Rand Capital Corporation, et al.; Notice of Application, 6156-6160 [2012-2670]
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annually, to determine whether the
purchases were influenced by the
investment by the Fund of Funds in the
Unaffiliated Investment Company. The
Board of the Unaffiliated Investment
Company will consider, among other
things, (a) whether the purchases were
consistent with the investment
objectives and policies of the
Unaffiliated Investment Company; (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 Unaffiliated
Investment Company in Affiliated
Underwritings and the amount
purchased directly from an
Underwriting Affiliate have changed
significantly from prior years. The
Board of the Unaffiliated Investment
Company 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 interests
of shareholders.
7. Each Unaffiliated Investment
Company shall 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 shall maintain and
preserve for a period 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 an Affiliated Underwriting
once an investment by a Fund of Funds
in the securities of an Unaffiliated
Investment Company exceeds the limit
of section 12(d)(1)(A)(i) of the Act,
setting forth the: (a) Party from whom
the securities were acquired, (b) identity
of the underwriting syndicate’s
members, (c) terms of the purchase, and
(d) information or materials upon which
the determinations of the Board of the
Unaffiliated Investment Company were
made.
8. Prior to its investment in shares of
an Unaffiliated Investment Company in
excess of the limit in section
12(d)(1)(A)(i) of the Act, the Fund of
Funds and the Unaffiliated Investment
Company will execute a Participation
Agreement stating, without limitation,
that their Boards and their investment
advisers understand the terms and
conditions of the order and agree to
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fulfill their responsibilities under the
order. At the time of its investment in
shares of an Unaffiliated Investment
Company in excess of the limit in
section 12(d)(1)(A)(i), a Fund of Funds
will notify the Unaffiliated Investment
Company of the investment. At such
time, the Fund of Funds will also
transmit to the Unaffiliated Investment
Company a list of the names of each
Fund of Funds Affiliate and
Underwriting Affiliate. The Fund of
Funds will notify the Unaffiliated
Investment Company of any changes to
the list of the names as soon as
reasonably practicable after a change
occurs. The Unaffiliated Investment
Company and the Fund of Funds will
maintain and preserve a copy of the
order, the 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.
9. Before approving any advisory
contract under section 15 of the Act, the
Board of each Fund of Funds, including
a majority of the Independent Trustees,
shall find that the advisory fees charged
under such advisory contract are based
on services provided that are in addition
to, rather than duplicative of, services
provided under the advisory contract(s)
of any Underlying Fund in which the
Fund of Funds may invest. Such finding
and the basis upon which the finding
was made will be recorded fully in the
minute books of the appropriate Fund of
Funds.
10. The Adviser will waive fees
otherwise payable to it by a Fund of
Funds in an amount at least equal to any
compensation (including fees received
pursuant to any plan adopted by an
Unaffiliated Investment Company under
rule 12b–1 under the Act) received from
an Unaffiliated Fund by the Adviser, or
an affiliated person of the Adviser, other
than any advisory fees paid to the
Adviser or its affiliated person by an
Unaffiliated Investment Company, in
connection with the investment by the
Fund of Funds in the Unaffiliated Fund.
Any Subadviser will waive fees
otherwise payable to the Subadviser,
directly or indirectly, by the Fund of
Funds in an amount at least equal to any
compensation received by the
Subadviser, or an affiliated person of the
Subadviser, from an Unaffiliated Fund,
other than any advisory fees paid to the
Subadviser or its affiliated person by an
Unaffiliated Investment Company, in
connection with the investment by the
Fund of Funds in the Unaffiliated Fund
made at the direction of the Subadviser.
In the event that the Subadviser waives
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fees, the benefit of the waiver will be
passed through to the Fund of Funds.
11. No Underlying Fund will acquire
securities of any other 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 that such Underlying Fund: (a)
receives securities of another
investment company as a dividend or as
a result of a plan of reorganization of a
company (other than a plan devised for
the purpose of evading section 12(d)(1)
of the Act); or (b) acquires (or is deemed
to have acquired) securities of another
investment company pursuant to
exemptive relief from the Commission
permitting such Underlying Fund to (i)
acquire securities of one or more
investment companies for short-term
cash management purposes, or (ii)
engage in interfund borrowing and
lending transactions.
12. Any sales charges and/or service
fees charged with respect to shares of a
Fund of Funds will not exceed the
limits applicable to fund of funds set
forth in NASD Conduct Rule 2830.
Other Investments by Same Group
Funds of Funds
Applicants agree that the relief to
permit Same Group Funds of Funds to
invest in Other Investments shall be
subject to the following condition:
13. Applicants will comply with all
provisions of rule 12d1–2 under the Act,
except for paragraph (a)(2), to the extent
that it restricts any Same Group Fund of
Funds from investing in Other
Investments as described in the
application.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2012–2733 Filed 2–6–12; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
29941; 812–13634]
Rand Capital Corporation, et al.; Notice
of Application
February 1, 2012.
Securities and Exchange
Commission (the ‘‘Commission’’).
ACTION: Notice of an application for an
order under sections 6(c), 12(d)(1)(J),
and 57(c) of the Investment Company
Act of 1940 (‘‘Act’’) granting exemptions
from sections 12(d)(1)(A) and (C), 18(a),
AGENCY:
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21(b), 57(a)(1)–(a)(3), and 61(a) of the
Act; under section 57(i) of the Act and
rule 17d–1 under the Act to permit
certain joint transactions otherwise
prohibited by section 57(a)(4) of the Act;
and under section 12(h) of the Securities
Exchange Act of 1934 (‘‘Exchange Act’’)
granting an exemption from section
13(a) of the Exchange Act.
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. Rand, a New York corporation, is
an internally managed, non-diversified,
APPLICANTS: Rand Capital Corporation
closed-end investment company that
(‘‘Rand’’) and Rand Capital SBIC, Inc.
has elected to be regulated as a BDC
(‘‘Rand SBIC’’).
under the Act.1 Rand’s principal
SUMMARY OF APPLICATION: Applicants
business is to make venture capital
request an order permitting a parent
investments in small, early-stage and
business development company
developing enterprises. Rand’s principal
(‘‘BDC’’) and its wholly-owned small
objective is long-term capital
business investment company (‘‘SBIC’’)
appreciation. Rand typically invests in
subsidiary and any future whollydebt securities and concurrently
owned BDC subsidiaries (‘‘Future
acquires equity interests in the form of
Subsidiaries’’) to engage in certain
stock, warrants or stock options or the
transactions that otherwise would be
right to convert debt securities into
permitted if such parent BDC and its
stock. Rand has a six member board of
subsidiaries were one company and to
directors (‘‘Rand Board’’), five of whom
file certain reports on a consolidated
are not ‘‘interested persons’’ of Rand
basis, and permitting such parent BDC
within the meaning of section 2(a)(19) of
to adhere to a modified asset coverage
the Act. The Rand Board appoints
requirement.
