RiverPark Advisors, LLC, et al.; Notice of Application, 66096-66103 [2011-27531]
Download as PDF
66096
Federal Register / Vol. 76, No. 206 / Tuesday, October 25, 2011 / Notices
Contact person for more information:
Rochelle Bavol, (301) 415–1651.
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The NRC Commission Meeting
Schedule can be found on the Internet
at: https://www.nrc.gov/public-involve/
public-meetings/schedule.html.
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The NRC provides reasonable
accommodation to individuals with
disabilities where appropriate. If you
need a reasonable accommodation to
participate in these public meetings, or
need this meeting notice or the
transcript or other information from the
public meetings in another format (e.g.
braille, large print), please notify Bill
Dosch, Chief, Work Life and Benefits
Branch, at 301–415–6200, TDD: 301–
415–2100, or by e-mail at
william.dosch@nrc.gov. Determinations
on requests for reasonable
accommodation will be made on a caseby-case basis.
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This notice is distributed
electronically to subscribers. If you no
longer wish to receive it, or would like
to be added to the distribution, please
contact the Office of the Secretary,
Washington, DC 20555 (301–415–1969),
or send an e-mail to darlene.wright@nrc.
gov.
October 20, 2011.
Rochelle Bavol,
Policy Coordinator, Office of the Secretary.
[FR Doc. 2011–27684 Filed 10–21–11; 4:15 pm]
BILLING CODE 7590–01–P
RAILROAD RETIREMENT BOARD
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Proposed Collection; Comment
Request
In accordance with the requirement of
Section 3506 (c)(2)(A) of the Paperwork
Reduction Act of 1995 which provides
opportunity for public comment on new
or revised data collections, the Railroad
Retirement Board (RRB) will publish
periodic summaries of proposed data
collections.
Comments are invited on: (a) Whether
the proposed information collection is
necessary for the proper performance of
the functions of the agency, including
whether the information has practical
utility; (b) the accuracy of the RRB’s
estimate of the burden of the collection
of the information; (c) ways to enhance
the quality, utility, and clarity of the
information to be collected; and (d)
ways to minimize the burden related to
the collection of information on
respondents, including the use of
automated collection techniques or
other forms of information technology.
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Title and purpose of information
collection:
Student Beneficiary Monitoring; OMB
3220–0123
Under provisions of the Railroad
Retirement Act (RRA), there are two
types of benefits whose payment is
based upon the status of a child being
in full-time elementary or secondary
school attendance at age 18–19; a
survivor child’s annuity benefit under
Section 2(d)(2)(iii) and an increase in
the employee retirement annuity under
the Special Guaranty computation as
prescribed in section 3(f)(3).
The survivor student annuity is
usually paid by direct deposit at a
financial institution to the student’s
checking or savings account or a joint
bank account with the parent. The
requirements for eligibility as a student
are prescribed in 20 CFR 216.74, and
include students in independent study
or home schooling.
The RRB requires evidence of fulltime school attendance in order to
determine that a child is entitled to
student benefits. The RRB utilizes the
following forms to conduct its student
monitoring program. Form G–315,
Student Questionnaire, obtains
certification of a student’s full-time
school attendance. It also obtains
information on a student’s marital
status, Social Security benefits, and
employment which are needed to
determine entitlement or continued
entitlement to benefits under the RRA.
Form G–315a, Statement of School
Official, is used to obtain verification
from a school that a student attends
school full-time and provides their
expected graduation date. Form G–
315a.1, School Officials Notice of
Cessation of Full-Time Attendance, is
used by a school to notify the RRB that
a student has ceased full-time school
attendance. Completion is required to
obtain or retain benefits. The RRB
proposes no changes to the forms.
The estimated annual respondent
burden is as follows:
Form(s): G–315, G–315a and G–
315a.1.
Estimate of Annual Responses: 900
(860 Form G–315’s, 20 Form G–315a’s
and 20 Form G–315a.1’s).
Estimated Completion Time: The
completion time for Form G–315 is
estimated at 15 minutes per response.
The completion time for Form G–315a
is estimated at 3 minutes per response.
The completion time for Form G–315a.1
is estimated at 2 minutes.
Estimated Annual Burden: 217 hours.
Additional Information or Comments:
Copies of the forms and supporting
documents can be obtained from
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Charles Mierzwa, the agency clearance
officer at (312) 751–3363 or
Charles.Mierzwa@RRB.GOV.
Comments regarding the information
collection should be addressed to
Patricia Henaghan, Railroad Retirement
Board, 844 North Rush Street, Chicago,
Illinois, 60611–2092 or
Patricia.Henaghan@RRB.GOV and to
the OMB Desk Officer for the RRB, Fax:
202–395–6974, E-mail address:
OIRA_Submission@omb.eop.gov.
Charles Mierzwa,
Clearance Officer.
[FR Doc. 2011–27488 Filed 10–24–11; 8:45 am]
BILLING CODE 7905–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
29840; 812–13755]
RiverPark Advisors, LLC, et al.; Notice
of Application
October 19, 2011.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 6(c) of the
Investment Company Act of 1940
(‘‘Act’’) for an exemption from sections
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
(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 (B) of the
Act.
AGENCY:
RiverPark Advisors, LLC
(‘‘RiverPark’’), RiverPark Funds Trust
(the ‘‘Trust’’) and ALPS Distributors,
Inc. (the ‘‘Distributor’’).
SUMMARY OF APPLICATION: Applicants
request an order that permits: (a) Series
of certain actively managed open-end
management investment companies to
issue exchange-traded 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 from the tender of Shares 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
unit investment trusts outside of the
same group of investment companies as
the series to acquire Shares.
APPLICANTS:
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Federal Register / Vol. 76, No. 206 / Tuesday, October 25, 2011 / Notices
The application was filed
on February 17, 2010, and amended on
July 29, 2010, December 22, 2010,
March 1, 2011, April 26, 2011,
September 30, 2011 and October 18,
2011.
HEARING OR NOTIFICATION OF HEARING: An
order granting the requested relief will
be issued unless the Commission orders
a hearing. Interested persons may
request a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on November 14, 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: RiverPark and the
Trust, 156 West 56th Street, New York,
NY 10019; the Distributor, c/o Thomas
A. Carter, 1290 Broadway #1100,
Denver, CO .
FOR FURTHER INFORMATION CONTACT:
Bruce R. MacNeil, Senior Counsel, at
(202) 551–6817 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.
investment objective of RiverPark Short
Term High Yield ETF will be to seek
high current income and capital
appreciation consistent with the
preservation of capital.
2. Applicants request that the order
apply to the Initial Funds and any
future series of the Trust and other
future open-end management
companies or series thereof that may
utilize active management investment
strategies (‘‘Future Funds’’). Any Future
Fund will (a) Advised by RiverPark or
an entity controlling, controlled by, or
under common control with RiverPark
(together with RiverPark, an ‘‘Advisor’’),
and (b) comply with the terms and
conditions of the application.1 The
Initial Funds and Future Funds together
are the ‘‘Funds’’. Each Fund will consist
of a portfolio of securities (including
fixed income securities and/or equity
securities) and/or currencies (‘‘Portfolio
Instruments’’).2 Funds may also invest
in ‘‘Depositary Receipts’’.3 A Fund will
not invest in any Depositary Receipts
that the Advisor deems to be illiquid or
for which pricing information is not
readily available. Each Fund will
operate as an actively managed
exchange-traded fund (‘‘ETF’’). The
Future Funds might include one or
more ETFs which invest in other openend and/or closed-end investment
companies and/or ETFs.
3. RiverPark, a Delaware corporation,
will be the investment advisor to the
Initial Funds. Each Advisor is or will be
registered as an ‘‘investment adviser’’
under the Investment Advisers Act of
1940 (the ‘‘Advisers Act’’). The Advisor
may retain investment advisers as subadvisers in connection with the Funds
(each, a ‘‘Subadvisor’’). Any Subadvisor
will be registered under the Advisers
Act. A registered broker-dealer under
the Securities Exchange Act of 1934
(‘‘Exchange Act’’), which may be an
affiliate of the Advisor, will act as the
distributor and principal underwriter of
Applicants’ Representations
1. The Trust is registered as an openend management investment company
under the Act and is a statutory trust
organized under the laws of Delaware.
The Trust will initially create and
operate four series of actively-managed
portfolios that offer Shares: RiverPark
Large Growth ETF, RiverPark/
Wedgewood ETF, RiverPark Small Cap
Growth ETF and RiverPark Short Term
High Yield ETF (together, the ‘‘Initial
Funds’’). The investment objectives of
RiverPark Large Growth ETF, RiverPark/
Wedgewood ETF and RiverPark Small
Cap Growth ETF will be to seek longterm capital appreciation. The
1 All entities that currently intend to rely on the
order are named as applicants. Any other entity that
relies on the order in the future will comply with
the terms and conditions of the application. An
Investing Fund (as defined below) may rely on the
order only to invest in Funds and not in any other
registered investment company. Each Fund will
comply with the disclosure requirements adopted
by the Commission in Investment Company Act
Release No. 28584 (Jan. 13, 2009).
2 Neither the Initial Funds nor any Future Fund
will invest in options contracts, futures contracts or
swap agreements.
3 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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FILING DATES:
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66097
the Funds. ALPS Distributors, Inc. will
serve as the initial Distributor.
4. Applicants anticipate that a
Creation Unit will consist of at least
50,000 Shares and that the price of a
Share will range from $20 to $200. All
orders to purchase Creation Units must
be placed with the Distributor by or
through a party that has entered into a
participant agreement with the
Distributor and the transfer agent of the
Trust (‘‘Authorized Participant’’) with
respect to the creation and redemption
of Creation Units. An Authorized
Participant is either: (a) A broker or
dealer registered under the Exchange
Act (‘‘Broker’’) or other participant in
the Continuous Net Settlement System
of the National Securities Clearing
Corporation, a clearing agency
registered with the Commission and
affiliated with the Depository Trust
Company (‘‘DTC’’), or (b) a participant
in the DTC (such participant, ‘‘DTC
Participant’’). The Initial Funds and
most Future Funds will generally be
purchased in Creation Units in
exchange for the ‘‘in-kind’’ deposit of
specified instruments (‘‘Deposit
Instruments’’) and will generally be
redeemed in-kind for specified Portfolio
Instruments (‘‘Redemption
Instruments’’). In-kind purchases and
in-kind redemptions will be
accompanied by an amount of cash
specified by the Advisor (‘‘Cash
Balancing Amount’’). The Deposit
Instruments and the Cash Balancing
Amount collectively are referred to as
the ‘‘Creation Deposit.’’ The Cash
Balancing Amount is a cash payment
designed to ensure that the net asset
value of a Creation Deposit is identical
to the net asset value of the Creation
Unit it is used to purchase. Certain
Future Funds may be purchased entirely
for cash (‘‘All-Cash Payment’’) and will
generally be redeemed in-kind.4
However, the Trust reserves the right to
accept and deliver Creation Units of
such Future Funds by means of an inkind tender of specified Deposit
Instruments) and to permit cash
redemptions for any Fund.5
4 On each Business Day (as defined below), prior
to the opening of trading on the Stock Exchange (as
defined below), the estimated All-Cash Payment for
each Fund or a list of the required Deposit
Instruments to be included in the Creation Deposit
for each Fund, as applicable, the previous day’s
Cash Balancing Amount, and the estimated Cash
Balancing Amount for the current day, will be made
available. The Stock Exchange will disseminate
every 15 seconds throughout the trading day
through the facilities of the Consolidated Tape
Association an amount representing, on a per Share
basis, the sum of the current value of the Portfolio
Instruments.
