IndexIQ Advisors LLC and IndexIQ Active ETF Trust; Notice of Application, 49839-49846 [2012-20264]
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Federal Register / Vol. 77, No. 160 / Friday, August 17, 2012 / Notices
data feed from OPRA’s processor rather
than an ‘‘indirect’’ data feed from an
OPRA Vendor. In this case, the
Professional Subscriber would be
required to pay the Direct Access Fee as
well as the Non-Display Application
Fee, even if the direct data feed to the
trading engine is the only data feed
received by the Professional
Subscriber.8
As noted above, any Professional
Subscriber that wants to receive an
indirect data feed of OPRA Data must
sign an Indirect Access Rider to its
Professional Subscriber Agreement, and
any Professional Subscriber that wants
to receive a direct data feed of OPRA
data must sign an Direct Access Rider to
its Professional Subscriber Agreement.
In either case, the Professional
Subscriber must provide OPRA with an
‘‘Exhibit A’’ to the Rider, in which it
describes its intended use of the OPRA
data, and both Riders require
Professional Subscribers to report their
use of OPRA data on a monthly basis.
These requirements would apply to a
Professional Subscriber that wants to
have a Non-Display Application receive
OPRA data. OPRA’s current form of
Exhibit A should provide OPRA staff
with the information that it needs to
generate invoices for the Non-Display
Application Fee.
OPRA believes that the use of NonDisplay Applications by active trading
firms is becoming increasingly common,
and that this use has resulted, and will
continue to result, in a significant
reduction in the number of devices and
user IDs that are reported to it.9 OPRA
believes that its Fee Schedule as revised
to include the new Non-Display
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8 OPRA
believes that it is fair and appropriate to
charge a Direct Access Fee for a ‘‘direct’’ data feed
connection to a Non-Display Application, but not
to charge an Indirect Access Fee for an ‘‘indirect’’
data feed connection to a Non-Display Application,
because of the differences in the Indirect Access Fee
and the Direct Access Fee: The Indirect Access Fee
is $600/month per Professional Subscriber,
regardless of the number of indirect data feed
connections that a particular Subscriber has,
whereas the Direct Access Fee is $1,000/month for
the first circuit connection, with no charge for one
back-up circuit connection and a charge of $100 per
connection for any additional connections. These
differences, in turn, reflect that OPRA does not
directly provide additional service when a
Professional Subscriber adds additional indirect
connections (because an OPRA Vendor is providing
the additional connections), but that OPRA does
provide additional service when a Professional
Subscriber adds additional direct connections.
9 In 2004, an average of 223,000 devices and User
IDs were reported to OPRA in each month of the
year. In 2011, an average of 164,000 devices and
User IDs were reported to OPRA in each month of
the year, a reduction over that eight year period of
approximately 26%. OPRA does not have a basis for
estimating the portion of that reduction that might
be due to the use of Non-Display Applications, but
does believe that the use of Non-Display
Applications contributed to the reduction.
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Application Fee will more fairly allocate
to Non-Display Applications a share of
the overall costs of OPRA and its
member exchanges to which OPRA’s
fees may properly be applied.
The text of the proposed amendment
to the OPRA Plan is available at OPRA,
the Commission’s Public Reference
Room, https://opradata.com, and on the
Commission’s Web site at www.sec.gov.
II. Implementation of the OPRA Plan
Amendment
OPRA designated this amendment as
qualified to be put into effect upon
filing with the Commission in
accordance with clause (i) of paragraph
(b)(3) of Rule 608 under the Act.10
OPRA intends to implement the
amendment on October 1, 2012.
The Commission may summarily
abrogate the amendment within sixty
days of its filing and require refiling and
approval of the amendment by
Commission order pursuant to Rule
608(b)(2) under the Act 11 if it appears
to the Commission that such action is
necessary or appropriate in the public
interest, for the protection of investors,
or the maintenance of fair and orderly
markets, to remove impediments to, and
perfect the mechanisms of, a national
market system, or otherwise in
furtherance of the purposes of the Act.
III. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed OPRA
Plan amendment is consistent with the
Act. Comments may be submitted by
any of the following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rulecomments@sec.gov. Please include File
No. SR–OPRA–2012–04 on the subject
line.
Paper Comments
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
100 F Street NE., Washington, DC
20549–1090.
All submissions should refer to File
Number SR–OPRA–2012–04. This file
number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
10 17
11 17
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CFR 242.608(b)(2).
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49839
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed plan
amendment that are filed with the
Commission, and all written
communications relating to the
proposed plan amendment between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of 1
a.m. and 3 p.m. Copies of such filing
also will be available for inspection and
copying at the principal office of OPRA.
All comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to File
Number SR–OPRA–2012–04 and should
be submitted on or before September 7,
2012.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.12
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2012–20263 Filed 8–16–12; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
30166; 812–13956]
IndexIQ Advisors LLC and IndexIQ
Active ETF Trust; Notice of Application
August 13, 2012.
Securities and Exchange
Commission (‘‘Commission’’).
AGENCY:
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) for an exemption from
sections 12(d)(1)(A) and (B) of the Act.
ACTION:
12 17
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CFR 200.30–3(a)(29).
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Federal Register / Vol. 77, No. 160 / Friday, August 17, 2012 / Notices
IndexIQ Advisors LLC
(‘‘IndexIQ’’) and IndexIQ Active ETF
Trust (the ‘‘Trust’’).
SUMMARY OF APPLICATION: Applicants
request an order that permits: (a)
Actively-managed series of certain
open-end management investment
companies to issue shares (‘‘Shares’’)
redeemable in large aggregations only
(‘‘Creation Units’’); (b) secondary market
transactions in Shares to occur at
negotiated market prices; (c) certain
series to pay redemption proceeds,
under certain circumstances, more than
seven days 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.
