Claymore Exchange-Traded Fund Trust, et al.;, 63222-63225 [2010-25819]
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adviser to a Fund) will cause a Fund to
purchase a security in an Affiliated
Underwriting.
7. The Board of the Fund, including
a majority of the disinterested Board
members, will adopt procedures
reasonably designed to monitor any
purchases of securities by the Fund in
an Affiliated Underwriting, once an
investment by an Investing Fund in the
securities of the 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 Investing Fund in the
Fund. The Board will consider, among
other things: (a) Whether the purchases
were consistent with the investment
objectives and policies of the 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 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.
8. Each 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 an Investing
Fund in the securities of the 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.
9. Before investing in a Fund in
excess of the limit in section
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12(d)(1)(A), an Investing Fund will
execute a FOF Participation Agreement
with the Fund stating that their
respective boards of directors or trustees
and their investment advisers, or
Trustee and Sponsor, 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 shares of a
Fund in excess of the limit in section
12(d)(1)(A)(i), an Investing Fund will
notify the Fund of the investment. At
such time, the Investing Fund will also
transmit to the Fund a list of the names
of each Investing Fund Affiliate and
Underwriting Affiliate. The Investing
Fund will notify the Fund of any
changes to the list as soon as reasonably
practicable after a change occurs. The
Fund and the Investing Fund will
maintain and preserve a copy of the
order, the FOF Participation 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.
10. Before approving any advisory
contract under section 15 of the Act, the
board of directors or trustees of each
Investing 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
Fund in which the Investing
Management Company may invest.
These findings and their basis will be
recorded fully in the minute books of
the appropriate Investing Management
Company.
11. Any sales charges and/or service
fees charged with respect to shares of an
Investing Fund will not exceed the
limits applicable to a fund of funds as
set forth in NASD Conduct Rule 2830.
12. No Fund will acquire securities of
any investment company or company
relying on section 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 a
Fund to purchase shares of a money
market fund 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. 2010–25866 Filed 10–13–10; 8:45 am]
BILLING CODE 8011–01–P
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SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
29458; 812–13657]
Claymore Exchange-Traded Fund
Trust, et al.; Notice of Application
October 7, 2010.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application to amend
a prior order under section 6(c) of the
Investment Company Act of 1940
(‘‘Act’’) granting an exemption from
sections 2(a)(32), 5(a)(1), 22(d), 22(e)
and 24(d) of the Act and rule 22c–1
under the Act, under sections 6(c) and
17(b) of the Act granting an exemption
from sections 17(a)(1) and (a)(2) of the
Act, and under section 12(d)(1)(J)
granting an exemption from sections
12(d)(1)(A) and (B) of the Act (‘‘Prior
Order’’).1
AGENCY:
The Prior
Order permits: (a) Open-end
management investment companies,
whose series are based on certain equity
or fixed-income securities indexes
(each, an ‘‘Underlying Index’’), to issue
shares of limited redeemability; (b)
secondary market transactions in the
shares of the series to occur at
negotiated prices; (c) dealers to sell
shares to purchasers in the secondary
market unaccompanied by a prospectus
when prospectus delivery is not
required by the Securities Act of 1933
(‘‘Securities Act’’); (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
aggregations of the series’ shares; (e)
under certain circumstances, certain
series to pay redemption proceeds more
than seven days after the tender of
shares; and (f) certain registered
management investment companies and
unit investment trusts outside of the
same group of investment companies as
the series to acquire shares of the series.
Applicants seek to amend the Prior
Order to: (a) Permit certain Funds (as
defined below) to track an Underlying
Index that is created, compiled,
sponsored, or maintained by an index
provider (‘‘Index Provider’’) that is an
affiliated person, or an affiliated person
of an affiliated person, of the Fund, its
investment adviser, distributor,
promoter, or any sub-adviser to the
SUMMARY OF APPLICATION:
1 Claymore Exchange-Traded Fund Trust, et al.,
Investment Company Act Release Nos. 27469 (Aug.
28, 2006) (notice) and 27483 (Sept. 18, 2006)
(order), as amended by Investment Company Act
Release Nos. 27982 (Sept. 26, 2007) (notice) and
28019 (Oct. 23, 2007) (order).
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Fund; (b) delete the relief granted from
the requirements of section 24(d) of the
Act in the Prior Order and revise the
applications on which the Prior Order
was issued (‘‘Prior Applications’’) to
reflect such deletion; (c) modify the
80%/90% investment requirement in
the Prior Applications; (d) revise the
discussion of depositary receipts
(‘‘Depositary Receipts’’) in the Prior
Applications; and (e) permit the
personnel of the Adviser (as defined
below) or any sub-adviser who are
responsible for the designation and
dissemination of the securities to be
used for creations (‘‘Deposit Securities’’)
or redemptions (‘‘Fund Securities’’) to
also select securities for purchase or sale
by actively-managed accounts of the
Adviser or any sub-adviser.
APPLICANTS: Claymore Exchange-Traded
Fund Trust, Claymore Exchange-Traded
Fund Trust 2, Claymore ExchangeTraded Fund Trust 3 (each, a ‘‘Trust’’
and together, the ‘‘Trusts’’), Guggenheim
Funds Investment Advisors, LLC
(‘‘Adviser’’), and Guggenheim Funds
Distributors, Inc. (‘‘Distributor’’).
