WNC Tax Credits 40, LLC, WNC Tax Credits 41, LLC, WNC Housing Tax Credits Manager 2, LLC, WNC National Partners, LLC and WNC & Associates, Inc.; Notice of Application, 40946-40948 [2011-17430]
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40946
Federal Register / Vol. 76, No. 133 / Tuesday, July 12, 2011 / Notices
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meaningful enforcement action toward
Indian Point.
• The petitioner focused on the
exemptions to Appendix R to 10 CFR
Part 50 that the licensee submitted in
March 2009. The exemptions include
operator manual actions in a large
number of fire areas at Indian Point. The
petitioner stated that the regulations do
not authorize operator manual actions
as a means for protecting a redundant
system from fire. The petitioner
referenced the ongoing situation in
Japan and questioned whether plant
operators would be physically able to
perform these duties.
• The petitioner stated that (1) the
NRC should reserve exemptions for
extraordinary circumstances, (2) the
NRC should not approve the
exemptions, and (3) Entergy has not
made a serious effort to comply with
Federal regulations.
The NRC is treating the request under
10 CFR 2.206, ‘‘Requests for Action
under This Subpart,’’ and has referred
the request to the Director of the Office
of Nuclear Reactor Regulation (NRR). In
accordance with 10 CFR 2.206, the NRC
will take appropriate action on this
petition within a reasonable period of
time. The petitioner met with the NRR
Petition Review Board on May 9, 2011,
to discuss the petition. The Petition
Review Board considered the results of
that discussion in its determination of
the petitioner’s request for immediate
action and in the establishment of the
schedule for the review of the petition.
A copy of the petition is available for
inspection at the NRC’s Public
Document Room (PDR) located at One
White Flint North, Public File Area O1
F21, 11555 Rockville Pike (first floor),
Rockville, MD. Publicly available
documents created or received at the
NRC are accessible electronically
through the Agencywide Documents
Access and Management System
(ADAMS) in the NRC Library at https://
www.nrc.gov/reading-rm/adams.html.
Persons who do not have access to
ADAMS or who encounter problems in
accessing the documents located in
ADAMS should contact the NRC PDR
reference staff by telephone at 1–800–
397–4209 or 301–415–4737 or by e-mail
at PDR.Resources@nrc.gov.
Dated at Rockville, Maryland, this 30th day
of June 2011.
For the Nuclear Regulatory Commission.
Eric J. Leeds,
Director, Office of Nuclear Reactor
Regulation.
[FR Doc. 2011–17438 Filed 7–11–11; 8:45 am]
BILLING CODE 7590–01–P
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RAILROAD RETIREMENT BOARD
Sunshine Act; Notice of Public Meeting
Notice is hereby given that the
Railroad Retirement Board will hold a
meeting on July 20, 2011, 10 a.m. at the
Board’s meeting room on the 8th floor
of its headquarters building, 844 North
Rush Street, Chicago, Illinois 60611.
The agenda for this meeting follows:
Executive Committee Reports
The entire meeting will be open to the
public. The person to contact for more
information is Martha P. Rico, Secretary
to the Board, Phone No. 312–751–4920.
Dated: July 5, 2011.
Martha P. Rico,
Secretary to the Board.
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on August 1, 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.
Secretary, U.S. Securities
and Exchange Commission, 100 F
Street, NE., Washington, DC 20549–
1090. Applicants, 17782 Sky Park
Circle, Irvine, CA 92614.
ADDRESSES:
[FR Doc. 2011–17620 Filed 7–8–11; 4:15 pm]
BILLING CODE 7905–01–P
FOR FURTHER INFORMATION CONTACT:
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
29715; 812–13885]
WNC Tax Credits 40, LLC, WNC Tax
Credits 41, LLC, WNC Housing Tax
Credits Manager 2, LLC, WNC National
Partners, LLC and WNC & Associates,
Inc.; Notice of Application
July 6, 2011.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under sections 6(c) and 6(e) of the
Investment Company Act of 1940 (the
‘‘Act’’) granting relief from all
provisions of the Act, except sections 37
through 53 of the Act and the rules and
regulations under those sections other
than rule 38a–1 under the Act.
AGENCY:
Emerson S. Davis, Sr., Senior Counsel,
(202) 551–6868, or Daniele Marchesani,
Branch Chief, (202) 551–6821 (Division
of Investment Management, Office of
Investment Company Regulation).