FILING DATES: The application was filed
on September 9, 2011, and amended on
March 27, 2012, July 6, 2012, and July
16, 2012. Applicants have agreed to file
an amendment during the notice period,
the substance of which is reflected in
this notice.
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 September 7, 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: Elizabeth M. Murphy,
Secretary, U.S. Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
Applicants, 800 Westchester Drive,
Suite N–611, Rye Brook, NY 10573.
FOR FURTHER INFORMATION CONTACT: Jean
E. Minarick, Senior Counsel, at (202)
551–6811 or Daniele Marchesani,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Office of Investment Company
Regulation).
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APPLICANTS:
SUPPLEMENTARY INFORMATION:
The
following is a summary of the
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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 will be 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
offer three actively-managed investment
series, IQ Global Equity Active ETF
(‘‘Global Equity ETF’’), IQ Global Fixed
Income Active ETF (‘‘Global Fixed
Income ETF’’) and IQ Long-Short Active
ETF (‘‘Long-Short ETF’’) (together, the
‘‘Initial Funds’’). The investment
objective of the Global Equity ETF will
be to seek long-term capital appreciation
by investing primarily in U.S. and
international equity securities. The
investment objective of the Global Fixed
Income ETF will be to seek as high a
level of current income as is consistent
with preservation of capital. The
investment objective of the Long-Short
ETF will be to seek long-term capital
appreciation by investing primarily in
U.S. and international equity securities.
2. IndexIQ, a Delaware limited
liability company, will serve as
investment adviser to the Initial Funds.
An Adviser (as defined below) may in
the future retain one or more subadvisers (‘‘Fund Sub-Advisers’’) to
manage the portfolio of the Funds (as
defined below). Any other Adviser and
any Fund Sub-Adviser will be registered
or exempt from registration under the
Investment Advisers Act of 1940
(‘‘Advisers Act’’). A registered brokerdealer under the Securities Exchange
Act of 1934 (‘‘Exchange Act’’), which
may be an affiliate of the Adviser, will
act as the distributor and principal
underwriter of the Funds
(‘‘Distributor’’).
3. Applicants request that the order
apply to the Initial Funds and any
future series of the Trust or of any other
open-end management companies that
may use active management investment
strategies (‘‘Future Funds’’). Any Future
Fund will (a) be advised by IndexIQ or
an entity controlling, controlled by, or
under common control with IndexIQ
(together with IndexIQ, an ‘‘Adviser’’),
and (b) comply with the terms and
conditions of the application.1 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
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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 and other
assets (‘‘Portfolio Instruments’’).2 Funds
may invest in ‘‘Depositary Receipts’’. A
Fund will not invest in any Depositary
Receipts that the Adviser deems to be
illiquid or for which pricing information
is not readily available.3 Each Fund will
operate as an actively managed
exchange-traded fund (‘‘ETF’’). The
Funds may invest in other open-end
and/or closed-end investment
companies and/or ETFs.
4. Applicants also request that any
exemption under section 12(d)(1)(J) of
the Act from sections 12(d)(1)(A) and
(B) apply to: (i) Any Fund that is
currently or subsequently part of the
same ‘‘group of investment companies’’
as an Initial Fund within the meaning
of section 12(d)(1)(G)(ii) of the Act; (ii)
any principal underwriter for the Fund;
(iii) any brokers selling Shares of a Fund
to an Investing Fund (as defined below);
and (iv) 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 within the
meaning of section 12(d)(1)(G)(ii) of the
Act and that enters into a FOF
Participation Agreement (as defined
below) with a Fund (such management
investment companies, ‘‘Investing
Management Companies,’’ such unit
investment trusts, ‘‘Investing Trusts,’’
and Investing Management Companies
and Investing Trusts together,
‘‘Investing Funds’’). Investing Funds do
not include the Funds.
5. Applicants anticipate that a
Creation Unit will consist of at least
50,000 Shares and that the price of a
Share will range from $15 to $100. 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 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
order only to invest in Funds and not in any other
registered investment company.
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 a Fund, Adviser or any Fund
Sub-Adviser will serve as the depositary bank for
any Depositary Receipts held by a Fund.
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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
Shares will be purchased and redeemed
in Creation Units and generally on an
in-kind basis. Except where the
purchase or redemption will include
cash under the limited circumstances
specified below, purchasers will be
required to purchase Creation Units by
making an in-kind deposit of specified
instruments (‘‘Deposit Instruments’’),
and shareholders redeeming their
Shares will receive an in-kind transfer
of specified instruments (‘‘Redemption
Instruments’’).4 On any given Business
Day 5 the names and quantities of the
instruments that constitute the Deposit
Instruments and the names and
quantities of the instruments that
constitute the Redemption Instruments
will be identical, and these instruments
may be referred to, in the case of either
a purchase or redemption, as the
‘‘Creation Basket.’’ In addition, the
Creation Basket will correspond pro rata
to the positions in a Fund’s portfolio
(including cash positions),6 except (a) in
the case of bonds, for minor differences
when it is impossible to break up bonds
beyond certain minimum sizes needed
for transfer and settlement; (b) for minor
differences when rounding is necessary
to eliminate fractional shares or lots that
are not tradeable round lots;7 or (c) TBA
Transactions,8 short positions and other
positions that cannot be transferred in
kind 9 will be excluded from the
4 The Funds must comply with the federal
securities laws in accepting Deposit Instruments
and satisfying redemptions with Redemption
Instruments, including that the Deposit Instruments
and Redemption Instruments are sold in
transactions that would be exempt from registration
under the Securities Act of 1933 (‘‘Securities Act’’).
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.
5 Each Fund will sell and redeem Creation Units
on any day the Fund is open, including as required
by section 22(e) of the Act (each, a ‘‘Business Day’’).