FILING DATES: The application was filed
on May 5, 2009, and amended on
November 23, 2009, September 3, 2010,
and October 1, 2010. Applicants have
agreed to file an amendment during the
notice period, the substance of which is
reflected in the notice.
HEARING OR NOTIFICATION OF HEARING:
An order granting the requested relief
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 November 1, 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–
1090. Applicants, 2455 Corporate West
Drive, Lisle, IL 60532.
FOR FURTHER INFORMATION CONTACT:
Courtney S. Thornton, Senior Counsel,
at (202) 551–6812, or Mary Kay Frech,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Office of Investment Company
Regulation).
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The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
website by searching for the file
number, or for an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm, or by
calling (202) 551–8090.
SUPPLEMENTARY INFORMATION:
Applicants’ Representations
1. Each Trust is organized as a
Delaware statutory trust and is
registered under the Act as an open-end
management investment company. Each
Trust offers one or more series (each a
‘‘Fund’’), each of which operates as an
exchange-traded fund (‘‘ETF’’). The
Adviser, a Delaware limited liability
company, is registered as an investment
adviser under the Investment Advisers
Act of 1940 (the ‘‘Advisers Act’’). The
Adviser serves as investment adviser to
each of the Funds and may retain subadvisers (‘‘Sub-Advisers’’) to manage the
assets of one or more of the Funds. Any
Sub-Adviser will be registered under the
Advisers Act. The Distributor, a brokerdealer registered under the Securities
Exchange Act of 1934 (‘‘Exchange Act’’),
serves as principal underwriter and
distributor for each of the Funds.
2. Applicants currently are permitted
to offer Funds that operate in reliance
on the Prior Order and seek to track the
performance of Underlying Indexes
from Index Providers that are not
‘‘affiliated persons’’ (as such term is
defined in section 2(a)(3) of the Act), or
affiliated persons of affiliated persons,
of a Trust, the Adviser, any Sub-Adviser
to a Fund, the Distributor or a promoter
of a Fund. Certain Funds rely on the
Prior Order and track an Underlying
Index provided by either AlphaShares,
LLC (‘‘AlphaShares’’) or Delta Global
Indices, LLC (‘‘Delta Global’’)
(collectively, the ‘‘Affected Funds’’).2
Currently, neither AlphaShares nor
Delta Global is an affiliated person, nor
an affiliated person of an affiliated
person, of a Trust, the Adviser, or any
Sub-Adviser to a Fund, the Distributor
or promoter of a Fund.
3. Applicants seek to amend the Prior
Order to permit an Affected Fund to
track an Underlying Index that is
created, compiled, sponsored, or
maintained by an Index Provider that is
an affiliated person, as defined in
section 2(a)(3) of the Act, or an affiliated
person of an affiliated person, of a Trust,
the Adviser, the Distributor, promoter,
2 AlphaShares is the Index Provider for
Guggenheim China Real Estate ETF, Guggenheim
China Small Cap ETF, Guggenheim China All-Cap
ETF, and Guggenheim China Technology ETF. Delta
Global is the Index Provider for Guggenheim
Shipping ETF.
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63223
or any Sub-Adviser to the Affected Fund
solely because the Index Provider serves
as a Sub-Adviser to a Subadvised Fund
(as defined below).3 The Adviser
proposes to offer a closed-end fund
(‘‘Closed-End Fund’’) for which
AlphaShares would serve as SubAdviser. In reliance on an order granting
relief with respect to the offering of
actively managed Future Funds,4 the
Adviser and Claymore Exchange-Traded
Fund Trust 3 propose to offer three
actively managed ETFs for which Delta
Global would serve as Sub-Adviser.
Because the Adviser serves or will serve
as investment adviser to each, the
Affected Funds and each Subadvised
Fund could be deemed to be under
common control for purposes of section
2(a)(3). In addition, section 2(a)(3)(E)
provides that any investment adviser to
an investment company is deemed to be
an affiliated person of such company.
Accordingly, by serving as Sub-Adviser
to a Subadvised Fund, each of
AlphaShares and Delta Global could be
deemed to be an affiliated person of an
affiliated person of the Adviser and/or
the Fund(s) for which it serves as Index
Provider. As a result, applicants would
not be permitted to retain either
AlphaShares or Delta Global as SubAdviser to a Subadvised Fund, absent
further exemptive relief.
4. Applicants state that the conflicts
of interest that could result if an Index
Provider has a proscribed relationship
with a Trust, the Adviser, any SubAdviser, the Distributor, or promoter of
a Fund include the ability of an
affiliated person to manipulate the
Underlying Index to the benefit or
detriment of the Fund, as well as
conflicts that may also arise with
respect to the personal trading activity
of personnel of the affiliated person who
may have access to, or knowledge of,
changes to an Underlying Index’s
composition methodology or the
constituent securities in an Underlying
Index prior to the time that information
is publicly disseminated. Applicants
believe that these conflicts of interest
are not applicable to the Affected Funds
because the Adviser is not part of the
3 Applicants request that the requested order
apply to any future series of the Trusts or other
registered investment company advised by the
Adviser or a person controlling, controlled by, or
under common control with the Adviser that
operates as an ETF (a ‘‘Future Fund’’) for which the
Index Provider also serves as Sub-Adviser to
another Fund or Future Fund or other registered
investment company advised by the Adviser, or a
person controlling, controlled by, or under common
control with the Adviser (collectively ‘‘Subadvised
Funds’’).
