MFS Series Trust I, et al., 62470-62475 [2011-25926]
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Oppenheimer Baring SMA
International Fund [File No. 811–
21915]
Summary: Applicant seeks an order
declaring that it has ceased to be an
investment company. On February 9,
2011, applicant made a liquidating
distribution to its shareholders, based
on net asset value. Applicant incurred
no expenses in connection with the
liquidation.
Filing Date: The application was filed
on September 1, 2011.
Applicant’s Address: 6803 S. Tucson
Way, Centennial, CO 80112.
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Blankinship Funds Inc. [File No. 811–
21387]
Summary: Applicant seeks an order
declaring that it has ceased to be an
investment company. On July 21, 2011,
applicant made a liquidating
distribution to its shareholders, based
on net asset value. Applicant incurred
no expenses in connection with the
liquidation.
Filing Dates: The application was
filed on July 22, 2011, and amended on
September 2, 2011.
Applicant’s Address: 1210 S.
Huntress Ct., McLean, VA 22102.
650 High Income Fund, Inc. [File No.
811–7359]
Summary: Applicant, a closed-end
investment company, seeks an order
declaring that it has ceased to be an
investment company. On March 22,
2011, applicant made a final liquidating
distribution to its shareholders, based
on net asset value. Distributions payable
to unlocated shareholders are being held
by American Stock Transfer & Trust
Company. Any unclaimed funds will
eventually escheat to the various states.
Expenses of $170,147 incurred in
connection with the liquidation were
paid by applicant. Expenses in the
amount of $297,816 have been accrued,
but have not yet been paid in full.
Applicant has placed $250,000 in cash
in a reserve account to cover an
insurance policy deductible for its
officers and directors, which amount is
included in applicant’s accrued but
unpaid expenses. Any amounts
remaining from the reserve account
would eventually be distributed to
applicant’s shareholders.
Filing Dates: The application was
filed on April 28, 2011, and amended on
July 1, 2011 and August 29, 2011.
Applicant’s Address: 650 Madison
Ave., 19th Floor, New York, NY 10022.
Separate Account VA GG [811–22477]
Summary: The Applicant, a unit
investment trust, seeks an order
declaring that it has ceased to be an
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investment company based on
abandonment of registration. The
Applicant has no policyholders.
Transamerica Life Insurance Company,
as the Applicant’s depositor, has
determined that the Applicant should
be deregistered inasmuch as it is not
engaged in or intending to engage in any
business activities other than those
necessary for winding up its affairs.
Filing Date: The application was filed
on August 26, 2011.
Applicant’s Address: Separate
Account VA GG, Transamerica Life
Insurance Company, 4333 Edgewood
Road NE., Cedar Rapids, Iowa 52499–
0001.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2011–25925 Filed 10–6–11; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
29827; File No. 812–13606]
MFS Series Trust I, et al.; Notice of
Application
September 30, 2011.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under (a) section 6(c) of the
Investment Company Act of 1940
(‘‘Act’’) granting an exemption from
sections 18(f) and 21(b) of the Act; (b)
section 12(d)(1)(J) of the Act granting an
exemption from section 12(d)(1) of the
Act; (c) sections 6(c) and 17(b) of the
Act granting an exemption from sections
17(a)(1), 17(a)(2) and 17(a)(3) of the Act;
and (d) section 17(d) of the Act and rule
17d–1 under the Act to permit certain
joint arrangements.
AGENCY:
SUMMARY OF THE APPLICATION:
Applicants request an order that would
permit certain registered open-end
management investment companies to
participate in a joint lending and
borrowing facility.
APPLICANTS: MFS Series Trust I, MFS
Series Trust II, MFS Series Trust III,
MFS Series Trust IV, MFS Series Trust
V, MFS Series Trust VI, MFS Series
Trust VII, MFS Series Trust VIII, MFS
Series Trust IX, MFS Series Trust X,
MFS Series Trust XI, MFS Series Trust
XII, MFS Series Trust XIII, MFS Series
Trust XIV, MFS Series Trust XV, MFS
Series Trust XVI, MFS Municipal Series
Trust, MFS Variable Insurance Trust,
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MFS Variable Insurance Trust II,
Massachusetts Investors Trust,
Massachusetts Investors Growth Stock
Fund, MFS Institutional Trust (each, a
‘‘Trust’’) and Massachusetts Financial
Services Company (‘‘MFS’’).
Filing Dates: The application was
filed on November 20, 2008, amended
on May 7, 2009, July 22, 2010 and
September 16, 2011.
DATES:
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 October 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.
HEARING OR NOTIFICATION OF HEARING:
Secretary, U.S. Securities
and Exchange Commission, 100 F
Street, NE., Washington, DC 20549–
1090. Applicants, Massachusetts
Financial Services Company, 500
Boylston Street, Boston, MA 02116.
ADDRESSES:
Jean
E. Minarick, Senior Counsel, at (202)
551–6811 or Janet M. Grossnickle,
Assistant Director, at (202) 551–6821
(Division of Investment Management,
Office of Investment Company
Regulation).
FOR FURTHER INFORMATION CONTACT:
The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
SUPPLEMENTARY INFORMATION:
Applicants’ Representations
1. Each Trust is organized as a
Massachusetts business trust and is
registered under the Act as an open-end
management investment company. Each
Trust may consist of one or more series
and may offer additional series in the
future (‘‘Funds’’). MFS, a Delaware
corporation, is registered as an
investment adviser under the
Investment Advisers Act of 1940, and
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serves as the investment adviser to each
Fund.1
2. Some Funds, including money
market Funds that rely on rule 2a–7
under the Act (‘‘Money Market Funds’’),
may lend money to banks or other
entities by entering into repurchase
agreements, purchasing other short-term
instruments, or, in the case of Funds
other than the Money Market Funds,
investing in the MFS Institutional
Money Market Fund (‘‘IMMF’’) pursuant
to rule 12d1–1 under the Act. Other
Funds may borrow money from the
same or similar banks for temporary
purposes to satisfy redemption requests,
to cover unanticipated cash shortfalls
such as a trade ‘‘fail’’ in which cash
payment for a security sold by a Fund
has been delayed, or for other temporary
purposes. Currently, the Trusts have a
committed credit facility provided by a
syndicate of lenders and uncommitted
lines of credit with two separate banks
(collectively, the ‘‘Loan Agreements’’).
The Funds also have an overdraft
facility with their custodians.
3. If a Fund were to borrow money
under a Loan Agreement, the Fund
would pay interest on the borrowed
cash at a rate which would be higher
than the rate that would be earned by
other (non-borrowing) Funds on
investments in repurchase agreements
and other short-term instruments of the
same maturity as the bank loan. In
addition, while bank borrowings
generally can supply needed cash to
cover unanticipated redemptions and
sales fails, the borrowing Funds incur
commitment fees and/or other charges
involved in obtaining a bank loan.
4. Applicants request an order that
would permit each Trust to enter into
master interfund lending agreements
(‘‘Interfund Lending Agreements’’) that
would permit each Fund to lend and
borrow money for temporary purposes
directly to and from each other Fund
through a credit facility (‘‘Interfund
Loan’’). Applicants believe that the
proposed credit facility would reduce
the Funds’ borrowing costs and enhance
their ability to earn higher interest rates
1 Applicants request that the relief apply to (a)
any Fund, (b) any successor entity to MFS, and (c)
any other registered open-end management
investment company or its series advised by MFS
and for which MFS Fund Distributors, Inc. (‘‘MFD’’)
or a person controlling, controlled by, or under
common control (within the meaning of section
2(a)(9) of the Act) with MFD serves as principal
underwriter (each, also a ‘‘Fund’’). The term
‘‘successor’’ is limited to entities that result from a
reorganization into another jurisdiction or a change
in the type of business organization. All entities
that currently intend to rely on the requested relief
are named as applicants. Any other existing or
future Funds that subsequently rely on the order
will comply with the terms and conditions set forth
in the application.