5 Applicants state that in determining whether a
particular Fund will be selling or redeeming
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5. An investor purchasing or
redeeming a Creation Unit from a Fund
may be charged a fee (‘‘Transaction
Fee’’) to protect existing shareholders of
the Funds from the dilutive costs
associated with the purchase and
redemption of Creation Units.6 All
orders to purchase Creation Units will
be placed with the Distributor and the
Distributor will transmit all purchase
orders to the relevant Fund. The
Distributor will be responsible for
delivering a prospectus (‘‘Prospectus’’)
to those persons purchasing Creation
Units and for maintaining records of
both the orders placed with it and the
confirmations of acceptance furnished
by it.
6. Shares will be listed and traded at
negotiated prices on a national
securities exchange as defined in
section 2(a)(26) of the Act (the ‘‘Stock
Exchange’’) and traded in the secondary
market. Applicants expect that exchange
market makers (‘‘Exchange Market
Makers’’) will be assigned to Shares.
The price of Shares trading on the Stock
Exchange will be based on a current
bid/offer market. Transactions involving
the purchases and sales of Shares on the
Stock Exchange will be subject to
customary brokerage commissions and
charges.
7. Applicants expect that purchasers
of Creation Units will include
arbitrageurs. Exchange Market Makers,
acting in their unique role to provide a
fair and orderly secondary market for
Shares, also may purchase Creation
Units for use in their own market
making activities.7 Applicants expect
that secondary market purchasers of
Shares will include both institutional
Creation Units on a cash or in-kind basis, the key
consideration will be the benefit which would
accrue to Fund investors. In many cases,
particularly to the extent the Deposit Instruments
are less liquid, investors may benefit by the use of
all cash creations because the Advisor would
execute trades rather than Exchange Market Makers
(as defined below). Applicants believe that the
Advisor may be able to obtain better execution for
certain Portfolio Instruments due to its size,
experience and relationships in the markets. With
respect to redemptions, tax considerations may
warrant in-kind redemptions which do not result in
a taxable event for the Fund.
6 Where a Fund permits an in-kind purchaser to
substitute cash in lieu of depositing one or more
Deposit Instruments, the purchaser may be assessed
a higher Transaction Fee to offset the cost to the
Fund of buying those particular Deposit
Instruments.
7 Applicants state that unlike other Stock
Exchanges where a lead market maker may oversee
trading in Shares, on NASDAQ, numerous
Exchange Market Makers may buy and sell shares
for their own account. If Shares are listed on
NASDAQ, and no designated liquidity provider has
been selected, then under NASDAQ’s listing
requirements, two or more Exchange Market Makers
will be registered in Shares and required to make
a continuous, two-sided market or face regulatory
sanctions.
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and retail investors.8 Applicants expect
that arbitrage opportunities created by
the ability to continually purchase or
redeem Creation Units at their net asset
value should ensure that the Shares will
not trade at a material discount or
premium in relation to net asset value
per individual share (‘‘NAV’’).
8. Shares may be redeemed only if
tendered in Creation Units. Redemption
requests must be placed by or through
an Authorized Participant. Applicants
currently contemplate that Creation
Units of the Initial Funds will be
redeemed principally in-kind (together
with a Cash Balancing Amount).9 To the
extent a Fund utilizes in-kind
redemptions, Shares in Creation Units
will be redeemable on any Business
Day, which is defined to include any
day that the Trust is open for business
as required by section 22(e) of the Act,
for the Redemption Instruments, which
will be the same as the Deposit
Instruments deposited by investors
purchasing Creation Units on the same
day, except for the limited exceptions
noted below. The redeeming investor
will also usually pay to the Fund a
Transaction Fee.
9. Applicants state that in accepting
Deposit Instruments and satisfying
redemptions with Redemption
Instruments, the Funds must comply
with the federal securities laws,
including that the Deposit Instruments
and Redemption Instruments are sold in
transactions that would be exempt from
registration under the Securities Act.10
To the extent in-kind purchases and
redemptions are utilized, the Deposit
Instruments and Redemption
Instruments will correspond pro rata to
the Fund portfolio, except that there
may be minor differences between a
basket of Deposit Instruments or
8 Shares will be registered in book-entry form
only. DTC or its nominee will be the record or
registered owner of all outstanding Shares.
Beneficial ownership of Shares will be shown on
the records of DTC or DTC Participants.
9 To the extent consistent with other investment
limitations, the Funds may invest in mortgage- or
asset-backed securities, including a ‘‘to-beannounced transaction’’ or ‘‘TBA Transactions’’.
Each Fund intends to substitute a cash-in-lieu
amount to replace any Deposit Instrument or
Redemption Instrument that is a TBA Transaction.
A TBA Transaction is a method of trading mortgagebacked securities. In a TBA Transaction, the buyer
and seller agree upon general trade parameters such
as agency, settlement date, par amount and price.
The actual pools delivered generally are determined
two days prior to the settlement date. The amount
of substituted cash in the case of TBA Transactions
will be equivalent to the value of the TBA
Transaction listed as a Deposit Instrument or
Redemption Instrument.
10 In accepting Deposit Instruments and satisfying
redemptions with Redemption Instruments that are
restricted securities eligible for resale pursuant to
rule 144A under the Securities Act, the Funds will
comply with the conditions of Rule 144A.
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Redemption Instruments and a true pro
rata slice of a Fund’s portfolio solely
when (a) It is impossible to break up
bonds beyond certain minimum sizes
needed for transfer and settlement or,
(b) in the case of equity securities,
rounding is necessary to eliminate
fractional shares or lots that are not
tradeable round lots. With respect to the
Funds that hold short positions, Deposit
Instruments and Redemption
Instruments will correspond pro rata to
the long Portfolio Securities of the
relevant Fund. There may be minor
differences between a basket of Deposit
Instruments or Redemption Instruments
and a true pro rata slice of the long
Portfolio Securities solely to the extent
necessary (a) Because it is impossible to
break up bonds beyond certain
minimum sizes needed for transfer and
settlement, or (b) because, in the case of
equity securities, rounding is necessary
to eliminate fractional shares or lots that
are not tradable round lots.11 Because
they cannot be transferred in-kind, short
positions will not be included in the
Deposit Securities and Redemption
Securities for a Fund.
10. Neither the Trust nor any Fund
will be marketed or otherwise held out
as a ‘‘mutual fund.’’ Instead, each Fund
will be marketed as an ‘‘activelymanaged exchange-traded fund.’’ Any
advertising material where features of
obtaining, buying or selling Creation
Units are described or where there is
reference to redeemability will
prominently disclose that Shares are not
individually redeemable and that
owners of Shares may acquire Shares
from a Fund and tender those Shares for
redemption to a Fund in Creation Units
only.
11. The Funds’ Web site, which will
be publicly available prior to the public
offering of Shares, will include the
Prospectus and additional quantitative
information updated on a daily basis,
including, on a per Share basis for each
Fund, the prior Business Day’s NAV and
the market closing price or mid-point of
the bid/ask spread at the time of the
calculation of such NAV (‘‘Bid/Ask
Price’’), and a calculation of the
premium or discount of the market
closing price or Bid/Ask Price against
such NAV. On each Business Day,
before commencement of trading in
Shares on the Stock Exchange, the Fund
will disclose on its Web site the
identities and quantities of the Portfolio
Instruments and other assets held by the
Fund that will form the basis for the
11 A tradeable round lot for an equity security will
be the standard unit of trading in that particular
type of security in its primary market.
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Fund’s calculation of NAV at the end of
the Business Day.12
Applicants’ Legal Analysis
1. Applicants request an order under
section 6(c) of 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 (B) of the Act.
2. Section 6(c) of the Act provides that
the Commission may exempt any
person, security or transaction, or any
class of persons, securities or
transactions, from any provisions of the
Act, 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 17(b)
of the Act authorizes the Commission to
exempt a proposed transaction from
section 17(a) of the Act if evidence
establishes that the terms of the
transaction, including the consideration
to be paid or received, are reasonable
and fair and do not involve
overreaching on the part of any person
concerned, and the proposed
transaction is consistent with the
policies of the registered investment
company and the general provisions of
the Act. Section 12(d)(1)(J) of the Act
provides that the Commission may
exempt any person, security, or
transaction, or any class or classes of
persons, securities or transactions, from
any provision of section 12(d)(1) if the
exemption is consistent with the public
interest and the protection of investors.
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Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an
‘‘open-end company’’ as a management
investment company that is offering for
sale or has outstanding any redeemable
security of which it is the issuer.
Section 2(a)(32) of the Act defines a
redeemable security as any security,
other than short-term paper, under the
terms of which the holder, upon its
presentation to the issuer, is entitled to
receive approximately a proportionate
share of the issuer’s current net assets,
or the cash equivalent. Because Shares
will not be individually redeemable,
12 Applicants note that under accounting
procedures followed by the Funds, trades made on
the prior Business Day (‘‘T’’) will be booked and
reflected in NAV on the current Business Day
(‘‘T+1’’). Accordingly, the Funds will be able to
disclose at the beginning of the Business Day the
portfolio that will form the basis for the NAV
calculation at the end of the Business Day.
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applicants request an order that would
permit the Trust to register as an openend management investment company
and redeem Shares in Creation Units
only. Applicants state that investors
may purchase Shares in Creation Units
from each Fund and redeem Creation
Units from each Fund. Applicants
further state that because the market
price of Creation Units will be
disciplined by arbitrage opportunities,
investors should be able to sell Shares
in the secondary market at prices that
do not vary substantially from their
NAV.
Section 22(d) of the Act and Rule
22c–1 Under the Act
4. Section 22(d) of the Act, among
other things, prohibits a dealer from
selling a redeemable security that is
currently being offered to the public by
or through a principal underwriter,
except at a current public offering price
described in the prospectus. Rule
22c–1 under the Act generally requires
that a dealer selling, redeeming, or
repurchasing a redeemable security do
so only at a price based on its NAV.
Applicants state that secondary market
trading in Shares will take place at
negotiated prices, not at a current
offering price described in the
Prospectus, and not at a price based on
NAV. Thus, purchases and sales of
Shares in the secondary market will not
comply with section 22(d) of the Act
and rule 22c–1 under the Act.
Applicants request an exemption under
section 6(c) from these provisions.
5. Applicants assert that the concerns
sought to be addressed by section 22(d)
of the Act and rule 22c–1 under the Act
with respect to pricing are equally
satisfied by the proposed method of
pricing Shares. Applicants maintain that
while there is little legislative history
regarding section 22(d), its provisions,
as well as those of rule 22c–1, appear to
have been designed to (a) Prevent
dilution caused by certain risklesstrading schemes by principal
underwriters and contract dealers,
(b) prevent unjust discrimination or
preferential treatment among buyers
resulting from sales at different prices,
and (c) assure an orderly distribution
system of investment company shares
by eliminating price competition from
Brokers offering shares at less than the
published sales price and repurchasing
shares at more than the published
redemption price.
6. Applicants believe that none of
these purposes will be thwarted by
permitting Shares to trade in the
secondary market at negotiated prices.
Applicants state that (a) Secondary
market trading in Shares does not
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66099
involve the Funds as parties and cannot
result in dilution of an investment in
Shares, and (b) to the extent different
prices exist during a given trading day,
or from day to day, such variances occur
as a result of third-party market forces,
such as supply and demand. Therefore,
applicants assert that secondary market
transactions in Shares will not lead to
discrimination or preferential treatment
among purchasers. Finally, applicants
contend that the proposed distribution
system will be orderly because arbitrage
activity should ensure that the
difference between the market price of
Shares and their NAV remains narrow.