4 Claymore Exchange-Traded Fund Trust 3, et al.,
Investment Company Act Release No. 29256 (Apr.
23, 2010) (notice) and 29271 (May 18, 2010) (order).
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same organization as either Index
Provider. Accordingly, the Adviser will
not be informed of any additions to or
deletions from an Underlying Index
tracked by an Affected Fund (each, an
‘‘Applicable Underlying Index’’) prior to
other market participants or the general
public. Applicants state that the Adviser
therefore will not have any ability to
manipulate the components of the
Applicable Underlying Indexes for its
own benefit, nor will it have an
informational advantage over other
market participants with regard to
additions to or deletions from the
Applicable Underlying Indexes.
Applicants further state that the Adviser
will not have any role in the (a)
modification of an Applicable
Underlying Index’s methodology, (b)
selection of an Applicable Underlying
Index’s constituents, or (c) calculation
or dissemination of an Applicable
Underlying Index’s value, and shall
have no access to the information
involved with items (a)–(c) or any
changes thereto prior to their public
dissemination in advance of the
rebalancing of an Applicable
Underlying Index or any interim
modification arising from any corporate
action.
5. Applicants also state that the
Adviser and the Index Providers have
adopted policies and procedures
designed to prevent the dissemination
and improper use of non-public
information in a manner similar to
firewalls. Each of the Adviser,
AlphaShares, and Delta Global has
adopted written policies and procedures
in accordance with rule 206(4)–7 under
the Advisers Act, that contains: (a) A
section that sets forth the applicable
entity’s insider trading policy and that
includes the applicable entity’s
procedures to prevent and detect the
misuse of material non-public
information; and (b) the applicable
entity’s code of ethics which was
adopted pursuant to rule 17j–1 under
the Act and rule 204A–1 under the
Advisers Act, which contains provisions
reasonably necessary to prevent Access
Persons (as defined in rule 17j–1) of the
applicable entity from trading on the
basis of, improperly disseminating or
otherwise engaging in any improper use
of nonpublic information.
6. Applicants further state that they
will adopt, and will require
AlphaShares and Delta Global to adopt,
policies and procedures that require the
Applicable Underlying Indexes to be
transparent. Each of AlphaShares and
Delta Global will maintain a publicly
available Web site on which it will
publish the basic concept of each
Applicable Underlying Index and
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disclose (a) the composition
methodology for each such Applicable
Underlying Index (‘‘Index Composition
Methodology’’) and (b) the components
and weightings of the components of
each Applicable Underlying Index (as of
each rebalancing or interim
modification arising from a corporate
action). Applicants note that the
identity and weightings of the
component securities of the Applicable
Underlying Index will be readily
ascertainable by a third party because
the Index Composition Methodology
will be publicly available. Although
each of AlphaShares and Delta Global
reserves the right to modify its Index
Composition Methodology in the future,
such modifications would not take
effect until the applicable Index
Provider has given the Calculation
Agent (as defined below) and the
investing public at least 60 days’ prior
written notice, disclosed on the publicly
available Web site of such Index
Provider, that such changes are being
planned to take effect.5 Each Underlying
Index will be reconstituted or
rebalanced no more frequently than on
a monthly basis.
7. Applicants represent that any Index
Provider to an existing Fund or a Future
Fund that enters into a similar
arrangement to serve as Sub-Adviser to
a Subadvised Fund will be subject to the
same policies and procedures as
proposed herein with respect to
AlphaShares and Delta Global.
Applicants further represent that any
relief granted pursuant to the
application will only apply to an Index
Provider whose affiliation with a Trust,
the Adviser or any Sub-Adviser to a
Fund, Distributor or promoter of a Fund
arises from relationships such as those
described in the application. Applicants
acknowledge that Index Providers
whose affiliation arises from
relationships other than those described
in the application may not serve as
Index Provider to a Fund without
additional exemptive relief.
5 The ‘‘Calculation Agent’’ is the entity that will
implement the Index Composition Methodology,
calculate and maintain the Applicable Underlying
Indexes, and calculate and disseminate the
Applicable Underlying Index values. The
Calculation Agent is not and will not be an
affiliated person within the meaning of section
2(a)(3) of the Act, or an affiliated person of an
affiliated person, of a Trust, the Adviser, any SubAdviser, the Distributor, or a promoter of a Fund.
The Calculation Agent will be instructed not to
communicate any non-public information about the
Applicable Underlying Indexes to anyone, but
specifically not to the personnel of the Adviser with
responsibility for the portfolio management of the
Affected Funds. The Calculation Agent will be
instructed to disseminate information about the
daily constituents of the Applicable Underlying
Indexes to the Adviser (on behalf of the Affected
Funds) and the public at the same time.
