J.P. Morgan Securities LLC, et al.; Notice of Application and Temporary Order, 39447-39449 [2011-16818]
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Federal Register / Vol. 76, No. 129 / Wednesday, July 6, 2011 / Notices
comply with a collection of information
subject to the PRA that does not display
a valid Office of Management and
Budget (OMB) control number.
Please direct your written comments
to: Thomas Bayer, Director/Chief
Information Officer, Securities and
Exchange Commission, c/o Remi PavlikSimon, 6432 General Green Way,
Alexandria, Virginia 22312 or send an email to: PRA_Mailbox@sec.gov.
Dated: June 29, 2011.
Cathy H. Ahn,
Deputy Secretary.
[FR Doc. 2011–16764 Filed 7–5–11; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Rule 15b6–1 and Form BDW; OMB Control
No. 3235–0018; SEC File No. 270–17]
sroberts on DSK5SPTVN1PROD with NOTICES
Submission for OMB Review;
Comment Request
Upon written request, copies available
from: U.S. Securities and Exchange
Commission, Office of Investor
Education and Advocacy,
Washington, DC 20549–0213.
Notice is hereby given that, pursuant
to the Paperwork Reduction Act of 1995
(44 U.S.C. 3501 et seq.), the Securities
and Exchange Commission
(‘‘Commission’’) has submitted to the
Office of Management and Budget a
request to revise the collection of
information discussed below. The Code
of Federal Regulations citation to this
collection of information is the
following rule: 17 CFR 240.15b6–1.
Registered broker-dealers use Form
BDW (17 CFR 249.501a) to withdraw
from registration with the Commission,
the self-regulatory organizations, and
the states. On average, the Commission
estimates that it would take a brokerdealer approximately one hour to
complete and file a Form BDW to
withdraw from Commission registration
as required by Rule 15b6–1. The
Commission estimates that
approximately 515 broker-dealers
withdraw from Commission registration
annually 1 and, therefore, file a Form
BDW via the Internet with Web CRD, a
computer system operated by the
Financial Industry Regulatory
Authority, Inc. that maintains
information regarding registered broker1 This estimate is based on Form BDW data
collected over the past three years. In fiscal year
(from 10/1 through 9/30) 2008, 503 broker-dealers
withdrew from registration. In fiscal year 2009, 533
broker-dealers withdrew from registration. In fiscal
year 2010, 510 broker-dealers withdrew from
registration. (503 + 533 + 510)/3 = 515.
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dealers and their registered personnel.
Therefore, the 515 broker-dealers that
withdraw from registration by filing
Form BDW would incur an aggregate
annual reporting burden of
approximately 515 hours.2
The Commission may not conduct or
sponsor a collection of information
unless it displays a currently valid
control number. No person shall be
subject to any penalty for failing to
comply with a collection of information
subject to the PRA that does not display
a valid Office of Management and
Budget (OMB) control number.
Comments should be directed to: (i)
Desk Officer for the Securities and
Exchange Commission, Office of
Information and Regulatory Affairs,
Office of Management and Budget,
Room 10102, New Executive Office
Building, Washington, DC 20503, or by
sending an e-mail to:
Shagufta_Ahmed@omb.eop.gov; and (ii)
Thomas Bayer, Chief Information
Officer, Securities and Exchange
Commission, c/o Remi Pavlik-Simon,
6432 General Green Way, Alexandria,
VA 22312 or send an e-mail to:
PRA_Mailbox@sec.gov. Comments must
be submitted to OMB within 30 days of
this notice.
Dated: June 29, 2011.
Cathy H. Ahn,
Deputy Secretary.
[FR Doc. 2011–16765 Filed 7–5–11; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–29711; File No. 812–13914]
J.P. Morgan Securities LLC, et al.;
Notice of Application and Temporary
Order
June 29, 2011.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Temporary order and notice of
application for a permanent order under
section 9(c) of the Investment Company
Act of 1940 (‘‘Act’’).
AGENCY:
Summary of Application: Applicants
have received a temporary order
exempting them from section 9(a) of the
Act, with respect to an injunction
entered against J.P. Morgan Securities
LLC (‘‘J.P. Morgan Securities’’) on June
29, 2011 by the United States District
Court for the Southern District of New
York (‘‘Injunction’’), until the
Commission takes final action on an
application for a permanent order.