The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or an applicant by using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
SUPPLEMENTARY INFORMATION:
Applicants’ Representations
1. Fund 40 and Fund 41 each was
formed as a California limited company
in 2011. Each Fund will operate as a
‘‘two-tier’’ partnership, i.e., each Fund
will invest as a limited partner or
member in other limited partnerships or
limited liability companies that are
Applicants: WNC Tax Credits 40, LLC characterized as partnerships for
(‘‘Fund 40’’) and WNC Tax Credits 41,
Federal income tax purposes (‘‘Local
LLC (‘‘Fund 41’’) (each a ‘‘Fund,’’ and
Limited Partnerships’’). The Local
collectively, the ‘‘Funds’’), WNC
Limited Partnerships in turn will engage
Housing Tax Credits Manager 2, LLC
in the ownership and operation of
(the ‘‘Manager’’), WNC National
Apartment Complexes expected to be
Partners, LLC (‘‘WNC National
qualified for the low income housing tax
Partners’’) and WNC & Associates, Inc.
credit under the Internal Revenue Code
(‘‘WNC & Associates’’).
of 1986, as amended. The Manager is a
Summary of the Application:
California limited liability company
Applicants request an order to permit
whose sole member is WNC National
each Fund to invest in limited liability
Partners. WNC National Partners is a
companies that engage in the ownership California limited liability company
and operation of apartment complexes
whose sole member is WNC &
for low and moderate income persons
Associates, a California corporation. The
(‘‘Apartment Complexes’’).
objectives of each Fund are to provide
current tax benefits in the form of (a) A
DATES: Filing Date: The application was
predictable stream of low income
filed on April 4, 2011.
Hearing or Notification of Hearing: An housing credits which investors may
use to offset their Federal income tax
order granting the application will be
liabilities, and (b) tax losses.
issued unless the Commission orders a
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2. Each Fund intends to conduct a
private placement of its units of limited
liability company member interest (the
‘‘Units’’) on a commencement date to be
determined by the Manager. Each
Fund’s placement will be conducted as
described in, and by means of a private
placement memorandum, to be
supplemented periodically with
updated information for each Fund’s
placement (the ‘‘Memorandum’’).
Purchasers of Units in a Fund will be
admitted as limited liability company
members (‘‘Members’’) of the issuing
Fund. The Units will be offered
pursuant to the exemption from the
registration requirements of the
Securities Act of 1933 (the ‘‘Securities
Act’’), provided by Rule 506 of
Regulation D under the Securities Act.
Each Member will be required, as
condition to acceptance of a
subscription, to qualify as an
‘‘accredited investor,’’ as that term is
defined in Rule 501(a) of Regulation D
(an ‘‘Accredited Investor’’). Each Fund
intends to offer its Units at a price to be
determined by the Manager prior to
commencement of the Fund’s
placement. The minimum investment
per Accredited Investor will be
determined prior to commencement of
the offerings. Each Fund will establish
its minimum and maximum
capitalization, and will disclose it by
supplement to its Memorandum and
deliver the supplement to all
prospective Accredited Investors prior
to subscription.
3. Each Fund will not accept any
subscriptions for Units until the
requested exemptive order is granted or
the Fund receives an opinion of counsel
that it is exempt from registration under
the Act. Subscriptions for Units must be
approved by the Manager. The
Accredited Investor will execute
representations confirming suitability
and the basis for such suitability. In
addition, transfers of Units will be
permitted only if the transferee meets
the same suitability standards as had
been imposed on the transferor Member.
4. Although a Fund’s direct control
over the management of each Apartment
Complex will be limited, the Fund’s
ownership of interests in Local Limited
Partnerships will, in an economic sense,
be the substantial equivalent of direct
ownership of the Apartment Complexes
themselves. A Fund normally will
acquire at least a 90% interest in the
profits, losses, and tax credits of the
Local Limited Partnerships. However, in
certain cases, at the discretion of the
Manager, the Fund may acquire a lesser
interest in a Local Limited Partnership.