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Additional Changes to Prior Order
1. Applicants seek to amend the Prior
Order to delete the relief granted from
section 24(d) of the Act. Applicants
believe that the deletion of the
exemption from section 24(d) is
warranted because the adoption of the
summary prospectus should supplant
any need by a Fund to use a product
description (‘‘Product Description’’).6
The deletion of the relief granted with
respect to section 24(d) of the Act from
the Prior Order will also result in the
deletion of related discussions in the
Prior Applications, revision of the Prior
Applications to delete references to
Product Descriptions, including in the
conditions, and the deletion of
condition 5 to the Prior Order.7
2. The Prior Applications state that a
Fund will hold, in the aggregate, at least
80 percent or 90 percent of its total
assets in the securities that comprise the
relevant Underlying Index (‘‘Component
Securities’’), and investments that have
economic characteristics that are
substantially identical to the economic
characteristics of the Component
Securities of its Underlying Index.
Applicants seek to amend the Prior
Order to require a Fund to hold at least
80 percent of its total assets in
Component Securities of its Underlying
Index or in Depositary Receipts or to-beannounced transactions (‘‘TBAs’’)
representing Component Securities (or
underlying securities representing
Depositary Receipts, if Depositary
Receipts are themselves Component
Securities).
3. Applicants wish to amend the Prior
Order to revise certain representations
regarding a Fund’s ability to invest in
Depositary Receipts. The Prior
Applications state, among other things,
that a Fund will invest only in
Depositary Receipts listed on a national
securities exchange as defined in
section 2(a)(26) of the Act and that all
Depositary Receipts in which a Fund
invests will be sponsored by the issuers
of the underlying security, except in
certain circumstances. Applicants seek
to amend the Prior Applications to state
that Depositary Receipts include
American Depositary Receipts (‘‘ADRs’’)
and Global Depositary Receipts
(‘‘GDRs’’). With respect to ADRs, the
depositary is typically a U.S. financial
institution, and the underlying
6 Investment Company Act Release No. 28584
(Jan. 13, 2009) (the ‘‘Summary Prospectus Rule’’).
7 Condition 5 states: Before a Fund may rely on
the order, the Commission will have approved,
pursuant to rule 19b–4 under the Exchange Act, an
Exchange rule requiring Exchange members and
member organizations effecting transactions in
Fund Shares to deliver a Product Description to
purchasers of Fund Shares.
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securities are issued by a foreign issuer.
The ADR is registered under the
Securities Act on Form F–6. ADR trades
occur either on an Exchange or offexchange. Rule 6620 of the Financial
Industry Regulatory Authority
(‘‘FINRA’’) requires all off-exchange
transactions in ADRs to be reported
within 90 seconds and ADR trade
reports to be disseminated on a realtime basis. With respect to GDRs, the
depositary may be foreign or a U.S.
entity, and the underlying securities
may have a foreign or a U.S. issuer. All
GDRs are sponsored and trade on a
foreign exchange. No affiliated persons
of applicants will serve as the
depositary for any Depositary Receipts
held by a Fund. A Fund will not invest
in any Depositary Receipts that the
Adviser deems to be illiquid or for
which pricing information is not readily
available.
4. Applicants also seek to amend the
terms and conditions of the Prior
Applications to provide that all
representations and conditions
contained in the Prior Applications that
require a Fund to disclose particular
information in the Fund’s prospectus
and/or annual report shall remain
effective with respect to the Fund until
the time the Fund complies with the
disclosure requirements adopted by the
Commission in the Summary Prospectus
Rule. Applicants believe that the
proposal to supersede the
representations and conditions
requiring certain disclosures in the Prior
Applications is warranted because the
Commission’s amendments to Form N–
1A with respect to ETFs as part of the
Summary Prospectus Rule reflect the
Commission’s view with respect to the
appropriate types of prospectus and
annual report disclosures for an ETF.
5. Applicants also wish to amend the
Prior Order to permit the personnel of
the Adviser or any Sub-Adviser who are
responsible for the designation and
dissemination of Deposit Securities or
Fund Securities to also select securities
for purchase or sale by activelymanaged accounts of the Adviser or
Sub-Adviser. The Prior Applications
currently state that such personnel will
have no responsibilities for the selection
of securities for purchase or sale by any
actively-managed accounts of the
Adviser or Sub-Adviser. Applicants
state that the Codes of Ethics adopted by
the Adviser and Distributor, among
other procedures, adequately address
any conflicts of interest. Applicants also
note that the Commission more recently
has granted exemptive relief with
respect to index-based ETFs that does
not contain the prohibition on adviser
personnel designating securities for a
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creation or redemption with respect to
such ETFs and also managing activelymanaged accounts for the adviser.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the same conditions as those
imposed by the Prior Order, except for
condition 5 to the Prior Order, which
will be deleted.8
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. 2010–25819 Filed 10–13–10; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–63050; File No. SR–Phlx–
2010–137]
Self-Regulatory Organizations;
NASDAQ OMX PHLX LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change Regarding
Anti-Internalization Functionality for
NASDAQ OMX PSX
October 6, 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
September 30, 2010, NASDAQ OMX
PHLX LLC (‘‘Phlx’’ or the ‘‘Exchange’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the Exchange. 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 amend
Phlx Rule 3307 to provide an optional
anti-internalization functionality on
NASDAQ OMX PSX (‘‘PSX’’). The text of
the proposed rule change is available
from the Exchange’s Web site at
https://
8 As noted above, all representations and
conditions contained in the application and the
Prior Applications that require a Fund to disclose
particular information in the Fund’s prospectus
and/or annual report shall remain effective with
respect to the Fund until the time that the Fund
complies with the disclosure requirements adopted
by the Commission in the Summary Prospectus
Rule.