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on short-term lendings. Although the
proposed credit facility would reduce
the Funds’ need to borrow from banks,
the Funds would be free to establish or
renew committed lines of credit or other
borrowing arrangements with
unaffiliated banks.
5. Applicants anticipate that the
credit facility would provide a
borrowing Fund with significant savings
when the cash position of the Fund is
insufficient to meet temporary cash
requirements. This situation could arise
when redemptions exceed anticipated
volumes and certain Funds have
insufficient cash on hand to satisfy such
redemptions. When a Fund liquidates
portfolio securities to meet redemption
requests, it often does not receive
payment in settlement for up to three
days (or longer for certain foreign
transactions). The credit facility would
provide a source of immediate, shortterm liquidity pending settlement of the
sale of portfolio securities.
6. Applicants also propose using the
credit facility when a sale of securities
‘‘fails’’ due to circumstances such as a
delay in the delivery of cash to a Fund’s
custodian or improper delivery
instructions by the broker effecting the
transaction. Sales fails may present a
cash shortfall if a Fund has undertaken
to purchase securities using the
proceeds from the securities sold. As a
result, the Fund could fail on its
intended purchase due to lack of funds
from the previous sale, resulting in
additional cost to the Fund, or sell a
security on a same-day settlement basis,
earning a lower return on the
investment. Use of the credit facility
under these circumstances would
enable the Fund to have access to
immediate short-term liquidity.
7. While bank borrowings generally
can supply needed cash to cover
unanticipated redemptions and sales
fails, under the proposed credit facility
a borrowing Fund would pay lower
interest rates than those offered by
banks on short-term loans. In addition,
Funds making short-term cash loans
directly to other Funds would earn
interest at a rate higher than they
otherwise could obtain from investing
their cash in repurchase agreements.
Thus, applicants believe that the
proposed credit facility would benefit
both borrowing and lending Funds.
8. The interest rate charged to a Fund
on any Interfund Loan (‘‘Interfund Loan
Rate’’) would be the average of the
‘‘Repo Rate’’ and the ‘‘Bank Loan Rate,’’
both as defined below. The Repo Rate
on any day would be the highest rate
available to a lending Fund from
investing in overnight repurchase
agreements. The Bank Loan Rate on any
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day would be calculated by the
‘‘Interfund Lending Committee’’ (as
defined below) each day an Interfund
Loan is made according to a formula
established by each Fund’s board of
trustees (‘‘Fund Board’’) intended to
approximate the lowest interest rate at
which bank short-term loans would be
available to the Funds. The formula
would be based upon a publicly
available rate (e.g., Federal funds rates
and/or Libor), plus an additional spread
of basis points and would vary with this
rate so as to reflect changing bank loan
rates. The initial formula and any
subsequent modifications to the formula
would be subject to the approval of each
Fund Board. Each Fund Board would at
least annually review the continuing
appropriateness of using the method of
calculating the Bank Loan Rate, as well
as the relationship between the Bank
Loan Rate and current bank loan rates
that would be available to the Funds.
9. The credit facility would be
administered by investment
professionals and administrative
personnel from MFS (the ‘‘Interfund
Lending Committee’’). No portfolio
manager, including research analysts
with portfolio management
responsibilities, for any Fund will serve
as a member of the Interfund Lending
Committee. Under the proposed credit
facility, senior members of MFS’
investment management team and
senior administrative and management
personnel (the ‘‘Investment
Management Committee’’) or a portfolio
manager for each participating Fund
could provide standing instructions to
the Interfund Lending Committee that
the participating Fund is authorized to
participate as a borrower or lender;
alternatively, the portfolio manager
could provide instructions from time to
time as to when the Fund wishes to
participate as a borrower or a lender.
The Interfund Lending Committee, no
more frequently than once daily in the
morning of each business day that a
transaction is requested under the credit
facility pursuant to instructions (an
‘‘Interfund Lending Day’’), would
request and collect data on the
uninvested cash and borrowing
requirements of all participating Funds
from the Funds’ custodian. Once it has
determined the aggregate amount of
cash available for loans and borrowing
demand, the Interfund Lending
Committee would allocate loans among
borrowing Funds without any further
communication from a Fund’s portfolio
managers. Applicants expect there will
typically be more available uninvested
cash each day than borrowing demand.
After the Interfund Lending Committee
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has allocated cash for Interfund Loans,
MFS’ cash desk personnel would invest
any remaining cash in accordance with
the Funds’ investment policies and
practices in the ordinary course.
10. The Interfund Lending Committee
would allocate borrowing demand and
cash available for lending among the
Funds on what the Interfund Lending
Committee believes to be an equitable
basis, subject to certain administrative
considerations applicable to all
participating Funds, such as the time of
filing requests to participate, minimum
loan lot sizes, the need to minimize the
number of transactions and associated
administrative costs, and the amount of
the existing borrowings outstanding. To
reduce transaction costs, each Interfund
Loan normally would be allocated in a
manner intended to minimize the
number of participants necessary to
complete the loan transaction. The
method of allocation and related
administrative procedures would be
approved by each Fund Board,
including a majority of trustees who are
not ‘‘interested persons’’ of the Fund, as
defined in section 2(a)(19) of the Act
(‘‘Independent Fund Board Members’’),
to ensure that both borrowing and
lending Funds participate on an
equitable basis.
11. The Interfund Lending Committee
would (a) monitor the Interfund Loan
Rates charged and the other terms and
conditions of the Interfund Loans; (b)
limit the borrowings and loans entered
into by each Fund to ensure that they
comply with the Fund’s investment
policies and limitations; (c) ensure
equitable treatment of each Fund; and
(d) directly or through MFS make
quarterly reports to each Fund Board
concerning any transactions by the
Funds under the credit facility and the
Interfund Loan Rate charged.
12. MFS, through the Interfund
Lending Committee, would administer
the credit facility as a fiduciary as part
of its duties under the investment
management contract with each Fund
and provide administrative support
pursuant to the administrative services
agreement between each Fund and MFS
and would receive no additional fee as
compensation for its services.
13. No Fund may participate in the
credit facility unless: (a) The Fund has
obtained shareholder approval for its
participation, if such approval is
required by law; (b) the Fund has fully
disclosed all material information
concerning the credit facility in its
prospectus and/or statement of
additional information (‘‘SAI’’); and (c)
the Fund’s participation in the credit
facility is consistent with its investment
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objectives, limitations and
organizational documents.
14. In connection with the credit
facility, applicants request an order
under (a) section 6(c) of the Act granting
relief from sections 18(f) and 21(b) of
the Act; (b) section 12(d)(1)(J) of the Act
granting relief from section 12(d)(1) of
the Act; (c) sections 6(c) and 17(b) of the
Act granting relief from sections
17(a)(1), 17(a)(2) and 17(a)(3) of the Act;
and (d) under section 17(d) of the Act
and rule 17d–1 under the Act to permit
certain joint arrangements.
Applicants’ Legal Analysis
1. Section 17(a)(3) of the Act generally
prohibits any affiliated person, or
affiliated person of an affiliated person,
from borrowing money or other property
from a registered investment company.
Section 21(b) of the Act generally
prohibits any registered management
company from lending money or other
property to any person if that person
controls or is under common control
with the company. Section 2(a)(3)(C) of
the Act defines an ‘‘affiliated person’’ of
another person, in part, to be any person
directly or indirectly controlling,
controlled by, or under common control
with, the other person. Applicants state
that the Funds may be under common
control by virtue of having MFS as their
common investment adviser and/or by
having a common Fund Board and
officers.
2. Section 6(c) of the Act provides that
an exemptive order may be granted
where an 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 17(b) of the Act
authorizes the Commission to exempt a
proposed transaction from section 17(a)
provided that the terms of the
transaction, including the consideration
to be paid or received, are fair and
reasonable and do not involve
overreaching on the part of any person
concerned, and the transaction is
consistent with the policy of the
investment company as recited in its
registration statement and reports filed
under the Act and with the general
purposes of the Act. Applicants believe
that the proposed arrangements satisfy
these standards for the reasons
discussed below.