Section 22(e) of the Act
7. Section 22(e) of the Act generally
prohibits a registered investment
company from suspending the right of
redemption or postponing the date of
payment of redemption proceeds for
more than seven days after the tender of
a security for redemption. Applicants
observe that settlement of redemptions
of Creation Units of Funds holding nonU.S. investments (‘‘Global Funds’’) is
contingent not only on the settlement
cycle of the U.S. securities markets but
also on the delivery cycles present in
foreign markets in which those Funds
invest. Applicants have been advised
that, under certain circumstances, the
delivery cycles for transferring Portfolio
Instruments to redeeming investors,
coupled with local market holiday
schedules, will require a delivery
process of up to 14 calendar days.
Applicants therefore request relief from
section 22(e) in order to provide
payment or satisfaction of redemptions
within the maximum number of
calendar days required for such
payment or satisfaction in the principal
local markets where transactions in the
Portfolio Instruments of each Global
Fund customarily clear and settle, but in
all cases no later than 14 calendar days
following the tender of a Creation Unit.
With respect to Future Funds that are
Global Funds, applicants seek the same
relief from section 22(e) only to the
extent that circumstances exist similar
to those described in the application.
Except as disclosed in the SAI for a
Fund, deliveries of redemption proceeds
for Global Funds are expected to be
made within seven days.13
8. Applicants submit that Congress
adopted section 22(e) to prevent
unreasonable, undisclosed or
unforeseen delays in the actual payment
13 Rule 15c6–1 under the Exchange Act requires
that most securities transactions be settled within
three business days of the trade date. Applicants
acknowledge that no relief obtained from the
requirements of section 22(e) will affect any
obligations that they have under rule 15c6–1.
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of redemption proceeds. Applicants
state that allowing redemption
payments for Creation Units of a Fund
to be made within a maximum of 14
calendar days would not be inconsistent
with the spirit and intent of section
22(e). Applicants state the SAI will
disclose those local holidays (over the
period of at least one year following the
date of the SAI), if any, that are
expected to prevent the delivery of
redemption proceeds in seven calendar
days and the maximum number of days
needed to deliver the proceeds for each
affected Global Fund.
9. Applicants are not seeking relief
from section 22(e) with respect to Global
Funds that do not effect creations or
redemptions in-kind.
Section 12(d)(1) of the Act
10. Section 12(d)(1)(A) of the Act
prohibits a registered investment
company from acquiring shares of an
investment company if the securities
represent more than 3% of the total
outstanding voting stock of the acquired
company, more than 5% of the total
assets of the acquiring company, or,
together with the securities of any other
investment companies, more than 10%
of the total assets of the acquiring
company. Section 12(d)(1)(B) of the Act
prohibits a registered open-end
investment company, its principal
underwriter, or any other broker or
dealer from selling its shares to another
investment company if the sale will
cause the acquiring company to own
more than 3% of the acquired
company’s voting stock, or if the sale
will cause more than 10% of the
acquired company’s voting stock to be
owned by investment companies
generally.
11. Applicants request relief to permit
Investing Funds (as defined below) to
acquire Shares in excess of the limits in
section 12(d)(1)(A) of the Act and to
permit the Funds, their principal
underwriters and any Brokers to sell
Shares to Investing Funds in excess of
the limits in section 12(d)(1)(B) of the
Act. Applicants request that these
exemptions apply to: (a) Any Fund that
is currently or subsequently part of the
same ‘‘group of investment companies’’
as the Initial Funds within the meaning
of section 12(d)(1)(G)(ii) of the Act as
well as any principal underwriter for
the Funds and any Brokers selling
Shares of a Fund to an Investing Fund;
and (b) each management investment
company or unit investment trust
registered under the Act that is not part
of the same ‘‘group of investment
companies’’ as the Funds and that
enters into a FOF Participation
Agreement (as defined below) with a
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Fund (such management investment
companies are referred to herein as
‘‘Investing Management Companies,’’
such unit investment trusts are referred
to herein as ‘‘Investing Trusts,’’ and
Investing Management Companies and
Investing Trusts together are referred to
herein as ‘‘Investing Funds’’).14
Investing Funds do not include the
Funds. Each Investing Trust will have a
sponsor (‘‘Sponsor’’) and each Investing
Management Company will have an
investment adviser within the meaning
of section 2(a)(20)(A) of the Act
(‘‘Investing Fund Advisor’’) that does
not control, is not controlled by or
under common control with the
Advisor. Each Investing Management
Company may also have one or more
investment advisers within the meaning
of section 2(a)(20)(B) of the Act (each,
an ‘‘Investing Fund Sub-Advisor’’). Each
Investing Fund Advisor and any
Investing Fund Sub-Advisor will be
registered as an investment adviser
under the Advisers Act.
12. Applicants submit that the
proposed conditions to the requested
relief are designed to address the
concerns underlying the limits in
section 12(d)(1), which include
concerns about undue influence,
excessive layering of fees and overly
complex structures.
13. Applicants propose a condition to
prohibit an Investing Fund or Investing
Fund Affiliate 15 from causing an
investment by an Investing Fund in a
Fund to influence the terms of services
or transactions between an Investing
Fund or an Investing Fund Affiliate and
the Fund or Fund Affiliate. Applicants
propose a condition to limit the ability
of the Investing Fund Advisor, or
Sponsor, any person controlling,
controlled by or under common control
with such Advisor or Sponsor, and any
investment company or issuer that
would be an investment company but
for sections 3(c)(1) or 3(c)(7) of the Act
that is advised or sponsored by the
Investing Fund Advisor, the Sponsor, or
any person controlling, controlled by, or
under common control with such
Advisor or Sponsor (‘‘Investing Fund’s
Advisory Group’’) from (individually or
14 Applicants anticipate that there may be
Investing Funds that are not part of the same group
of investment companies as the Funds but may be
subadvised by an Advisor.
15 An ‘‘Investing Fund Affiliate’’ is defined as the
Investing Fund Advisor, Investing Fund SubAdvisor, Sponsor, promoter and principal
underwriter of an Investing Fund, and any person
controlling, controlled by or under common control
with any of these entities. A ‘‘Fund Affiliate’’ is
defined as an investment adviser, promoter or
principal underwriter of a Fund and any person
controlling, controlled by or under common control
with any of these entities.
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in the aggregate) controlling a Fund
within the meaning of section 2(a)(9) of
the Act. The same prohibition would
apply to any Investing Fund SubAdvisor, any person controlling,
controlled by, or under common control
with the Investing Fund Sub-Advisor,
and any investment company or issuer
that would be an investment company
but for sections 3(c)(1) or 3(c)(7) of the
Act (or portion of such investment
company or issuer) advised or
sponsored by the Investing Fund SubAdvisor or any person controlling,
controlled by or under common control
with the Investing Fund Sub-Advisor
(‘‘Investing Fund’s Sub-Advisory
Group’’).
14. Applicants propose other
conditions to limit the potential for an
Investing Fund and certain affiliates of
an Investing Fund (including
Underwriting Affiliates) to exercise
undue influence over a Fund and
certain of its affiliates, including that no
Investing Fund or Investing Fund
Affiliate (except to the extent it is acting
in its capacity as an investment adviser
to a Fund) will cause a Fund to
purchase a security in an offering of
securities during the existence of an
underwriting or selling syndicate of
which a principal underwriter is an
Underwriting Affiliate (‘‘Affiliated
Underwriting’’). An ‘‘Underwriting
Affiliate’’ is a principal underwriter in
any underwriting or selling syndicate
that is an officer, director, member of an
advisory board, Investing Fund Advisor,
Investing Fund Sub-Advisor, employee
or Sponsor of the Investing Fund, or a
person of which any such officer,
director, member of an advisory board,
Investing Fund Advisor or Investing
Fund Sub-Advisor, employee or
Sponsor is an affiliated person. An
Underwriting Affiliate does not include
any person whose relationship to the
Fund is covered by section 10(f) of the
Act.
15. Applicants propose several
conditions to address the concerns
regarding layering of fees and expenses.
Applicants note that the board of
directors or trustees of any Investing
Management Company, including a
majority of the directors or trustees who
are not ‘‘interested persons’’ within the
meaning of section 2(a)(19) of the Act
(‘‘disinterested directors or trustees’’),
will be required to find that the advisory
fees charged under the contract are
based on services provided that will be
in addition to, rather than duplicative
of, services provided under the advisory
contract of any Fund in which the
Investing Management Company may
invest. In addition, an Investing Fund
Advisor, trustee of an Investing Trust
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(‘‘Trustee’’) or Sponsor, as applicable,
will waive fees otherwise payable to it
by the Investing Fund in an amount at
least equal to any compensation
(including fees received pursuant to any
plan adopted by a Fund under rule 12b–
1 under the Act) received from a Fund
by the Investing Fund Advisor, Trustee
or Sponsor or an affiliated person of the
Investing Fund Advisor, Trustee or
Sponsor, other than any advisory fees
paid to the Investing Fund Advisor,
Trustee or Sponsor or its affiliated
person by a Fund, in connection with
the investment by the Investing Fund in
the Fund. Applicants also propose a
condition to prevent any sales charges
or service fees on shares of an Investing
Fund from exceeding the limits
applicable to a fund of funds set forth
in NASD Conduct Rule 2830.16
16. Applicants submit that the
proposed arrangement will not create an
overly complex fund structure.
Applicants note that a Fund will be
prohibited from acquiring securities of
any investment company or company
relying on sections 3(c)(1) or 3(c)(7) of
the Act in excess of the limits contained
in section 12(d)(1)(A) of the Act, except
to the extent permitted by exemptive
relief from the Commission permitting
the Fund to purchase shares of other
investment companies for short-term
cash management purposes.
17. To ensure that the Investing Funds
understand and comply with the terms
and conditions of the requested order,
any Investing Fund that intends to
invest in a Fund in reliance on the
requested order will be required to enter
into a participation agreement (‘‘FOF
Participation Agreement’’) with the
Fund. The FOF Participation Agreement
will include an acknowledgment from
the Investing Fund that it may rely on
the order only to invest in the Funds
and not in any other investment
company.
Sections 17(a)(1) and (2) of the Act
18. Section 17(a) of the Act generally
prohibits an affiliated person of a
registered investment company, or an
affiliated person of such a person
(‘‘second tier affiliate’’), from selling any
security to or purchasing any security
from the company. Section 2(a)(3) of the
Act defines ‘‘affiliated person’’ to
include any person directly or indirectly
owning, controlling, or holding with
power to vote, 5% or more of the
outstanding voting securities of the
other person and any person directly or
indirectly controlling, controlled by, or
16 Any references to NASD Conduct Rule 2830
include any successor or replacement rule to NASD
Conduct Rule that may be adopted by FINRA.
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under common control with, the other
person. Section 2(a)(9) of the Act
defines ‘‘control’’ as the power to
exercise a controlling influence over the
management or policies of a company
and provides that a control relationship
will be presumed where one person
owns more than 25% of another
person’s voting securities. Each Fund
may be deemed to be controlled by an
Advisor and hence affiliated persons of
each other. In addition, the Funds may
be deemed to be under common control
with any other registered investment
company (or series thereof) advised by
an Advisor (an ‘‘Affiliated Fund’’).