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
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Sfmt 4703
63225
nasdaqomxphlx.cchwallstreet.com, at
the Exchange’s principal office, 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, the
Exchange included statements
concerning the purpose of, and basis for,
the proposed rule change. The text of
these statements may be examined at
the places specified in Item IV below,
and is set forth in Sections A, B, and C
below.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange is proposing to provide
a voluntary anti-internalization function
for the PSX System. Under the proposal,
market participants entering orders
under a specific market participant
identifier (‘‘MPID’’) may voluntarily
direct that they not execute against
other orders entered into the System
under the same MPID.
Under the proposal, the System, if
requested, will not execute orders
entered under the same MPID against
each other. Instead, the System will
execute against all eligible trading
interest of other market participants, in
accordance with PSX’s price-size
execution priority, up to the point
where an incoming order would interact
with a resting order having the same
MPID. In such a case, share amounts
equal to the size of the portion of an
incoming order that is designated by the
order execution algorithm to interact
with an order already in the System
with the same MPID will be
decremented from each order.
For example, if market participant
ABCD had an order to sell 1,000 shares
at $10 on the book, entered an order to
buy 1,000 shares at $10, and the System
allocated 100 shares of the incoming
order to the resting ABCD order and 900
shares to other market participants’
orders, the System would execute the
900 shares allocated to other market
participants and would decrement,
without execution, the remaining 100
shares of the incoming order as well as
100 shares from ABCD’s resting order.
Similarly, if ABCD had a resting order
to sell 2,000 shares at $10, entered an
order to buy 500 shares at $10, and the
System allocated all 500 shares to the
resting ABCD order, the System would
cancel the incoming order and
E:\FR\FM\14OCN1.SGM
14OCN1
Agencies
[Federal Register Volume 75, Number 198 (Thursday, October 14, 2010)]
[Notices]
[Pages 63222-63225]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-25819]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 29458; 812-13657]
Claymore Exchange-Traded Fund Trust, et al.; Notice of
Application
October 7, 2010.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application to amend a prior order under section 6(c)
of the Investment Company Act of 1940 (``Act'') granting an exemption
from sections 2(a)(32), 5(a)(1), 22(d), 22(e) and 24(d) of the Act and
rule 22c-1 under the Act, under sections 6(c) and 17(b) of the Act
granting an exemption from sections 17(a)(1) and (a)(2) of the Act, and
under section 12(d)(1)(J) granting an exemption from sections
12(d)(1)(A) and (B) of the Act (``Prior Order'').\1\
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\1\ Claymore Exchange-Traded Fund Trust, et al., Investment
Company Act Release Nos. 27469 (Aug. 28, 2006) (notice) and 27483
(Sept. 18, 2006) (order), as amended by Investment Company Act
Release Nos. 27982 (Sept. 26, 2007) (notice) and 28019 (Oct. 23,
2007) (order).
Summary of Application: The Prior Order permits: (a) Open-end
management investment companies, whose series are based on certain
equity or fixed-income securities indexes (each, an ``Underlying
Index''), to issue shares of limited redeemability; (b) secondary
market transactions in the shares of the series to occur at negotiated
prices; (c) dealers to sell shares to purchasers in the secondary
market unaccompanied by a prospectus when prospectus delivery is not
required by the Securities Act of 1933 (``Securities Act''); (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 aggregations of the series' shares; (e) under certain
circumstances, certain series to pay redemption proceeds more than
seven days after the tender of shares; and (f) certain registered
management investment companies and unit investment trusts outside of
the same group of investment companies as the series to acquire shares
of the series. Applicants seek to amend the Prior Order to: (a) Permit
certain Funds (as defined below) to track an Underlying Index that is
created, compiled, sponsored, or maintained by an index provider
(``Index Provider'') that is an affiliated person, or an affiliated
person of an affiliated person, of the Fund, its investment adviser,
distributor, promoter, or any sub-adviser to the
[[Page 63223]]
Fund; (b) delete the relief granted from the requirements of section
24(d) of the Act in the Prior Order and revise the applications on
which the Prior Order was issued (``Prior Applications'') to reflect
such deletion; (c) modify the 80%/90% investment requirement in the
Prior Applications; (d) revise the discussion of depositary receipts
(``Depositary Receipts'') in the Prior Applications; and (e) permit the
personnel of the Adviser (as defined below) or any sub-adviser who are
responsible for the designation and dissemination of the securities to
be used for creations (``Deposit Securities'') or redemptions (``Fund
Securities'') to also select securities for purchase or sale by
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actively-managed accounts of the Adviser or any sub-adviser.