Rand’s president and chief executive
DATES: Filing Dates: The application was officer and its executive vice president
filed on February 6, 2009 and amended
and chief financial officer (collectively,
on August 5, 2009, September 8, 2011
the ‘‘Principal Officers’’). Subject to the
and January 10, 2012.
oversight of the Rand Board, the
Hearing or Notification of Hearing: An Principal Officers make all investment
order granting the application will be
decisions for Rand.
issued unless the Commission orders a
2. Rand SBIC, a New York
hearing. Interested persons may request
corporation, is an SBIC licensed by the
a hearing by writing to the
Small Business Administration (‘‘SBA’’)
Commission’s Secretary and serving
to operate under the Small Business
applicants with a copy of the request,
Investment Act of 1958 (‘‘SBA Act’’).
personally or by mail. Hearing requests
Rand SBIC is registered as an
should be received by the Commission
investment company under the Act and
by 5:30 pm on February 27, 2012, and
will elect to be regulated as a BDC prior
should be accompanied by proof of
to relying on the requested order. Rand
service on applicants, in the form of an
SBIC has the same investment purposes
affidavit or, for lawyers, a certificate of
and will invest in the same kinds of
service. Hearing requests should state
securities as Rand.
the nature of the writer’s interest, the
3. Rand SBIC is a wholly-owned
reason for the request, and the issues
subsidiary of Rand, which owns all of
contested. Persons who wish to be
its outstanding voting stock. The Rand
notified of a hearing may request
Board annually elects the same persons
notification by writing to the
who comprise the Rand Board to serve
Commission’s Secretary.
on the board of directors of Rand SBIC.
ADDRESSES: Secretary, U.S. Securities
Pursuant to a by-law provision required
and Exchange Commission, 100 F Street
by the SBA, Rand SBIC is required to
NE., Washington, DC 20549–1090.
maintain an investment committee
Applicants, c/o Allen F. Grum, Rand
consisting of the Principal Officers that
Capital Corporation, 2200 Rand
has responsibility for all investment
Building, Buffalo, NY 14203.
decisions by Rand SBIC. Rand SBIC’s
FOR FURTHER INFORMATION CONTACT:
operations have been and will be
Keith A. Gregory, Senior Counsel, at
consolidated with those of Rand for
(202) 551–6815, or Mary Kay Frech,
financial reporting and tax purposes.
Branch Chief, at (202) 551–6821
(Division of Investment Management,
1 Section 2(a)(48) of the Act defines a BDC to be
Office of Investment Company
any closed-end investment company that operates
Regulation).
for the purpose of making investments in securities
described in sections 55(a)(1) through 55(a)(3) of the
SUPPLEMENTARY INFORMATION: The
Act and makes available significant managerial
following is a summary of the
assistance with respect to the issuers of such
securities.
application. The complete application
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4. Rand may in the future create
wholly-owned Future Subsidiaries each
of which (i) will be a BDC, and (ii) may
be licensed by the SBA to operate as an
SBIC (collectively with Rand SBIC, the
‘‘SBIC Subsidiaries’’) or may not be an
SBIC.2 Any future SBIC Subsidiary will
be operated in the same manner as Rand
SBIC and will be subject to the
requirements of the SBA Act and the
SBA regulations. Rand SBIC, the SBIC
Subsidiaries and the Future Subsidiaries
are collectively referred to as the
‘‘Subsidiaries.’’
Applicants’ Legal Analysis
1. Applicants request an order under
sections 6(c), 12(d)(1)(J), 57(c) and 57(i)
of the Act and rule 17d–1 under the Act
granting exemptions from sections
12(d)(1), 18(a), 21(b), 57(a)(1), 57(a)(2),
57(a)(3), 57(a)(4), and 61(a) of the Act to
permit Rand, Rand SBIC and any Future
Subsidiary to engage in certain
transactions that otherwise would be
permitted if Rand and its Subsidiaries
were one company and to permit Rand
to adhere to a modified asset coverage
requirement. Applicants also request an
exemption under section 12(h) of the
Exchange Act for an exemption from
section 13(a) of the Exchange Act.
2. Section 12(d)(1)(A) of the Act,
made applicable to BDCs by section 60
of the Act, limits the amount of
securities a registered investment
company or BDC may hold of other
investment companies. Section
12(d)(1)(C) of the Act limits the amount
of securities of a closed-end investment
company that may be acquired by an
investment company. Rule 60a–1
exempts a BDC’s acquisition of the
securities of a wholly-owned SBIC
subsidiary from sections 12(d)(1)(A) and
(C). Accordingly, the acquisition of
Rand SBIC securities by Rand will be
exempt from the provisions of sections
12(d)(1)(A) and 12(d)(1)(C) by virtue of
rule 60a–1.
3. Applicants state that section
12(d)(1) would prohibit the acquisition
by Rand of the debt or equity securities
of, or the making of loans by Rand to,
Future Subsidiaries that are not SBICs.
Applicants state that section 12(d)(1)
would also prohibit the acquisition of
debt securities of Rand by any such
Future Subsidiary since they would
each be a BDC and an entity controlled
by a BDC. Thus, the making of loans or
advances by Rand SBIC or a Future
Subsidiary to Rand might be deemed to
violate section 12(d)(1) if the loans or
2 All existing entities that currently intend to rely
on the order have been named as applicants. Any
other existing or future entity that subsequently
relies on the order will comply with the terms [and
conditions] of the application.
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advances are construed as purchases by
the Subsidiary of the securities of Rand.
4. Applicants request an exemption
under section 12(d)(1)(J) from section
12(d)(1) to permit: (1) The purchase of
debt or equity securities of, or a
contribution to capital to, a Future
Subsidiary that is not an SBIC by Rand,
(ii) the making of loans or advances by
any Subsidiary to Rand or to any other
Subsidiary, and (iii) the acquisition by
the Subsidiaries of any securities of
Rand representing indebtedness or any
securities representing indebtedness
issued by any of the other Subsidiaries.
Section 12(d)(1)(J) of the Act provides
that the Commission may exempt
persons or transactions from any
provision of section 12(d)(1) if and to
the extent such exception is consistent
with the public interest and the
protection of investors. Applicants state
that the requested relief meets this
standard because the Subsidiaries are
wholly-owned and this status and the
consolidated financial reporting with
Rand will eliminate the possibility of
overreaching and prevent confusion as
to the financial status of Rand to Rand’s
shareholders, who are the investors that
the Act is intended to protect.