19. Applicants request an exemption
under sections 6(c) and 17(b) of the Act
from sections 17(a)(1) and 17(a)(2) of the
Act to permit in-kind purchases and
redemptions of Creation Units by
persons that are affiliated persons or
second tier affiliates of the Funds solely
by virtue of one or more of the
following: (a) Holding 5% or more, or in
excess of 25% of the outstanding Shares
of one or more Funds; (b) having an
affiliation with a person with an
ownership interest described in (a); or
(c) holding 5% or more, or more than
25% of the Shares of one or more
Affiliated Funds.17 Applicants also
request an exemption in order to permit
a Fund to sell its Shares to and redeem
its Shares from, and engage in the inkind transactions that would
accompany such sales and redemptions
with, certain Investing Funds of which
the Funds are affiliated persons or a
second-tier affiliates.18
20. Applicants assert that no useful
purpose would be served by prohibiting
such affiliated persons from making inkind purchases or in-kind redemptions
of Shares of a Fund in Creation Units.
Absent the unusual circumstances
discussed in the application, the
Deposit Instruments and Redemption
Instruments available for a Fund will be
the same for all purchases and
redeemers, respectively, and will
17 Applicants are not seeking relief from section
17(a) for, and the requested relief will not apply to,
transactions where a Fund could be deemed an
affiliated person, or an affiliated person of an
affiliated person, of an Investing Fund because an
investment adviser to the Funds is also an
investment adviser to an Investing Fund.
18 Applicants expect most Investing Funds will
purchase Shares in the secondary market and will
not purchase Creation Units directly from a Fund.
To the extent that purchases and sales of Shares
occur in the secondary market and not through
principal transactions directly between an Investing
Fund and a Fund, relief from section 17(a) would
not be necessary. However, the requested relief
would apply to direct sales of Shares in Creation
Units by a Fund to an Investing Fund and
redemptions of those Shares. The requested relief
is also intended to cover the in-kind transactions
that may accompany such sales and redemptions.
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66101
correspond pro rata to the Fund’s
portfolio instruments. Both the deposit
procedures for in-kind purchases of
Creation Units and the redemption
procedures for in-kind redemptions will
be effected in exactly the same manner
for all purchases and redemptions.
Deposit Instruments and Redemption
Instruments will be valued in the same
manner as those Portfolio Instruments
currently held by the relevant Funds.
Therefore, applicants state that the inkind purchases and redemptions create
no opportunity for affiliated persons or
the Applicants to effect a transaction
detrimental to other holders of Shares of
that Fund. Applicants do not believe
that in-kind purchases and redemptions
will result in abusive self-dealing or
overreaching of the Fund.
21. Applicants also submit that the
sale of Shares to and redemption of
Shares from an Investing Fund meets
the standards for relief under sections
17(b) and 6(c) of the Act. Applicants
note that any consideration paid for the
purchase or redemption of Shares
directly from a Fund will be based on
the NAV of the Fund in accordance with
policies and procedures set forth in the
Fund’s registration statement.19 Absent
the unusual circumstances discussed in
the application, the Deposit Instruments
and Redemption Instruments available
for a Fund will be the same for all
purchases and redeemers, respectively,
and will correspond pro rata to the
Fund’s portfolio instruments.
Applicants also state that the proposed
transactions are consistent with the
general purposes of the Act and
appropriate in the public interest.
Applicants’ Conditions:
Applicants agree that any order of the
Commission granting the requested
relief will be subject to the following
conditions:
A. Actively-Managed Exchange-Traded
Fund Relief
1. As long as a Fund operates in
reliance on the requested order, the
Shares of the Fund will be listed on a
Stock Exchange.
2. Neither the Trust nor any Fund will
be advertised or marketed as an openend investment company or a mutual
fund. Any advertising material that
describes the purchase or sale of
19 Applicants acknowledge that the receipt of
compensation by (a) An affiliated person of an
Investing Fund, or an affiliated person of such
person, for the purchase by the Investing Fund of
Shares of the Fund or (b) an affiliated person of a
Fund, or an affiliated person of such person, for the
sale by the Fund of its Shares to an Investing Fund,
may be prohibited by section 17(e)(1) of the Act.
The FOF Participation Agreement also will include
this acknowledgment.
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Creation Units or refers to redeemability
will prominently disclose that the
Shares are not individually redeemable
and that owners of the Shares may
acquire those Shares from the Fund and
tender those Shares for redemption to
the Fund in Creation Units only.
3. The Web site for the Funds, which
is and will be publicly accessible at no
charge, will contain, on a per Share
basis, for each Fund the prior Business
Day’s NAV and the market closing price
or Bid/Ask Price, and a calculation of
the premium or discount of the market
closing price or Bid/Ask Price against
such NAV.
4. On each Business Day, before
commencement of trading in Shares on
the Stock Exchange, the Fund will
disclose on its Web site the identities
and quantities of the Portfolio
Instruments and other assets held by the
Fund that will form the basis for the
Fund’s calculation of NAV at the end of
the Business Day.
5. The Advisor or any Subadvisor,
directly or indirectly, will not cause any
Authorized Participant (or any investor
on whose behalf an Authorized
Participant may transact with the Fund)
to acquire any Deposit Instrument for
the Fund through a transaction in which
the Fund could not engage directly.
6. The requested relief to permit ETF
operations will expire on the effective
date of any Commission rule under the
Act that provides relief permitting the
operation of actively-managed
exchange-traded funds.
B. Section 12(d)(1) Relief
1. The members of the Investing
Fund’s Advisory Group will not control
(individually or in the aggregate) a Fund
within the meaning of section 2(a)(9) of
the Act. The members of the Investing
Fund’s Sub-Advisory Group will not
control (individually or in the aggregate)
a Fund within the meaning of section
2(a)(9) of the Act. If, as a result of a
decrease in the outstanding voting
securities of a Fund, the Investing
Fund’s Advisory Group or the Investing
Fund’s Sub-Advisory Group, each in the
aggregate, becomes a holder of more
than 25 percent of the outstanding
voting securities of a Fund, it will vote
its Shares of the Fund in the same
proportion as the vote of all other
holders of the Fund’s Shares. This
condition does not apply to the
Investing Fund’s Sub-Advisory Group
with respect to a Fund for which the
Investing Fund Sub-Advisor or a person
controlling, controlled by or under
common control with the Investing
Fund Sub-Advisor acts as the
investment adviser within the meaning
of section 2(a)(20)(A) of the Act.
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2. No Investing Fund or Investing
Fund Affiliate will cause any existing or
potential investment by the Investing
Fund in a Fund to influence the terms
of any services or transactions between
the Investing Fund or an Investing Fund
Affiliate and the Fund or a Fund
Affiliate.
3. The board of directors or trustees of
an Investing Management Company,
including a majority of the disinterested
directors or trustees, will adopt
procedures reasonably designed to
assure that the Investing Fund Advisor
and any Investing Fund Sub-Advisor are
conducting the investment program of
the Investing Management Company
without taking into account any
consideration received by the Investing
Management Company or an Investing
Fund Affiliate from a Fund or a Fund
Affiliate in connection with any services
or transactions.
4. Once an investment by an Investing
Fund in Shares of a Fund exceeds the
limit in section 12(d)(1)(A)(i) of the Act,
the Board of a Fund, including a
majority of the disinterested Board
members, will determine that any
consideration paid by the Fund to the
Investing Fund or an Investing Fund
Affiliate in connection with any services
or transactions: (a) Is fair and reasonable
in relation to the nature and quality of
the services and benefits received by the
Fund; (b) is within the range of
consideration that the Fund would be
required to pay to another unaffiliated
entity in connection with the same
services or transactions; and (c) does not
involve overreaching on the part of any
person concerned. This condition does
not apply with respect to any services
or transactions between a Fund and its
investment adviser(s), or any person
controlling, controlled by or under
common control with such investment
adviser(s).
5. The Investing Fund Advisor, or
Trustee or Sponsor, as applicable, will
waive fees otherwise payable to it by the
Investing Fund in an amount at least
equal to any compensation (including
fees received pursuant to any plan
adopted by a Fund under rule 12b–1
under the Act) received from a Fund by
the Investing Fund Advisor, or Trustee
or Sponsor, or an affiliated person of the
Investing Fund Advisor, or Trustee or
Sponsor, other than any advisory fees
paid to the Investing Fund Advisor, or
Trustee, or Sponsor, or its affiliated
person by the Fund, in connection with
the investment by the Investing Fund in
the Fund. Any Investing Fund SubAdvisor will waive fees otherwise
payable to the Investing Fund SubAdvisor, directly or indirectly, by the
Investing Management Company in an
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amount at least equal to any
compensation received from a Fund by
the Investing Fund Sub-Advisor, or an
affiliated person of the Investing Fund
Sub-Advisor, other than any advisory
fees paid to the Investing Fund SubAdvisor or its affiliated person by the
Fund, in connection with the
investment by the Investing
Management Company in the Fund
made at the direction of the Investing
Fund Sub-Advisor. In the event that the
Investing Fund Sub-Advisor waives
fees, the benefit of the waiver will be
passed through to the Investing
Management Company.
6. No Investing Fund or Investing
Fund Affiliate (except to the extent it is
acting in its capacity as an investment
adviser to a Fund) will cause a Fund to
purchase a security in an Affiliated
Underwriting.
7. The Board of the Fund, including
a majority of the disinterested Board
members, will adopt procedures
reasonably designed to monitor any
purchases of securities by the Fund in
an Affiliated Underwriting, once an
investment by an Investing Fund in the
securities of the Fund exceeds the limit
of section 12(d)(1)(A)(i) of the Act,
including any purchases made directly
from an Underwriting Affiliate. The
Board will review these purchases
periodically, but no less frequently than
annually, to determine whether the
purchases were influenced by the
investment by the Investing Fund in the
Fund. The Board will consider, among
other things: (a) Whether the purchases
were consistent with the investment
objectives and policies of the Fund; (b)
how the performance of securities
purchased in an Affiliated Underwriting
compares to the performance of
comparable securities purchased during
a comparable period of time in
underwritings other than Affiliated
Underwritings or to a benchmark such
as a comparable market index; and (c)
whether the amount of securities
purchased by the Fund in Affiliated
Underwritings and the amount
purchased directly from an
Underwriting Affiliate have changed
significantly from prior years. The
Board will take any appropriate actions
based on its review, including, if
appropriate, the institution of
procedures designed to assure that
purchases of securities in Affiliated
Underwritings are in the best interest of
shareholders.
8. Each Fund will maintain and
preserve permanently in an easily
accessible place a written copy of the
procedures described in the preceding
condition, and any modifications to
such procedures, and will maintain and
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preserve for a period of not less than six
years from the end of the fiscal year in
which any purchase in an Affiliated
Underwriting occurred, the first two
years in an easily accessible place, a
written record of each purchase of
securities in Affiliated Underwritings
once an investment by an Investing
Fund in the securities of the Fund
exceeds the limit of section
12(d)(1)(A)(i) of the Act, setting forth
from whom the securities were
acquired, the identity of the
underwriting syndicate’s members, the
terms of the purchase, and the
information or materials upon which
the Board’s determinations were made.
9. Before investing in a Fund in
excess of the limits in section
12(d)(1)(A), an Investing Fund will
execute a FOF Participation Agreement
with the Fund stating that their
respective boards of directors or trustees
and their investment advisers, or
Trustee and Sponsor, as applicable,
understand the terms and conditions of
the order, and agree to fulfill their
responsibilities under the order. At the
time of its investment in shares of a
Fund in excess of the limit in section
12(d)(1)(A)(i), an Investing Fund will
notify the Fund of the investment. At
such time, the Investing Fund will also
transmit to the Fund a list of the names
of each Investing Fund Affiliate and
Underwriting Affiliate. The Investing
Fund will notify the Fund of any
changes to the list as soon as reasonably
practicable after a change occurs. The
Fund and the Investing Fund will
maintain and preserve a copy of the
order, the FOF Participation Agreement,
and the list with any updated
information for the duration of the
investment and for a period of not less
than six years thereafter, the first two
years in an easily accessible place.