6 The portfolio used for this purpose will be the
same portfolio used to calculate the Fund’s NAV for
that Business Day.
7 A tradeable round lot for a security will be the
standard unit of trading in that particular type of
security in its primary market.
8 A TBA Transaction is a method of trading
mortgage-backed securities. In a TBA Transaction,
the buyer and seller agree on general trade
parameters such as agency, settlement date, par
amount and price.
9 This includes instruments that can be
transferred in kind only with the consent of the
original counterparty to the extent the Fund does
not intend to seek such consents.
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Creation Basket.10 If there is a difference
between the net asset value (‘‘NAV’’)
attributable to a Creation Unit and the
aggregate market value of the Creation
Basket exchanged for the Creation Unit,
the party conveying instruments with
the lower value will also pay to the
other an amount in cash equal to that
difference (the ‘‘Cash Amount’’).
6. Purchases and redemptions of
Creation Units may be made in whole or
in part on a cash basis, rather than in
kind, solely under the following
circumstances: (a) To the extent there is
a Cash Amount, as described above; (b)
if, on a given Business Day, a Fund
announces before the open of trading
that all purchases, all redemptions or all
purchases and redemptions on that day
will be made entirely in cash; (c) if,
upon receiving, a purchase or
redemption order from an Authorized
Participant, a Fund determines to
require the purchase or redemption, as
applicable, to be made entirely in cash;
(d) if, on a given Business Day, a Fund
requires all Authorized Participants
purchasing or redeeming Shares on that
day to deposit or receive (as applicable)
cash in lieu of some or all of the Deposit
Instruments or Redemption Instruments,
respectively, solely because (i) such
instruments are not eligible for transfer
through either the NSCC Process or DTC
Process; or (ii) in the case of Funds
holding securities traded on global
markets (‘‘Foreign Funds’’), such
instruments are not eligible for trading
due to local trading restrictions, local
restrictions on securities transfers or
other similar circumstances; or (e) if a
Fund permits an Authorized Participant
to deposit or receive (as applicable) cash
in lieu of some or all of the Deposit
Instruments or Redemption Instruments,
respectively, solely because: (i) Such
instruments are, in the case of the
purchase of a Creation Unit, not
available in sufficient quantity; (ii) such
instruments are not eligible for trading
by an Authorized Participant or the
investor on whose behalf the
Authorized Participant is acting; or (iii)
a holder of Shares of a Foreign Fund
would be subject to unfavorable income
tax treatment if the holder receives
redemption proceeds in kind.11
7. Each Business Day, before the open
of trading on a national securities
exchange as defined in section 2(a)(26)
of the Act (‘‘Stock Exchange’’), on which
Shares are listed, each Fund will cause
10 Because these instruments will be excluded
from the Creation Basket, their value will be
reflected in the determination of the Cash Amount
(as defined below).
11 A ‘‘custom order’’ is any purchase or
redemption of Shares made in whole or in part on
a cash basis in reliance on clause (e)(i) or (e)(ii).
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49841
to be published through the NSCC the
names and quantities of the instruments
comprising the Creation Basket, as well
as the estimated Cash Amount (if any),
for that day. The published Creation
Basket will apply until a new Creation
Basket is announced on the following
Business Day, and there will be no intraday changes to the Creation Basket
except to correct errors in the published
Creation Basket. A Stock Exchange will
disseminate every 15 seconds
throughout the trading day an amount
representing, on a per Share basis, the
sum of the current value of the Deposit
Instruments and the estimated Cash
Amount.
8. 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.12 All
orders to purchase Creation Units will
be placed with the Distributor by or
through an Authorized Participant, 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.
9. Shares will be listed and traded at
negotiated prices on a Stock Exchange
and traded in the secondary market.
Applicants expect that market makers
(‘‘Market Makers’’) will be assigned to
Shares. The price of Shares trading on
the Stock Exchange will be based on a
current bid/offer in the secondary
market. Transactions involving the
purchases and sales of Shares on the
Stock Exchange will be subject to
customary brokerage commissions and
charges.
10. Applicants expect that purchasers
of Creation Units will include
institutional investors and arbitrageurs.
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.13
12 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.
13 There will be at least one Market Maker on the
Stock Exchange for a Fund’s Shares (e.g., NYSE
Arca would designate a Lead Market Maker) to
maintain a market for such Fund’s Shares. No
Market Maker will be an affiliated person, or an
affiliated person of an affiliated person, of the
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Applicants expect that secondary
market purchasers of Shares will
include both institutional and retail
investors.14 Applicants expect that
arbitrage opportunities created by the
ability to continually purchase or
redeem Creation Units at their NAV per
Share should ensure that the Shares will
not trade at a material discount or
premium in relation to their NAV.
11. Shares will not be individually
redeemable and owners of Shares may
acquire those Shares from a Fund, or
tender such shares for redemption to the
Fund, in Creation Units only. To
redeem, an investor must accumulate
enough Shares to constitute a Creation
Unit. Redemption requests must be
placed by or through an Authorized
Participant. As discussed above,
redemptions of Creation Units will
generally be made on an in-kind basis,
subject to certain specified exceptions
under which redemptions may be made
in whole or in part on a cash basis, and
will be subject to a Transaction Fee.
12. 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.’’ In any
advertising material where features of
obtaining, buying or selling Shares
traded on the Stock Exchange are
described there will be an appropriate
statement to the effect that Shares are
not individually redeemable.
13. 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, held by the Fund that will
form the basis for the Fund’s calculation
of NAV at the end of the Business Day.15
Funds, except within section 2(a)(3)(A) or (C) of the
Act due to ownership of Shares, as described below.
14 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.
15 Applicants note that under accounting
procedures followed by the Funds, trades made on
the prior Business Day will be booked and reflected
in NAV on the current Business Day. Accordingly,
the Funds will be able to disclose at the beginning
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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 each Fund to 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
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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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 materially 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
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
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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.