5. Section 18(a) prohibits a registered
closed-end investment company from
issuing any class of senior security or
selling any such security of which it is
the issuer unless the company complies
with the asset coverage requirements set
forth in that section. Section 61(a) of the
Act makes section 18 applicable to
BDCs, with certain modifications.
Section 18(k) exempts an investment
company operating as an SBIC from the
asset coverage requirements of section
18(a)(1)(A) and (B) (with respect to
senior securities representing
indebtedness).
6. Applicants state that a question
exists as to whether Rand must comply
with the asset coverage requirements of
section 18(a) (as modified by section
61(a)) on a consolidated basis because
Rand may be deemed to be an indirect
issuer of any class of senior security
representing indebtedness issued by any
Subsidiary. For Rand to comply with
these asset coverage requirements
would mean that, with certain
exceptions, Rand would treat as its own
all assets held directly by Rand and the
Subsidiaries and any liabilities of the
Subsidiaries, including liabilities of the
Subsidiaries with respect to senior
securities as to which any of the
Subsidiaries is exempt from the asset
coverage requirements of section
18(a)(1)(A) and (B) by virtue of section
18(k). Accordingly, applicants request
relief under section 6(c) of the Act from
sections 18(a) and 61(a) to permit Rand
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to exclude from its consolidated asset
coverage ratio any SBA preferred stock
interest in any of the Subsidiaries (if
applicable) and any senior security
representing indebtedness issued by any
Subsidiary.
7. Section 6(c) of the Act, in relevant
part, permits the Commission to exempt
any transaction or class of transactions
from any provision 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. Applicants state
that the requested relief satisfies the
section 6(c) standards. Applicants state
that, without the requested relief from
sections 18(a) and 61(a), the ability of an
SBIC Subsidiary to obtain the kind of
financing that would be available to
Rand if it were to conduct the SBIC
operations itself would be restricted.
Moreover, the exclusion by Rand from
its consolidated asset coverage ratio of
any senior security representing
indebtedness that is issued by an SBIC
Subsidiary would not harm the public
interest because the SBA regulates the
leverage and capital structure of the
SBIC Subsidiaries.
8. Sections 57(a)(1) and (2) of the Act
generally prohibit, with certain
exceptions, sales or purchases of any
security or other property between BDCs
and certain of their affiliates as
described in section 57(b) of the Act.
Section 57(b) includes a person, directly
or indirectly, either controlling,
controlled by or under common control
with the BDC. Applicants state that
Rand directly owns all of each
Subsidiary’s outstanding voting stock.
Applicants further state that each of the
Subsidiaries and Rand may be deemed
to be under the common control of the
Rand Board and the Principal Officers.
Accordingly, Rand and the Subsidiaries
are related to each other in the manner
described in section 57(b). In addition,
each Subsidiary would also be a person
related to each other Subsidiary in a
manner described in section 57(b) as
long as they remain under the common
control of Rand.
9. Applicants state that there may be
circumstances when it is in the interest
of Rand and its shareholders that one or
more of the Subsidiaries invest in
securities of an issuer that may be
deemed to be a controlled portfolio
affiliate of Rand or another Subsidiary
or that Rand invest in securities of an
issuer that may be deemed to be a
controlled portfolio affiliate of a
Subsidiary. Applicants therefore request
an exemption from sections 57(a)(1) and
57(a)(2) of the Act to permit any
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transaction between Rand and any
Subsidiary, and any transaction between
a Subsidiary and any other Subsidiary,
with respect to the purchase or sale of
securities or other property. Applicants
also seek an exemption from these
provisions to allow any purchase or sale
transaction between Rand and a
controlled portfolio affiliate of any
Subsidiary, and a purchase or sale
transaction between a Subsidiary and a
controlled portfolio affiliate of Rand or
another Subsidiary. Applicants state
that the requested relief is intended only
to permit Rand and the Subsidiaries to
do that which they otherwise would be
permitted to do if they were one
company.
10. Section 57(c) provides that the
Commission will exempt a proposed
transaction from the provisions of
section 57(a)(1) and (2) of the Act if the
terms of the proposed transaction,
including the consideration to be paid
or received, are reasonable and fair and
do not involve overreaching of any
person concerned, and the proposed
transaction is consistent with the policy
of the BDC concerned and the general
purposes of the Act.
11. Applicants submit that the
requested relief from section 57(a)(1)
and (2) meets this standard. Applicants
represent that the proposed operations
as one company will enhance efficient
operations of Rand and its wholly
owned Subsidiaries, and allow them to
deal with portfolio companies as if Rand
and such Subsidiaries were one
company. Applicants contend that the
terms of the proposed transactions are
reasonable and fair and do not involve
overreaching of Rand or its stockholders
or its stockholders by any person, and
that the requested order would permit
Rand and the Subsidiaries to carry out
more effectively their purposes and
objectives of investing primarily in
small business concerns. Finally,
applicants note that the proposed
transactions are consistent with the
policies of Rand and Rand SBIC as
specified in filings with the Commission
and Rand’s reports to shareholders, as
well as consistent with the policies and
provisions of the Act.
12. Section 57(a)(3) of the Act makes
it unlawful for certain affiliated persons
of a BDC, and certain affiliated persons
of those persons, to borrow money or
other property from such BDC or from
any company controlled by the BDC,
except as permitted by section 21(b) or
section 62. Section 21(b) of the Act
(made applicable to BDCs by section 62)
provides that it shall be unlawful for a
BDC to lend any money or property,
directly or indirectly, to any person that
controls or is under common control
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with the BDC, except for loans to any
company that owns all of the
outstanding securities of the BDC (other
than directors’ qualifying shares).
13. Rand is an affiliated person of
each of the Subsidiaries by reason of its
direct ownership of all of the
outstanding voting capital stock of the
Subsidiaries. Each of the Subsidiaries is
an affiliated person of Rand because
they are deemed to be under the control
of Rand. Each of the Subsidiaries is an
affiliated person of each other
Subsidiary because they are deemed to
be under the common control of Rand.
In addition, each of the directors and
Principal Officers of Rand are also or
will be the directors and principal
officers of Rand SBIC and the Future
Subsidiaries, so that Rand and the
Subsidiaries may be deemed to be under
common control.
14. Applicants state that there may be
instances when it would be in the best
interests of Rand and its shareholders
for Rand to make loans to one of more
of the Subsidiaries or for the
Subsidiaries to make loans to Rand or
each other. Applicants note that, in the
case of loans from Rand to the
Subsidiaries or loans from the
Subsidiaries to each other, the loans
may be prohibited by section 21(b)
because Rand and the Subsidiaries may
be deemed to be under common control.