10. Before approving any advisory
contract under section 15 of the Act, the
board of directors or trustees of each
Investing Management Company,
including a majority of the disinterested
directors or trustees, will find that the
advisory fees charged under such
contract are based on services provided
that will be in addition to, rather than
duplicative of, the services provided
under the advisory contract(s) of any
Fund in which the Investing
Management Company may invest.
These findings and their basis will be
recorded fully in the minute books of
the appropriate Investing Management
Company.
11. Any sales charges and/or service
fees charged with respect to shares of an
Investing Fund will not exceed the
limits applicable to a fund of funds as
set forth in NASD Conduct Rule 2830.
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12. No Fund relying on this section
12(d)(1) relief will acquire securities of
any investment company or company
relying on section 3(c)(1) or 3(c)(7) of
the Act in excess of the limits contained
in section 12(d)(1)(A) of the Act, except
to the extent permitted by exemptive
relief from the Commission permitting
the Fund to purchase shares of other
investment companies for short-term
cash management purposes.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2011–27531 Filed 10–24–11; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Sunshine Act Meeting
Notice is hereby given, pursuant to
the provisions of the Government in the
Sunshine Act, Public Law 94–409, that
the Securities and Exchange
Commission Advisory Committee on
Small and Emerging Companies will
hold an Open Meeting on Monday,
October 31, 2011, in the Multipurpose
Room, L–006. The meeting will begin at
9 a.m. and will be open to the public.
Seating will be on a first-come, firstserved basis. Doors will open at 8:30
a.m. Visitors will be subject to security
checks.
On October 7, 2011, the Commission
published notice of the Committee
meeting (Release No. 33–9266),
indicating that the meeting is open to
the public and inviting the public to
submit written comments to the
Committee. This Sunshine Act notice is
being issued because a majority of the
Commission may attend the meeting.
The agenda for the meeting includes
opening remarks, introduction of
Committee members, discussion of the
Committee’s agenda and organization,
and discussion of capital formation
issues relevant to small and emerging
companies.
For further information, please
contact the Office of the Secretary at
(202) 551–5400.
October 21, 2011.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2011–27750 Filed 10–21–11; 4:15 pm]
BILLING CODE 8011–01–P
PO 00000
Frm 00072
Fmt 4703
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66103
SECURITIES AND EXCHANGE
COMMISSION
[Securities Exchange Act of 1934 Release
No. 65592; File No. SR–BX–2011–046]
In the Matter of NASDAQ OMX BX, Inc.:
Order Denying NASDAQ OMX BX,
Inc.’s Petition for Review of Division of
Trading and Markets Suspension of
and Institution of Proceedings by
Delegated Authority of SR–BX–2011–
046; Lifting the Automatic Stay; and
Notice of Designation of a Longer
Comment Period for the Proceedings
Before the Securities and Exchange
Commission October 19, 2011.
Pursuant to Rule 431(b)(2) of the
Rules of Practice,1 It is ordered that the
petition 2 of Boston Options Exchange
Group LLC, an options trading facility of
NASDAQ OMX BX, Inc., (‘‘BOX’’) for
review of the temporary suspension and
institution of proceedings by the
Division of Trading and Markets (the
‘‘Division’’) by delegated authority of
SR–BX–2011–046 3 is hereby denied. It
is further ordered that the automatic
stay of delegated action pursuant to
Rule 431(e) of the Rules of Practice 4 is
hereby lifted.
The Commission hereby is also
extending the length of the period for
market participants to submit comments
related to SR–BX–2011–046 until
November 17, 2011 and the length of the
period for submission of rebuttal
comments until December 14, 2011.
On July 15, 2011, NASDAQ OMX BX,
Inc. filed, pursuant to Section 19(b)(1) of
the Exchange Act 5 and Rule 19b–4
thereunder, 6 a proposed rule change
that amended the BOX Fee Schedule to
increase the credits and fees for certain
transactions in the BOX Price
Improvement Period (‘‘PIP’’).7
1 17
CFR 201.431(b)(2).
for Review of Action by Delegated
Authority from BOX, dated September 27, 2011
(‘‘BOX Petition’’).
3 See Securities Exchange Act Release No. 65330
(September 13, 2011), 76 FR 58065 (September 19,
2011) (‘‘Suspension Order’’).
4 17 CFR 201.431(e).
5 15 U.S.C. 78s(b)(1).
6 17 CFR 240.19b–4.
7 The PIP is a mechanism in which members
submit an agency order on behalf of a customer for
price improvement over the BOX BBO, paired with
a contra-order guaranteeing execution of the agency
order at or better than the NBBO. The contra-order
could be for the account of the member, or an order
solicited from someone else. The agency order is
exposed for a 1-second auction in which members
may submit competing interest at the same price or
better. The initiating member is guaranteed 40% of
the order (after public customers) at the final price
for the PIP order, assuming it is at the best price.
See Chapter V, Section 18 of the BOX Rules.
2 Petition
E:\FR\FM\25OCN1.SGM
25OCN1
Agencies
[Federal Register Volume 76, Number 206 (Tuesday, October 25, 2011)]
[Notices]
[Pages 66096-66103]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-27531]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 29840; 812-13755]
RiverPark Advisors, LLC, et al.; Notice of Application
October 19, 2011.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under section 6(c) of the
Investment Company Act of 1940 (``Act'') for an exemption from sections
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 (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 (B) of the
Act.
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Applicants: RiverPark Advisors, LLC (``RiverPark''), RiverPark Funds
Trust (the ``Trust'') and ALPS Distributors, Inc. (the
``Distributor'').
Summary of Application: Applicants request an order that permits: (a)
Series of certain actively managed open-end management investment
companies to issue exchange-traded 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 from the tender of Shares 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 unit investment trusts outside of the same
group of investment companies as the series to acquire Shares.
[[Page 66097]]
Filing Dates: The application was filed on February 17, 2010, and
amended on July 29, 2010, December 22, 2010, March 1, 2011, April 26,
2011, September 30, 2011 and October 18, 2011.
Hearing or Notification of Hearing: An order granting the requested
relief will be issued unless the Commission orders a hearing.
Interested persons may request a hearing by writing to the Commission's
Secretary and serving applicants with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 p.m. on November 14, 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: RiverPark and the
Trust, 156 West 56th Street, New York, NY 10019; the Distributor, c/o
Thomas A. Carter, 1290 Broadway 1100, Denver, CO .
FOR FURTHER INFORMATION CONTACT: Bruce R. MacNeil, Senior Counsel, at
(202) 551-6817 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. The Trust is registered as an open-end management investment
company under the Act and is a statutory trust organized under the laws
of Delaware. The Trust will initially create and operate four series of
actively-managed portfolios that offer Shares: RiverPark Large Growth
ETF, RiverPark/Wedgewood ETF, RiverPark Small Cap Growth ETF and
RiverPark Short Term High Yield ETF (together, the ``Initial Funds'').
The investment objectives of RiverPark Large Growth ETF, RiverPark/
Wedgewood ETF and RiverPark Small Cap Growth ETF will be to seek long-
term capital appreciation. The investment objective of RiverPark Short
Term High Yield ETF will be to seek high current income and capital
appreciation consistent with the preservation of capital.
2. Applicants request that the order apply to the Initial Funds and
any future series of the Trust and other future open-end management
companies or series thereof that may utilize active management
investment strategies (``Future Funds''). Any Future Fund will (a)
Advised by RiverPark or an entity controlling, controlled by, or under
common control with RiverPark (together with RiverPark, an
``Advisor''), and (b) comply with the terms and conditions of the
application.\1\ The Initial Funds and Future Funds together are the
``Funds''. Each Fund will consist of a portfolio of securities
(including fixed income securities and/or equity securities) and/or
currencies (``Portfolio Instruments'').\2\ Funds may also invest in
``Depositary Receipts''.\3\ A Fund will not invest in any Depositary
Receipts that the Advisor deems to be illiquid or for which pricing
information is not readily available. Each Fund will operate as an
actively managed exchange-traded fund (``ETF''). The Future Funds might
include one or more ETFs which invest in other open-end and/or closed-
end investment companies and/or ETFs.
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\1\ All entities that currently intend to rely on the order are
named as applicants. Any other entity that relies on the order in
the future will comply with the terms and conditions of the
application. An Investing Fund (as defined below) may rely on the
order only to invest in Funds and not in any other registered
investment company. Each Fund will comply with the disclosure
requirements adopted by the Commission in Investment Company Act
Release No. 28584 (Jan. 13, 2009).
\2\ Neither the Initial Funds nor any Future Fund will invest in
options contracts, futures contracts or swap agreements.
\3\ 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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3. RiverPark, a Delaware corporation, will be the investment
advisor to the Initial Funds. Each Advisor is or will be registered as
an ``investment adviser'' under the Investment Advisers Act of 1940
(the ``Advisers Act''). The Advisor may retain investment advisers as
sub-advisers in connection with the Funds (each, a ``Subadvisor''). Any
Subadvisor will be registered under the Advisers Act. A registered
broker-dealer under the Securities Exchange Act of 1934 (``Exchange
Act''), which may be an affiliate of the Advisor, will act as the
distributor and principal underwriter of the Funds. ALPS Distributors,
Inc. will serve as the initial Distributor.
4. Applicants anticipate that a Creation Unit will consist of at
least 50,000 Shares and that the price of a Share will range from $20
to $200. All orders to purchase Creation Units must be placed with the
Distributor by or through a party that has entered into a participant
agreement with the Distributor and the transfer agent of the Trust
(``Authorized Participant'') with respect to the creation and
redemption of Creation Units. An Authorized Participant is either: (a)
A broker or dealer registered under the Exchange Act (``Broker'') or
other participant in the Continuous Net Settlement System of the
National Securities Clearing Corporation, a clearing agency registered
with the Commission and affiliated with the Depository Trust Company
(``DTC''), or (b) a participant in the DTC (such participant, ``DTC
Participant''). The Initial Funds and most Future Funds will generally
be purchased in Creation Units in exchange for the ``in-kind'' deposit
of specified instruments (``Deposit Instruments'') and will generally
be redeemed in-kind for specified Portfolio Instruments (``Redemption
Instruments''). In-kind purchases and in-kind redemptions will be
accompanied by an amount of cash specified by the Advisor (``Cash
Balancing Amount''). The Deposit Instruments and the Cash Balancing
Amount collectively are referred to as the ``Creation Deposit.'' The
Cash Balancing Amount is a cash payment designed to ensure that the net
asset value of a Creation Deposit is identical to the net asset value
of the Creation Unit it is used to purchase. Certain Future Funds may
be purchased entirely for cash (``All-Cash Payment'') and will
generally be redeemed in-kind.\4\ However, the Trust reserves the right
to accept and deliver Creation Units of such Future Funds by means of
an in-kind tender of specified Deposit Instruments) and to permit cash
redemptions for any Fund.\5\
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\4\ On each Business Day (as defined below), prior to the
opening of trading on the Stock Exchange (as defined below), the
estimated All-Cash Payment for each Fund or a list of the required
Deposit Instruments to be included in the Creation Deposit for each
Fund, as applicable, the previous day's Cash Balancing Amount, and
the estimated Cash Balancing Amount for the current day, will be
made available. The Stock Exchange will disseminate every 15 seconds
throughout the trading day through the facilities of the
Consolidated Tape Association an amount representing, on a per Share
basis, the sum of the current value of the Portfolio Instruments.