3. Applicants submit that sections
17(a)(3) and 21(b) of the Act were
intended to prevent a party with strong
potential adverse interests to, and some
influence over the investment decisions
of, a registered investment company
from causing or inducing the investment
company to engage in lending
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transactions that unfairly inure to the
benefit of such party and that are
detrimental to the best interests of the
investment company and its
shareholders. Applicants assert that the
proposed credit facility transactions do
not raise these concerns because: (a)
MFS, through the Interfund Lending
Committee, would administer the
program as a fiduciary; (b) all Interfund
Loans would consist only of uninvested
cash reserves that the lending Fund
otherwise would invest in short-term
repurchase agreements or other shortterm instruments; (c) the Interfund
Loans would not involve a greater risk
than such other investments; (d) the
lending Fund would receive interest at
a rate higher than it could otherwise
obtain through such other investments;
and (e) the borrowing Fund would pay
interest at a rate lower than otherwise
available to it under its bank loan
agreements. Moreover, applicants
believe that the other terms and
conditions in the application would
effectively preclude the possibility of
any Fund obtaining an undue advantage
over any other Fund.
4. Section 17(a)(1) of the Act generally
prohibits any affiliated person of a
registered investment company, or an
affiliated person of an affiliated person,
from selling any securities or other
property to the company. Section
17(a)(2) of the Act generally prohibits
any affiliated person of a registered
investment company, or any affiliated
person of such a person, from
purchasing securities or other property
from the investment company. Section
12(d)(1) of the Act generally makes it
unlawful for a registered investment
company to purchase or otherwise
acquire any security issued by any other
investment company except in
accordance with the limitations set forth
in that section.
5. Applicants state that the obligation
of a borrowing Fund to repay an
Interfund Loan may constitute a security
for the purposes of sections 17(a)(1) and
12(d)(1). Applicants also state that any
pledge of assets in connection with an
Interfund Loan could be construed as a
purchase of the borrowing Fund’s
securities or other property for purposes
of section 17(a)(2) of the Act. Section
12(d)(1)(J) of the Act provides that the
Commission may exempt persons or
transactions from any provision of
section 12(d)(1) if and to the extent such
exemption is consistent with the public
interest and the protection of investors.
Applicants contend that the standards
under sections 6(c), 17(b), and
12(d)(1)(J) are satisfied for all the
reasons set forth above in support of
their request for relief from sections
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17(a)(3) and 21(b) and for the reasons
discussed below. Applicants also state
that the requested relief from section
17(a)(2) of the Act meets the standards
of section 6(c) and 17(b) because any
collateral pledged to secure an Interfund
Loan would be subject to the same
conditions imposed by any other lender
to a Fund that imposes conditions on
the quality of or access to collateral for
a borrowing (if the lender is another
Fund) or the same or less restrictive
conditions (in any other circumstance).
Any collateral pledged to secure an
Interfund Loan will be available solely
to secure repayment of such Interfund
Loan.
6. Applicants state that, among other
things, section 12(d)(1) was intended to
prevent the pyramiding of investment
companies in order to avoid imposing
on investors additional and duplicative
costs and fees attendant upon multiple
layers of investment companies.
Applicants submit that the proposed
credit facility does not involve these
abuses. Applicants note that there will
be no duplicative costs or fees to the
Funds or shareholders, and that MFS
will receive no additional compensation
for its services in administering the
credit facility through the Interfund
Lending Committee. Applicants also
note that the entire purpose of the
proposed credit facility is to provide
economic benefits for all of the
participating Funds and their
shareholders.
7. Section 18(f)(1) of the Act prohibits
open-end investment companies from
issuing any senior security except that
a company is permitted to borrow from
any bank; provided, that immediately
after the borrowing, there is asset
coverage of at least 300 per centum for
all borrowings of the company. Under
section 18(g) of the Act, the term ‘‘senior
security’’ includes any bond, debenture,
note or similar obligation or instrument
constituting a security and evidencing
indebtedness. Applicants request relief
from section 18(f)(1) to the limited
extent necessary to implement the credit
facility (because the lending Funds are
not banks).
8. Applicants believe that granting
relief under section 6(c) is appropriate
because the Funds would remain
subject to the requirement of section
18(f)(1) that all borrowings of a Fund,
including combined interfund and bank
borrowings, have at least 300% asset
coverage. Based on the conditions and
safeguards described in the application,
applicants also submit that to allow the
Funds to borrow from other Funds
pursuant to the proposed credit facility
is consistent with the purposes and
policies of section 18(f)(1).
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9. Section 17(d) of the Act and rule
17d–1 under the Act generally prohibit
any affiliated person of a registered
investment company, or affiliated
person of an affiliated person, when
acting as principal, from effecting any
joint transactions in which the company
participates unless the transaction is
approved by the Commission. Rule
17d–1(b) provides that in passing upon
applications filed under the rule, the
Commission will consider whether the
participation of a registered investment
company in a joint enterprise on the
basis proposed is consistent with the
provisions, policies, and purposes of the
Act and the extent to which the
company’s participation is on a basis
different from or less advantageous than
that of other participants.
10. Applicants submit that the
purpose of section 17(d) is to avoid
overreaching by and unfair advantage to
investment company insiders.
Applicants believe that the credit
facility is consistent with the
provisions, policies, and purposes of the
Act in that it offers both reduced
borrowing costs and enhanced returns
on loaned funds to all participating
Funds and their shareholders.
Applicants note that each Fund would
have an equal opportunity to borrow
and lend on equal terms consistent with
its investment policies and fundamental
investment limitations. Applicants
therefore believe that each Fund’s
participation in the credit facility will
be on terms that are no different from
or less advantageous than that of other
participating Funds.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
1. The Interfund Loan Rate will be the
average of the Repo Rate and the Bank
Loan Rate.
2. On each business day that the
Interfund Lending Committee considers
whether to use Interfund Loans, the
Interfund Lending Committee will
compare the Bank Loan Rate with the
Repo Rate and will make cash available
for Interfund Loans only if the Interfund
Loan Rate is: (a) More favorable to the
lending Fund than the Repo Rate and,
if applicable, the yield of any money
market fund approved by the
Investment Management Committee as a
money market fund in which the
lending Fund could otherwise invest;
and (b) more favorable to the borrowing
Fund than the Bank Loan Rate.
3. If a Fund has outstanding
borrowings, any Interfund Loans to the
Fund: (a) Will be at an interest rate
equal to or lower than any outstanding
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62473
bank loan; (b) will be secured at least on
an equal priority basis with at least an
equivalent percentage of collateral to
loan value as any outstanding bank loan
that requires collateral; (c) will have a
maturity no longer than any outstanding
bank loan (and in any event not over
seven days); and (d) will provide that,
if an event of default by the Fund occurs
under any agreement evidencing an
outstanding bank loan to the Fund, that
event of default will automatically
(without need for action or notice by the
lending Fund) constitute an immediate
event of default under the Interfund
Lending Agreement entitling the
lending Fund to call the Interfund Loan
(and exercise all rights with respect to
any collateral) and that such call will be
made if the lending bank exercises its
right to call its loan under its agreement
with the borrowing Fund.
4. A Fund may make an unsecured
borrowing through the proposed credit
facility if its outstanding borrowings
from all sources immediately after the
interfund borrowing total 10% or less of
its total assets, provided that if the Fund
has a secured loan outstanding from any
other lender, including but not limited
to another Fund, the Fund’s interfund
borrowing will be secured on at least an
equal priority basis with at least an
equivalent percentage of collateral to
loan value as any outstanding loan that
requires collateral. If a Fund’s total
outstanding borrowings immediately
after an interfund borrowing would be
greater than 10% of its total assets, the
Fund may borrow through the proposed
credit facility only on a secured basis.
A Fund may not borrow through the
proposed credit facility or from any
other source if its total outstanding
borrowings immediately after such
borrowing would be more than 331⁄3%
of its total assets.
