
Restated Non-Employee Director Plan would not meet the terms of section
63(2), sections 23(b) and 63 prohibit the issuance of the Restricted
Stock.
3. Section 6(c) provides that the Commission may, by order upon
application, conditionally or unconditionally exempt any person,
security, or transaction, or any class or classes of persons,
securities or transactions, from any provision of the Act, if and to
the extent that the exemption is necessary or appropriate in the public
interest and consistent with the protection of investors and the
purposes fairly intended by the policy and provisions of the Act.
4. Kohlberg Capital requests an order pursuant to section 6(c) of
the Act granting an exemption from the provisions of sections 23(a) and
(b) and section 63 of the Act. Kohlberg Capital states that the
concerns underlying those sections include: (a) preferential treatment
of investment company insiders and the use of options and other rights
by insiders to obtain control of the investment company; (b)
complication of the investment company's structure that makes it
difficult to determine the value of the company's shares; and (c)
dilution of shareholders' equity in the investment company. Kohlberg
Capital states that the 2010 Amended and Restated Non-Employee Director
Plan does not raise the concern about preferential treatment of
Kohlberg Capital's insiders because the 2010 Amended and Restated Non-
Employee Director Plan is bona fide compensation plan of the type that
is common among corporations generally. In addition, section
61(a)(3)(B) of the Act permits a BDC to issue to its officers,
directors and employees, pursuant to an executive compensation plan,
warrants, options and rights to purchase the BDC's voting securities,
subject to certain requirements. Kohlberg Capital states that it is not
aware of any specific discussion in Section 61 and its legislative
history regarding the use of direct grants of stock as incentive
compensation. Kohlberg Capital states, however, that the issuance of
Restricted Stock is substantially similar, for purposes of investor
protection under the Act, to the issuance of warrants, options, and
rights as contemplated by section 61. Kohlberg Capital also asserts
that the 2010 Amended and Restated Non-Employee Director Plan would not
become a means for insiders to obtain control of Kohlberg Capital
because the number of shares of Kohlberg Capital issuable under the
2010 Amended and Restated Non-Employee Director Plan, and the number of
shares issuable to an individual Non-Employee Director, would be
limited as set forth in the conditions.
5. Kohlberg Capital further states that the 2010 Amended and
Restated Non-Employee Director Plan will not unduly complicate Kohlberg
Capital's capital structure because equity-based compensation
arrangements are widely used among corporations and commonly known to
investors. Kohlberg Capital notes that the 2010 Amended and Restated
Non-Employee Director Plan will be submitted to its shareholders for
their approval or disapproval after the issuance of any order. Kohlberg
Capital represents that a concise, ``plain English'' description of the
2010 Amended and Restated Non-Employee Director Plan, including its
potential dilutive effect, will be provided in the proxy materials that
will be submitted to Kohlberg Capital's shareholders. Kohlberg Capital
also states that it will comply with the proxy disclosure requirements
in Item 10 of Schedule 14A under the Securities Exchange Act of 1934
(``Exchange Act''). Kohlberg Capital further notes that the 2010
Amended and Restated Non-Employee Director Plan will be disclosed to
investors in accordance with the requirements of the Form N-2
registration statement for closed-end investment companies, and
pursuant to the standards and guidelines adopted by the Financial
Accounting Standards Board for operating companies. In addition,
Kohlberg Capital will comply with the disclosure requirements for
[[Page 47862]]
executive compensation plans applicable to operating companies under
the Exchange Act.\3\ Kohlberg Capital thus concludes that the 2010
Amended and Restated Non-Employee Director Plan will be adequately
disclosed to investors and appropriately reflected in the market value
of Kohlberg Capital's common stock.
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\3\ Kohlberg Capital will comply with the amendments to the
disclosure requirements for executive and director compensation,
related party transactions, director independence and other
corporate governance matters, and security ownership of officers and
directors to the extent adopted and applicable to BDCs. See
Executive Compensation and Related Party Disclosure, Securities Act
Release No. 8655 (Jan. 27, 2006) (proposed rule); Executive
Compensation and Related Party Disclosure, Securities Act Release
No. 8732A (Aug. 29, 2006) (final rule and proposed rule), as amended
by Executive Compensation Disclosure, Securities Act Release No.
8765 (Dec. 22, 2006) (adopted as interim final rules with request
for comments).
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6. Kohlberg Capital acknowledges that, while awards granted under
the 2010 Amended and Restated Non-Employee Director Plan would have a
dilutive effect on the shareholders' equity in Kohlberg Capital, that
effect would be outweighed by the anticipated benefits of the 2010
Amended and Restated Non-Employee Director Plan to Kohlberg Capital and
its shareholders. Kohlberg Capital asserts that it needs the
flexibility to provide the requested equity-based compensation in order
to be able to compete effectively with other financial services firms
for talented directors. Kohlberg Capital states that its Non-Employee
Directors make a significant contribution to the management of its
business and to the analysis and supervision of its portfolio
investments, by providing guidance regarding, among other things,
operational matters and strategic direction, as well as by serving on
the Board's three committees. Kohlberg Capital believes that its
ability to make Restricted Stock grants under the 2010 Amended and
Restated Non-Employee Director Plan to Non-Employee Directors provides
a means of retaining the services of current Non-Employee Directors and
of attracting qualified persons to serve as Non-Employee Directors in
the future. Kohlberg Capital believes that the Restricted Stock grants
will provide significant incentives to the Non-Employee Directors to
devote their best efforts to the success of Kohlberg Capital's business
and the enhancement of shareholder value in the future. Kohlberg
Capital also states that the Restricted Stock will provide a means for
the Non-Employee Directors to increase their ownership interests in
Kohlberg Capital, thereby ensuring close identification of their
interests with those of Kohlberg Capital and its shareholders.