5. Each Fund will have certain voting
rights with respect to each Local
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Limited Partnership. The voting rights
will include the right to dismiss and
replace the local general partner on the
basis of performance, to approve or
disapprove a sale or refinancing of the
Apartment Complex owned by such
Local Limited Partnership, to approve or
disapprove the dissolution of the Local
Limited Partnership, and to approve or
disapprove amendments to the Local
Limited Partnership agreement
materially and adversely affecting the
Fund’s investment.
6. Each Fund will be controlled by the
Manager, pursuant to an operating
agreement (the ‘‘Operating Agreement’’).
The Members of each Fund, consistent
with their limited liability status, will
not be entitled to participate in the
control of the Fund’s business
operations. However, a majority-ininterest of the Members will have the
right to amend the Operating Agreement
of their Fund (subject to certain
limitations) with the consent of the
Manager, which shall not be
unreasonably withheld, to dissolve the
Fund with the consent of the Manager,
which shall not be unreasonably
withheld, and to remove any Manager
and elect a replacement. In addition,
under the Operating Agreement, each
Member is entitled to review all books
and records of the Member’s Fund at
any and all reasonable times.
7. Applicants state that the Operating
Agreement and Memorandum of the
Funds contain provisions to ensure fair
dealing by the Manager with the
Members. Applicants also state that all
compensation to be paid to the Manager
and its affiliates by a Fund is specified
in the Operating Agreement and
Memorandum, and no compensation
will be payable to the Manager or any
of its affiliates by the Fund unless so
specified. Applicants believe that the
fees and other forms of compensation
that will be paid by each Fund to the
Manager and its affiliates are fair and on
terms no less favorable to the Fund than
would be the case if such arrangements
had been made with independent third
parties.
8. During the offering and
organizational phase, WNC Capital
Corporation, an affiliate of the Manager,
will receive a dealer-manager fee from
each Fund for its services in managing
a group of independent broker-dealers
who will sell the Units. The Manager or
an affiliate will also receive from each
Fund a nonaccountable organizational
and offering expense allowance. In
exchange for this allowance, the
Manager has agreed to pay all
organizational and offering expenses of
each Fund (excluding retail selling
commissions, the dealer-manager fee,
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40947
and the nonaccountable organizational
and offering expense allowance). During
its acquisition phase, each Fund will
pay to the Manager or its affiliates an
acquisition fee for analyzing and
evaluating potential investments in
Local Limited Partnerships and for
various other services. The Manager or
its affiliates will receive from each Fund
a nonaccountable acquisition expense
allowance in consideration of which the
Manager or its affiliates will pay all
acquisition expenses of each Fund. All
fees and expenses paid to all persons in
connection with the organization of
each Fund, the offering of Units and the
acquisition of Local Limited Partnership
interests will not exceed an amount
equal to 22% of the Fund’s gross
offering proceeds.
9. During the operating phase, the
Manager will receive a yearly asset
management fee from each Fund in an
amount equal to 0.75% of the Fund’s
invested assets for services rendered by
the Manager in connection with the
administration of the affairs of the Fund
and the management of the Fund’s
assets. During the liquidation phase,
each Fund will pay the Manager or its
affiliates a disposition fee in an amount
of up to 3% of the gross sales price of
an Apartment Complex or a Local
Limited Partnership interest.
10. All proceeds of the private
placement of a Fund’s Units initially
will be placed in an escrow account
with U.S. Bank, National Association
(‘‘Escrow Agent’’). Pending release of
offering proceeds to the Fund, the
Escrow Agent will deposit escrowed
funds in accordance with instructions
from time to time received from the
Manager in short-term United States
Government securities, securities issued
or guaranteed by the United States
Government, and certificates of deposit
or time or demand deposits in
commercial banks. Upon receipt of a
prescribed minimum amount of gross
operating proceeds for a Fund, funds in
escrow will be released to the Fund and
held by it pending investment in Local
Limited Partnerships. Any of a Fund’s
offering proceeds available for
investment in Local Limited Partnership
interests that the Fund has not either
invested or committed to invest within
24 months following the termination of
its offering of Units will be distributed
to investors pro rata as a return of
capital.
11. If more than one entity that the
General Partner or its affiliates advises
or manages may invest in a particular
investment opportunity, the decision as
to the entity that will be allocated the
investment will be based upon such
factors as the effect of the acquisition on
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Federal Register / Vol. 76, No. 133 / Tuesday, July 12, 2011 / Notices
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diversification of each entity’s portfolio,
the estimated income tax effects of the
purchase on each entity, the amount of
funds of each entity available for
investment, and the length of time such
funds have been available for
investment.