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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 Foreign 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 15 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, up to a
maximum of 15 calendar days, in the
principal local markets where
transactions in the Portfolio Instruments
of each Foreign Fund customarily clear
and settle, but in all cases no later than
15 calendar days following the tender of
a Creation Unit.
8. Applicants state that section 22(e)
was designed to prevent unreasonable,
undisclosed and unforeseen delays in
the actual payment of redemption
proceeds. Applicants assert that the
requested relief will not lead to the
problems that section 22(e) was
designed to prevent. Applicants state
that allowing redemption payments for
Creation Units of a Fund to be made
within a maximum of 15 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
Foreign Fund. Applicants are not
seeking relief from section 22(e) with
respect to Foreign Funds that do not
effect creations or redemptions in-kind.
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Section 12(d)(1) of the Act
9. 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.
10. Applicants request relief to permit
Investing Funds 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 Broker to sell Shares to Investing
Funds in excess of the limits in section
12(d)(l)(B) of the Act. Applicants submit
that the proposed conditions to the
requested relief 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.
11. Applicants submit that their
proposed conditions address any
concerns regarding the potential for
undue influence. To limit the control
that an Investing Fund may have over a
Fund, applicants propose a condition
prohibiting the adviser of an Investing
Management Company (‘‘Investing Fund
Adviser’), sponsor of an Investing Trust
(‘‘Sponsor’’), any person controlling,
controlled by, or under common control
with the Investing Fund Adviser 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
Adviser, the Sponsor, or any person
controlling, controlled by, or under
common control with the Investing
Fund Adviser or Sponsor (‘‘Investing
Fund’s Advisory Group’’) from
controlling (individually or in the
aggregate) a Fund within the meaning of
section 2(a)(9) of the Act. The same
prohibition would apply to any subadviser to an Investing Management
Company (‘‘Sub-Adviser’’), any person
controlling, controlled by or under
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49843
common control with the Sub-Adviser,
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 Sub-Adviser or any
person controlling, controlled by or
under common control with the SubAdviser (‘‘Investing Fund’s SubAdvisory Group’’).
12. Applicants propose a condition to
ensure that no Investing Fund or
Investing Fund Affiliate 16 (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 Adviser, Sub-Adviser,
employee or Sponsor of the Investing
Fund, or a person of which any such
officer, director, member of an advisory
board, Investing Fund Adviser, SubAdviser, employee or Sponsor is an
affiliated person (except any person
whose relationship to the Fund is
covered by section 10(f) of the Act is not
an Underwriting Affiliate).
13. Applicants propose several
conditions to address the potential for
layering of fees. Applicants note that the
board of directors or trustees (‘‘Board’’)
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.
Applicants also state that any sales
charges and/or service fees charged with
respect to shares of an Investing Fund
will not exceed the limits applicable to
16 An ‘‘Investing Fund Affiliate’’ is any Investing
Fund Adviser, Sub-Adviser, Sponsor, promoter and
principal underwriter of an Investing Fund, and any
person controlling, controlled by or under common
control with any of these entities. ‘‘Fund Affiliate’’
is an investment adviser, promoter, or principal
underwriter of a Fund or any person controlling,
controlled by or under common control with any
of these entities.
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a fund of funds as set forth in NASD
Conduct Rule 2830.17
14. 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 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.
15. To ensure that an Investing Fund
is aware of the terms and conditions of
the requested order, the Investing Funds
must enter into an agreement with the
respective Funds (‘‘FOF Participation
Agreement’’). The FOF Participation
Agreement will include an
acknowledgement from the Investing
Fund that it may rely on the order only
to invest in a Fund and not in any other
investment company.
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Sections 17(a)(1) and (2) of the Act
16. 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
Adviser 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 Adviser (an ‘‘Affiliated Fund’’).
17. 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
17 Any reference to NASD Conduct Rule 2830
includes any successor or replacement rule that
may be adopted by the Financial Industry
Regulatory Authority.
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15:13 Aug 16, 2012
Jkt 226001
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.18 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 an affiliated person or a
second tier affiliate.19
18. 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 purchasers and
redeemers, respectively, and will
correspond pro rata to the Fund’s
Portfolio Instruments. The deposit
procedures for in-kind purchases of
Creation Units and the redemption
procedures for in-kind redemptions will
be the same 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. Applicants do not
believe that in-kind purchases and
redemptions will result in abusive selfdealing or overreaching of the Fund.
19. 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
18 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.
19 Applicants anticipate that most Investing
Funds will purchase Shares in the secondary
market and will not purchase Creation Units
directly from a Fund. To the extent purchases and
sales of Shares occur in the secondary market and
not through principal transactions directly between
and 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 intended to also cover the in-kind
transactions that would accompany such sales and
redemptions.
PO 00000
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Sfmt 4703
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.20
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. ETF Relief
1. As long as a Fund operates in
reliance on the requested order, the
Shares of the Funds 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
Creation Units or refers to redeemability
will prominently disclose that the
Shares are not individually redeemable
and that owners of the Shares may
purchase those Shares from the Fund
and tender those Shares for redemption
to the Fund in Creation Units only.
3. The Web site for each Fund, 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 listing Stock Exchange, the Fund
will disclose on its Web site the
identities and quantities of the Portfolio
Instruments 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 Adviser or Fund Sub-Adviser,
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
20 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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Act that provides relief permitting the
operation of actively-managed
exchange-traded funds.