Applicants state that in the case of loans
from a Subsidiary to Rand, the loans
would be prohibited by section 21(b)
and section 57(a)(3) because the
borrower controls the lender and the
lender may have outstanding securities
not owned by the borrower.
15. Accordingly, applicants request an
order under section 6(c) to exempt from
the provisions of section 21(b) the
lending of money or other property by
Rand to the Subsidiaries and by the
Subsidiaries to Rand or another
Subsidiary. Applicants argue that
because these transactions are solely
between Rand and its wholly-owned
Subsidiaries, they will have no
substantive economic effect and there
will be no basis for overreaching or
harm to the public interest. Applicants
also request an order under section 57(c)
to exempt the borrowing of money or
other property by Rand or a Subsidiary
from any other Subsidiary from the
provisions of section 57(a)(3).
Applicants submit that the requested
relief meets the standards of section 6(c)
and 57(c).
16. Applicants also request relief from
section 21(b) under section 6(c) to
exempt any lending of money or other
property by Rand or a Subsidiary to
portfolio companies of any Subsidiary
controlled by the Subsidiary or portfolio
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companies of Rand controlled by Rand.
The requested exemption is intended to
permit Rand and the Subsidiaries to do
that which they otherwise would be
permitted to do if they were one
company, as opposed to each of the
Subsidiaries being a wholly-owned
Subsidiary of Rand.
17. Section 17(d) of the Act and rule
17d–1 under the Act (made applicable
to BDCs by section 57(i)) prohibit
affiliated persons of a registered
investment company, or an affiliated
person of such person, acting as
principal, from participating in any joint
transaction or arrangement in which the
registered company or a company it
controls is a participant, unless the
Commission has issued an order
authorizing the arrangement. Section
57(a)(4) of the Act imposes substantially
the same prohibitions on joint
transactions involving any BDC and an
affiliated person of such BDC, or an
affiliated person of such affiliated
person, as specified in section 57(b) of
the Act. Section 57(i) of the Act
provides that rules and regulations
under section 17(d) of the Act will
apply to transactions subject to section
57(a)(4) in the absence of rules under
that section. The Commission has not
adopted rules under section 57(a)(4)
with respect to joint transactions and,
accordingly, the standards set forth in
rule 17d–1 govern applicants’ request
for relief.
18. Applicants request relief under
section 57(i) and rule 17d–1 to permit
any joint transaction that would
otherwise be prohibited by section
57(a)(4), in which a Subsidiary and
Rand or another Subsidiary participate,
but only to the extent that the
transaction would not be prohibited if
the Subsidiaries were deemed to be a
part of Rand and not separate
companies.
19. In determining whether to grant
an order under section 57(i) and rule
17d–1, the Commission considers
whether the participation of the BDC in
the joint transaction is consistent with
the provisions, policies, and purposes of
the Act, and the extent to which such
participation is on a basis different from
or less advantageous than that of other
participants. Applicants note that the
proposed transactions are consistent
with the policy and provisions of the
Act and will enhance the interests of
Rand and its stockholders while
retaining the important protections
afforded by the Act. In addition, because
the joint participants will conduct their
operations as though they comprise one
company, the participation of one will
not be on a basis different from or less
advantageous than the others.
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Accordingly, applicants believe that the
standard for relief under section 57(i)
and rule 17d–1 is satisfied.
20. Section 54 of the Act provides that
a closed-end company may elect BDC
treatment under the Act if the company
has either a class of equity securities
registered under section 12 of the
Exchange Act or has filed a registration
statement pursuant to section 12 of the
Exchange Act for a class of its equity
securities. Section 12(g) of the Exchange
Act requires issuers with specified
assets and a specified number of
security holders to register under the
Exchange Act. Rand has elected to be
regulated as a BDC and its common
stock is deemed registered under section
12(g)(1) of the Exchange Act. Rand SBIC
will elect to be regulated as a BDC under
the Act prior to relying on the order,
and such election will cause Rand
SBIC’s common stock to be registered
under the Exchange Act by operation of
rule 12g–2 under the Exchange Act.
21. By filing a registration statement
under section 12 of the Exchange Act,
absent an exemption, Rand SBIC and
each Future Subsidiary would be
required by section 13(a) of the
Exchange Act to file periodically with
the Commission, even though their sole
shareholder will be Rand. Accordingly,
applicants request an order under
section 12(h) of the Exchange Act
exempting Rand SBIC and each Future
Subsidiary from the reporting
requirements of section 13(a) of the
Exchange Act to permit the filing of
consolidated reports with Rand.
22. Section 12(h) of the Exchange Act
provides that the Commission may
exempt an issuer from section 13 of the
Exchange Act if the Commission finds
that by reason of the number of public
investors, amount of trading interest in
the securities, the nature and extent of
the activities of the issuer, income or
assets of the issuer, or otherwise, that
such action is not inconsistent with the
public interest or the protection of
investors. Each of the Subsidiaries will
have only one investor, which is itself
a reporting company, and no public
investors. There will be no trading in
the Subsidiaries securities, so no public
interest or investor protective purpose
will be served by separate Subsidiary
reporting. Further, applicants state that
the nature and extent of the
Subsidiaries’ activities are such that
their activities will be fully reported
through consolidated reporting in
accordance with normal accounting
rules. Accordingly, applicants believe
that the requested exemption meets the
standards of section 12(h) of the
Exchange Act.
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Federal Register / Vol. 77, No. 25 / Tuesday, February 7, 2012 / Notices
tkelley on DSK3SPTVN1PROD with NOTICES
Applicants’ Conditions
Applicants agree that the requested
order will be subject to the following
conditions:
1. Rand will at all times own and
hold, beneficially and of record, all of
the outstanding voting capital stock of
each of the Subsidiaries.
2. The Subsidiaries will have
investment policies not inconsistent
with those of Rand, as set forth in
Rand’s registration statement.
3. No person shall serve as investment
adviser or principal underwriter to Rand
SBIC or any Subsidiary unless the Rand
Board and the shareholders of Rand
shall have taken the same action with
respect thereto also required to be taken
by the board of directors and the sole
shareholder of such Subsidiary.
4. Rand will not itself issue or sell any
senior security, and Rand will not cause
or permit any Subsidiary to issue or sell
any senior security of which Rand or
such Subsidiary is the issuer except to
the extent permitted by section 18 (as
modified for BDCs by section 61) of the
Act; provided that immediately after the
issuance or sale of any such senior
security by either Rand or any
Subsidiary, Rand and its Subsidiaries on
a consolidated basis, and Rand
individually, shall have the asset
coverage required by section 18(a) (as
modified for BDCs by section 61(a)),
except that, in determining whether
Rand and its Subsidiaries on a
consolidated basis have the asset
coverage required by section 61(a), any
SBA preferred stock interest in any SBIC
Subsidiary and any borrowings by any
SBIC Subsidiary shall not be considered
senior securities and, for purposes of the
definition of ‘‘asset coverage’’ in section
18(h), shall be treated as indebtedness
not represented by senior securities.