Applicants’ Legal Analysis
1. Applicants believe that the Funds
will not be ‘‘investment companies’’
under sections 3(a)(1)(A) or 3(a)(1)(C) of
the Act. If the Funds are deemed to be
investment companies, however,
applicants request an exemption under
section 6(c) and 6(e) of the Act from all
provisions of the Act, except sections 37
through 53 of the Act and the rules and
regulations under those sections, except
rule 38a-1 thereunder.
2. Section 3(a)(1)(A) of the Act
provides that an issuer is an
‘‘investment company’’ if it is or holds
itself out as being engaged primarily, or
proposes to engage primarily, in the
business of investing, reinvesting, or
trading in securities. Applicants believe
that the Funds will not be investment
companies under section 3(a)(1)(A)
because each Fund will be in the
business of investing in and being a
beneficial owner of Apartment
Complexes, not securities.
3. Section 3(a)(1)(C) of the Act
provides that an issuer is an
‘‘investment company’’ if it is engaged
or proposes to engage in the business of
investing, reinvesting, owning, holding,
or trading in securities, and owns or
proposes to acquire ‘‘investment
securities’’ having a value exceeding
40% of the value of such issuer’s total
assets (exclusive of Government
securities and cash items). Applicants
state that although the Local Limited
Partnership interests may be deemed
‘‘investment securities,’’ they are not
readily marketable, cannot be sold
without severe adverse tax
consequences, and have no value apart
from the value of the Apartment
Complexes owned by the Local Limited
Partnerships.
4. Applicants believe that the two-tier
structure is consistent with the purposes
and criteria set forth in the
Commission’s release concerning twotier real estate partnerships (the
‘‘Release’’).1 The Release states that
investment companies that are two-tier
real estate partnerships that invest in
limited partnerships engaged in the
development and operation of housing
for low and moderate income persons
may qualify for an exemption from the
Act pursuant to section 6(c). Section
1 Investment Company Act Release No. 8456
(Aug. 9, 1974).
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6(c) provides that the Commission may
exempt any person from any provision
of the Act and any rule thereunder, if,
and to the extent that, such exemption
is necessary or appropriate in the public
interest and consistent with the
protection of investors and the purposes
fairly intended by the policy and
provisions of the Act. Section 6(e)
permits the Commission to require
companies exempted from the
registration requirements of the Act to
comply with certain specified
provisions of the Act as though the
company were a registered investment
company.
5. The Release lists two conditions,
designed for the protection of investors,
which must be satisfied by two-tier
partnerships to qualify for the
exemption under section 6(c). First,
interests in the issuer should be sold
only to persons for whom investments
in limited profit, essentially tax shelter,
investments would not be unsuitable.
Second, requirements for fair dealing by
the general partner of the issuer with the
limited partners of the issuer should be
included in the basic organizational
documents of the company.
6. Applicants represent that Units will
be sold only to persons for whom
investment in limited profit, essentially
tax shelter, investments would be
suitable. Applicants further state that
the requirements for fair dealing by the
Manager with the Members are included
in the basic organizational documents of
each Fund. Applicants assert, among
other things, that the suitability
standards set forth in the application,
the requirements for fair dealing
provided by the Operating Agreement,
and pertinent governmental regulations
imposed on each Local Limited
Partnership by various Federal, state,
and local agencies provide protection to
Accredited Investors in Units. In
addition, applicants assert that the
requested exemption is both necessary
and appropriate in the public interest.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Cathy H. Ahn,
Deputy Secretary.
[FR Doc. 2011–17430 Filed 7–11–11; 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
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Commission will hold a Closed Meeting
on Thursday, July 14, 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 Walter, 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
14, 2011 will be:
Institution and settlement of injunctive
actions;
Institution and settlement of
administrative proceedings;
Adjudicatory matters; and
Other matters relating to enforcement
proceedings.
At times, changes in Commission
priorities require alterations in the
scheduling of meeting items.
For further information and to
ascertain what, if any, matters have been
added, deleted or postponed, please
contact:
The Office of the Secretary at (202)
551–5400.