\5\ Applicants state that in determining whether a particular
Fund will be selling or redeeming Creation Units on a cash or in-
kind basis, the key consideration will be the benefit which would
accrue to Fund investors. In many cases, particularly to the extent
the Deposit Instruments are less liquid, investors may benefit by
the use of all cash creations because the Advisor would execute
trades rather than Exchange Market Makers (as defined below).
Applicants believe that the Advisor may be able to obtain better
execution for certain Portfolio Instruments due to its size,
experience and relationships in the markets. With respect to
redemptions, tax considerations may warrant in-kind redemptions
which do not result in a taxable event for the Fund.
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[[Page 66098]]
5. An investor purchasing or redeeming a Creation Unit from a Fund
may be charged a fee (``Transaction Fee'') to protect existing
shareholders of the Funds from the dilutive costs associated with the
purchase and redemption of Creation Units.\6\ All orders to purchase
Creation Units will be placed with the Distributor and the Distributor
will transmit all purchase orders to the relevant Fund. The Distributor
will be responsible for delivering a prospectus (``Prospectus'') to
those persons purchasing Creation Units and for maintaining records of
both the orders placed with it and the confirmations of acceptance
furnished by it.
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\6\ Where a Fund permits an in-kind purchaser to substitute cash
in lieu of depositing one or more Deposit Instruments, the purchaser
may be assessed a higher Transaction Fee to offset the cost to the
Fund of buying those particular Deposit Instruments.
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6. Shares will be listed and traded at negotiated prices on a
national securities exchange as defined in section 2(a)(26) of the Act
(the ``Stock Exchange'') and traded in the secondary market. Applicants
expect that exchange market makers (``Exchange Market Makers'') will be
assigned to Shares. The price of Shares trading on the Stock Exchange
will be based on a current bid/offer market. Transactions involving the
purchases and sales of Shares on the Stock Exchange will be subject to
customary brokerage commissions and charges.
7. Applicants expect that purchasers of Creation Units will include
arbitrageurs. Exchange Market Makers, acting in their unique role to
provide a fair and orderly secondary market for Shares, also may
purchase Creation Units for use in their own market making
activities.\7\ Applicants expect that secondary market purchasers of
Shares will include both institutional and retail investors.\8\
Applicants expect that arbitrage opportunities created by the ability
to continually purchase or redeem Creation Units at their net asset
value should ensure that the Shares will not trade at a material
discount or premium in relation to net asset value per individual share
(``NAV'').
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\7\ Applicants state that unlike other Stock Exchanges where a
lead market maker may oversee trading in Shares, on NASDAQ, numerous
Exchange Market Makers may buy and sell shares for their own
account. If Shares are listed on NASDAQ, and no designated liquidity
provider has been selected, then under NASDAQ's listing
requirements, two or more Exchange Market Makers will be registered
in Shares and required to make a continuous, two-sided market or
face regulatory sanctions.
\8\ Shares will be registered in book-entry form only. DTC or
its nominee will be the record or registered owner of all
outstanding Shares. Beneficial ownership of Shares will be shown on
the records of DTC or DTC Participants.
---------------------------------------------------------------------------
8. Shares may be redeemed only if tendered in Creation Units.
Redemption requests must be placed by or through an Authorized
Participant. Applicants currently contemplate that Creation Units of
the Initial Funds will be redeemed principally in-kind (together with a
Cash Balancing Amount).\9\ To the extent a Fund utilizes in-kind
redemptions, Shares in Creation Units will be redeemable on any
Business Day, which is defined to include any day that the Trust is
open for business as required by section 22(e) of the Act, for the
Redemption Instruments, which will be the same as the Deposit
Instruments deposited by investors purchasing Creation Units on the
same day, except for the limited exceptions noted below. The redeeming
investor will also usually pay to the Fund a Transaction Fee.
---------------------------------------------------------------------------
\9\ To the extent consistent with other investment limitations,
the Funds may invest in mortgage- or asset-backed securities,
including a ``to-be-announced transaction'' or ``TBA Transactions''.
Each Fund intends to substitute a cash-in-lieu amount to replace any
Deposit Instrument or Redemption Instrument that is a TBA
Transaction. A TBA Transaction is a method of trading mortgage-
backed securities. In a TBA Transaction, the buyer and seller agree
upon general trade parameters such as agency, settlement date, par
amount and price. The actual pools delivered generally are
determined two days prior to the settlement date. The amount of
substituted cash in the case of TBA Transactions will be equivalent
to the value of the TBA Transaction listed as a Deposit Instrument
or Redemption Instrument.
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9. Applicants state that in accepting Deposit Instruments and
satisfying redemptions with Redemption Instruments, the Funds must
comply with the federal securities laws, including that the Deposit
Instruments and Redemption Instruments are sold in transactions that
would be exempt from registration under the Securities Act.\10\ To the
extent in-kind purchases and redemptions are utilized, the Deposit
Instruments and Redemption Instruments will correspond pro rata to the
Fund portfolio, except that there may be minor differences between a
basket of Deposit Instruments or Redemption Instruments and a true pro
rata slice of a Fund's portfolio solely when (a) It is impossible to
break up bonds beyond certain minimum sizes needed for transfer and
settlement or, (b) in the case of equity securities, rounding is
necessary to eliminate fractional shares or lots that are not tradeable
round lots. With respect to the Funds that hold short positions,
Deposit Instruments and Redemption Instruments will correspond pro rata
to the long Portfolio Securities of the relevant Fund. There may be
minor differences between a basket of Deposit Instruments or Redemption
Instruments and a true pro rata slice of the long Portfolio Securities
solely to the extent necessary (a) Because it is impossible to break up
bonds beyond certain minimum sizes needed for transfer and settlement,
or (b) because, in the case of equity securities, rounding is necessary
to eliminate fractional shares or lots that are not tradable round
lots.\11\ Because they cannot be transferred in-kind, short positions
will not be included in the Deposit Securities and Redemption
Securities for a Fund.
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\10\ In accepting Deposit Instruments and satisfying redemptions
with Redemption Instruments that are restricted securities eligible
for resale pursuant to rule 144A under the Securities Act, the Funds
will comply with the conditions of Rule 144A.
\11\ A tradeable round lot for an equity security will be the
standard unit of trading in that particular type of security in its
primary market.
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10. Neither the Trust nor any Fund will be marketed or otherwise
held out as a ``mutual fund.'' Instead, each Fund will be marketed as
an ``actively-managed exchange-traded fund.'' Any advertising material
where features of obtaining, buying or selling Creation Units are
described or where there is reference to redeemability will prominently
disclose that Shares are not individually redeemable and that owners of
Shares may acquire Shares from a Fund and tender those Shares for
redemption to a Fund in Creation Units only.
11. The Funds' Web site, which will be publicly available prior to
the public offering of Shares, will include the Prospectus and
additional quantitative information updated on a daily basis,
including, on a per Share basis for each Fund, the prior Business Day's
NAV and the market closing price or mid-point of the bid/ask spread at
the time of the calculation of such NAV (``Bid/Ask Price''), and a
calculation of the premium or discount of the market closing price or
Bid/Ask Price against such NAV. On each Business Day, before
commencement of trading in Shares on the Stock Exchange, the Fund will
disclose on its Web site the identities and quantities of the Portfolio
Instruments and other assets held by the Fund that will form the basis
for the
[[Page 66099]]
Fund's calculation of NAV at the end of the Business Day.\12\
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\12\ Applicants note that under accounting procedures followed
by the Funds, trades made on the prior Business Day (``T'') will be
booked and reflected in NAV on the current Business Day (``T+1'').
Accordingly, the Funds will be able to disclose at the beginning of
the Business Day the portfolio that will form the basis for the NAV
calculation at the end of the Business Day.
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Applicants' Legal Analysis
1. Applicants request an order under section 6(c) of 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 (B) of the Act.
2. Section 6(c) of the Act provides that the Commission may exempt
any person, security or transaction, or any class of persons,
securities or transactions, from any provisions of the Act, 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 17(b) of the Act authorizes the Commission to exempt a proposed
transaction from section 17(a) of the Act if evidence establishes that
the terms of the transaction, including the consideration to be paid or
received, are reasonable and fair and do not involve overreaching on
the part of any person concerned, and the proposed transaction is
consistent with the policies of the registered investment company and
the general provisions of the Act. Section 12(d)(1)(J) of the Act
provides that the Commission may exempt any person, security, or
transaction, or any class or classes of persons, securities or
transactions, from any provision of section 12(d)(1) if the exemption
is consistent with the public interest and the protection of investors.
Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an ``open-end company'' as a
management investment company that is offering for sale or has
outstanding any redeemable security of which it is the issuer. Section
2(a)(32) of the Act defines a redeemable security as any security,
other than short-term paper, under the terms of which the holder, upon
its presentation to the issuer, is entitled to receive approximately a
proportionate share of the issuer's current net assets, or the cash
equivalent. Because Shares will not be individually redeemable,
applicants request an order that would permit the Trust to register as
an open-end management investment company and redeem Shares in Creation
Units only. Applicants state that investors may purchase Shares in
Creation Units from each Fund and redeem Creation Units from each Fund.
Applicants further state that because the market price of Creation
Units will be disciplined by arbitrage opportunities, investors should
be able to sell Shares in the secondary market at prices that do not
vary substantially from their NAV.
Section 22(d) of the Act and Rule 22c-1 Under the Act
4. Section 22(d) of the Act, among other things, prohibits a dealer
from selling a redeemable security that is currently being offered to
the public by or through a principal underwriter, except at a current
public offering price described in the prospectus. Rule 22c-1 under the
Act generally requires that a dealer selling, redeeming, or
repurchasing a redeemable security do so only at a price based on its
NAV. Applicants state that secondary market trading in Shares will take
place at negotiated prices, not at a current offering price described
in the Prospectus, and not at a price based on NAV. Thus, purchases and
sales of Shares in the secondary market will not comply with section
22(d) of the Act and rule 22c-1 under the Act. Applicants request an
exemption under section 6(c) from these provisions.
5. Applicants assert that the concerns sought to be addressed by
section 22(d) of the Act and rule 22c-1 under the Act with respect to
pricing are equally satisfied by the proposed method of pricing Shares.
Applicants maintain that while there is little legislative history
regarding section 22(d), its provisions, as well as those of rule 22c-
1, appear to have been designed to (a) Prevent dilution caused by
certain riskless-trading schemes by principal underwriters and contract
dealers, (b) prevent unjust discrimination or preferential treatment
among buyers resulting from sales at different prices, and (c) assure
an orderly distribution system of investment company shares by
eliminating price competition from Brokers offering shares at less than
the published sales price and repurchasing shares at more than the
published redemption price.
6. Applicants believe that none of these purposes will be thwarted
by permitting Shares to trade in the secondary market at negotiated
prices. Applicants state that (a) Secondary market trading in Shares
does not involve the Funds as parties and cannot result in dilution of
an investment in Shares, and (b) to the extent different prices exist
during a given trading day, or from day to day, such variances occur as
a result of third-party market forces, such as supply and demand.
Therefore, applicants assert that secondary market transactions in
Shares will not lead to discrimination or preferential treatment among
purchasers. Finally, applicants contend that the proposed distribution
system will be orderly because arbitrage activity should ensure that
the difference between the market price of Shares and their NAV remains
narrow.
Section 22(e) of the Act
7. Section 22(e) of the Act generally prohibits a registered
investment company from suspending the right of redemption or
postponing the date of payment of redemption proceeds for more than
seven days after the tender of a security for redemption. Applicants
observe that settlement of redemptions of Creation Units of Funds
holding non-U.S. investments (``Global Funds'') is contingent not only
on the settlement cycle of the U.S. securities markets but also on the
delivery cycles present in foreign markets in which those Funds invest.