PO 00000
2 (515
× 1 hour) = 515 hours.
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39447
Applicants also have applied for a
permanent order.
Applicants: J.P. Morgan Securities;
Bear Stearns Asset Management Inc.
(‘‘BSAM’’); Bear Stearns Health
Innoventures Management, L.L.C.
(‘‘BSHIM’’); BSCGP Inc. (‘‘BSCGP’’);
Constellation Growth Capital LLC
(‘‘Constellation’’); Constellation
Ventures Management II, LLC
(‘‘Constellation II’’); Highbridge Capital
Management, LLC (‘‘Highbridge’’); JF
International Management Inc.
(‘‘JFIMI’’); JPMorgan Asset Management
(UK) Limited (‘‘JPMAMUK’’); JPMorgan
Distribution Services, Inc. (‘‘JPMDS’’);
J.P. Morgan Institutional Investments,
Inc. (‘‘JPMII’’); J.P. Morgan Investment
Management Inc. (‘‘JPMIM’’); J.P.
Morgan Latin America Management
Company, LLC (‘‘JPMLAM’’); J.P.
Morgan Partners, LLC (‘‘JPMP’’); J.P.
Morgan Private Investments Inc.
(‘‘JPMPI’’); OEP Co-Investors
Management II, Ltd. (‘‘OEP II’’); OEP CoInvestors Management III, Ltd. (‘‘OEP
III’’, and together with OEP II, the ‘‘OEP
Entities’’); Security Capital Research &
Management Incorporated (‘‘Security
Capital’’); Sixty Wall Street GP
Corporation (‘‘Sixty Wall GP’’); Sixty
Wall Street Management Company, LLC
(‘‘Sixty Wall Management’’); and
Technology Coinvestors Management,
LLC (‘‘TCM’’) (collectively, the
‘‘Applicants’’).1
Filing Date: The application was filed
on June 21, 2011 and amended on June
29, 2011.
Hearing or Notification of Hearing: An
order granting the application will be
issued unless the Commission orders a
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
Applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on July 25, 2011, 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: J.P. Morgan
1 Applicants request that any relief granted
pursuant to the application also apply to any other
company of which J.P. Morgan Securities is or may
become an affiliated person within the meaning of
Section 2(a)(3) of the Act (together with the
Applicants, the ‘‘Covered Persons’’).
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Federal Register / Vol. 76, No. 129 / Wednesday, July 6, 2011 / Notices
Securities, 338 Madison Avenue, New
York, NY 10179; BSAM, BSHIM,
BSCGP, Constellation II, JPMII, JPMIM,
JPMLAM, JPMP, JPMPI, Sixty Wall GP,
Sixty Wall Management, and TCM, 270
Park Avenue, New York, NY 10017;
Constellation and Highbridge, 49 West
57th Street, 32nd Floor, New York, NY
10019; JFIMI, 21st Floor, Chater House,
8 Connaught Road Central, Hong Kong;
JPMAMUK, 125 London Wall, London,
UK EC2Y5AJ; JPMDS, 1111 Polaris
Pkwy, Columbus, Ohio 43240; OEP
Entities, 320 Park Avenue, 18th Floor,
New York, NY 10022; and Security
Capital, 10 South Dearborn Street, Suite
1400, Chicago, IL 60603.
FOR FURTHER INFORMATION CONTACT:
Laura J. Riegel, at (202) 551–6873, or
Dalia Osman Blass, Branch Chief, at
(202) 551–6821 (Division of Investment
Management, Office of Investment
Company Regulation).
SUPPLEMENTARY INFORMATION: The
following is a temporary order and a
summary of the application. The
complete application may be obtained
via the Commission’s Web site by
searching for the file number, or an
applicant using the Company name box,
at https://www.sec.gov/search/
search.htm, or by calling (202) 551–
8090.
Applicants’ Representations:
1. Each of the Applicants (other than
Constellation and Highbridge) is either
directly or indirectly a wholly-owned
subsidiary of J.P. Morgan Chase & Co.