Dated: July 7, 2011.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2011–17520 Filed 7–8–11; 11:15 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–64817; File No. SR–CBOE–
2011–059]
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Relating to an Extension
of the Waiver of the Transaction Fee
for Public Customer Orders in SPY
Options Executed in Open Outcry or in
the Automated Improvement
Mechanism
July 6, 2011.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2
1 15
2 17
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U.S.C. 78s(b)(1).
CFR 240.19b–4.
12JYN1
Agencies
[Federal Register Volume 76, Number 133 (Tuesday, July 12, 2011)]
[Notices]
[Pages 40946-40948]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-17430]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 29715; 812-13885]
WNC Tax Credits 40, LLC, WNC Tax Credits 41, LLC, WNC Housing Tax
Credits Manager 2, LLC, WNC National Partners, LLC and WNC &
Associates, Inc.; Notice of Application
July 6, 2011.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under sections 6(c) and
6(e) of the Investment Company Act of 1940 (the ``Act'') granting
relief from all provisions of the Act, except sections 37 through 53 of
the Act and the rules and regulations under those sections other than
rule 38a-1 under the Act.
-----------------------------------------------------------------------
Applicants: WNC Tax Credits 40, LLC (``Fund 40'') and WNC Tax
Credits 41, LLC (``Fund 41'') (each a ``Fund,'' and collectively, the
``Funds''), WNC Housing Tax Credits Manager 2, LLC (the ``Manager''),
WNC National Partners, LLC (``WNC National Partners'') and WNC &
Associates, Inc. (``WNC & Associates'').
Summary of the Application: Applicants request an order to permit
each Fund to invest in limited liability companies that engage in the
ownership and operation of apartment complexes for low and moderate
income persons (``Apartment Complexes'').
DATES: Filing Date: The application was filed on April 4, 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 August 1, 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, 17782 Sky Park
Circle, Irvine, CA 92614.
FOR FURTHER INFORMATION CONTACT: Emerson S. Davis, Sr., Senior Counsel,
(202) 551-6868, or Daniele Marchesani, Branch Chief, (202) 551-6821
(Division of Investment Management, Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or an applicant
by using the Company name box, at https://www.sec.gov/search/search.htm
or by calling (202) 551-8090.
Applicants' Representations
1. Fund 40 and Fund 41 each was formed as a California limited
company in 2011. Each Fund will operate as a ``two-tier'' partnership,
i.e., each Fund will invest as a limited partner or member in other
limited partnerships or limited liability companies that are
characterized as partnerships for Federal income tax purposes (``Local
Limited Partnerships''). The Local Limited Partnerships in turn will
engage in the ownership and operation of Apartment Complexes expected
to be qualified for the low income housing tax credit under the
Internal Revenue Code of 1986, as amended. The Manager is a California
limited liability company whose sole member is WNC National Partners.
WNC National Partners is a California limited liability company whose
sole member is WNC & Associates, a California corporation. The
objectives of each Fund are to provide current tax benefits in the form
of (a) A predictable stream of low income housing credits which
investors may use to offset their Federal income tax liabilities, and
(b) tax losses.
[[Page 40947]]
2. Each Fund intends to conduct a private placement of its units of
limited liability company member interest (the ``Units'') on a
commencement date to be determined by the Manager. Each Fund's
placement will be conducted as described in, and by means of a private
placement memorandum, to be supplemented periodically with updated
information for each Fund's placement (the ``Memorandum''). Purchasers
of Units in a Fund will be admitted as limited liability company
members (``Members'') of the issuing Fund. The Units will be offered
pursuant to the exemption from the registration requirements of the
Securities Act of 1933 (the ``Securities Act''), provided by Rule 506
of Regulation D under the Securities Act. Each Member will be required,
as condition to acceptance of a subscription, to qualify as an
``accredited investor,'' as that term is defined in Rule 501(a) of
Regulation D (an ``Accredited Investor''). Each Fund intends to offer
its Units at a price to be determined by the Manager prior to
commencement of the Fund's placement. The minimum investment per
Accredited Investor will be determined prior to commencement of the
offerings. Each Fund will establish its minimum and maximum
capitalization, and will disclose it by supplement to its Memorandum
and deliver the supplement to all prospective Accredited Investors
prior to subscription.
3. Each Fund will not accept any subscriptions for Units until the
requested exemptive order is granted or the Fund receives an opinion of
counsel that it is exempt from registration under the Act.