Applicants have been advised that, under certain circumstances, the
delivery cycles for transferring Portfolio Instruments to redeeming
investors, coupled with local market holiday schedules, will require a
delivery process of up to 14 calendar days. Applicants therefore
request relief from section 22(e) in order to provide payment or
satisfaction of redemptions within the maximum number of calendar days
required for such payment or satisfaction in the principal local
markets where transactions in the Portfolio Instruments of each Global
Fund customarily clear and settle, but in all cases no later than 14
calendar days following the tender of a Creation Unit. With respect to
Future Funds that are Global Funds, applicants seek the same relief
from section 22(e) only to the extent that circumstances exist similar
to those described in the application. Except as disclosed in the SAI
for a Fund, deliveries of redemption proceeds for Global Funds are
expected to be made within seven days.\13\
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\13\ Rule 15c6-1 under the Exchange Act requires that most
securities transactions be settled within three business days of the
trade date. Applicants acknowledge that no relief obtained from the
requirements of section 22(e) will affect any obligations that they
have under rule 15c6-1.
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8. Applicants submit that Congress adopted section 22(e) to prevent
unreasonable, undisclosed or unforeseen delays in the actual payment
[[Page 66100]]
of redemption proceeds. Applicants state that allowing redemption
payments for Creation Units of a Fund to be made within a maximum of 14
calendar days would not be inconsistent with the spirit and intent of
section 22(e). Applicants state the SAI will disclose those local
holidays (over the period of at least one year following the date of
the SAI), if any, that are expected to prevent the delivery of
redemption proceeds in seven calendar days and the maximum number of
days needed to deliver the proceeds for each affected Global Fund.
9. Applicants are not seeking relief from section 22(e) with
respect to Global Funds that do not effect creations or redemptions in-
kind.
Section 12(d)(1) of the Act
10. Section 12(d)(1)(A) of the Act prohibits a registered
investment company from acquiring shares of an investment company if
the securities represent more than 3% of the total outstanding voting
stock of the acquired company, more than 5% of the total assets of the
acquiring company, or, together with the securities of any other
investment companies, more than 10% of the total assets of the
acquiring company. Section 12(d)(1)(B) of the Act prohibits a
registered open-end investment company, its principal underwriter, or
any other broker or dealer from selling its shares to another
investment company if the sale will cause the acquiring company to own
more than 3% of the acquired company's voting stock, or if the sale
will cause more than 10% of the acquired company's voting stock to be
owned by investment companies generally.
11. Applicants request relief to permit Investing Funds (as defined
below) to acquire Shares in excess of the limits in section 12(d)(1)(A)
of the Act and to permit the Funds, their principal underwriters and
any Brokers to sell Shares to Investing Funds in excess of the limits
in section 12(d)(1)(B) of the Act. Applicants request that these
exemptions apply to: (a) Any Fund that is currently or subsequently
part of the same ``group of investment companies'' as the Initial Funds
within the meaning of section 12(d)(1)(G)(ii) of the Act as well as any
principal underwriter for the Funds and any Brokers selling Shares of a
Fund to an Investing Fund; and (b) each management investment company
or unit investment trust registered under the Act that is not part of
the same ``group of investment companies'' as the Funds and that enters
into a FOF Participation Agreement (as defined below) with a Fund (such
management investment companies are referred to herein as ``Investing
Management Companies,'' such unit investment trusts are referred to
herein as ``Investing Trusts,'' and Investing Management Companies and
Investing Trusts together are referred to herein as ``Investing
Funds'').\14\ Investing Funds do not include the Funds. Each Investing
Trust will have a sponsor (``Sponsor'') and each Investing Management
Company will have an investment adviser within the meaning of section
2(a)(20)(A) of the Act (``Investing Fund Advisor'') that does not
control, is not controlled by or under common control with the Advisor.
Each Investing Management Company may also have one or more investment
advisers within the meaning of section 2(a)(20)(B) of the Act (each, an
``Investing Fund Sub-Advisor''). Each Investing Fund Advisor and any
Investing Fund Sub-Advisor will be registered as an investment adviser
under the Advisers Act.
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\14\ Applicants anticipate that there may be Investing Funds
that are not part of the same group of investment companies as the
Funds but may be subadvised by an Advisor.
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12. Applicants submit that the proposed conditions to the requested
relief are designed to address the concerns underlying the limits in
section 12(d)(1), which include concerns about undue influence,
excessive layering of fees and overly complex structures.
13. Applicants propose a condition to prohibit an Investing Fund or
Investing Fund Affiliate \15\ from causing an investment by an
Investing Fund in a Fund to influence the terms of services or
transactions between an Investing Fund or an Investing Fund Affiliate
and the Fund or Fund Affiliate. Applicants propose a condition to limit
the ability of the Investing Fund Advisor, or Sponsor, any person
controlling, controlled by or under common control with such Advisor or
Sponsor, and any investment company or issuer that would be an
investment company but for sections 3(c)(1) or 3(c)(7) of the Act that
is advised or sponsored by the Investing Fund Advisor, the Sponsor, or
any person controlling, controlled by, or under common control with
such Advisor or Sponsor (``Investing Fund's Advisory Group'') from
(individually or in the aggregate) controlling a Fund within the
meaning of section 2(a)(9) of the Act. The same prohibition would apply
to any Investing Fund Sub-Advisor, any person controlling, controlled
by, or under common control with the Investing Fund Sub-Advisor, and
any investment company or issuer that would be an investment company
but for sections 3(c)(1) or 3(c)(7) of the Act (or portion of such
investment company or issuer) advised or sponsored by the Investing
Fund Sub-Advisor or any person controlling, controlled by or under
common control with the Investing Fund Sub-Advisor (``Investing Fund's
Sub-Advisory Group'').
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\15\ An ``Investing Fund Affiliate'' is defined as the Investing
Fund Advisor, Investing Fund Sub-Advisor, Sponsor, promoter and
principal underwriter of an Investing Fund, and any person
controlling, controlled by or under common control with any of these
entities. A ``Fund Affiliate'' is defined as an investment adviser,
promoter or principal underwriter of a Fund and any person
controlling, controlled by or under common control with any of these
entities.
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14. Applicants propose other conditions to limit the potential for
an Investing Fund and certain affiliates of an Investing Fund
(including Underwriting Affiliates) to exercise undue influence over a
Fund and certain of its affiliates, including that no Investing Fund or
Investing Fund Affiliate (except to the extent it is acting in its
capacity as an investment adviser to a Fund) will cause a Fund to
purchase a security in an offering of securities during the existence
of an underwriting or selling syndicate of which a principal
underwriter is an Underwriting Affiliate (``Affiliated Underwriting'').
An ``Underwriting Affiliate'' is a principal underwriter in any
underwriting or selling syndicate that is an officer, director, member
of an advisory board, Investing Fund Advisor, Investing Fund Sub-
Advisor, employee or Sponsor of the Investing Fund, or a person of
which any such officer, director, member of an advisory board,
Investing Fund Advisor or Investing Fund Sub-Advisor, employee or
Sponsor is an affiliated person. An Underwriting Affiliate does not
include any person whose relationship to the Fund is covered by section
10(f) of the Act.
15. Applicants propose several conditions to address the concerns
regarding layering of fees and expenses. Applicants note that the board
of directors or trustees of any Investing Management Company, including
a majority of the directors or trustees who are not ``interested
persons'' within the meaning of section 2(a)(19) of the Act
(``disinterested directors or trustees''), will be required to find
that the advisory fees charged under the contract are based on services
provided that will be in addition to, rather than duplicative of,
services provided under the advisory contract of any Fund in which the
Investing Management Company may invest. In addition, an Investing Fund
Advisor, trustee of an Investing Trust
[[Page 66101]]
(``Trustee'') or Sponsor, as applicable, will waive fees otherwise
payable to it by the Investing Fund in an amount at least equal to any
compensation (including fees received pursuant to any plan adopted by a
Fund under rule 12b-1 under the Act) received from a Fund by the
Investing Fund Advisor, Trustee or Sponsor or an affiliated person of
the Investing Fund Advisor, Trustee or Sponsor, other than any advisory
fees paid to the Investing Fund Advisor, Trustee or Sponsor or its
affiliated person by a Fund, in connection with the investment by the
Investing Fund in the Fund. Applicants also propose a condition to
prevent any sales charges or service fees on shares of an Investing
Fund from exceeding the limits applicable to a fund of funds set forth
in NASD Conduct Rule 2830.\16\
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\16\ Any references to NASD Conduct Rule 2830 include any
successor or replacement rule to NASD Conduct Rule that may be
adopted by FINRA.
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16. Applicants submit that the proposed arrangement will not create
an overly complex fund structure. Applicants note that a Fund will be
prohibited from acquiring securities of any investment company or
company relying on sections 3(c)(1) or 3(c)(7) of the Act in excess of
the limits contained in section 12(d)(1)(A) of the Act, except to the
extent permitted by exemptive relief from the Commission permitting the
Fund to purchase shares of other investment companies for short-term
cash management purposes.
17. To ensure that the Investing Funds understand and comply with
the terms and conditions of the requested order, any Investing Fund
that intends to invest in a Fund in reliance on the requested order
will be required to enter into a participation agreement (``FOF
Participation Agreement'') with the Fund. The FOF Participation
Agreement will include an acknowledgment from the Investing Fund that
it may rely on the order only to invest in the Funds and not in any
other investment company.
Sections 17(a)(1) and (2) of the Act
18. Section 17(a) of the Act generally prohibits an affiliated
person of a registered investment company, or an affiliated person of
such a person (``second tier affiliate''), from selling any security to
or purchasing any security from the company. Section 2(a)(3) of the Act
defines ``affiliated person'' to include any person directly or
indirectly owning, controlling, or holding with power to vote, 5% or
more of the outstanding voting securities of the other person and any
person directly or indirectly controlling, controlled by, or under
common control with, the other person. Section 2(a)(9) of the Act
defines ``control'' as the power to exercise a controlling influence
over the management or policies of a company and provides that a
control relationship will be presumed where one person owns more than
25% of another person's voting securities. Each Fund may be deemed to
be controlled by an Advisor and hence affiliated persons of each other.
In addition, the Funds may be deemed to be under common control with
any other registered investment company (or series thereof) advised by
an Advisor (an ``Affiliated Fund'').
19. Applicants request an exemption under sections 6(c) and 17(b)
of the Act from sections 17(a)(1) and 17(a)(2) of the Act to permit in-
kind purchases and redemptions of Creation Units by persons that are
affiliated persons or second tier affiliates of the Funds solely by
virtue of one or more of the following: (a) Holding 5% or more, or in
excess of 25% of the outstanding Shares of one or more Funds; (b)
having an affiliation with a person with an ownership interest
described in (a); or (c) holding 5% or more, or more than 25% of the
Shares of one or more Affiliated Funds.\17\ Applicants also request an
exemption in order to permit a Fund to sell its Shares to and redeem
its Shares from, and engage in the in-kind transactions that would
accompany such sales and redemptions with, certain Investing Funds of
which the Funds are affiliated persons or a second-tier affiliates.\18\
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\17\ Applicants are not seeking relief from section 17(a) for,
and the requested relief will not apply to, transactions where a
Fund could be deemed an affiliated person, or an affiliated person
of an affiliated person, of an Investing Fund because an investment
adviser to the Funds is also an investment adviser to an Investing
Fund.