5. Before any Fund that has
outstanding interfund borrowings may,
through additional borrowings, cause its
outstanding borrowings from all sources
to exceed 10% of its total assets, the
Fund must first secure each outstanding
Interfund Loan by the pledge of
segregated collateral with a market
value at least equal to 102% of the
outstanding principal value of the loan.
If the total outstanding borrowings of a
Fund with outstanding Interfund Loans
exceed 10% of its total assets for any
other reason (such as a decline in net
asset value or because of shareholder
redemptions), the Fund will within one
business day thereafter: (a) Repay all its
outstanding Interfund Loans; (b) reduce
its outstanding indebtedness to 10% or
less of its total assets; or (c) secure each
outstanding Interfund Loan by the
pledge of segregated collateral with a
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market value at least equal to 102% of
the outstanding principal value of the
loan until the Fund’s total outstanding
borrowings cease to exceed 10% of its
total assets, at which time the collateral
called for by this condition 5 shall no
longer be required. Until each Interfund
Loan that is outstanding at any time that
a Fund’s total outstanding borrowings
exceeds 10% is repaid or the Fund’s
total outstanding borrowings cease to
exceed 10% of its total assets, the Fund
will mark the value of the collateral to
market each day and will pledge such
additional collateral as is necessary to
maintain the market value of the
collateral that secures each outstanding
Interfund Loan at least equal to 102% of
the outstanding principal value of the
Interfund Loan.
6. No Fund may lend to another Fund
through the proposed credit facility if
the loan would cause its aggregate
outstanding loans through the proposed
credit facility to exceed 15% of the
lending Fund’s current net assets at the
time of the loan.
7. A Fund’s Interfund Loans to any
one Fund shall not exceed 5% of the
lending Fund’s net assets.
8. The duration of Interfund Loans
will be limited to no more than the
number of days required to receive
payment for securities sold, up to a
maximum of seven days. Loans effected
within seven days of each other will be
treated as separate loan transactions for
purposes of this condition.
9. The Fund’s borrowings through the
proposed credit facility, as measured on
the day when the most recent loan was
made, will not exceed the greater of
125% of the Fund’s total net cash
redemptions or 102% of sales fails for
the preceding seven calendar days.
10. Each Interfund Loan may be called
on one business day’s notice by a
lending Fund and may be repaid on any
day by a borrowing Fund.
11. A Fund’s participation in the
proposed credit facility must be
consistent with its investment objectives
and limitations and organizational
documents.
12. The Interfund Lending Committee,
on each Interfund Lending Day, will
calculate total Fund borrowing and
lending demand through the proposed
credit facility, and allocate loans on an
equitable basis among the Funds,
without the intervention of any portfolio
manager of participating Funds. The
Interfund Lending Committee will not
solicit cash for loans from any Fund or
prospectively publish or disseminate
the amount of current borrowing
demand to the Investment Management
Committee or portfolio managers of the
Funds. Once it determines the aggregate
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16:33 Oct 06, 2011
Jkt 226001
amount of cash available for loans and
borrowing demand, the Interfund
Lending Committee will allocate loans
among borrowing Funds without any
further communication from a Fund’s
portfolio managers. If there is more
available uninvested cash than
borrowing demand on any Interfund
Lending Day, any remaining cash will
be invested in accordance with the
Funds’ investment policies and
practices in the ordinary course.
13. The Interfund Lending Committee
will monitor the Interfund Loan Rates
charged and the other terms and
conditions of the Interfund Loans and
will make a quarterly report to each
Fund Board concerning the
participation of the Funds in the
proposed credit facility and the terms
and other conditions of any extensions
of credit under the credit facility.
14. Each Fund Board, including a
majority of the Independent Fund Board
Members, will:
(a) Review, no less frequently than
quarterly, each Fund’s participation in
the proposed credit facility during the
preceding quarter for compliance with
the conditions of any order permitting
such transactions;
(b) Review at least annually the
continuing appropriateness of the
method used to calculate the Bank Loan
Rate; and
(c) Review, no less frequently than
annually, the continuing
appropriateness of each Fund’s
participation in the proposed credit
facility.
15. In the event an Interfund Loan is
not paid according to its terms and such
default is not cured within two business
days from its maturity or from the time
the lending Fund makes a demand for
payment under the provisions of the
Interfund Lending Agreement, MFS will
promptly refer such loan for arbitration
to an independent arbitrator who was
selected by each Fund Board involved
in the loan who will serve as arbitrator
of disputes concerning Interfund
Loans.2 The arbitrator will resolve any
dispute promptly, and the arbitrator’s
decision will be binding on both Funds.
The arbitrator will submit, at least
annually, a written report to each Fund
Board setting forth a description of the
nature of any dispute and the actions
taken by the Funds to resolve the
dispute.
16. Each Fund will maintain and
preserve for a period of not less than six
years from the end of the fiscal year in
2 If the dispute involves Funds with different
Fund Boards, the respective Fund Boards will select
an independent arbitrator that is satisfactory to each
Fund.
PO 00000
Frm 00139
Fmt 4703
Sfmt 4703
which any transaction by it under the
proposed credit facility occurred, the
first two years in an easily accessible
place, written records of all such
transactions setting forth a description
of the terms of the transactions,
including the amount, the maturity and
the Interfund Loan Rate, the rate of
interest available at the time on
overnight repurchase agreements and
commercial bank borrowings, and such
other information presented to the Fund
Board in connection with the review
required by conditions 13 and 14.
17. MFS, through or on behalf of the
Interfund Lending Committee, will
prepare and submit to the Fund Board
for review an initial report describing
how the proposed credit facility will
operate and the procedures to be
implemented to ensure that all Funds
are treated fairly. For each calendar
quarter after the commencement of the
credit facility, the Interfund Lending
Committee will report on the operations
of the credit facility at the Fund Board’s
quarterly meetings.
Each Fund’s chief compliance officer
(‘‘CCO’’), as defined in rule 38a–1(4)
under the Act, shall prepare an annual
report for its Fund Board each year that
the Fund participates in the proposed
credit facility, that evaluates the Fund’s
compliance with the terms and
conditions of the application and the
procedures established to achieve such
compliance. Each Fund’s CCO will also
annually file a certification pursuant to
Item 77Q3 of Form N–SAR as such
Form may be revised, amended, or
superseded from time to time for each
year that the Fund participates in the
proposed credit facility, that certifies
that the Fund and MFS have established
procedures reasonably designed to
achieve compliance with the terms and
conditions of the order. In particular,
such certification will address
procedures designed to achieve the
following objectives:
(a) That the Interfund Loan Rate is
higher than the Repo Rate, but lower
than the Bank Loan Rate;
(b) Compliance with the collateral
requirements as set forth in the
Interfund Loan Borrowing Conditions;
(c) Compliance with the percentage
limitations on interfund borrowing and
lending;
(d) Allocation of interfund borrowing
and lending demand in an equitable
manner and in accordance with
procedures established by the Fund
Board; and
(e) That the interest rate on any
Interfund Loan does not exceed the
interest rate on any third-party
borrowings of a borrowing Fund at the
time of the Interfund Loan.
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Additionally, each Fund’s independent
auditors, in connection with their audit
examinations of the Fund, will review
the operation of the credit facility for
compliance with the Interfund Loan
Borrowing Conditions and their review
will form the basis, in part, of the
auditor’s report on internal accounting
controls in Form N–SAR.
18. No Fund will participate in the
proposed credit facility upon receipt of
requisite regulatory approval unless it
has fully disclosed in its prospectus
and/or SAI all material facts about its
intended participation.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2011–25926 Filed 10–6–11; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
29829; File No. 812–13830]
Global X Funds, et al.; Notice of
Application
September 30, 2011.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order to supersede a prior order under
section 6(c) of the Investment Company
Act of 1940 (the ‘‘Act’’) for an
exemption from sections 2(a)(32),
5(a)(1), 22(d), and 22(e) of the Act and
rule 22c–1 under the Act, under
sections 6(c) and 17(b) of the Act for an
exemption from sections 17(a)(1) and
17(a)(2) of the Act, and under section
12(d)(1)(J) of the Act for an exemption
from sections 12(d)(1)(A) and
12(d)(1)(B) of the Act.