Applicants: Claymore Exchange-Traded Fund Trust, Claymore Exchange-
Traded Fund Trust 2, Claymore Exchange-Traded Fund Trust 3 (each, a
``Trust'' and together, the ``Trusts''), Guggenheim Funds Investment
Advisors, LLC (``Adviser''), and Guggenheim Funds Distributors, Inc.
(``Distributor'').
Filing Dates: The application was filed on May 5, 2009, and amended on
November 23, 2009, September 3, 2010, and October 1, 2010. Applicants
have agreed to file an amendment during the notice period, the
substance of which is reflected in the notice.
Hearing or Notification of Hearing: An order granting the requested
relief 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 November 1, 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 20549-1090. Applicants, 2455 Corporate West
Drive, Lisle, IL 60532.
FOR FURTHER INFORMATION CONTACT: Courtney S. Thornton, Senior Counsel,
at (202) 551-6812, or Mary Kay Frech, 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 website by searching for the file number, or for an
applicant using the Company name box, at https://www.sec.gov/search/search.htm, or by calling (202) 551-8090.
Applicants' Representations
1. Each Trust is organized as a Delaware statutory trust and is
registered under the Act as an open-end management investment company.
Each Trust offers one or more series (each a ``Fund''), each of which
operates as an exchange-traded fund (``ETF''). The Adviser, a Delaware
limited liability company, is registered as an investment adviser under
the Investment Advisers Act of 1940 (the ``Advisers Act''). The Adviser
serves as investment adviser to each of the Funds and may retain sub-
advisers (``Sub-Advisers'') to manage the assets of one or more of the
Funds. Any Sub-Adviser will be registered under the Advisers Act. The
Distributor, a broker-dealer registered under the Securities Exchange
Act of 1934 (``Exchange Act''), serves as principal underwriter and
distributor for each of the Funds.
2. Applicants currently are permitted to offer Funds that operate
in reliance on the Prior Order and seek to track the performance of
Underlying Indexes from Index Providers that are not ``affiliated
persons'' (as such term is defined in section 2(a)(3) of the Act), or
affiliated persons of affiliated persons, of a Trust, the Adviser, any
Sub-Adviser to a Fund, the Distributor or a promoter of a Fund. Certain
Funds rely on the Prior Order and track an Underlying Index provided by
either AlphaShares, LLC (``AlphaShares'') or Delta Global Indices, LLC
(``Delta Global'') (collectively, the ``Affected Funds'').\2\
Currently, neither AlphaShares nor Delta Global is an affiliated
person, nor an affiliated person of an affiliated person, of a Trust,
the Adviser, or any Sub-Adviser to a Fund, the Distributor or promoter
of a Fund.
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\2\ AlphaShares is the Index Provider for Guggenheim China Real
Estate ETF, Guggenheim China Small Cap ETF, Guggenheim China All-Cap
ETF, and Guggenheim China Technology ETF. Delta Global is the Index
Provider for Guggenheim Shipping ETF.
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3. Applicants seek to amend the Prior Order to permit an Affected
Fund to track an Underlying Index that is created, compiled, sponsored,
or maintained by an Index Provider that is an affiliated person, as
defined in section 2(a)(3) of the Act, or an affiliated person of an
affiliated person, of a Trust, the Adviser, the Distributor, promoter,
or any Sub-Adviser to the Affected Fund solely because the Index
Provider serves as a Sub-Adviser to a Subadvised Fund (as defined
below).\3\ The Adviser proposes to offer a closed-end fund (``Closed-
End Fund'') for which AlphaShares would serve as Sub-Adviser. In
reliance on an order granting relief with respect to the offering of
actively managed Future Funds,\4\ the Adviser and Claymore Exchange-
Traded Fund Trust 3 propose to offer three actively managed ETFs for
which Delta Global would serve as Sub-Adviser. Because the Adviser
serves or will serve as investment adviser to each, the Affected Funds
and each Subadvised Fund could be deemed to be under common control for
purposes of section 2(a)(3). In addition, section 2(a)(3)(E) provides
that any investment adviser to an investment company is deemed to be an
affiliated person of such company. Accordingly, by serving as Sub-
Adviser to a Subadvised Fund, each of AlphaShares and Delta Global
could be deemed to be an affiliated person of an affiliated person of
the Adviser and/or the Fund(s) for which it serves as Index Provider.
As a result, applicants would not be permitted to retain either
AlphaShares or Delta Global as Sub-Adviser to a Subadvised Fund, absent
further exemptive relief.
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\3\ Applicants request that the requested order apply to any
future series of the Trusts or other registered investment company
advised by the Adviser or a person controlling, controlled by, or
under common control with the Adviser that operates as an ETF (a
``Future Fund'') for which the Index Provider also serves as Sub-
Adviser to another Fund or Future Fund or other registered
investment company advised by the Adviser, or a person controlling,
controlled by, or under common control with the Adviser
(collectively ``Subadvised Funds'').
\4\ Claymore Exchange-Traded Fund Trust 3, et al., Investment
Company Act Release No. 29256 (Apr. 23, 2010) (notice) and 29271
(May 18, 2010) (order).