5. No person shall serve as a member
of any board of directors of any
Subsidiary unless such person shall also
serve as a member of the Rand Board.
The board of directors of any Subsidiary
will be elected by Rand as the sole
shareholder of such Subsidiary.
6. Rand and any Subsidiary will
acquire securities representing
indebtedness of Rand SBIC or any SBIC
Subsidiary only if, in each case, the
prior approval of the SBA has been
obtained. In addition, the SBIC
Subsidiaries, on the one hand, and Rand
or any other Subsidiary on the other
hand, will purchase and sell portfolio
securities between themselves only if, in
each case, the prior approval of the SBA
has been obtained.
VerDate Mar<15>2010
17:34 Feb 06, 2012
Jkt 226001
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Kevin M. O’Neill,
Deputy Secretary.
SECURITIES AND EXCHANGE
COMMISSION
[FR Doc. 2012–2670 Filed 2–6–12; 8:45 am]
Self-Regulatory Organizations;
NASDAQ OMX PHLX LLC; Order
Granting Approval of Proposed Rule
Change Regarding Strike Price
Intervals for SLV and USO Options
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Notice of Sunshine Act Meeting.
Notice is hereby given, pursuant to
the provisions of the Government in the
Sunshine Act, Public Law 94–409, that
the Securities and Exchange
Commission will hold a Closed Meeting
on Thursday, February 9, 2012 at 2 p.m.
Commissioners, Counsel to the
Commissioners, the Secretary to the
Commission, and recording secretaries
will attend the Closed Meeting. Certain
staff members who have an interest in
the matters also may be present.
The General Counsel of the
Commission, or his designee, has
certified that, in his opinion, one or
more of the exemptions set forth in 5
U.S.C. 552b(c)(3), (5), (7), 9(B) and (10)
and 17 CFR 200.402(a)(3), (5), (7), 9(ii)
and (10), permit consideration of the
scheduled matters at the Closed
Meeting.
Commissioner Paredes, as duty
officer, voted to consider the items
listed for the Closed Meeting in a closed
session.
The subject matter of the Closed
Meeting scheduled for Thursday,
February 9, 2012 will be:
Institution and settlement of injunctive
actions;
Institution and settlement of
administrative proceedings;
An adjudicatory matter; and
Other matters relating to enforcement
proceedings.
At times, changes in Commission
priorities require alterations in the
scheduling of meeting items.
For further information and to
ascertain what, if any, matters have been
added, deleted or postponed, please
contact:
The Office of the Secretary at (202)
551–5400.
Dated: February 2, 2012.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2012–2815 Filed 2–3–12; 11:15 am]
BILLING CODE 8011–01–P
PO 00000
Frm 00106
Fmt 4703
Sfmt 4703
[Release No. 34–66285; File No. SR–Phlx–
2011–175]
February 1, 2012.
I. Introduction
On December 7, 2011, NASDAQ OMX
PHLX LLC (‘‘Phlx’’ or ‘‘Exchange’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change regarding strike price intervals
for options on iShares® Silver Trust
(‘‘SLV’’ or ‘‘SLV Trust’’) and United
States Oil Fund (‘‘USO’’ or ‘‘USO
Fund’’). The proposed rule change was
published for comment in the Federal
Register on December 22, 2011.3 The
Commission received no comment
letters on the proposal. This order
approves the proposed rule change.
II. Description of the Proposal
The proposed rule change seeks to
amend Commentary .05 of Rule 1012 to
allow trading of SLV and USO options
at $0.50 strike price intervals where the
strike price is less than $75.4 The
Exchange proposed no other changes to
SLV and USO strike price intervals.
The Exchange stated that the
proposed rule change is designed to
address customer demand to hedge the
SLV and USO options in smaller
intervals and would, in part, allow
better tailored investment and hedging
opportunities.5
III. Discussion
The Commission finds that the
proposed rule change is consistent with
the requirements of the Act and the
rules and regulations thereunder
applicable to a national securities
exchange.6 Specifically, the
Commission finds that the proposal is
consistent with Section 6(b)(5) of the
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 Securities Exchange Act Release No. 65986
(December 16, 2011), 76 FR 79748 (December 22,
2011) (‘‘Notice’’).
4 The Exchange also proposed certain nonsubstantive changes to Commentary .06 of Rule
1009.
5 See Notice at 79749.
6 In approving this proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
2 17
E:\FR\FM\07FEN1.SGM
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Agencies
[Federal Register Volume 77, Number 25 (Tuesday, February 7, 2012)]
[Notices]
[Pages 6156-6160]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-2670]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 29941; 812-13634]
Rand Capital Corporation, et al.; Notice of Application
February 1, 2012.
AGENCY: Securities and Exchange Commission (the ``Commission'').
ACTION: Notice of an application for an order under sections 6(c),
12(d)(1)(J), and 57(c) of the Investment Company Act of 1940 (``Act'')
granting exemptions from sections 12(d)(1)(A) and (C), 18(a),
[[Page 6157]]
21(b), 57(a)(1)-(a)(3), and 61(a) of the Act; under section 57(i) of
the Act and rule 17d-1 under the Act to permit certain joint
transactions otherwise prohibited by section 57(a)(4) of the Act; and
under section 12(h) of the Securities Exchange Act of 1934 (``Exchange
Act'') granting an exemption from section 13(a) of the Exchange Act.
-----------------------------------------------------------------------
Applicants: Rand Capital Corporation (``Rand'') and Rand Capital SBIC,
Inc. (``Rand SBIC'').
Summary of Application: Applicants request an order permitting a parent
business development company (``BDC'') and its wholly-owned small
business investment company (``SBIC'') subsidiary and any future
wholly-owned BDC subsidiaries (``Future Subsidiaries'') to engage in
certain transactions that otherwise would be permitted if such parent
BDC and its subsidiaries were one company and to file certain reports
on a consolidated basis, and permitting such parent BDC to adhere to a
modified asset coverage requirement.
DATES: Filing Dates: The application was filed on February 6, 2009 and
amended on August 5, 2009, September 8, 2011 and January 10, 2012.
Hearing or Notification of Hearing: An order granting the
application will be issued unless the Commission orders a hearing.