AGENCY:
Summary of Application:
Applicants request an order that would
permit (a) series of certain open-end
management investment companies to
issue shares (‘‘Shares’’) redeemable in
large aggregations only (‘‘Creation
Units’’); (b) secondary market
transactions in Shares to occur at
negotiated market prices; (c) certain
series to pay redemption proceeds,
under certain circumstances, more than
seven days after the tender of Creation
Units for redemption; (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 Creation
Units; and (e) certain registered
management investment companies and
jlentini on DSK4TPTVN1PROD with NOTICES
SUMMARY:
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16:33 Oct 06, 2011
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unit investment trusts outside of the
same group of investment companies as
the series to acquire Shares. The order
would supersede a prior order.1
APPLICANTS: Global X Funds (the
‘‘Trust’’), Global X Management
Company LLC (the ‘‘Adviser’’) and SEI
Investments Distribution Company (the
‘‘Distributor’’).
DATES: Filing Dates: The application was
filed on October 4, 2010, and amended
on March 11, 2011, July 29, 2011 and
September 30, 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 October 27, 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, Securities and
Exchange Commission, 100 F Street,
NE., Washington, DC 20549–1090;
Applicants: Global X Funds and Global
X Management Company LLC, 399 Park
Avenue, 32nd Floor, New York, NY
10022; and SEI Investments Distribution
Company, One Freedom Valley Drive,
Oaks, PA 19456.
FOR FURTHER INFORMATION CONTACT:
Laura J. Riegel, Senior Counsel 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 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. The Trust, a statutory trust
organized under the laws of Delaware,
is registered with the Commission as an
open-end management investment
1 Global X Funds and Global X Management
Company LLC, Investment Company Act Release
Nos. 28378 (Sep. 10, 2008) (notice) and 28433 (Oct.
3, 2008) (order).
PO 00000
Frm 00140
Fmt 4703
Sfmt 4703
62475
company. The Trust consists of 86 series
(‘‘Current Funds’’) whose performance
correspond to the price and yield
performance of a specified securities
index (each, an ‘‘Underlying Index’’).
2. Applicants request that the order
apply to the Current Funds or any future
series of the Trust or any other open-end
management investment companies or
series thereof advised by the Adviser or
an entity controlling, controlled by, or
under common control with the Adviser
that comply with the terms and
conditions of the application and whose
performance will closely correspond to
the price and yield performance of their
Underlying Index (each such company
or series, a ‘‘Future Fund’’ and together
with the Current Funds, the ‘‘Funds’’).
3. The Current Funds are based on
Underlying Indexes comprised solely of
equity securities. The Future Funds will
invest primarily in equity securities and
seek investment returns that closely
correspond to the price and yield
performance of Underlying Indexes
comprised of equity securities (‘‘Equity
Funds’’), or invest primarily in
Underlying Indexes comprised of fixed
income securities and seek investment
returns that closely correspond to the
price and yield performance of
Underlying Indexes comprised of fixed
income indices (‘‘Fixed Income
Funds’’). Certain of the Funds may
invest in equity securities or fixed
income securities traded in foreign
markets and seek investment results that
correspond closely to the price and
yield performance of Underlying
Indexes whose component securities
include such securities (‘‘International
Funds’’). The Funds may also invest in
a combination of equity, fixed income
and U.S. money market securities and/
or non-U.S. money market securities.
The Funds may also invest in
‘‘Depositary Receipts.’’ 2 A Fund will
not invest in any Depositary Receipts
that the Adviser or Subadviser deems to
be illiquid or for which pricing
information is not readily available.
4. The Adviser is registered as an
investment adviser under the
Investment Advisers Act of 1940 (the
‘‘Advisers Act’’). The Adviser or any
entity controlling, controlled by or
under common control with the Adviser
(also included in the term ‘‘Adviser’’)
serves or will serve as investment
adviser to the Funds, subject to approval
by the Board of Trustees of the Trust
2 Depositary Receipts are typically issued by a
financial institution, a ‘‘depositary’’, and evidence
ownership in a security or pool of securities that
have been deposited with the depositary. No
affiliated persons of applicants will serve as the
depositary bank for any Depositary Receipts held by
a Fund.
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Agencies
[Federal Register Volume 76, Number 195 (Friday, October 7, 2011)]
[Notices]
[Pages 62470-62475]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-25926]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 29827; File No. 812-13606]
MFS Series Trust I, et al.; Notice of Application
September 30, 2011.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under (a) section 6(c) of
the Investment Company Act of 1940 (``Act'') granting an exemption from
sections 18(f) and 21(b) of the Act; (b) section 12(d)(1)(J) of the Act
granting an exemption from section 12(d)(1) of the Act; (c) sections
6(c) and 17(b) of the Act granting an exemption from sections 17(a)(1),
17(a)(2) and 17(a)(3) of the Act; and (d) section 17(d) of the Act and
rule 17d-1 under the Act to permit certain joint arrangements.
-----------------------------------------------------------------------
Summary of the Application: Applicants request an order that would
permit certain registered open-end management investment companies to
participate in a joint lending and borrowing facility.
Applicants: MFS Series Trust I, MFS Series Trust II, MFS Series Trust
III, MFS Series Trust IV, MFS Series Trust V, MFS Series Trust VI, MFS
Series Trust VII, MFS Series Trust VIII, MFS Series Trust IX, MFS
Series Trust X, MFS Series Trust XI, MFS Series Trust XII, MFS Series
Trust XIII, MFS Series Trust XIV, MFS Series Trust XV, MFS Series Trust
XVI, MFS Municipal Series Trust, MFS Variable Insurance Trust, MFS
Variable Insurance Trust II, Massachusetts Investors Trust,
Massachusetts Investors Growth Stock Fund, MFS Institutional Trust
(each, a ``Trust'') and Massachusetts Financial Services Company
(``MFS'').
DATES: Filing Dates: The application was filed on November 20, 2008,
amended on May 7, 2009, July 22, 2010 and September 16, 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 October 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, Massachusetts
Financial Services Company, 500 Boylston Street, Boston, MA 02116.
FOR FURTHER INFORMATION CONTACT: Jean E. Minarick, Senior Counsel, at
(202) 551-6811 or Janet M. Grossnickle, Assistant Director, at (202)
551-6821 (Division of Investment Management, Office of Investment
Company Regulation).
SUPPLEMENTARY INFORMATION: The following is a 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 Trust is organized as a Massachusetts business trust and is
registered under the Act as an open-end management investment company.
Each Trust may consist of one or more series and may offer additional
series in the future (``Funds''). MFS, a Delaware corporation, is
registered as an investment adviser under the Investment Advisers Act
of 1940, and
[[Page 62471]]
serves as the investment adviser to each Fund.\1\
---------------------------------------------------------------------------
\1\ Applicants request that the relief apply to (a) any Fund,
(b) any successor entity to MFS, and (c) any other registered open-
end management investment company or its series advised by MFS and
for which MFS Fund Distributors, Inc. (``MFD'') or a person
controlling, controlled by, or under common control (within the
meaning of section 2(a)(9) of the Act) with MFD serves as principal
underwriter (each, also a ``Fund''). The term ``successor'' is
limited to entities that result from a reorganization into another
jurisdiction or a change in the type of business organization. All
entities that currently intend to rely on the requested relief are
named as applicants. Any other existing or future Funds that
subsequently rely on the order will comply with the terms and
conditions set forth in the application.