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4. Applicants state that the conflicts of interest that could
result if an Index Provider has a proscribed relationship with a Trust,
the Adviser, any Sub-Adviser, the Distributor, or promoter of a Fund
include the ability of an affiliated person to manipulate the
Underlying Index to the benefit or detriment of the Fund, as well as
conflicts that may also arise with respect to the personal trading
activity of personnel of the affiliated person who may have access to,
or knowledge of, changes to an Underlying Index's composition
methodology or the constituent securities in an Underlying Index prior
to the time that information is publicly disseminated. Applicants
believe that these conflicts of interest are not applicable to the
Affected Funds because the Adviser is not part of the
[[Page 63224]]
same organization as either Index Provider. Accordingly, the Adviser
will not be informed of any additions to or deletions from an
Underlying Index tracked by an Affected Fund (each, an ``Applicable
Underlying Index'') prior to other market participants or the general
public. Applicants state that the Adviser therefore will not have any
ability to manipulate the components of the Applicable Underlying
Indexes for its own benefit, nor will it have an informational
advantage over other market participants with regard to additions to or
deletions from the Applicable Underlying Indexes. Applicants further
state that the Adviser will not have any role in the (a) modification
of an Applicable Underlying Index's methodology, (b) selection of an
Applicable Underlying Index's constituents, or (c) calculation or
dissemination of an Applicable Underlying Index's value, and shall have
no access to the information involved with items (a)-(c) or any changes
thereto prior to their public dissemination in advance of the
rebalancing of an Applicable Underlying Index or any interim
modification arising from any corporate action.
5. Applicants also state that the Adviser and the Index Providers
have adopted policies and procedures designed to prevent the
dissemination and improper use of non-public information in a manner
similar to firewalls. Each of the Adviser, AlphaShares, and Delta
Global has adopted written policies and procedures in accordance with
rule 206(4)-7 under the Advisers Act, that contains: (a) A section that
sets forth the applicable entity's insider trading policy and that
includes the applicable entity's procedures to prevent and detect the
misuse of material non-public information; and (b) the applicable
entity's code of ethics which was adopted pursuant to rule 17j-1 under
the Act and rule 204A-1 under the Advisers Act, which contains
provisions reasonably necessary to prevent Access Persons (as defined
in rule 17j-1) of the applicable entity from trading on the basis of,
improperly disseminating or otherwise engaging in any improper use of
nonpublic information.
6. Applicants further state that they will adopt, and will require
AlphaShares and Delta Global to adopt, policies and procedures that
require the Applicable Underlying Indexes to be transparent. Each of
AlphaShares and Delta Global will maintain a publicly available Web
site on which it will publish the basic concept of each Applicable
Underlying Index and disclose (a) the composition methodology for each
such Applicable Underlying Index (``Index Composition Methodology'')
and (b) the components and weightings of the components of each
Applicable Underlying Index (as of each rebalancing or interim
modification arising from a corporate action). Applicants note that the
identity and weightings of the component securities of the Applicable
Underlying Index will be readily ascertainable by a third party because
the Index Composition Methodology will be publicly available. Although
each of AlphaShares and Delta Global reserves the right to modify its
Index Composition Methodology in the future, such modifications would
not take effect until the applicable Index Provider has given the
Calculation Agent (as defined below) and the investing public at least
60 days' prior written notice, disclosed on the publicly available Web
site of such Index Provider, that such changes are being planned to
take effect.\5\ Each Underlying Index will be reconstituted or
rebalanced no more frequently than on a monthly basis.
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\5\ The ``Calculation Agent'' is the entity that will implement
the Index Composition Methodology, calculate and maintain the
Applicable Underlying Indexes, and calculate and disseminate the
Applicable Underlying Index values. The Calculation Agent is not and
will not be an affiliated person within the meaning of section
2(a)(3) of the Act, or an affiliated person of an affiliated person,
of a Trust, the Adviser, any Sub-Adviser, the Distributor, or a
promoter of a Fund. The Calculation Agent will be instructed not to
communicate any non-public information about the Applicable
Underlying Indexes to anyone, but specifically not to the personnel
of the Adviser with responsibility for the portfolio management of
the Affected Funds. The Calculation Agent will be instructed to
disseminate information about the daily constituents of the
Applicable Underlying Indexes to the Adviser (on behalf of the
Affected Funds) and the public at the same time.
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7. Applicants represent that any Index Provider to an existing Fund
or a Future Fund that enters into a similar arrangement to serve as
Sub-Adviser to a Subadvised Fund will be subject to the same policies
and procedures as proposed herein with respect to AlphaShares and Delta
Global. Applicants further represent that any relief granted pursuant
to the application will only apply to an Index Provider whose
affiliation with a Trust, the Adviser or any Sub-Adviser to a Fund,
Distributor or promoter of a Fund arises from relationships such as
those described in the application. Applicants acknowledge that Index
Providers whose affiliation arises from relationships other than those
described in the application may not serve as Index Provider to a Fund
without additional exemptive relief.