Interested persons may request a hearing by writing to the Commission's
Secretary and serving applicants with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 pm on February 27, 2012, 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, c/o Allen F. Grum,
Rand Capital Corporation, 2200 Rand Building, Buffalo, NY 14203.
FOR FURTHER INFORMATION CONTACT: Keith A. Gregory, Senior Counsel, at
(202) 551-6815, or Mary Kay Frech, Branch Chief, at (202) 551-6821
(Division of Investment Management, Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's 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. Rand, a New York corporation, is an internally managed, non-
diversified, closed-end investment company that has elected to be
regulated as a BDC under the Act.\1\ Rand's principal business is to
make venture capital investments in small, early-stage and developing
enterprises. Rand's principal objective is long-term capital
appreciation. Rand typically invests in debt securities and
concurrently acquires equity interests in the form of stock, warrants
or stock options or the right to convert debt securities into stock.
Rand has a six member board of directors (``Rand Board''), five of whom
are not ``interested persons'' of Rand within the meaning of section
2(a)(19) of the Act. The Rand Board appoints Rand's president and chief
executive officer and its executive vice president and chief financial
officer (collectively, the ``Principal Officers''). Subject to the
oversight of the Rand Board, the Principal Officers make all investment
decisions for Rand.
---------------------------------------------------------------------------
\1\ Section 2(a)(48) of the Act defines a BDC to be any closed-
end investment company that operates for the purpose of making
investments in securities described in sections 55(a)(1) through
55(a)(3) of the Act and makes available significant managerial
assistance with respect to the issuers of such securities.
---------------------------------------------------------------------------
2. Rand SBIC, a New York corporation, is an SBIC licensed by the
Small Business Administration (``SBA'') to operate under the Small
Business Investment Act of 1958 (``SBA Act''). Rand SBIC is registered
as an investment company under the Act and will elect to be regulated
as a BDC prior to relying on the requested order. Rand SBIC has the
same investment purposes and will invest in the same kinds of
securities as Rand.
3. Rand SBIC is a wholly-owned subsidiary of Rand, which owns all
of its outstanding voting stock. The Rand Board annually elects the
same persons who comprise the Rand Board to serve on the board of
directors of Rand SBIC. Pursuant to a by-law provision required by the
SBA, Rand SBIC is required to maintain an investment committee
consisting of the Principal Officers that has responsibility for all
investment decisions by Rand SBIC. Rand SBIC's operations have been and
will be consolidated with those of Rand for financial reporting and tax
purposes.
4. Rand may in the future create wholly-owned Future Subsidiaries
each of which (i) will be a BDC, and (ii) may be licensed by the SBA to
operate as an SBIC (collectively with Rand SBIC, the ``SBIC
Subsidiaries'') or may not be an SBIC.\2\ Any future SBIC Subsidiary
will be operated in the same manner as Rand SBIC and will be subject to
the requirements of the SBA Act and the SBA regulations. Rand SBIC, the
SBIC Subsidiaries and the Future Subsidiaries are collectively referred
to as the ``Subsidiaries.''
---------------------------------------------------------------------------
\2\ All existing entities that currently intend to rely on the
order have been named as applicants. Any other existing or future
entity that subsequently relies on the order will comply with the
terms [and conditions] of the application.
---------------------------------------------------------------------------
Applicants' Legal Analysis
1. Applicants request an order under sections 6(c), 12(d)(1)(J),
57(c) and 57(i) of the Act and rule 17d-1 under the Act granting
exemptions from sections 12(d)(1), 18(a), 21(b), 57(a)(1), 57(a)(2),
57(a)(3), 57(a)(4), and 61(a) of the Act to permit Rand, Rand SBIC and
any Future Subsidiary to engage in certain transactions that otherwise
would be permitted if Rand and its Subsidiaries were one company and to
permit Rand to adhere to a modified asset coverage requirement.
Applicants also request an exemption under section 12(h) of the
Exchange Act for an exemption from section 13(a) of the Exchange Act.
2. Section 12(d)(1)(A) of the Act, made applicable to BDCs by
section 60 of the Act, limits the amount of securities a registered
investment company or BDC may hold of other investment companies.
Section 12(d)(1)(C) of the Act limits the amount of securities of a
closed-end investment company that may be acquired by an investment
company. Rule 60a-1 exempts a BDC's acquisition of the securities of a
wholly-owned SBIC subsidiary from sections 12(d)(1)(A) and (C).
Accordingly, the acquisition of Rand SBIC securities by Rand will be
exempt from the provisions of sections 12(d)(1)(A) and 12(d)(1)(C) by
virtue of rule 60a-1.
3. Applicants state that section 12(d)(1) would prohibit the
acquisition by Rand of the debt or equity securities of, or the making
of loans by Rand to, Future Subsidiaries that are not SBICs. Applicants
state that section 12(d)(1) would also prohibit the acquisition of debt
securities of Rand by any such Future Subsidiary since they would each
be a BDC and an entity controlled by a BDC. Thus, the making of loans
or advances by Rand SBIC or a Future Subsidiary to Rand might be deemed
to violate section 12(d)(1) if the loans or
[[Page 6158]]
advances are construed as purchases by the Subsidiary of the securities
of Rand.
4. Applicants request an exemption under section 12(d)(1)(J) from
section 12(d)(1) to permit: (1) The purchase of debt or equity
securities of, or a contribution to capital to, a Future Subsidiary
that is not an SBIC by Rand, (ii) the making of loans or advances by
any Subsidiary to Rand or to any other Subsidiary, and (iii) the
acquisition by the Subsidiaries of any securities of Rand representing
indebtedness or any securities representing indebtedness issued by any
of the other Subsidiaries. Section 12(d)(1)(J) of the Act provides that
the Commission may exempt persons or transactions from any provision of
section 12(d)(1) if and to the extent such exception is consistent with
the public interest and the protection of investors. Applicants state
that the requested relief meets this standard because the Subsidiaries
are wholly-owned and this status and the consolidated financial
reporting with Rand will eliminate the possibility of overreaching and
prevent confusion as to the financial status of Rand to Rand's
shareholders, who are the investors that the Act is intended to
protect.
5. Section 18(a) prohibits a registered closed-end investment
company from issuing any class of senior security or selling any such
security of which it is the issuer unless the company complies with the
asset coverage requirements set forth in that section. Section 61(a) of
the Act makes section 18 applicable to BDCs, with certain
modifications. Section 18(k) exempts an investment company operating as
an SBIC from the asset coverage requirements of section 18(a)(1)(A) and
(B) (with respect to senior securities representing indebtedness).