---------------------------------------------------------------------------
2. Some Funds, including money market Funds that rely on rule 2a-7
under the Act (``Money Market Funds''), may lend money to banks or
other entities by entering into repurchase agreements, purchasing other
short-term instruments, or, in the case of Funds other than the Money
Market Funds, investing in the MFS Institutional Money Market Fund
(``IMMF'') pursuant to rule 12d1-1 under the Act. Other Funds may
borrow money from the same or similar banks for temporary purposes to
satisfy redemption requests, to cover unanticipated cash shortfalls
such as a trade ``fail'' in which cash payment for a security sold by a
Fund has been delayed, or for other temporary purposes. Currently, the
Trusts have a committed credit facility provided by a syndicate of
lenders and uncommitted lines of credit with two separate banks
(collectively, the ``Loan Agreements''). The Funds also have an
overdraft facility with their custodians.
3. If a Fund were to borrow money under a Loan Agreement, the Fund
would pay interest on the borrowed cash at a rate which would be higher
than the rate that would be earned by other (non-borrowing) Funds on
investments in repurchase agreements and other short-term instruments
of the same maturity as the bank loan. In addition, while bank
borrowings generally can supply needed cash to cover unanticipated
redemptions and sales fails, the borrowing Funds incur commitment fees
and/or other charges involved in obtaining a bank loan.
4. Applicants request an order that would permit each Trust to
enter into master interfund lending agreements (``Interfund Lending
Agreements'') that would permit each Fund to lend and borrow money for
temporary purposes directly to and from each other Fund through a
credit facility (``Interfund Loan''). Applicants believe that the
proposed credit facility would reduce the Funds' borrowing costs and
enhance their ability to earn higher interest rates on short-term
lendings. Although the proposed credit facility would reduce the Funds'
need to borrow from banks, the Funds would be free to establish or
renew committed lines of credit or other borrowing arrangements with
unaffiliated banks.
5. Applicants anticipate that the credit facility would provide a
borrowing Fund with significant savings when the cash position of the
Fund is insufficient to meet temporary cash requirements. This
situation could arise when redemptions exceed anticipated volumes and
certain Funds have insufficient cash on hand to satisfy such
redemptions. When a Fund liquidates portfolio securities to meet
redemption requests, it often does not receive payment in settlement
for up to three days (or longer for certain foreign transactions). The
credit facility would provide a source of immediate, short-term
liquidity pending settlement of the sale of portfolio securities.
6. Applicants also propose using the credit facility when a sale of
securities ``fails'' due to circumstances such as a delay in the
delivery of cash to a Fund's custodian or improper delivery
instructions by the broker effecting the transaction. Sales fails may
present a cash shortfall if a Fund has undertaken to purchase
securities using the proceeds from the securities sold. As a result,
the Fund could fail on its intended purchase due to lack of funds from
the previous sale, resulting in additional cost to the Fund, or sell a
security on a same-day settlement basis, earning a lower return on the
investment. Use of the credit facility under these circumstances would
enable the Fund to have access to immediate short-term liquidity.
7. While bank borrowings generally can supply needed cash to cover
unanticipated redemptions and sales fails, under the proposed credit
facility a borrowing Fund would pay lower interest rates than those
offered by banks on short-term loans. In addition, Funds making short-
term cash loans directly to other Funds would earn interest at a rate
higher than they otherwise could obtain from investing their cash in
repurchase agreements. Thus, applicants believe that the proposed
credit facility would benefit both borrowing and lending Funds.
8. The interest rate charged to a Fund on any Interfund Loan
(``Interfund Loan Rate'') would be the average of the ``Repo Rate'' and
the ``Bank Loan Rate,'' both as defined below. The Repo Rate on any day
would be the highest rate available to a lending Fund from investing in
overnight repurchase agreements. The Bank Loan Rate on any day would be
calculated by the ``Interfund Lending Committee'' (as defined below)
each day an Interfund Loan is made according to a formula established
by each Fund's board of trustees (``Fund Board'') intended to
approximate the lowest interest rate at which bank short-term loans
would be available to the Funds. The formula would be based upon a
publicly available rate (e.g., Federal funds rates and/or Libor), plus
an additional spread of basis points and would vary with this rate so
as to reflect changing bank loan rates. The initial formula and any
subsequent modifications to the formula would be subject to the
approval of each Fund Board. Each Fund Board would at least annually
review the continuing appropriateness of using the method of
calculating the Bank Loan Rate, as well as the relationship between the
Bank Loan Rate and current bank loan rates that would be available to
the Funds.
9. The credit facility would be administered by investment
professionals and administrative personnel from MFS (the ``Interfund
Lending Committee''). No portfolio manager, including research analysts
with portfolio management responsibilities, for any Fund will serve as
a member of the Interfund Lending Committee. Under the proposed credit
facility, senior members of MFS' investment management team and senior
administrative and management personnel (the ``Investment Management
Committee'') or a portfolio manager for each participating Fund could
provide standing instructions to the Interfund Lending Committee that
the participating Fund is authorized to participate as a borrower or
lender; alternatively, the portfolio manager could provide instructions
from time to time as to when the Fund wishes to participate as a
borrower or a lender. The Interfund Lending Committee, no more
frequently than once daily in the morning of each business day that a
transaction is requested under the credit facility pursuant to
instructions (an ``Interfund Lending Day''), would request and collect
data on the uninvested cash and borrowing requirements of all
participating Funds from the Funds' custodian. Once it has determined
the aggregate amount of cash available for loans and borrowing demand,
the Interfund Lending Committee would allocate loans among borrowing
Funds without any further communication from a Fund's portfolio
managers. Applicants expect there will typically be more available
uninvested cash each day than borrowing demand. After the Interfund
Lending Committee
[[Page 62472]]
has allocated cash for Interfund Loans, MFS' cash desk personnel would
invest any remaining cash in accordance with the Funds' investment
policies and practices in the ordinary course.
10. The Interfund Lending Committee would allocate borrowing demand
and cash available for lending among the Funds on what the Interfund
Lending Committee believes to be an equitable basis, subject to certain
administrative considerations applicable to all participating Funds,
such as the time of filing requests to participate, minimum loan lot
sizes, the need to minimize the number of transactions and associated
administrative costs, and the amount of the existing borrowings
outstanding. To reduce transaction costs, each Interfund Loan normally
would be allocated in a manner intended to minimize the number of
participants necessary to complete the loan transaction. The method of
allocation and related administrative procedures would be approved by
each Fund Board, including a majority of trustees who are not
``interested persons'' of the Fund, as defined in section 2(a)(19) of
the Act (``Independent Fund Board Members''), to ensure that both
borrowing and lending Funds participate on an equitable basis.
11. The Interfund Lending Committee would (a) monitor the Interfund
Loan Rates charged and the other terms and conditions of the Interfund
Loans; (b) limit the borrowings and loans entered into by each Fund to
ensure that they comply with the Fund's investment policies and
limitations; (c) ensure equitable treatment of each Fund; and (d)
directly or through MFS make quarterly reports to each Fund Board
concerning any transactions by the Funds under the credit facility and
the Interfund Loan Rate charged.
12. MFS, through the Interfund Lending Committee, would administer
the credit facility as a fiduciary as part of its duties under the
investment management contract with each Fund and provide
administrative support pursuant to the administrative services
agreement between each Fund and MFS and would receive no additional fee
as compensation for its services.
13. No Fund may participate in the credit facility unless: (a) The
Fund has obtained shareholder approval for its participation, if such
approval is required by law; (b) the Fund has fully disclosed all
material information concerning the credit facility in its prospectus
and/or statement of additional information (``SAI''); and (c) the
Fund's participation in the credit facility is consistent with its
investment objectives, limitations and organizational documents.
14. In connection with the credit facility, applicants request an
order under (a) section 6(c) of the Act granting relief from sections
18(f) and 21(b) of the Act; (b) section 12(d)(1)(J) of the Act granting
relief from section 12(d)(1) of the Act; (c) sections 6(c) and 17(b) of
the Act granting relief from sections 17(a)(1), 17(a)(2) and 17(a)(3)
of the Act; and (d) under section 17(d) of the Act and rule 17d-1 under
the Act to permit certain joint arrangements.