Additional Changes to Prior Order
1. Applicants seek to amend the Prior Order to delete the relief
granted from section 24(d) of the Act. Applicants believe that the
deletion of the exemption from section 24(d) is warranted because the
adoption of the summary prospectus should supplant any need by a Fund
to use a product description (``Product Description'').\6\ The deletion
of the relief granted with respect to section 24(d) of the Act from the
Prior Order will also result in the deletion of related discussions in
the Prior Applications, revision of the Prior Applications to delete
references to Product Descriptions, including in the conditions, and
the deletion of condition 5 to the Prior Order.\7\
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\6\ Investment Company Act Release No. 28584 (Jan. 13, 2009)
(the ``Summary Prospectus Rule'').
\7\ Condition 5 states: Before a Fund may rely on the order, the
Commission will have approved, pursuant to rule 19b-4 under the
Exchange Act, an Exchange rule requiring Exchange members and member
organizations effecting transactions in Fund Shares to deliver a
Product Description to purchasers of Fund Shares.
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2. The Prior Applications state that a Fund will hold, in the
aggregate, at least 80 percent or 90 percent of its total assets in the
securities that comprise the relevant Underlying Index (``Component
Securities''), and investments that have economic characteristics that
are substantially identical to the economic characteristics of the
Component Securities of its Underlying Index. Applicants seek to amend
the Prior Order to require a Fund to hold at least 80 percent of its
total assets in Component Securities of its Underlying Index or in
Depositary Receipts or to-be-announced transactions (``TBAs'')
representing Component Securities (or underlying securities
representing Depositary Receipts, if Depositary Receipts are themselves
Component Securities).
3. Applicants wish to amend the Prior Order to revise certain
representations regarding a Fund's ability to invest in Depositary
Receipts. The Prior Applications state, among other things, that a Fund
will invest only in Depositary Receipts listed on a national securities
exchange as defined in section 2(a)(26) of the Act and that all
Depositary Receipts in which a Fund invests will be sponsored by the
issuers of the underlying security, except in certain circumstances.
Applicants seek to amend the Prior Applications to state that
Depositary Receipts include American Depositary Receipts (``ADRs'') and
Global Depositary Receipts (``GDRs''). With respect to ADRs, the
depositary is typically a U.S. financial institution, and the
underlying
[[Page 63225]]
securities are issued by a foreign issuer. The ADR is registered under
the Securities Act on Form F-6. ADR trades occur either on an Exchange
or off-exchange. Rule 6620 of the Financial Industry Regulatory
Authority (``FINRA'') requires all off-exchange transactions in ADRs to
be reported within 90 seconds and ADR trade reports to be disseminated
on a real-time basis. With respect to GDRs, the depositary may be
foreign or a U.S. entity, and the underlying securities may have a
foreign or a U.S. issuer. All GDRs are sponsored and trade on a foreign
exchange. No affiliated persons of applicants will serve as the
depositary for any Depositary Receipts held by a Fund. A Fund will not
invest in any Depositary Receipts that the Adviser deems to be illiquid
or for which pricing information is not readily available.
4. Applicants also seek to amend the terms and conditions of the
Prior Applications to provide that all representations and conditions
contained in the Prior Applications that require a Fund to disclose
particular information in the Fund's prospectus and/or annual report
shall remain effective with respect to the Fund until the time the Fund
complies with the disclosure requirements adopted by the Commission in
the Summary Prospectus Rule. Applicants believe that the proposal to
supersede the representations and conditions requiring certain
disclosures in the Prior Applications is warranted because the
Commission's amendments to Form N-1A with respect to ETFs as part of
the Summary Prospectus Rule reflect the Commission's view with respect
to the appropriate types of prospectus and annual report disclosures
for an ETF.
5. Applicants also wish to amend the Prior Order to permit the
personnel of the Adviser or any Sub-Adviser who are responsible for the
designation and dissemination of Deposit Securities or Fund Securities
to also select securities for purchase or sale by actively-managed
accounts of the Adviser or Sub-Adviser. The Prior Applications
currently state that such personnel will have no responsibilities for
the selection of securities for purchase or sale by any actively-
managed accounts of the Adviser or Sub-Adviser. Applicants state that
the Codes of Ethics adopted by the Adviser and Distributor, among other
procedures, adequately address any conflicts of interest. Applicants
also note that the Commission more recently has granted exemptive
relief with respect to index-based ETFs that does not contain the
prohibition on adviser personnel designating securities for a creation
or redemption with respect to such ETFs and also managing actively-
managed accounts for the adviser.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the same conditions as those imposed by the Prior Order,
except for condition 5 to the Prior Order, which will be deleted.\8\
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\8\ As noted above, all representations and conditions contained
in the application and the Prior Applications that require a Fund to
disclose particular information in the Fund's prospectus and/or
annual report shall remain effective with respect to the Fund until
the time that the Fund complies with the disclosure requirements
adopted by the Commission in the Summary Prospectus Rule.
For the Commission, by the Division of Investment Management,
pursuant to delegated authority.
Florence E. Harmon,
Deputy Secretary.
[FR Doc. 2010-25819 Filed 10-13-10; 8:45 am]
BILLING CODE 8011-01-P