\18\ Applicants expect most Investing Funds will purchase Shares
in the secondary market and will not purchase Creation Units
directly from a Fund. To the extent that purchases and sales of
Shares occur in the secondary market and not through principal
transactions directly between an Investing Fund and a Fund, relief
from section 17(a) would not be necessary. However, the requested
relief would apply to direct sales of Shares in Creation Units by a
Fund to an Investing Fund and redemptions of those Shares. The
requested relief is also intended to cover the in-kind transactions
that may accompany such sales and redemptions.
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20. Applicants assert that no useful purpose would be served by
prohibiting such affiliated persons from making in-kind purchases or
in-kind redemptions of Shares of a Fund in Creation Units. Absent the
unusual circumstances discussed in the application, the Deposit
Instruments and Redemption Instruments available for a Fund will be the
same for all purchases and redeemers, respectively, and will correspond
pro rata to the Fund's portfolio instruments. Both the deposit
procedures for in-kind purchases of Creation Units and the redemption
procedures for in-kind redemptions will be effected in exactly the same
manner for all purchases and redemptions. Deposit Instruments and
Redemption Instruments will be valued in the same manner as those
Portfolio Instruments currently held by the relevant Funds. Therefore,
applicants state that the in-kind purchases and redemptions create no
opportunity for affiliated persons or the Applicants to effect a
transaction detrimental to other holders of Shares of that Fund.
Applicants do not believe that in-kind purchases and redemptions will
result in abusive self-dealing or overreaching of the Fund.
21. Applicants also submit that the sale of Shares to and
redemption of Shares from an Investing Fund meets the standards for
relief under sections 17(b) and 6(c) of the Act. Applicants note that
any consideration paid for the purchase or redemption of Shares
directly from a Fund will be based on the NAV of the Fund in accordance
with policies and procedures set forth in the Fund's registration
statement.\19\ Absent the unusual circumstances discussed in the
application, the Deposit Instruments and Redemption Instruments
available for a Fund will be the same for all purchases and redeemers,
respectively, and will correspond pro rata to the Fund's portfolio
instruments. Applicants also state that the proposed transactions are
consistent with the general purposes of the Act and appropriate in the
public interest.
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\19\ Applicants acknowledge that the receipt of compensation by
(a) An affiliated person of an Investing Fund, or an affiliated
person of such person, for the purchase by the Investing Fund of
Shares of the Fund or (b) an affiliated person of a Fund, or an
affiliated person of such person, for the sale by the Fund of its
Shares to an Investing Fund, may be prohibited by section 17(e)(1)
of the Act. The FOF Participation Agreement also will include this
acknowledgment.
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Applicants' Conditions:
Applicants agree that any order of the Commission granting the
requested relief will be subject to the following conditions:
A. Actively-Managed Exchange-Traded Fund Relief
1. As long as a Fund operates in reliance on the requested order,
the Shares of the Fund will be listed on a Stock Exchange.
2. Neither the Trust nor any Fund will be advertised or marketed as
an open-end investment company or a mutual fund. Any advertising
material that describes the purchase or sale of
[[Page 66102]]
Creation Units or refers to redeemability will prominently disclose
that the Shares are not individually redeemable and that owners of the
Shares may acquire those Shares from the Fund and tender those Shares
for redemption to the Fund in Creation Units only.
3. The Web site for the Funds, which is and will be publicly
accessible at no charge, will contain, on a per Share basis, for each
Fund the prior Business Day's NAV and the market closing price or Bid/
Ask Price, and a calculation of the premium or discount of the market
closing price or Bid/Ask Price against such NAV.
4. On each Business Day, before commencement of trading in Shares
on the Stock Exchange, the Fund will disclose on its Web site the
identities and quantities of the Portfolio Instruments and other assets
held by the Fund that will form the basis for the Fund's calculation of
NAV at the end of the Business Day.
5. The Advisor or any Subadvisor, directly or indirectly, will not
cause any Authorized Participant (or any investor on whose behalf an
Authorized Participant may transact with the Fund) to acquire any
Deposit Instrument for the Fund through a transaction in which the Fund
could not engage directly.
6. The requested relief to permit ETF operations will expire on the
effective date of any Commission rule under the Act that provides
relief permitting the operation of actively-managed exchange-traded
funds.
B. Section 12(d)(1) Relief
1. The members of the Investing Fund's Advisory Group will not
control (individually or in the aggregate) a Fund within the meaning of
section 2(a)(9) of the Act. The members of the Investing Fund's Sub-
Advisory Group will not control (individually or in the aggregate) a
Fund within the meaning of section 2(a)(9) of the Act. If, as a result
of a decrease in the outstanding voting securities of a Fund, the
Investing Fund's Advisory Group or the Investing Fund's Sub-Advisory
Group, each in the aggregate, becomes a holder of more than 25 percent
of the outstanding voting securities of a Fund, it will vote its Shares
of the Fund in the same proportion as the vote of all other holders of
the Fund's Shares. This condition does not apply to the Investing
Fund's Sub-Advisory Group with respect to a Fund for which the
Investing Fund Sub-Advisor or a person controlling, controlled by or
under common control with the Investing Fund Sub-Advisor acts as the
investment adviser within the meaning of section 2(a)(20)(A) of the
Act.
2. No Investing Fund or Investing Fund Affiliate will cause any
existing or potential investment by the Investing Fund in a Fund to
influence the terms of any services or transactions between the
Investing Fund or an Investing Fund Affiliate and the Fund or a Fund
Affiliate.
3. The board of directors or trustees of an Investing Management
Company, including a majority of the disinterested directors or
trustees, will adopt procedures reasonably designed to assure that the
Investing Fund Advisor and any Investing Fund Sub-Advisor are
conducting the investment program of the Investing Management Company
without taking into account any consideration received by the Investing
Management Company or an Investing Fund Affiliate from a Fund or a Fund
Affiliate in connection with any services or transactions.
4. Once an investment by an Investing Fund in Shares of a Fund
exceeds the limit in section 12(d)(1)(A)(i) of the Act, the Board of a
Fund, including a majority of the disinterested Board members, will
determine that any consideration paid by the Fund to the Investing Fund
or an Investing Fund Affiliate in connection with any services or
transactions: (a) Is fair and reasonable in relation to the nature and
quality of the services and benefits received by the Fund; (b) is
within the range of consideration that the Fund would be required to
pay to another unaffiliated entity in connection with the same services
or transactions; and (c) does not involve overreaching on the part of
any person concerned. This condition does not apply with respect to any
services or transactions between a Fund and its investment adviser(s),
or any person controlling, controlled by or under common control with
such investment adviser(s).
5. The Investing Fund Advisor, or Trustee or Sponsor, as
applicable, will waive fees otherwise payable to it by the Investing
Fund in an amount at least equal to any compensation (including fees
received pursuant to any plan adopted by a Fund under rule 12b-1 under
the Act) received from a Fund by the Investing Fund Advisor, or Trustee
or Sponsor, or an affiliated person of the Investing Fund Advisor, or
Trustee or Sponsor, other than any advisory fees paid to the Investing
Fund Advisor, or Trustee, or Sponsor, or its affiliated person by the
Fund, in connection with the investment by the Investing Fund in the
Fund. Any Investing Fund Sub-Advisor will waive fees otherwise payable
to the Investing Fund Sub-Advisor, directly or indirectly, by the
Investing Management Company in an amount at least equal to any
compensation received from a Fund by the Investing Fund Sub-Advisor, or
an affiliated person of the Investing Fund Sub-Advisor, other than any
advisory fees paid to the Investing Fund Sub-Advisor or its affiliated
person by the Fund, in connection with the investment by the Investing
Management Company in the Fund made at the direction of the Investing
Fund Sub-Advisor. In the event that the Investing Fund Sub-Advisor
waives fees, the benefit of the waiver will be passed through to the
Investing Management Company.
6. No Investing Fund or Investing Fund Affiliate (except to the
extent it is acting in its capacity as an investment adviser to a Fund)
will cause a Fund to purchase a security in an Affiliated Underwriting.
7. The Board of the Fund, including a majority of the disinterested
Board members, will adopt procedures reasonably designed to monitor any
purchases of securities by the Fund in an Affiliated Underwriting, once
an investment by an Investing Fund in the securities of the Fund
exceeds the limit of section 12(d)(1)(A)(i) of the Act, including any
purchases made directly from an Underwriting Affiliate. The Board will
review these purchases periodically, but no less frequently than
annually, to determine whether the purchases were influenced by the
investment by the Investing Fund in the Fund. The Board will consider,
among other things: (a) Whether the purchases were consistent with the
investment objectives and policies of the Fund; (b) how the performance
of securities purchased in an Affiliated Underwriting compares to the
performance of comparable securities purchased during a comparable
period of time in underwritings other than Affiliated Underwritings or
to a benchmark such as a comparable market index; and (c) whether the
amount of securities purchased by the Fund in Affiliated Underwritings
and the amount purchased directly from an Underwriting Affiliate have
changed significantly from prior years. The Board will take any
appropriate actions based on its review, including, if appropriate, the
institution of procedures designed to assure that purchases of
securities in Affiliated Underwritings are in the best interest of
shareholders.
8. Each Fund will maintain and preserve permanently in an easily
accessible place a written copy of the procedures described in the
preceding condition, and any modifications to such procedures, and will
maintain and
[[Page 66103]]
preserve for a period of not less than six years from the end of the
fiscal year in which any purchase in an Affiliated Underwriting
occurred, the first two years in an easily accessible place, a written
record of each purchase of securities in Affiliated Underwritings once
an investment by an Investing Fund in the securities of the Fund
exceeds the limit of section 12(d)(1)(A)(i) of the Act, setting forth
from whom the securities were acquired, the identity of the
underwriting syndicate's members, the terms of the purchase, and the
information or materials upon which the Board's determinations were
made.
9. Before investing in a Fund in excess of the limits in section
12(d)(1)(A), an Investing Fund will execute a FOF Participation
Agreement with the Fund stating that their respective boards of
directors or trustees and their investment advisers, or Trustee and
Sponsor, as applicable, understand the terms and conditions of the
order, and agree to fulfill their responsibilities under the order. At
the time of its investment in shares of a Fund in excess of the limit
in section 12(d)(1)(A)(i), an Investing Fund will notify the Fund of
the investment. At such time, the Investing Fund will also transmit to
the Fund a list of the names of each Investing Fund Affiliate and
Underwriting Affiliate. The Investing Fund will notify the Fund of any
changes to the list as soon as reasonably practicable after a change
occurs. The Fund and the Investing Fund will maintain and preserve a
copy of the order, the FOF Participation Agreement, and the list with
any updated information for the duration of the investment and for a
period of not less than six years thereafter, the first two years in an
easily accessible place.
10. Before approving any advisory contract under section 15 of the
Act, the board of directors or trustees of each Investing Management
Company, including a majority of the disinterested directors or
trustees, will find that the advisory fees charged under such contract
are based on services provided that will be in addition to, rather than
duplicative of, the services provided under the advisory contract(s) of
any Fund in which the Investing Management Company may invest. These
findings and their basis will be recorded fully in the minute books of
the appropriate Investing Management Company.
11. Any sales charges and/or service fees charged with respect to
shares of an Investing Fund will not exceed the limits applicable to a
fund of funds as set forth in NASD Conduct Rule 2830.
12. No Fund relying on this section 12(d)(1) relief will acquire
securities of any investment company or company relying on section
3(c)(1) or 3(c)(7) of the Act in excess of the limits contained in
section 12(d)(1)(A) of the Act, except to the extent permitted by
exemptive relief from the Commission permitting the Fund to purchase
shares of other investment companies for short-term cash management
purposes.
For the Commission, by the Division of Investment Management,
under delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2011-27531 Filed 10-24-11; 8:45 am]
BILLING CODE 8011-01-P