Applicants' Legal Analysis
1. Section 17(a)(3) of the Act generally prohibits any affiliated
person, or affiliated person of an affiliated person, from borrowing
money or other property from a registered investment company. Section
21(b) of the Act generally prohibits any registered management company
from lending money or other property to any person if that person
controls or is under common control with the company. Section
2(a)(3)(C) of the Act defines an ``affiliated person'' of another
person, in part, to be any person directly or indirectly controlling,
controlled by, or under common control with, the other person.
Applicants state that the Funds may be under common control by virtue
of having MFS as their common investment adviser and/or by having a
common Fund Board and officers.
2. Section 6(c) of the Act provides that an exemptive order may be
granted where an 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 17(b) of the Act authorizes the Commission to exempt a proposed
transaction from section 17(a) provided that the terms of the
transaction, including the consideration to be paid or received, are
fair and reasonable and do not involve overreaching on the part of any
person concerned, and the transaction is consistent with the policy of
the investment company as recited in its registration statement and
reports filed under the Act and with the general purposes of the Act.
Applicants believe that the proposed arrangements satisfy these
standards for the reasons discussed below.
3. Applicants submit that sections 17(a)(3) and 21(b) of the Act
were intended to prevent a party with strong potential adverse
interests to, and some influence over the investment decisions of, a
registered investment company from causing or inducing the investment
company to engage in lending transactions that unfairly inure to the
benefit of such party and that are detrimental to the best interests of
the investment company and its shareholders. Applicants assert that the
proposed credit facility transactions do not raise these concerns
because: (a) MFS, through the Interfund Lending Committee, would
administer the program as a fiduciary; (b) all Interfund Loans would
consist only of uninvested cash reserves that the lending Fund
otherwise would invest in short-term repurchase agreements or other
short-term instruments; (c) the Interfund Loans would not involve a
greater risk than such other investments; (d) the lending Fund would
receive interest at a rate higher than it could otherwise obtain
through such other investments; and (e) the borrowing Fund would pay
interest at a rate lower than otherwise available to it under its bank
loan agreements. Moreover, applicants believe that the other terms and
conditions in the application would effectively preclude the
possibility of any Fund obtaining an undue advantage over any other
Fund.
4. Section 17(a)(1) of the Act generally prohibits any affiliated
person of a registered investment company, or an affiliated person of
an affiliated person, from selling any securities or other property to
the company. Section 17(a)(2) of the Act generally prohibits any
affiliated person of a registered investment company, or any affiliated
person of such a person, from purchasing securities or other property
from the investment company. Section 12(d)(1) of the Act generally
makes it unlawful for a registered investment company to purchase or
otherwise acquire any security issued by any other investment company
except in accordance with the limitations set forth in that section.
5. Applicants state that the obligation of a borrowing Fund to
repay an Interfund Loan may constitute a security for the purposes of
sections 17(a)(1) and 12(d)(1). Applicants also state that any pledge
of assets in connection with an Interfund Loan could be construed as a
purchase of the borrowing Fund's securities or other property for
purposes of section 17(a)(2) of the Act. Section 12(d)(1)(J) of the Act
provides that the Commission may exempt persons or transactions from
any provision of section 12(d)(1) if and to the extent such exemption
is consistent with the public interest and the protection of investors.
Applicants contend that the standards under sections 6(c), 17(b), and
12(d)(1)(J) are satisfied for all the reasons set forth above in
support of their request for relief from sections
[[Page 62473]]
17(a)(3) and 21(b) and for the reasons discussed below. Applicants also
state that the requested relief from section 17(a)(2) of the Act meets
the standards of section 6(c) and 17(b) because any collateral pledged
to secure an Interfund Loan would be subject to the same conditions
imposed by any other lender to a Fund that imposes conditions on the
quality of or access to collateral for a borrowing (if the lender is
another Fund) or the same or less restrictive conditions (in any other
circumstance). Any collateral pledged to secure an Interfund Loan will
be available solely to secure repayment of such Interfund Loan.
6. Applicants state that, among other things, section 12(d)(1) was
intended to prevent the pyramiding of investment companies in order to
avoid imposing on investors additional and duplicative costs and fees
attendant upon multiple layers of investment companies. Applicants
submit that the proposed credit facility does not involve these abuses.
Applicants note that there will be no duplicative costs or fees to the
Funds or shareholders, and that MFS will receive no additional
compensation for its services in administering the credit facility
through the Interfund Lending Committee. Applicants also note that the
entire purpose of the proposed credit facility is to provide economic
benefits for all of the participating Funds and their shareholders.
7. Section 18(f)(1) of the Act prohibits open-end investment
companies from issuing any senior security except that a company is
permitted to borrow from any bank; provided, that immediately after the
borrowing, there is asset coverage of at least 300 per centum for all
borrowings of the company. Under section 18(g) of the Act, the term
``senior security'' includes any bond, debenture, note or similar
obligation or instrument constituting a security and evidencing
indebtedness. Applicants request relief from section 18(f)(1) to the
limited extent necessary to implement the credit facility (because the
lending Funds are not banks).
8. Applicants believe that granting relief under section 6(c) is
appropriate because the Funds would remain subject to the requirement
of section 18(f)(1) that all borrowings of a Fund, including combined
interfund and bank borrowings, have at least 300% asset coverage. Based
on the conditions and safeguards described in the application,
applicants also submit that to allow the Funds to borrow from other
Funds pursuant to the proposed credit facility is consistent with the
purposes and policies of section 18(f)(1).
9. Section 17(d) of the Act and rule 17d-1 under the Act generally
prohibit any affiliated person of a registered investment company, or
affiliated person of an affiliated person, when acting as principal,
from effecting any joint transactions in which the company participates
unless the transaction is approved by the Commission. Rule 17d-1(b)
provides that in passing upon applications filed under the rule, the
Commission will consider whether the participation of a registered
investment company in a joint enterprise on the basis proposed is
consistent with the provisions, policies, and purposes of the Act and
the extent to which the company's participation is on a basis different
from or less advantageous than that of other participants.
10. Applicants submit that the purpose of section 17(d) is to avoid
overreaching by and unfair advantage to investment company insiders.
Applicants believe that the credit facility is consistent with the
provisions, policies, and purposes of the Act in that it offers both
reduced borrowing costs and enhanced returns on loaned funds to all
participating Funds and their shareholders. Applicants note that each
Fund would have an equal opportunity to borrow and lend on equal terms
consistent with its investment policies and fundamental investment
limitations. Applicants therefore believe that each Fund's
participation in the credit facility will be on terms that are no
different from or less advantageous than that of other participating
Funds.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
1. The Interfund Loan Rate will be the average of the Repo Rate and
the Bank Loan Rate.
2. On each business day that the Interfund Lending Committee
considers whether to use Interfund Loans, the Interfund Lending
Committee will compare the Bank Loan Rate with the Repo Rate and will
make cash available for Interfund Loans only if the Interfund Loan Rate
is: (a) More favorable to the lending Fund than the Repo Rate and, if
applicable, the yield of any money market fund approved by the
Investment Management Committee as a money market fund in which the
lending Fund could otherwise invest; and (b) more favorable to the
borrowing Fund than the Bank Loan Rate.
3. If a Fund has outstanding borrowings, any Interfund Loans to the
Fund: (a) Will be at an interest rate equal to or lower than any
outstanding bank loan; (b) will be secured at least on an equal
priority basis with at least an equivalent percentage of collateral to
loan value as any outstanding bank loan that requires collateral; (c)
will have a maturity no longer than any outstanding bank loan (and in
any event not over seven days); and (d) will provide that, if an event
of default by the Fund occurs under any agreement evidencing an
outstanding bank loan to the Fund, that event of default will
automatically (without need for action or notice by the lending Fund)
constitute an immediate event of default under the Interfund Lending
Agreement entitling the lending Fund to call the Interfund Loan (and
exercise all rights with respect to any collateral) and that such call
will be made if the lending bank exercises its right to call its loan
under its agreement with the borrowing Fund.