B. 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
Sub-Adviser or a person controlling,
controlled by or under common control
with the Sub-Adviser 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 Adviser
and any Sub-Adviser 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 the Shares exceeds the limit in
section l2(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: (i) Is
fair and reasonable in relation to the
nature and quality of the services and
benefits received by the Fund; (ii) is
within the range of consideration that
the Fund would be required to pay to
another unaffiliated entity in connection
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15:13 Aug 16, 2012
Jkt 226001
with the same services or transactions;
and (iii) 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 Adviser, 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 Adviser, or Trustee
or Sponsor, or an affiliated person of the
Investing Fund Adviser, or Trustee or
Sponsor, other than any advisory fees
paid to the Investing Fund Adviser, or
Trustee or Sponsor, or its affiliated
person by the Fund, in connection with
the investment by the Investing Fund in
the Fund. Any Sub-Adviser will waive
fees otherwise payable to the SubAdviser, directly or indirectly, by the
Investing Management Company in an
amount at least equal to any
compensation received from a Fund by
the Sub-Adviser, or an affiliated person
of the Sub-Adviser, other than any
advisory fees paid to the Sub-Adviser 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 SubAdviser. In the event that the SubAdviser 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: (i) Whether the purchases
were consistent with the investment
objectives and policies of the Fund; (ii)
how the performance of securities
PO 00000
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49845
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 (iii)
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 ensure 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
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 limit 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
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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 a
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.
Jill M. Peterson,
Assistant Secretary.
SECURITIES AND EXCHANGE
COMMISSION
erowe on DSK2VPTVN1PROD with NOTICES
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 Wednesday, August 22, 2012 at 2:00
p.m. and Thursday, August 23, 2012 at
2:00 p.m.
Commissioners, Counsel to the
Commissioners, the Secretary to the
Commission, and recording secretaries
will attend the Closed Meetings. 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
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[FR Doc. 2012–20400 Filed 8–15–12; 4:15 pm]
BILLING CODE 8011–01–P
[Release No. 34–67644; File No. SR–CBOE–
2012–077]
BILLING CODE 8011–01–P
15:13 Aug 16, 2012
Dated: August 15, 2012.
Elizabeth M. Murphy,
Secretary.
SECURITIES AND EXCHANGE
COMMISSION
[FR Doc. 2012–20264 Filed 8–16–12; 8:45 am]
VerDate Mar<15>2010
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
Meetings.
Commissioner Paredes, as duty
officer, voted to consider the items
listed for the Closed Meetings in closed
sessions.
The subject matter of the Closed
Meeting scheduled for Wednesday,
August 22, 2012 will be a litigation
matter.
The subject matter of the Closed
Meeting scheduled for Thursday,
August 23, 2012 will be:
Institution and settlement of injunctive
actions;
Institution and settlement of
administrative proceedings; 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.
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Notice of Filing and
Immediate Effectiveness of a Proposed
Rule Change To Delay the
Implementation Date of Changes to
Market-Makers’ Continuous Quoting
Obligations
August 13, 2012.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on August 3,
2012, Chicago Board Options Exchange,
Incorporated (the ‘‘Exchange’’ or
‘‘CBOE’’) filed with the Securities and
Exchange Commission (the
‘‘Commission’’) the proposed rule
change as described in Items I and II
below, which Items have been prepared
by the Exchange. The Commission is
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
Frm 00073
Fmt 4703
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to delay the
implementation date of changes to
Market-Makers’ continuous quoting
obligations.
The text of the proposed rule change
is available on the Exchange’s Web site
(https://www.cboe.com/AboutCBOE/
CBOELegalRegulatoryHome.aspx), at
the Exchange’s Office of the Secretary,
and at the Commission.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in sections A, B, and C below, of
the most significant aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange recently submitted a
proposed rule change to amend Rule
1.1(ccc), ‘‘Continuous Electronic
Quotes,’’ to reduce to 90% the
percentage of time for which a MarketMaker is required to provide electronic
quotes in an appointed option class on
a given trading day.3 That filing also
included a proposed rule change to
amend Rules 8.13, 8.15A, 8.85, and 8.93
to increase to the lesser of 99% or 100%
minus one call-put pair the percentage
of series in each class in which
Preferred Market-Makers, Lead MarketMakers, Designated Primary MarketMakers, and Electronic Designated
Primary Market-Makers, respectively
(collectively, ‘‘Market-Makers’’), must
provide continuous electronic quotes.
The Exchange is proposing to delay
implementation of these changes to
allow Market-Makers more time to make
necessary system changes to comply
with these new quoting obligations. The
Exchange will announce the
3 Securities Exchange Act Release No. 34–67410
(July 11, 2012), 77 FR 42040 (July 17, 2012) (SR–
CBOE–2012–064).
1 15
PO 00000
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
Sfmt 4703
E:\FR\FM\17AUN1.SGM
17AUN1
Agencies
[Federal Register Volume 77, Number 160 (Friday, August 17, 2012)]
[Notices]
[Pages 49839-49846]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-20264]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 30166; 812-13956]
IndexIQ Advisors LLC and IndexIQ Active ETF Trust; Notice of
Application
August 13, 2012.
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)
for an exemption from sections 12(d)(1)(A) and (B) of the Act.
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[[Page 49840]]
APPLICANTS: IndexIQ Advisors LLC (``IndexIQ'') and IndexIQ Active ETF
Trust (the ``Trust'').
SUMMARY OF APPLICATION: Applicants request an order that permits: (a)
Actively-managed series of certain open-end management investment
companies to issue shares (``Shares'') redeemable in large aggregations
only (``Creation Units''); (b) secondary market transactions in Shares
to occur at negotiated market prices; (c) certain series to pay
redemption proceeds, under certain circumstances, more than seven days
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.
FILING DATES: The application was filed on September 9, 2011, and
amended on March 27, 2012, July 6, 2012, and July 16, 2012. Applicants
have agreed to file an amendment during the notice period, the
substance of which is reflected in this notice.