(‘‘JPMC’’). Each of Constellation and
Highbridge is an indirect, majorityowned subsidiary of JPMC. JPMC is a
financial services holding company
whose businesses provide a broad range
of financial services. J.P. Morgan
Securities is registered as a brokerdealer under the Securities Exchange
Act of 1934, as amended (‘‘Exchange
Act’’) and is registered as an investment
adviser under the Investment Advisers
Act of 1940, as amended (the ‘‘Advisers
Act’’). J.P. Morgan Securities does not
currently serve as an investment
adviser, sub-adviser, depositor or
principal underwriter (as defined in
section 2(a)(29) of the Act) for any of the
registered investment companies
(‘‘Funds’’) or employees’ securities
companies (‘‘ESCs,’’ and included in the
term Funds), as defined in section
2(a)(13) of the Act. BSAM is registered
as an investment adviser under the
Advisers Act and serves as investment
adviser or sub-adviser to various Funds,
including as general partner that
provides investment advisory services
to various ESCs.2 BSHIM, BSCGP,
2 Every Applicant that is a general partner that
provides investment advisory services to one or
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Constellation II, the OEP Entities and
TCM serve as general partners that
provide investment advisory services to
various ESCs. Constellation serves as a
sub-adviser to various ESCs. Highbridge,
JFIMI, JPMAMUK, JPMIM, JPMPI, and
Security Capital are registered as
investment advisers under the Advisers
Act and serve as investment advisers or
sub-advisers to various Funds.
JPMLAM, JPMP, Sixty Wall GP and
Sixty Wall Management are registered as
investment advisers under the Advisers
Act and serve as investment advisers or
sub-advisers to ESCs. JPMDS is
registered as a broker-dealer under the
Exchange Act and serves as principal
underwriter to certain Funds. JPMII is
registered as a broker-dealer under the
Exchange Act and serves as placement
agent to certain Funds.3
2. On June 29, 2011, the United States
District Court for the Southern District
of New York entered a judgment, which
included the Injunction, against J.P.
Morgan Securities (‘‘Final Judgment’’) in
a matter brought by the Commission.4
The conduct of J.P. Morgan Securities
alleged in the Complaint involved an
offering of a largely synthetic
collateralized debt obligation (‘‘CDO’’)
whose portfolio consisted primarily of
credit default swaps referencing other
CDO securities. The Complaint alleged
that J.P. Morgan Securities represented
in marketing materials that the collateral
manager selected the CDO’s investment
portfolio but failed to disclose that a
hedge fund that purchased the
subordinated notes (or ‘‘equity’’), which
also took the short position on roughly
half of the portfolio assets, played a
significant role in the selection process.
The Final Judgment would restrain and
enjoin J.P. Morgan Securities from
violating sections 17(a)(2) and 17(a)(3)
of the Securities Act. Without admitting
or denying any of the allegations in the
Complaint, except as to personal and
subject matter jurisdiction, J.P. Morgan
Securities consented to the entry of the
Final Judgment and other equitable
relief including certain undertakings.
Applicants’ Legal Analysis:
more ESCs believes, for purposes of the application,
that it is performing a function that falls within the
definition of ‘‘investment adviser’’ in section
2(a)(20) of the Act.
3 JPMII serves as placement agent to JPMorgan
Institutional Trust with respect to three series.
JPMorgan Institutional Trust is an open-end
investment company registered under the Act, but
its shares are not registered under the Securities Act
of 1933, as amended. JPMII believes, for purposes
of the application, that it is performing a function
that falls within the definition of ‘‘principal
underwriter’’ in Section 2(a)(29) of the Act.
4 U.S. Securities and Exchange Commission v. J.P.
Morgan Securities LLC (f/k/a J.P. Morgan Securities
Inc.) Case No. 1:11–cv–04206–RMB (S.D.N.Y. June
29, 2011).