Section 57(a)(4), Rule 17d-1
7. Section 57(a) proscribes certain transactions between a BDC and
persons related to the BDC in the manner described in section 57(b)
(``57(b) persons''), absent a Commission order. Section 57(a)(4)
generally prohibits a 57(b) person from effecting a transaction in
which the BDC is a joint participant absent such an order. Rule 17d-1,
made applicable to BDCs by section 57(i), proscribes participation in a
``joint enterprise or other joint arrangement or profit-sharing plan,''
which includes a stock option or purchase plan. Non-employee directors
of a BDC are 57(b) persons. Thus, the issuance of shares of Restricted
Stock could be deemed to involve a joint transaction involving a BDC
and a 57(b) person in contravention of section 57(a)(4). Rule 17d-1(b)
provides that, in considering relief pursuant to the rule, the
Commission will consider (i) whether the participation of the company
in a joint enterprise is consistent with the Act's policies and
purposes and (ii) the extent to which that participation is on a basis
different from or less advantageous than that of other participants.
8. Kohlberg Capital requests an order pursuant to section 57(a)(4)
and rule 17d-1 to permit Kohlberg Capital to issue Restricted Stock to
Non-Employee Directors pursuant to the 2010 Amended and Restated Non-
Employee Director Plan. Kohlberg Capital states that the 2010 Amended
and Restated Non-Employee Director Plan is in the interests of Kohlberg
Capital's shareholders because the 2010 Amended and Restated Non-
Employee Director Plan will help Kohlberg Capital attract and retain
highly qualified directors, help align the interests of Kohlberg
Capital's Non-Employee Directors with those of its shareholders, and is
designed to produce a better return for Kohlberg Capital's
shareholders.
Applicant's Conditions
Applicant agrees that the order granting the requested relief will
be subject to the following conditions:
1. The 2010 Amended and Restated Non-Employee Director Plan will be
authorized by Kohlberg Capital's shareholders.
2. The amount of voting securities that would result from the
exercise of all of Kohlberg Capital's outstanding warrants, options,
and rights, together with any Restricted Stock issued pursuant to the
Plans, at the time of issuance shall not exceed 25% of the outstanding
voting securities of Kohlberg Capital (excluding Restricted Stock),
except that if the amount of voting securities that would result from
the exercise of all of Kohlberg Capital's outstanding warrants,
options, and rights issued to Kohlberg Capital's directors, officers,
and employees, together with any Restricted Stock issued pursuant to
the Plans, would exceed 15% of the outstanding voting securities of
Kohlberg Capital (excluding Restricted Stock), then the total amount of
voting securities that would result from the exercise of all
outstanding warrants, options, and rights, together with any Restricted
Stock issued pursuant to the Plans, at the time of issuance shall not
exceed 20% of the outstanding voting securities of Kohlberg Capital
(excluding Restricted Stock).
3. The maximum amount of Restricted Stock that may be issued under
the Plans will be 10% of the outstanding shares of common stock of
Kohlberg Capital on the effective date of the 2010 Amended and Restated
Non-Employee Director Plan plus 10% of the number of shares of Kohlberg
Capital's common stock issued or delivered by Kohlberg Capital (other
than pursuant to compensation plans) during the term of the 2010
Amended and Restated Non-Employee Director Plan.
4. The Board will review the 2010 Amended and Restated Non-Employee
Director Plan at least annually. In addition, the Board will review
periodically the potential impact that the issuance of Restricted Stock
under the 2010 Amended and Restated Non-Employee Director Plan could
have on Kohlberg Capital's earnings and NAV per share, such review to
take place prior to any decisions to grant Restricted Stock under the
2010 Amended and Restated Non-Employee Director Plan, but in no event
less frequently than annually. Adequate procedures and records will be
maintained to permit such review. The Board will be authorized to take
appropriate steps to ensure that the grant of Restricted Stock under
the 2010 Amended and Restated Non-Employee Director Plan would not have
an effect contrary to the interests of Kohlberg Capital's shareholders.
This authority will include the authority to prevent or limit the
granting of additional Restricted Stock under the 2010 Amended and
Restated Non-Employee Director Plan. All records maintained pursuant to
this condition will be subject to examination by the Commission and its
staff.
[[Page 47863]]
For the Commission, by the Division of Investment Management,
pursuant to delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. 2010-19527 Filed 8-6-10; 8:45 am]
BILLING CODE 8010-01-P