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 September 7, 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: Elizabeth M. Murphy, Secretary, U.S. Securities and Exchange
Commission, 100 F Street NE., Washington, DC 20549-1090. Applicants,
800 Westchester Drive, Suite N-611, Rye Brook, NY 10573.
FOR FURTHER INFORMATION CONTACT: Jean E. Minarick, Senior Counsel, at
(202) 551-6811 or Daniele Marchesani, Branch Chief, at (202) 551-6821
(Division of Investment Management, Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or an applicant
using the Company name box, at https://www.sec.gov/search/search.htm or
by calling (202) 551-8090.
Applicants' Representations
1. The Trust will be 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 offer three
actively-managed investment series, IQ Global Equity Active ETF
(``Global Equity ETF''), IQ Global Fixed Income Active ETF (``Global
Fixed Income ETF'') and IQ Long-Short Active ETF (``Long-Short ETF'')
(together, the ``Initial Funds''). The investment objective of the
Global Equity ETF will be to seek long-term capital appreciation by
investing primarily in U.S. and international equity securities. The
investment objective of the Global Fixed Income ETF will be to seek as
high a level of current income as is consistent with preservation of
capital. The investment objective of the Long-Short ETF will be to seek
long-term capital appreciation by investing primarily in U.S. and
international equity securities.
2. IndexIQ, a Delaware limited liability company, will serve as
investment adviser to the Initial Funds. An Adviser (as defined below)
may in the future retain one or more sub-advisers (``Fund Sub-
Advisers'') to manage the portfolio of the Funds (as defined below).
Any other Adviser and any Fund Sub-Adviser will be registered or exempt
from registration under the Investment Advisers Act of 1940 (``Advisers
Act''). A registered broker-dealer under the Securities Exchange Act of
1934 (``Exchange Act''), which may be an affiliate of the Adviser, will
act as the distributor and principal underwriter of the Funds
(``Distributor'').
3. Applicants request that the order apply to the Initial Funds and
any future series of the Trust or of any other open-end management
companies that may use active management investment strategies
(``Future Funds''). Any Future Fund will (a) be advised by IndexIQ or
an entity controlling, controlled by, or under common control with
IndexIQ (together with IndexIQ, an ``Adviser''), 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 and other assets (``Portfolio
Instruments'').\2\ Funds may invest in ``Depositary Receipts''. A Fund
will not invest in any Depositary Receipts that the Adviser deems to be
illiquid or for which pricing information is not readily available.\3\
Each Fund will operate as an actively managed exchange-traded fund
(``ETF''). The Funds may 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.
\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 a Fund, Adviser or any Fund Sub-Adviser
will serve as the depositary bank for any Depositary Receipts held
by a Fund.
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4. Applicants also request that any exemption under section
12(d)(1)(J) of the Act from sections 12(d)(1)(A) and (B) apply to: (i)
Any Fund that is currently or subsequently part of the same ``group of
investment companies'' as an Initial Fund within the meaning of section
12(d)(1)(G)(ii) of the Act; (ii) any principal underwriter for the
Fund; (iii) any brokers selling Shares of a Fund to an Investing Fund
(as defined below); and (iv) 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 within the meaning of
section 12(d)(1)(G)(ii) of the Act and that enters into a FOF
Participation Agreement (as defined below) with a Fund (such management
investment companies, ``Investing Management Companies,'' such unit
investment trusts, ``Investing Trusts,'' and Investing Management
Companies and Investing Trusts together, ``Investing Funds'').
Investing Funds do not include the Funds.
5. Applicants anticipate that a Creation Unit will consist of at
least 50,000 Shares and that the price of a Share will range from $15
to $100. 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 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
[[Page 49841]]
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 Shares will be purchased
and redeemed in Creation Units and generally on an in-kind basis.
Except where the purchase or redemption will include cash under the
limited circumstances specified below, purchasers will be required to
purchase Creation Units by making an in-kind deposit of specified
instruments (``Deposit Instruments''), and shareholders redeeming their
Shares will receive an in-kind transfer of specified instruments
(``Redemption Instruments'').\4\ On any given Business Day \5\ the
names and quantities of the instruments that constitute the Deposit
Instruments and the names and quantities of the instruments that
constitute the Redemption Instruments will be identical, and these
instruments may be referred to, in the case of either a purchase or
redemption, as the ``Creation Basket.'' In addition, the Creation
Basket will correspond pro rata to the positions in a Fund's portfolio
(including cash positions),\6\ except (a) in the case of bonds, for
minor differences when it is impossible to break up bonds beyond
certain minimum sizes needed for transfer and settlement; (b) for minor
differences when rounding is necessary to eliminate fractional shares
or lots that are not tradeable round lots;\7\ or (c) TBA
Transactions,\8\ short positions and other positions that cannot be
transferred in kind \9\ will be excluded from the Creation Basket.\10\
If there is a difference between the net asset value (``NAV'')
attributable to a Creation Unit and the aggregate market value of the
Creation Basket exchanged for the Creation Unit, the party conveying
instruments with the lower value will also pay to the other an amount
in cash equal to that difference (the ``Cash Amount'').
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\4\ The Funds must comply with the federal securities laws in
accepting Deposit Instruments and satisfying redemptions with
Redemption Instruments, including that the Deposit Instruments and
Redemption Instruments are sold in transactions that would be exempt
from registration under the Securities Act of 1933 (``Securities
Act''). 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.
\5\ Each Fund will sell and redeem Creation Units on any day the
Fund is open, including as required by section 22(e) of the Act
(each, a ``Business Day'').
\6\ The portfolio used for this purpose will be the same
portfolio used to calculate the Fund's NAV for that Business Day.
\7\ A tradeable round lot for a security will be the standard
unit of trading in that particular type of security in its primary
market.
\8\ A TBA Transaction is a method of trading mortgage-backed
securities. In a TBA Transaction, the buyer and seller agree on
general trade parameters such as agency, settlement date, par amount
and price.