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Fmt 4703
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1. Section 9(a)(2) of the Act, in
relevant part, prohibits a person who
has been enjoined from engaging in or
continuing any conduct or practice in
connection with the purchase or sale of
a security, or in connection with
activities as an underwriter, broker or
dealer, from acting, among other things,
as an investment adviser or depositor of
any registered investment company or a
principal underwriter for any registered
open-end company, registered unit
investment trust or registered faceamount certificate company. Section
9(a)(3) of the Act makes the prohibition
in section 9(a)(2) applicable to a
company, any affiliated person of which
has been disqualified under the
provisions of section 9(a)(2). Section
2(a)(3) of the Act defines ‘‘affiliated
person’’ to include, among others, any
person directly or indirectly controlling,
controlled by, or under common control
with, the other person. Applicants state
that J.P. Morgan Securities is an
affiliated person of each of the other
Applicants within the meaning of
section 2(a)(3) of the Act. Applicants
state that the entry of the Injunction
results in Applicants being subject to
the disqualification provisions of
section 9(a) of the Act.
2. Section 9(c) of the Act provides that
the Commission shall grant an
application for exemption from the
disqualification provisions of section
9(a) if it is established that these
provisions, as applied to the applicants,
are unduly or disproportionately severe
or that the applicants’ conduct has been
such as not to make it against the public
interest or the protection of investors to
grant the exemption. Applicants have
filed an application pursuant to section
9(c) seeking a temporary and permanent
order exempting them and other
Covered Persons from the
disqualification provisions of section
9(a) of the Act.
3. Applicants believe they meet the
standard for exemption specified in
section 9(c). Applicants state that the
prohibitions of section 9(a) as applied to
them would be unduly and
disproportionately severe and that the
conduct of the Applicants has been such
as not to make it against the public
interest or the protection of investors to
grant the exemption from section 9(a).
4. Applicants state that the alleged
conduct giving rise to the Injunction did
not involve any of the Applicants acting
in the capacity of investment adviser,
sub-adviser or depositor for any Fund
(including as general partner providing
investment advisory services to ESCs) or
as principal underwriter for any
registered open-end company, registered
unit investment trust or registered face-
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amount certificate company. Applicants
also state that to the best of their
knowledge, none of the current
directors, officers, or employees of the
Applicants that are involved in
providing services as investment adviser
or sub-adviser of the Funds (including
as general partner providing investment
advisory services to ESCs) or principal
underwriter for any registered open-end
company (or any other persons in such
roles during the time period covered by
the Complaint) participated in the
conduct alleged in the Complaint to
have constituted the violations that
provide a basis for the Injunction.
Applicants further represent that the
personnel at J.P. Morgan Securities who
participated in the conduct alleged in
the Complaint to have constituted the
violations that provided a basis for the
Injunction have had no, and will not
have any, involvement in providing
advisory, depositary (including as
general partner providing investment
advisory services to ESCs) to the Funds
or principal underwriting services to
any registered open-end company,
registered unit investment trust, or
registered face-amount certificate
company on the behalf of the
Applicants or other Covered Persons.
Applicants also represent that because
the personnel of the Applicants (other
than those at J.P. Morgan Securities) did
not participate in the conduct alleged in
the Complaint to have constituted the
violations that provide a basis for the
Injunction, the shareholders of those
Funds were not affected any differently
than if those Funds had received
services from any other non-affiliated
investment adviser or principal
underwriter. Applicants state that the
alleged conduct did not involve any
Fund or the assets of any Fund.
5. Applicants state that their inability
to continue to provide investment
advisory and subadvisory services to the
Funds (including as general partner
providing investment advisory services
to ESCs) and principal underwriting
services to any registered open-end
company would result in potential
hardship for the Funds and their
shareholders. Applicants state that they
will, as soon as reasonably practical,
distribute written materials, including
an offer to meet in person to discuss the
materials, to the boards of directors of
the Funds (‘‘Boards’’) (excluding, for
this purpose, the ESCs) for which the
Applicants serve as investment adviser,
investment sub-adviser or principal
underwriter, including the directors
who are not ‘‘interested persons,’’ as
defined in section 2(a)(19) of the Act, of
such Funds, and their independent legal
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counsel, if any, describing the
circumstances that led to the Injunction
and any impact on the Funds, and the
application. Applicants state they will
provide the Boards with the information
concerning the Injunction and the
application that is necessary for the
Funds to fulfill their disclosure and
other obligations under the Federal
securities laws.
6. Applicants also state that, if they
were barred from providing services to
the Funds, the effect on their businesses
and employees would be severe.