Subscriptions for Units must be approved by the Manager. The Accredited
Investor will execute representations confirming suitability and the
basis for such suitability. In addition, transfers of Units will be
permitted only if the transferee meets the same suitability standards
as had been imposed on the transferor Member.
4. Although a Fund's direct control over the management of each
Apartment Complex will be limited, the Fund's ownership of interests in
Local Limited Partnerships will, in an economic sense, be the
substantial equivalent of direct ownership of the Apartment Complexes
themselves. A Fund normally will acquire at least a 90% interest in the
profits, losses, and tax credits of the Local Limited Partnerships.
However, in certain cases, at the discretion of the Manager, the Fund
may acquire a lesser interest in a Local Limited Partnership.
5. Each Fund will have certain voting rights with respect to each
Local Limited Partnership. The voting rights will include the right to
dismiss and replace the local general partner on the basis of
performance, to approve or disapprove a sale or refinancing of the
Apartment Complex owned by such Local Limited Partnership, to approve
or disapprove the dissolution of the Local Limited Partnership, and to
approve or disapprove amendments to the Local Limited Partnership
agreement materially and adversely affecting the Fund's investment.
6. Each Fund will be controlled by the Manager, pursuant to an
operating agreement (the ``Operating Agreement''). The Members of each
Fund, consistent with their limited liability status, will not be
entitled to participate in the control of the Fund's business
operations. However, a majority-in-interest of the Members will have
the right to amend the Operating Agreement of their Fund (subject to
certain limitations) with the consent of the Manager, which shall not
be unreasonably withheld, to dissolve the Fund with the consent of the
Manager, which shall not be unreasonably withheld, and to remove any
Manager and elect a replacement. In addition, under the Operating
Agreement, each Member is entitled to review all books and records of
the Member's Fund at any and all reasonable times.
7. Applicants state that the Operating Agreement and Memorandum of
the Funds contain provisions to ensure fair dealing by the Manager with
the Members. Applicants also state that all compensation to be paid to
the Manager and its affiliates by a Fund is specified in the Operating
Agreement and Memorandum, and no compensation will be payable to the
Manager or any of its affiliates by the Fund unless so specified.
Applicants believe that the fees and other forms of compensation that
will be paid by each Fund to the Manager and its affiliates are fair
and on terms no less favorable to the Fund than would be the case if
such arrangements had been made with independent third parties.
8. During the offering and organizational phase, WNC Capital
Corporation, an affiliate of the Manager, will receive a dealer-manager
fee from each Fund for its services in managing a group of independent
broker-dealers who will sell the Units. The Manager or an affiliate
will also receive from each Fund a nonaccountable organizational and
offering expense allowance. In exchange for this allowance, the Manager
has agreed to pay all organizational and offering expenses of each Fund
(excluding retail selling commissions, the dealer-manager fee, and the
nonaccountable organizational and offering expense allowance). During
its acquisition phase, each Fund will pay to the Manager or its
affiliates an acquisition fee for analyzing and evaluating potential
investments in Local Limited Partnerships and for various other
services. The Manager or its affiliates will receive from each Fund a
nonaccountable acquisition expense allowance in consideration of which
the Manager or its affiliates will pay all acquisition expenses of each
Fund. All fees and expenses paid to all persons in connection with the
organization of each Fund, the offering of Units and the acquisition of
Local Limited Partnership interests will not exceed an amount equal to
22% of the Fund's gross offering proceeds.
9. During the operating phase, the Manager will receive a yearly
asset management fee from each Fund in an amount equal to 0.75% of the
Fund's invested assets for services rendered by the Manager in
connection with the administration of the affairs of the Fund and the
management of the Fund's assets. During the liquidation phase, each
Fund will pay the Manager or its affiliates a disposition fee in an
amount of up to 3% of the gross sales price of an Apartment Complex or
a Local Limited Partnership interest.
10. All proceeds of the private placement of a Fund's Units
initially will be placed in an escrow account with U.S. Bank, National
Association (``Escrow Agent''). Pending release of offering proceeds to
the Fund, the Escrow Agent will deposit escrowed funds in accordance
with instructions from time to time received from the Manager in short-
term United States Government securities, securities issued or
guaranteed by the United States Government, and certificates of deposit
or time or demand deposits in commercial banks. Upon receipt of a
prescribed minimum amount of gross operating proceeds for a Fund, funds
in escrow will be released to the Fund and held by it pending
investment in Local Limited Partnerships. Any of a Fund's offering
proceeds available for investment in Local Limited Partnership
interests that the Fund has not either invested or committed to invest
within 24 months following the termination of its offering of Units
will be distributed to investors pro rata as a return of capital.