\9\ This includes instruments that can be transferred in kind
only with the consent of the original counterparty to the extent the
Fund does not intend to seek such consents.
\10\ Because these instruments will be excluded from the
Creation Basket, their value will be reflected in the determination
of the Cash Amount (as defined below).
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6. Purchases and redemptions of Creation Units may be made in whole
or in part on a cash basis, rather than in kind, solely under the
following circumstances: (a) To the extent there is a Cash Amount, as
described above; (b) if, on a given Business Day, a Fund announces
before the open of trading that all purchases, all redemptions or all
purchases and redemptions on that day will be made entirely in cash;
(c) if, upon receiving, a purchase or redemption order from an
Authorized Participant, a Fund determines to require the purchase or
redemption, as applicable, to be made entirely in cash; (d) if, on a
given Business Day, a Fund requires all Authorized Participants
purchasing or redeeming Shares on that day to deposit or receive (as
applicable) cash in lieu of some or all of the Deposit Instruments or
Redemption Instruments, respectively, solely because (i) such
instruments are not eligible for transfer through either the NSCC
Process or DTC Process; or (ii) in the case of Funds holding securities
traded on global markets (``Foreign Funds''), such instruments are not
eligible for trading due to local trading restrictions, local
restrictions on securities transfers or other similar circumstances; or
(e) if a Fund permits an Authorized Participant to deposit or receive
(as applicable) cash in lieu of some or all of the Deposit Instruments
or Redemption Instruments, respectively, solely because: (i) Such
instruments are, in the case of the purchase of a Creation Unit, not
available in sufficient quantity; (ii) such instruments are not
eligible for trading by an Authorized Participant or the investor on
whose behalf the Authorized Participant is acting; or (iii) a holder of
Shares of a Foreign Fund would be subject to unfavorable income tax
treatment if the holder receives redemption proceeds in kind.\11\
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\11\ A ``custom order'' is any purchase or redemption of Shares
made in whole or in part on a cash basis in reliance on clause
(e)(i) or (e)(ii).
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7. Each Business Day, before the open of trading on a national
securities exchange as defined in section 2(a)(26) of the Act (``Stock
Exchange''), on which Shares are listed, each Fund will cause to be
published through the NSCC the names and quantities of the instruments
comprising the Creation Basket, as well as the estimated Cash Amount
(if any), for that day. The published Creation Basket will apply until
a new Creation Basket is announced on the following Business Day, and
there will be no intra-day changes to the Creation Basket except to
correct errors in the published Creation Basket. A Stock Exchange will
disseminate every 15 seconds throughout the trading day an amount
representing, on a per Share basis, the sum of the current value of the
Deposit Instruments and the estimated Cash Amount.
8. 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.\12\ All orders to purchase
Creation Units will be placed with the Distributor by or through an
Authorized Participant, 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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\12\ 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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9. Shares will be listed and traded at negotiated prices on a Stock
Exchange and traded in the secondary market. Applicants expect that
market makers (``Market Makers'') will be assigned to Shares. The price
of Shares trading on the Stock Exchange will be based on a current bid/
offer in the secondary market. Transactions involving the purchases and
sales of Shares on the Stock Exchange will be subject to customary
brokerage commissions and charges.
10. Applicants expect that purchasers of Creation Units will
include institutional investors and arbitrageurs. 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.\13\
[[Page 49842]]
Applicants expect that secondary market purchasers of Shares will
include both institutional and retail investors.\14\ Applicants expect
that arbitrage opportunities created by the ability to continually
purchase or redeem Creation Units at their NAV per Share should ensure
that the Shares will not trade at a material discount or premium in
relation to their NAV.
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\13\ There will be at least one Market Maker on the Stock
Exchange for a Fund's Shares (e.g., NYSE Arca would designate a Lead
Market Maker) to maintain a market for such Fund's Shares. No Market
Maker will be an affiliated person, or an affiliated person of an
affiliated person, of the Funds, except within section 2(a)(3)(A) or
(C) of the Act due to ownership of Shares, as described below.
\14\ 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.
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11. Shares will not be individually redeemable and owners of Shares
may acquire those Shares from a Fund, or tender such shares for
redemption to the Fund, in Creation Units only. To redeem, an investor
must accumulate enough Shares to constitute a Creation Unit. Redemption
requests must be placed by or through an Authorized Participant. As
discussed above, redemptions of Creation Units will generally be made
on an in-kind basis, subject to certain specified exceptions under
which redemptions may be made in whole or in part on a cash basis, and
will be subject to a Transaction Fee.
12. 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.'' In any advertising
material where features of obtaining, buying or selling Shares traded
on the Stock Exchange are described there will be an appropriate
statement to the effect that Shares are not individually redeemable.
13. 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, held by the
Fund that will form the basis for the Fund's calculation of NAV at the
end of the Business Day.\15\
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\15\ Applicants note that under accounting procedures followed
by the Funds, trades made on the prior Business Day will be booked
and reflected in NAV on the current Business Day. 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 each Fund to 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 materially 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
[[Page 49843]]
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 Foreign
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 15 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, up
to a maximum of 15 calendar days, in the principal local markets where
transactions in the Portfolio Instruments of each Foreign Fund
customarily clear and settle, but in all cases no later than 15
calendar days following the tender of a Creation Unit.
8. Applicants state that section 22(e) was designed to prevent
unreasonable, undisclosed and unforeseen delays in the actual payment
of redemption proceeds. Applicants assert that the requested relief
will not lead to the problems that section 22(e) was designed to
prevent. Applicants state that allowing redemption payments for
Creation Units of a Fund to be made within a maximum of 15 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 Foreign Fund. Applicants are
not seeking relief from section 22(e) with respect to Foreign Funds
that do not effect creations or redemptions in-kind.