Applicants state that they have
committed substantial resources to
establishing expertise in providing
advisory and distribution services to
Funds. Applicants further state that
prohibiting them from providing such
services would not only adversely affect
their businesses, but would also
adversely affect about 940 employees
who are involved in those activities.
Applicants also state that disqualifying
certain Applicants from continuing to
provide investment advisory services to
the ESCs is not in the public interest or
in the furtherance of the protection of
investors. Because the ESCs have been
formed for certain key employees,
officers and directors of JPMC and its
affiliates, it would not be consistent
with the purposes of the ESC provisions
of the Act or the terms and conditions
of the ESC orders to require another
entity not affiliated with JPMC to
manage the ESCs. In addition,
participating employees of JPM and its
affiliates likely subscribed for interests
in the ESCs with the expectation that
the ESCs would be managed by an
affiliate of JPMC.
7. Certain of the Applicants
previously have applied for and
received exemptions under section 9(c)
as the result of conduct that triggered
section 9(a) of the Act, as described in
greater detail in the application.
Applicants’ Condition:
Applicants agree that any order
granting the requested relief will be
subject to the following condition:
Any temporary exemption granted
pursuant to the application shall be
without prejudice to, and shall not limit
the Commission’s rights in any manner
with respect to, any Commission
investigation of, or administrative
proceedings involving or against,
Covered Persons, including, without
limitation, the consideration by the
Commission of a permanent exemption
from section 9(a) of the Act requested
pursuant to the application or the
revocation or removal of any temporary
exemptions granted under the Act in
connection with the application.
Temporary Order:
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39449
The Commission has considered the
matter and finds that Applicants have
made the necessary showing to justify
granting a temporary exemption.
Accordingly,
It is hereby ordered, pursuant to
section 9(c) of the Act, that Applicants
and any other Covered Persons are
granted a temporary exemption from the
provisions of section 9(a), solely with
respect to the Injunction, subject to the
condition in the application, from June
29, 2011, until the Commission takes
final action on their application for a
permanent order.
By the Commission.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2011–16818 Filed 7–5–11; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Sunshine Act Meeting
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, July 7, 2011 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, July 7,
2011 will be:
Institution and settlement of
injunctive actions;
Institution and settlement of
administrative proceedings;
An adjudicatory matter; 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:
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Agencies
[Federal Register Volume 76, Number 129 (Wednesday, July 6, 2011)]
[Notices]
[Pages 39447-39449]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-16818]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-29711; File No. 812-13914]
J.P. Morgan Securities LLC, et al.; Notice of Application and
Temporary Order
June 29, 2011.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Temporary order and notice of application for a permanent order
under section 9(c) of the Investment Company Act of 1940 (``Act'').
-----------------------------------------------------------------------
Summary of Application: Applicants have received a temporary order
exempting them from section 9(a) of the Act, with respect to an
injunction entered against J.P. Morgan Securities LLC (``J.P. Morgan
Securities'') on June 29, 2011 by the United States District Court for
the Southern District of New York (``Injunction''), until the
Commission takes final action on an application for a permanent order.
Applicants also have applied for a permanent order.
Applicants: J.P. Morgan Securities; Bear Stearns Asset Management
Inc. (``BSAM''); Bear Stearns Health Innoventures Management, L.L.C.
(``BSHIM''); BSCGP Inc. (``BSCGP''); Constellation Growth Capital LLC
(``Constellation''); Constellation Ventures Management II, LLC
(``Constellation II''); Highbridge Capital Management, LLC
(``Highbridge''); JF International Management Inc. (``JFIMI'');
JPMorgan Asset Management (UK) Limited (``JPMAMUK''); JPMorgan
Distribution Services, Inc. (``JPMDS''); J.P. Morgan Institutional
Investments, Inc. (``JPMII''); J.P. Morgan Investment Management Inc.
(``JPMIM''); J.P. Morgan Latin America Management Company, LLC
(``JPMLAM''); J.P. Morgan Partners, LLC (``JPMP''); J.P. Morgan Private
Investments Inc. (``JPMPI''); OEP Co-Investors Management II, Ltd.