4. A Fund may make an unsecured borrowing through the proposed
credit facility if its outstanding borrowings from all sources
immediately after the interfund borrowing total 10% or less of its
total assets, provided that if the Fund has a secured loan outstanding
from any other lender, including but not limited to another Fund, the
Fund's interfund borrowing will be secured on at least an equal
priority basis with at least an equivalent percentage of collateral to
loan value as any outstanding loan that requires collateral. If a
Fund's total outstanding borrowings immediately after an interfund
borrowing would be greater than 10% of its total assets, the Fund may
borrow through the proposed credit facility only on a secured basis. A
Fund may not borrow through the proposed credit facility or from any
other source if its total outstanding borrowings immediately after such
borrowing would be more than 33\1/3\% of its total assets.
5. Before any Fund that has outstanding interfund borrowings may,
through additional borrowings, cause its outstanding borrowings from
all sources to exceed 10% of its total assets, the Fund must first
secure each outstanding Interfund Loan by the pledge of segregated
collateral with a market value at least equal to 102% of the
outstanding principal value of the loan. If the total outstanding
borrowings of a Fund with outstanding Interfund Loans exceed 10% of its
total assets for any other reason (such as a decline in net asset value
or because of shareholder redemptions), the Fund will within one
business day thereafter: (a) Repay all its outstanding Interfund Loans;
(b) reduce its outstanding indebtedness to 10% or less of its total
assets; or (c) secure each outstanding Interfund Loan by the pledge of
segregated collateral with a
[[Page 62474]]
market value at least equal to 102% of the outstanding principal value
of the loan until the Fund's total outstanding borrowings cease to
exceed 10% of its total assets, at which time the collateral called for
by this condition 5 shall no longer be required. Until each Interfund
Loan that is outstanding at any time that a Fund's total outstanding
borrowings exceeds 10% is repaid or the Fund's total outstanding
borrowings cease to exceed 10% of its total assets, the Fund will mark
the value of the collateral to market each day and will pledge such
additional collateral as is necessary to maintain the market value of
the collateral that secures each outstanding Interfund Loan at least
equal to 102% of the outstanding principal value of the Interfund Loan.
6. No Fund may lend to another Fund through the proposed credit
facility if the loan would cause its aggregate outstanding loans
through the proposed credit facility to exceed 15% of the lending
Fund's current net assets at the time of the loan.
7. A Fund's Interfund Loans to any one Fund shall not exceed 5% of
the lending Fund's net assets.
8. The duration of Interfund Loans will be limited to no more than
the number of days required to receive payment for securities sold, up
to a maximum of seven days. Loans effected within seven days of each
other will be treated as separate loan transactions for purposes of
this condition.
9. The Fund's borrowings through the proposed credit facility, as
measured on the day when the most recent loan was made, will not exceed
the greater of 125% of the Fund's total net cash redemptions or 102% of
sales fails for the preceding seven calendar days.
10. Each Interfund Loan may be called on one business day's notice
by a lending Fund and may be repaid on any day by a borrowing Fund.
11. A Fund's participation in the proposed credit facility must be
consistent with its investment objectives and limitations and
organizational documents.
12. The Interfund Lending Committee, on each Interfund Lending Day,
will calculate total Fund borrowing and lending demand through the
proposed credit facility, and allocate loans on an equitable basis
among the Funds, without the intervention of any portfolio manager of
participating Funds. The Interfund Lending Committee will not solicit
cash for loans from any Fund or prospectively publish or disseminate
the amount of current borrowing demand to the Investment Management
Committee or portfolio managers of the Funds. Once it determines the
aggregate amount of cash available for loans and borrowing demand, the
Interfund Lending Committee will allocate loans among borrowing Funds
without any further communication from a Fund's portfolio managers. If
there is more available uninvested cash than borrowing demand on any
Interfund Lending Day, any remaining cash will be invested in
accordance with the Funds' investment policies and practices in the
ordinary course.
13. The Interfund Lending Committee will monitor the Interfund Loan
Rates charged and the other terms and conditions of the Interfund Loans
and will make a quarterly report to each Fund Board concerning the
participation of the Funds in the proposed credit facility and the
terms and other conditions of any extensions of credit under the credit
facility.
14. Each Fund Board, including a majority of the Independent Fund
Board Members, will:
(a) Review, no less frequently than quarterly, each Fund's
participation in the proposed credit facility during the preceding
quarter for compliance with the conditions of any order permitting such
transactions;
(b) Review at least annually the continuing appropriateness of the
method used to calculate the Bank Loan Rate; and
(c) Review, no less frequently than annually, the continuing
appropriateness of each Fund's participation in the proposed credit
facility.
15. In the event an Interfund Loan is not paid according to its
terms and such default is not cured within two business days from its
maturity or from the time the lending Fund makes a demand for payment
under the provisions of the Interfund Lending Agreement, MFS will
promptly refer such loan for arbitration to an independent arbitrator
who was selected by each Fund Board involved in the loan who will serve
as arbitrator of disputes concerning Interfund Loans.\2\ The arbitrator
will resolve any dispute promptly, and the arbitrator's decision will
be binding on both Funds. The arbitrator will submit, at least
annually, a written report to each Fund Board setting forth a
description of the nature of any dispute and the actions taken by the
Funds to resolve the dispute.
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\2\ If the dispute involves Funds with different Fund Boards,
the respective Fund Boards will select an independent arbitrator
that is satisfactory to each Fund.
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16. Each Fund will maintain and preserve for a period of not less
than six years from the end of the fiscal year in which any transaction
by it under the proposed credit facility occurred, the first two years
in an easily accessible place, written records of all such transactions
setting forth a description of the terms of the transactions, including
the amount, the maturity and the Interfund Loan Rate, the rate of
interest available at the time on overnight repurchase agreements and
commercial bank borrowings, and such other information presented to the
Fund Board in connection with the review required by conditions 13 and
14.
17. MFS, through or on behalf of the Interfund Lending Committee,
will prepare and submit to the Fund Board for review an initial report
describing how the proposed credit facility will operate and the
procedures to be implemented to ensure that all Funds are treated
fairly. For each calendar quarter after the commencement of the credit
facility, the Interfund Lending Committee will report on the operations
of the credit facility at the Fund Board's quarterly meetings.
Each Fund's chief compliance officer (``CCO''), as defined in rule
38a-1(4) under the Act, shall prepare an annual report for its Fund
Board each year that the Fund participates in the proposed credit
facility, that evaluates the Fund's compliance with the terms and
conditions of the application and the procedures established to achieve
such compliance. Each Fund's CCO will also annually file a
certification pursuant to Item 77Q3 of Form N-SAR as such Form may be
revised, amended, or superseded from time to time for each year that
the Fund participates in the proposed credit facility, that certifies
that the Fund and MFS have established procedures reasonably designed
to achieve compliance with the terms and conditions of the order. In
particular, such certification will address procedures designed to
achieve the following objectives:
(a) That the Interfund Loan Rate is higher than the Repo Rate, but
lower than the Bank Loan Rate;
(b) Compliance with the collateral requirements as set forth in the
Interfund Loan Borrowing Conditions;
(c) Compliance with the percentage limitations on interfund
borrowing and lending;
(d) Allocation of interfund borrowing and lending demand in an
equitable manner and in accordance with procedures established by the
Fund Board; and
(e) That the interest rate on any Interfund Loan does not exceed
the interest rate on any third-party borrowings of a borrowing Fund at
the time of the Interfund Loan.
[[Page 62475]]
Additionally, each Fund's independent auditors, in connection with
their audit examinations of the Fund, will review the operation of the
credit facility for compliance with the Interfund Loan Borrowing
Conditions and their review will form the basis, in part, of the
auditor's report on internal accounting controls in Form N-SAR.
18. No Fund will participate in the proposed credit facility upon
receipt of requisite regulatory approval unless it has fully disclosed
in its prospectus and/or SAI all material facts about its intended
participation.
For the Commission, by the Division of Investment Management,
under delegated authority.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2011-25926 Filed 10-6-11; 8:45 am]
BILLING CODE 8011-01-P