11. If more than one entity that the General Partner or its
affiliates advises or manages may invest in a particular investment
opportunity, the decision as to the entity that will be allocated the
investment will be based upon such factors as the effect of the
acquisition on
[[Page 40948]]
diversification of each entity's portfolio, the estimated income tax
effects of the purchase on each entity, the amount of funds of each
entity available for investment, and the length of time such funds have
been available for investment.
Applicants' Legal Analysis
1. Applicants believe that the Funds will not be ``investment
companies'' under sections 3(a)(1)(A) or 3(a)(1)(C) of the Act. If the
Funds are deemed to be investment companies, however, applicants
request an exemption under section 6(c) and 6(e) of the Act from all
provisions of the Act, except sections 37 through 53 of the Act and the
rules and regulations under those sections, except rule 38a-1
thereunder.
2. Section 3(a)(1)(A) of the Act provides that an issuer is an
``investment company'' if it is or holds itself out as being engaged
primarily, or proposes to engage primarily, in the business of
investing, reinvesting, or trading in securities. Applicants believe
that the Funds will not be investment companies under section
3(a)(1)(A) because each Fund will be in the business of investing in
and being a beneficial owner of Apartment Complexes, not securities.
3. Section 3(a)(1)(C) of the Act provides that an issuer is an
``investment company'' if it is engaged or proposes to engage in the
business of investing, reinvesting, owning, holding, or trading in
securities, and owns or proposes to acquire ``investment securities''
having a value exceeding 40% of the value of such issuer's total assets
(exclusive of Government securities and cash items). Applicants state
that although the Local Limited Partnership interests may be deemed
``investment securities,'' they are not readily marketable, cannot be
sold without severe adverse tax consequences, and have no value apart
from the value of the Apartment Complexes owned by the Local Limited
Partnerships.
4. Applicants believe that the two-tier structure is consistent
with the purposes and criteria set forth in the Commission's release
concerning two-tier real estate partnerships (the ``Release'').\1\ The
Release states that investment companies that are two-tier real estate
partnerships that invest in limited partnerships engaged in the
development and operation of housing for low and moderate income
persons may qualify for an exemption from the Act pursuant to section
6(c). Section 6(c) provides that the Commission may exempt any person
from any provision of the Act and any rule thereunder, if, and to the
extent that, such exemption is necessary or appropriate in the public
interest and consistent with the protection of investors and the
purposes fairly intended by the policy and provisions of the Act.
Section 6(e) permits the Commission to require companies exempted from
the registration requirements of the Act to comply with certain
specified provisions of the Act as though the company were a registered
investment company.
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\1\ Investment Company Act Release No. 8456 (Aug. 9, 1974).
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5. The Release lists two conditions, designed for the protection of
investors, which must be satisfied by two-tier partnerships to qualify
for the exemption under section 6(c). First, interests in the issuer
should be sold only to persons for whom investments in limited profit,
essentially tax shelter, investments would not be unsuitable. Second,
requirements for fair dealing by the general partner of the issuer with
the limited partners of the issuer should be included in the basic
organizational documents of the company.
6. Applicants represent that Units will be sold only to persons for
whom investment in limited profit, essentially tax shelter, investments
would be suitable. Applicants further state that the requirements for
fair dealing by the Manager with the Members are included in the basic
organizational documents of each Fund. Applicants assert, among other
things, that the suitability standards set forth in the application,
the requirements for fair dealing provided by the Operating Agreement,
and pertinent governmental regulations imposed on each Local Limited
Partnership by various Federal, state, and local agencies provide
protection to Accredited Investors in Units. In addition, applicants
assert that the requested exemption is both necessary and appropriate
in the public interest.
For the Commission, by the Division of Investment Management,
pursuant to delegated authority.
Cathy H. Ahn,
Deputy Secretary.
[FR Doc. 2011-17430 Filed 7-11-11; 8:45 am]
BILLING CODE 8011-01-P