(``OEP II''); OEP Co-Investors Management III, Ltd. (``OEP III'', and
together with OEP II, the ``OEP Entities''); Security Capital Research
& Management Incorporated (``Security Capital''); Sixty Wall Street GP
Corporation (``Sixty Wall GP''); Sixty Wall Street Management Company,
LLC (``Sixty Wall Management''); and Technology Coinvestors Management,
LLC (``TCM'') (collectively, the ``Applicants'').\1\
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\1\ Applicants request that any relief granted pursuant to the
application also apply to any other company of which J.P. Morgan
Securities is or may become an affiliated person within the meaning
of Section 2(a)(3) of the Act (together with the Applicants, the
``Covered Persons'').
---------------------------------------------------------------------------
Filing Date: The application was filed on June 21, 2011 and amended
on June 29, 2011.
Hearing or Notification of Hearing: An order granting the
application will be issued unless the Commission orders a hearing.
Interested persons may request a hearing by writing to the Commission's
Secretary and serving Applicants with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 p.m. on July 25, 2011, 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: J.P. Morgan
[[Page 39448]]
Securities, 338 Madison Avenue, New York, NY 10179; BSAM, BSHIM, BSCGP,
Constellation II, JPMII, JPMIM, JPMLAM, JPMP, JPMPI, Sixty Wall GP,
Sixty Wall Management, and TCM, 270 Park Avenue, New York, NY 10017;
Constellation and Highbridge, 49 West 57th Street, 32nd Floor, New
York, NY 10019; JFIMI, 21st Floor, Chater House, 8 Connaught Road
Central, Hong Kong; JPMAMUK, 125 London Wall, London, UK EC2Y5AJ;
JPMDS, 1111 Polaris Pkwy, Columbus, Ohio 43240; OEP Entities, 320 Park
Avenue, 18th Floor, New York, NY 10022; and Security Capital, 10 South
Dearborn Street, Suite 1400, Chicago, IL 60603.
FOR FURTHER INFORMATION CONTACT: Laura J. Riegel, at (202) 551-6873, or
Dalia Osman Blass, Branch Chief, at (202) 551-6821 (Division of
Investment Management, Office of Investment Company Regulation).
SUPPLEMENTARY INFORMATION: The following is a temporary order and a
summary of the application. The complete application may be obtained
via the Commission's Web site by searching for the file number, or an
applicant using the Company name box, at https://www.sec.gov/search/search.htm, or by calling (202) 551-8090.
Applicants' Representations:
1. Each of the Applicants (other than Constellation and Highbridge)
is either directly or indirectly a wholly-owned subsidiary of J.P.
Morgan Chase & Co. (``JPMC''). Each of Constellation and Highbridge is
an indirect, majority-owned subsidiary of JPMC. JPMC is a financial
services holding company whose businesses provide a broad range of
financial services. J.P. Morgan Securities is registered as a broker-
dealer under the Securities Exchange Act of 1934, as amended
(``Exchange Act'') and is registered as an investment adviser under the
Investment Advisers Act of 1940, as amended (the ``Advisers Act'').
J.P. Morgan Securities does not currently serve as an investment
adviser, sub-adviser, depositor or principal underwriter (as defined in
section 2(a)(29) of the Act) for any of the registered investment
companies (``Funds'') or employees' securities companies (``ESCs,'' and
included in the term Funds), as defined in section 2(a)(13) of the Act.
BSAM is registered as an investment adviser under the Advisers Act and
serves as investment adviser or sub-adviser to various Funds, including
as general partner that provides investment advisory services to
various ESCs.\2\ BSHIM, BSCGP, Constellation II, the OEP Entities and
TCM serve as general partners that provide investment advisory services
to various ESCs. Constellation serves as a sub-adviser to various ESCs.
Highbridge, JFIMI, JPMAMUK, JPMIM, JPMPI, and Security Capital are
registered as investment advisers under the Advisers Act and serve as
investment advisers or sub-advisers to various Funds. JPMLAM, JPMP,
Sixty Wall GP and Sixty Wall Management are registered as investment
advisers under the Advisers Act and serve as investment advisers or
sub-advisers to ESCs. JPMDS is registered as a broker-dealer under the
Exchange Act and serves as principal underwriter to certain Funds.