Section 12(d)(1) of the Act
9. 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.
10. Applicants request relief to permit Investing Funds 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 Broker to sell
Shares to Investing Funds in excess of the limits in section
12(d)(l)(B) of the Act. Applicants submit that the proposed conditions
to the requested relief 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.
11. Applicants submit that their proposed conditions address any
concerns regarding the potential for undue influence. To limit the
control that an Investing Fund may have over a Fund, applicants propose
a condition prohibiting the adviser of an Investing Management Company
(``Investing Fund Adviser'), sponsor of an Investing Trust
(``Sponsor''), any person controlling, controlled by, or under common
control with the Investing Fund Adviser 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 Adviser, the Sponsor, or any person controlling,
controlled by, or under common control with the Investing Fund Adviser
or Sponsor (``Investing Fund's Advisory Group'') from controlling
(individually or in the aggregate) a Fund within the meaning of section
2(a)(9) of the Act. The same prohibition would apply to any sub-adviser
to an Investing Management Company (``Sub-Adviser''), any person
controlling, controlled by or under common control with the Sub-
Adviser, 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 Sub-Adviser or any person controlling, controlled by or under
common control with the Sub-Adviser (``Investing Fund's Sub-Advisory
Group'').
12. Applicants propose a condition to ensure that no Investing Fund
or Investing Fund Affiliate \16\ (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 Adviser, Sub-Adviser, employee or
Sponsor of the Investing Fund, or a person of which any such officer,
director, member of an advisory board, Investing Fund Adviser, Sub-
Adviser, employee or Sponsor is an affiliated person (except any person
whose relationship to the Fund is covered by section 10(f) of the Act
is not an Underwriting Affiliate).
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\16\ An ``Investing Fund Affiliate'' is any Investing Fund
Adviser, Sub-Adviser, Sponsor, promoter and principal underwriter of
an Investing Fund, and any person controlling, controlled by or
under common control with any of these entities. ``Fund Affiliate''
is an investment adviser, promoter, or principal underwriter of a
Fund or any person controlling, controlled by or under common
control with any of these entities.
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13. Applicants propose several conditions to address the potential
for layering of fees. Applicants note that the board of directors or
trustees (``Board'') 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. Applicants also state that any
sales charges and/or service fees charged with respect to shares of an
Investing Fund will not exceed the limits applicable to
[[Page 49844]]
a fund of funds as set forth in NASD Conduct Rule 2830.\17\
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\17\ Any reference to NASD Conduct Rule 2830 includes any
successor or replacement rule that may be adopted by the Financial
Industry Regulatory Authority.
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14. 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 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.
15. To ensure that an Investing Fund is aware of the terms and
conditions of the requested order, the Investing Funds must enter into
an agreement with the respective Funds (``FOF Participation
Agreement''). The FOF Participation Agreement will include an
acknowledgement from the Investing Fund that it may rely on the order
only to invest in a Fund and not in any other investment company.
Sections 17(a)(1) and (2) of the Act
16. 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 Adviser 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 Adviser (an ``Affiliated Fund'').
17. 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.\18\ 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 an affiliated person or a second tier
affiliate.\19\
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\18\ 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.
\19\ Applicants anticipate that most Investing Funds will
purchase Shares in the secondary market and will not purchase
Creation Units directly from a Fund. To the extent purchases and
sales of Shares occur in the secondary market and not through
principal transactions directly between and 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 intended to also cover the in-kind
transactions that would accompany such sales and redemptions.
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18. 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 purchasers and redeemers, respectively, and will
correspond pro rata to the Fund's Portfolio Instruments. The deposit
procedures for in-kind purchases of Creation Units and the redemption
procedures for in-kind redemptions will be the same 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. Applicants do not believe that in-kind purchases
and redemptions will result in abusive self-dealing or overreaching of
the Fund.
19. 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.\20\ 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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\20\ 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. ETF Relief
1. As long as a Fund operates in reliance on the requested order,
the Shares of the Funds 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 Creation Units or
refers to redeemability will prominently disclose that the Shares are
not individually redeemable and that owners of the Shares may purchase
those Shares from the Fund and tender those Shares for redemption to
the Fund in Creation Units only.
3. The Web site for each Fund, 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 listing Stock Exchange, the Fund will disclose on its Web site
the identities and quantities of the Portfolio Instruments 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 Adviser or Fund Sub-Adviser, 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
[[Page 49845]]
Act that provides relief permitting the operation of actively-managed
exchange-traded funds.
B. 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 Sub-
Adviser or a person controlling, controlled by or under common control
with the Sub-Adviser 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 Adviser and any Sub-Adviser 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 the Shares exceeds
the limit in section l2(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: (i) Is fair and reasonable in relation to the nature and
quality of the services and benefits received by the Fund; (ii) 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 (iii) 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 Adviser, 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 Adviser, or Trustee
or Sponsor, or an affiliated person of the Investing Fund Adviser, or
Trustee or Sponsor, other than any advisory fees paid to the Investing
Fund Adviser, or Trustee or Sponsor, or its affiliated person by the
Fund, in connection with the investment by the Investing Fund in the
Fund. Any Sub-Adviser will waive fees otherwise payable to the Sub-
Adviser, directly or indirectly, by the Investing Management Company in
an amount at least equal to any compensation received from a Fund by
the Sub-Adviser, or an affiliated person of the Sub-Adviser, other than
any advisory fees paid to the Sub-Adviser 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 Sub-Adviser. In the
event that the Sub-Adviser 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: (i) Whether the purchases were consistent with the
investment objectives and policies of the Fund; (ii) 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
(iii) 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 ensure 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 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 limit 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
[[Page 49846]]
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 a 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.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2012-20264 Filed 8-16-12; 8:45 am]
BILLING CODE 8011-01-P