6. Applicants state that a question exists as to whether Rand must
comply with the asset coverage requirements of section 18(a) (as
modified by section 61(a)) on a consolidated basis because Rand may be
deemed to be an indirect issuer of any class of senior security
representing indebtedness issued by any Subsidiary. For Rand to comply
with these asset coverage requirements would mean that, with certain
exceptions, Rand would treat as its own all assets held directly by
Rand and the Subsidiaries and any liabilities of the Subsidiaries,
including liabilities of the Subsidiaries with respect to senior
securities as to which any of the Subsidiaries is exempt from the asset
coverage requirements of section 18(a)(1)(A) and (B) by virtue of
section 18(k). Accordingly, applicants request relief under section
6(c) of the Act from sections 18(a) and 61(a) to permit Rand to exclude
from its consolidated asset coverage ratio any SBA preferred stock
interest in any of the Subsidiaries (if applicable) and any senior
security representing indebtedness issued by any Subsidiary.
7. Section 6(c) of the Act, in relevant part, permits the
Commission to exempt any transaction or class of transactions from any
provision 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. Applicants state that the requested relief
satisfies the section 6(c) standards. Applicants state that, without
the requested relief from sections 18(a) and 61(a), the ability of an
SBIC Subsidiary to obtain the kind of financing that would be available
to Rand if it were to conduct the SBIC operations itself would be
restricted. Moreover, the exclusion by Rand from its consolidated asset
coverage ratio of any senior security representing indebtedness that is
issued by an SBIC Subsidiary would not harm the public interest because
the SBA regulates the leverage and capital structure of the SBIC
Subsidiaries.
8. Sections 57(a)(1) and (2) of the Act generally prohibit, with
certain exceptions, sales or purchases of any security or other
property between BDCs and certain of their affiliates as described in
section 57(b) of the Act. Section 57(b) includes a person, directly or
indirectly, either controlling, controlled by or under common control
with the BDC. Applicants state that Rand directly owns all of each
Subsidiary's outstanding voting stock. Applicants further state that
each of the Subsidiaries and Rand may be deemed to be under the common
control of the Rand Board and the Principal Officers. Accordingly, Rand
and the Subsidiaries are related to each other in the manner described
in section 57(b). In addition, each Subsidiary would also be a person
related to each other Subsidiary in a manner described in section 57(b)
as long as they remain under the common control of Rand.
9. Applicants state that there may be circumstances when it is in
the interest of Rand and its shareholders that one or more of the
Subsidiaries invest in securities of an issuer that may be deemed to be
a controlled portfolio affiliate of Rand or another Subsidiary or that
Rand invest in securities of an issuer that may be deemed to be a
controlled portfolio affiliate of a Subsidiary. Applicants therefore
request an exemption from sections 57(a)(1) and 57(a)(2) of the Act to
permit any transaction between Rand and any Subsidiary, and any
transaction between a Subsidiary and any other Subsidiary, with respect
to the purchase or sale of securities or other property. Applicants
also seek an exemption from these provisions to allow any purchase or
sale transaction between Rand and a controlled portfolio affiliate of
any Subsidiary, and a purchase or sale transaction between a Subsidiary
and a controlled portfolio affiliate of Rand or another Subsidiary.
Applicants state that the requested relief is intended only to permit
Rand and the Subsidiaries to do that which they otherwise would be
permitted to do if they were one company.
10. Section 57(c) provides that the Commission will exempt a
proposed transaction from the provisions of section 57(a)(1) and (2) of
the Act if the terms of the proposed transaction, including the
consideration to be paid or received, are reasonable and fair and do
not involve overreaching of any person concerned, and the proposed
transaction is consistent with the policy of the BDC concerned and the
general purposes of the Act.
11. Applicants submit that the requested relief from section
57(a)(1) and (2) meets this standard. Applicants represent that the
proposed operations as one company will enhance efficient operations of
Rand and its wholly owned Subsidiaries, and allow them to deal with
portfolio companies as if Rand and such Subsidiaries were one company.
Applicants contend that the terms of the proposed transactions are
reasonable and fair and do not involve overreaching of Rand or its
stockholders or its stockholders by any person, and that the requested
order would permit Rand and the Subsidiaries to carry out more
effectively their purposes and objectives of investing primarily in
small business concerns. Finally, applicants note that the proposed
transactions are consistent with the policies of Rand and Rand SBIC as
specified in filings with the Commission and Rand's reports to
shareholders, as well as consistent with the policies and provisions of
the Act.
12. Section 57(a)(3) of the Act makes it unlawful for certain
affiliated persons of a BDC, and certain affiliated persons of those
persons, to borrow money or other property from such BDC or from any
company controlled by the BDC, except as permitted by section 21(b) or
section 62. Section 21(b) of the Act (made applicable to BDCs by
section 62) provides that it shall be unlawful for a BDC to lend any
money or property, directly or indirectly, to any person that controls
or is under common control
[[Page 6159]]
with the BDC, except for loans to any company that owns all of the
outstanding securities of the BDC (other than directors' qualifying
shares).
13. Rand is an affiliated person of each of the Subsidiaries by
reason of its direct ownership of all of the outstanding voting capital
stock of the Subsidiaries. Each of the Subsidiaries is an affiliated
person of Rand because they are deemed to be under the control of Rand.
Each of the Subsidiaries is an affiliated person of each other
Subsidiary because they are deemed to be under the common control of
Rand. In addition, each of the directors and Principal Officers of Rand
are also or will be the directors and principal officers of Rand SBIC
and the Future Subsidiaries, so that Rand and the Subsidiaries may be
deemed to be under common control.
14. Applicants state that there may be instances when it would be
in the best interests of Rand and its shareholders for Rand to make
loans to one of more of the Subsidiaries or for the Subsidiaries to
make loans to Rand or each other. Applicants note that, in the case of
loans from Rand to the Subsidiaries or loans from the Subsidiaries to
each other, the loans may be prohibited by section 21(b) because Rand
and the Subsidiaries may be deemed to be under common control.
Applicants state that in the case of loans from a Subsidiary to Rand,
the loans would be prohibited by section 21(b) and section 57(a)(3)
because the borrower controls the lender and the lender may have
outstanding securities not owned by the borrower.
15. Accordingly, applicants request an order under section 6(c) to
exempt from the provisions of section 21(b) the lending of money or
other property by Rand to the Subsidiaries and by the Subsidiaries to
Rand or another Subsidiary. Applicants argue that because these
transactions are solely between Rand and its wholly-owned Subsidiaries,
they will have no substantive economic effect and there will be no
basis for overreaching or harm to the public interest. Applicants also
request an order under section 57(c) to exempt the borrowing of money
or other property by Rand or a Subsidiary from any other Subsidiary
from the provisions of section 57(a)(3). Applicants submit that the
requested relief meets the standards of section 6(c) and 57(c).