JPMII is registered as a broker-dealer under the Exchange Act and
serves as placement agent to certain Funds.\3\
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\2\ Every Applicant that is a general partner that provides
investment advisory services to one or more ESCs believes, for
purposes of the application, that it is performing a function that
falls within the definition of ``investment adviser'' in section
2(a)(20) of the Act.
\3\ JPMII serves as placement agent to JPMorgan Institutional
Trust with respect to three series. JPMorgan Institutional Trust is
an open-end investment company registered under the Act, but its
shares are not registered under the Securities Act of 1933, as
amended. JPMII believes, for purposes of the application, that it is
performing a function that falls within the definition of
``principal underwriter'' in Section 2(a)(29) of the Act.
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2. On June 29, 2011, the United States District Court for the
Southern District of New York entered a judgment, which included the
Injunction, against J.P. Morgan Securities (``Final Judgment'') in a
matter brought by the Commission.\4\ The conduct of J.P. Morgan
Securities alleged in the Complaint involved an offering of a largely
synthetic collateralized debt obligation (``CDO'') whose portfolio
consisted primarily of credit default swaps referencing other CDO
securities. The Complaint alleged that J.P. Morgan Securities
represented in marketing materials that the collateral manager selected
the CDO's investment portfolio but failed to disclose that a hedge fund
that purchased the subordinated notes (or ``equity''), which also took
the short position on roughly half of the portfolio assets, played a
significant role in the selection process. The Final Judgment would
restrain and enjoin J.P. Morgan Securities from violating sections
17(a)(2) and 17(a)(3) of the Securities Act. Without admitting or
denying any of the allegations in the Complaint, except as to personal
and subject matter jurisdiction, J.P. Morgan Securities consented to
the entry of the Final Judgment and other equitable relief including
certain undertakings.
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\4\ U.S. Securities and Exchange Commission v. J.P. Morgan
Securities LLC (f/k/a J.P. Morgan Securities Inc.) Case No. 1:11-cv-
04206-RMB (S.D.N.Y. June 29, 2011).
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Applicants' Legal Analysis:
1. Section 9(a)(2) of the Act, in relevant part, prohibits a person
who has been enjoined from engaging in or continuing any conduct or
practice in connection with the purchase or sale of a security, or in
connection with activities as an underwriter, broker or dealer, from
acting, among other things, as an investment adviser or depositor of
any registered investment company or a principal underwriter for any
registered open-end company, registered unit investment trust or
registered face-amount certificate company. Section 9(a)(3) of the Act
makes the prohibition in section 9(a)(2) applicable to a company, any
affiliated person of which has been disqualified under the provisions
of section 9(a)(2). Section 2(a)(3) of the Act defines ``affiliated
person'' to include, among others, any person directly or indirectly
controlling, controlled by, or under common control with, the other
person. Applicants state that J.P. Morgan Securities is an affiliated
person of each of the other Applicants within the meaning of section
2(a)(3) of the Act. Applicants state that the entry of the Injunction
results in Applicants being subject to the disqualification provisions
of section 9(a) of the Act.
2. Section 9(c) of the Act provides that the Commission shall grant
an application for exemption from the disqualification provisions of
section 9(a) if it is established that these provisions, as applied to
the applicants, are unduly or disproportionately severe or that the
applicants' conduct has been such as not to make it against the public
interest or the protection of investors to grant the exemption.
Applicants have filed an application pursuant to section 9(c) seeking a
temporary and permanent order exempting them and other Covered Persons
from the disqualification provisions of section 9(a) of the Act.
3. Applicants believe they meet the standard for exemption
specified in section 9(c). Applicants state that the prohibitions of
section 9(a) as applied to them would be unduly and disproportionately
severe and that the conduct of the Applicants has been such as not to
make it against the public interest or the protection of investors to
grant the exemption from section 9(a).
4. Applicants state that the alleged conduct giving rise to the
Injunction did not involve any of the Applicants acting in the capacity
of investment adviser, sub-adviser or depositor for any Fund (including
as general partner providing investment advisory services to ESCs) or
as principal underwriter for any registered open-end company,
registered unit investment trust or registered face-
[[Page 39449]]
amount certificate company. Applicants also state that to the best of
their knowledge, none of the current directors, officers, or employees
of the Applicants that are involved in providing services as investment
adviser or sub-adviser of the Funds (including as general partner
providing investment advisory services to ESCs) or principal
underwriter for any registered open-end company (or any other persons
in such roles during the time period covered by the Complaint)
participated in the conduct alleged in the Complaint to have
constituted the violations that provide a basis for the Injunction.
Applicants further represent that the personnel at J.P. Morgan
Securities who participated in the conduct alleged in the Complaint to
have constituted the violations that provided a basis for the
Injunction have had no, and will not have any, involvement in providing
advisory, depositary (including as general partner providing investment
advisory services to ESCs) to the Funds or principal underwriting
services to any registered open-end company, registered unit investment
trust, or registered face-amount certificate company on the behalf of
the Applicants or other Covered Persons. Applicants also represent that
because the personnel of the Applicants (other than those at J.P.
Morgan Securities) did not participate in the conduct alleged in the
Complaint to have constituted the violations that provide a basis for
the Injunction, the shareholders of those Funds were not affected any
differently than if those Funds had received services from any other
non-affiliated investment adviser or principal underwriter. Applicants
state that the alleged conduct did not involve any Fund or the assets
of any Fund.
5. Applicants state that their inability to continue to provide
investment advisory and subadvisory services to the Funds (including as
general partner providing investment advisory services to ESCs) and
principal underwriting services to any registered open-end company
would result in potential hardship for the Funds and their
shareholders. Applicants state that they will, as soon as reasonably
practical, distribute written materials, including an offer to meet in
person to discuss the materials, to the boards of directors of the
Funds (``Boards'') (excluding, for this purpose, the ESCs) for which
the Applicants serve as investment adviser, investment sub-adviser or
principal underwriter, including the directors who are not ``interested
persons,'' as defined in section 2(a)(19) of the Act, of such Funds,
and their independent legal counsel, if any, describing the
circumstances that led to the Injunction and any impact on the Funds,
and the application. Applicants state they will provide the Boards with
the information concerning the Injunction and the application that is
necessary for the Funds to fulfill their disclosure and other
obligations under the Federal securities laws.
6. Applicants also state that, if they were barred from providing
services to the Funds, the effect on their businesses and employees
would be severe. Applicants state that they have committed substantial
resources to establishing expertise in providing advisory and
distribution services to Funds. Applicants further state that
prohibiting them from providing such services would not only adversely
affect their businesses, but would also adversely affect about 940
employees who are involved in those activities. Applicants also state
that disqualifying certain Applicants from continuing to provide
investment advisory services to the ESCs is not in the public interest
or in the furtherance of the protection of investors. Because the ESCs
have been formed for certain key employees, officers and directors of
JPMC and its affiliates, it would not be consistent with the purposes
of the ESC provisions of the Act or the terms and conditions of the ESC
orders to require another entity not affiliated with JPMC to manage the
ESCs. In addition, participating employees of JPM and its affiliates
likely subscribed for interests in the ESCs with the expectation that
the ESCs would be managed by an affiliate of JPMC.
7. Certain of the Applicants previously have applied for and
received exemptions under section 9(c) as the result of conduct that
triggered section 9(a) of the Act, as described in greater detail in
the application.
Applicants' Condition:
Applicants agree that any order granting the requested relief will
be subject to the following condition:
Any temporary exemption granted pursuant to the application shall
be without prejudice to, and shall not limit the Commission's rights in
any manner with respect to, any Commission investigation of, or
administrative proceedings involving or against, Covered Persons,
including, without limitation, the consideration by the Commission of a
permanent exemption from section 9(a) of the Act requested pursuant to
the application or the revocation or removal of any temporary
exemptions granted under the Act in connection with the application.
Temporary Order:
The Commission has considered the matter and finds that Applicants
have made the necessary showing to justify granting a temporary
exemption.
Accordingly,
It is hereby ordered, pursuant to section 9(c) of the Act, that
Applicants and any other Covered Persons are granted a temporary
exemption from the provisions of section 9(a), solely with respect to
the Injunction, subject to the condition in the application, from June
29, 2011, until the Commission takes final action on their application
for a permanent order.
By the Commission.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2011-16818 Filed 7-5-11; 8:45 am]
BILLING CODE 8011-01-P