16. Applicants also request relief from section 21(b) under section
6(c) to exempt any lending of money or other property by Rand or a
Subsidiary to portfolio companies of any Subsidiary controlled by the
Subsidiary or portfolio companies of Rand controlled by Rand. The
requested exemption is intended to permit Rand and the Subsidiaries to
do that which they otherwise would be permitted to do if they were one
company, as opposed to each of the Subsidiaries being a wholly-owned
Subsidiary of Rand.
17. Section 17(d) of the Act and rule 17d-1 under the Act (made
applicable to BDCs by section 57(i)) prohibit affiliated persons of a
registered investment company, or an affiliated person of such person,
acting as principal, from participating in any joint transaction or
arrangement in which the registered company or a company it controls is
a participant, unless the Commission has issued an order authorizing
the arrangement. Section 57(a)(4) of the Act imposes substantially the
same prohibitions on joint transactions involving any BDC and an
affiliated person of such BDC, or an affiliated person of such
affiliated person, as specified in section 57(b) of the Act. Section
57(i) of the Act provides that rules and regulations under section
17(d) of the Act will apply to transactions subject to section 57(a)(4)
in the absence of rules under that section. The Commission has not
adopted rules under section 57(a)(4) with respect to joint transactions
and, accordingly, the standards set forth in rule 17d-1 govern
applicants' request for relief.
18. Applicants request relief under section 57(i) and rule 17d-1 to
permit any joint transaction that would otherwise be prohibited by
section 57(a)(4), in which a Subsidiary and Rand or another Subsidiary
participate, but only to the extent that the transaction would not be
prohibited if the Subsidiaries were deemed to be a part of Rand and not
separate companies.
19. In determining whether to grant an order under section 57(i)
and rule 17d-1, the Commission considers whether the participation of
the BDC in the joint transaction is consistent with the provisions,
policies, and purposes of the Act, and the extent to which such
participation is on a basis different from or less advantageous than
that of other participants. Applicants note that the proposed
transactions are consistent with the policy and provisions of the Act
and will enhance the interests of Rand and its stockholders while
retaining the important protections afforded by the Act. In addition,
because the joint participants will conduct their operations as though
they comprise one company, the participation of one will not be on a
basis different from or less advantageous than the others. Accordingly,
applicants believe that the standard for relief under section 57(i) and
rule 17d-1 is satisfied.
20. Section 54 of the Act provides that a closed-end company may
elect BDC treatment under the Act if the company has either a class of
equity securities registered under section 12 of the Exchange Act or
has filed a registration statement pursuant to section 12 of the
Exchange Act for a class of its equity securities. Section 12(g) of the
Exchange Act requires issuers with specified assets and a specified
number of security holders to register under the Exchange Act. Rand has
elected to be regulated as a BDC and its common stock is deemed
registered under section 12(g)(1) of the Exchange Act. Rand SBIC will
elect to be regulated as a BDC under the Act prior to relying on the
order, and such election will cause Rand SBIC's common stock to be
registered under the Exchange Act by operation of rule 12g-2 under the
Exchange Act.
21. By filing a registration statement under section 12 of the
Exchange Act, absent an exemption, Rand SBIC and each Future Subsidiary
would be required by section 13(a) of the Exchange Act to file
periodically with the Commission, even though their sole shareholder
will be Rand. Accordingly, applicants request an order under section
12(h) of the Exchange Act exempting Rand SBIC and each Future
Subsidiary from the reporting requirements of section 13(a) of the
Exchange Act to permit the filing of consolidated reports with Rand.
22. Section 12(h) of the Exchange Act provides that the Commission
may exempt an issuer from section 13 of the Exchange Act if the
Commission finds that by reason of the number of public investors,
amount of trading interest in the securities, the nature and extent of
the activities of the issuer, income or assets of the issuer, or
otherwise, that such action is not inconsistent with the public
interest or the protection of investors. Each of the Subsidiaries will
have only one investor, which is itself a reporting company, and no
public investors. There will be no trading in the Subsidiaries
securities, so no public interest or investor protective purpose will
be served by separate Subsidiary reporting. Further, applicants state
that the nature and extent of the Subsidiaries' activities are such
that their activities will be fully reported through consolidated
reporting in accordance with normal accounting rules. Accordingly,
applicants believe that the requested exemption meets the standards of
section 12(h) of the Exchange Act.
[[Page 6160]]
Applicants' Conditions
Applicants agree that the requested order will be subject to the
following conditions:
1. Rand will at all times own and hold, beneficially and of record,
all of the outstanding voting capital stock of each of the
Subsidiaries.
2. The Subsidiaries will have investment policies not inconsistent
with those of Rand, as set forth in Rand's registration statement.
3. No person shall serve as investment adviser or principal
underwriter to Rand SBIC or any Subsidiary unless the Rand Board and
the shareholders of Rand shall have taken the same action with respect
thereto also required to be taken by the board of directors and the
sole shareholder of such Subsidiary.
4. Rand will not itself issue or sell any senior security, and Rand
will not cause or permit any Subsidiary to issue or sell any senior
security of which Rand or such Subsidiary is the issuer except to the
extent permitted by section 18 (as modified for BDCs by section 61) of
the Act; provided that immediately after the issuance or sale of any
such senior security by either Rand or any Subsidiary, Rand and its
Subsidiaries on a consolidated basis, and Rand individually, shall have
the asset coverage required by section 18(a) (as modified for BDCs by
section 61(a)), except that, in determining whether Rand and its
Subsidiaries on a consolidated basis have the asset coverage required
by section 61(a), any SBA preferred stock interest in any SBIC
Subsidiary and any borrowings by any SBIC Subsidiary shall not be
considered senior securities and, for purposes of the definition of
``asset coverage'' in section 18(h), shall be treated as indebtedness
not represented by senior securities.
5. No person shall serve as a member of any board of directors of
any Subsidiary unless such person shall also serve as a member of the
Rand Board. The board of directors of any Subsidiary will be elected by
Rand as the sole shareholder of such Subsidiary.
6. Rand and any Subsidiary will acquire securities representing
indebtedness of Rand SBIC or any SBIC Subsidiary only if, in each case,
the prior approval of the SBA has been obtained. In addition, the SBIC
Subsidiaries, on the one hand, and Rand or any other Subsidiary on the
other hand, will purchase and sell portfolio securities between
themselves only if, in each case, the prior approval of the SBA has
been obtained.
For the Commission, by the Division of Investment Management,
pursuant to delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2012-2670 Filed 2-6-12; 8:45 am]
BILLING CODE 8011-01-P