Cash Account Trust, et al.; Notice of Application, 55235-55240 [2012-22017]
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Federal Register / Vol. 77, No. 174 / Friday, September 7, 2012 / Notices
Morgan Stanley Special Growth Fund
[File No. 811–6711]
Summary: Applicant seeks an order
declaring that it has ceased to be an
investment company. The applicant has
transferred its assets to Morgan Stanley
Institutional Fund, Inc. and, on
November 14, 2011, made a final
distribution to its shareholders based on
net asset value. Expenses of
approximately $203,828 incurred in
connection with the reorganization were
paid by applicant.
Filing Dates: The application was
filed on June 13, 2012, and amended on
July 31, 2012.
Applicant’s Address: c/o Morgan
Stanley Investment Management Inc.,
522 Fifth Ave., New York, NY 10036.
Thirty Eight Hundred Fund LLC
[File No. 811–22158]
Summary: Applicant, a closed-end
investment company, seeks an order
declaring that it has ceased to be an
investment company. Applicant
currently has a single beneficial owner,
is not presently making an offering of
securities and does not propose to make
any offering of securities. Applicant will
continue to operate as a private
investment fund in reliance on section
3(c)(1) of the Act.
Filing Dates: The application was
filed on July 9, 2012, and amended on
August 27, 2012.
Applicant’s Address: 3800 Howard
Hughes Parkway, Suite 900, 605 Third
Ave., 2nd Floor, Las Vegas, NV 89169–
0925.
Separate Account II of Integrity Life
Insurance Company
[File No. 811–7134]
Separate Account II of National
Integrity Life Insurance Company
[File No. 811–7132]
Western-Southern Life Assurance
Company Separate Account 2
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[File No. 811–8550]
Summary: Each Applicant seeks an
order declaring that it has ceased to be
an investment company. Each Applicant
is a registered separate account that is
organized as a unit investment trust.
The management of each Applicant’s
depositor gave final authorization for
the consolidation of the applicable
Applicant with another registered
separate account of the depositor on
October 19, 2011. Each depositor bore
all of the applicable merger expenses.
Applicants have no assets, debts or any
other liabilities. Applicants are not
parties to any litigation or
administrative proceeding and are not
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engaged in or intending to engage in any
business activities.
Filing Dates: Each Applicant’s
application was filed on June 28, 2012
and amended on August 17, 2012.
Applicants’ Address: 400 Broadway,
Cincinnati, OH 45202.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2012–22057 Filed 9–6–12; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
30188; 812–13933]
Cash Account Trust, et al.; Notice of
Application
August 31, 2012.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under sections 6(c) and 17(b) of
the Investment Company Act of 1940
(the ‘‘Act’’) for an exemption from
section 17(a) of the Act.
AGENCY:
Applicants: Cash Account Trust, on
behalf of its series, Government &
Agency Securities Portfolio and Money
Market Portfolio; Cash Management
Portfolio; Cash Reserve Fund, Inc., on
behalf of its series, Prime Series; DWS
Money Funds, on behalf of its series,
DWS Money Market Prime Series; DWS
Money Market Trust, on behalf of its
series, DWS Money Market Series, Cash
Management Fund, Cash Reserves Fund
Institutional, and Daily Assets Fund
Institutional; DWS Variable Series II, on
behalf of its series, DWS Money Market
VIP; and Investors Cash Trust, on behalf
of its series, Treasury Portfolio, Central
Cash Management Fund and DWS
Variable NAV Money Fund
(collectively, the ‘‘DWS Funds’’),
Deutsche Investment Management
Americas Inc. (‘‘DIMA’’), and Deutsche
Bank Securities, Inc. (‘‘DBSI’’).
SUMMARY: Summary of Application:
Applicants request an order to permit
the Money Market Portfolios (as defined
below) to engage in principal
transactions in certain taxable money
market instruments including
repurchase agreements with DBSI.
DATES: Filing Dates: The application
was filed on August 1, 2011, and
amended on January 27, 2012, and July
20, 2012.
Hearing or Notification of Hearing: An
order granting the application will be
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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 24, 2012,
and should be accompanied by proof of
service on the 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 may request
notification of a hearing by writing to
the Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
Applicants: the DWS Funds and DIMA,
345 Park Avenue, New York, NY 10154;
DBSI, 60 Wall Street, New York, NY
10005.
FOR FURTHER INFORMATION CONTACT:
Christine Y. Greenlees, Senior Counsel,
(202) 551–6879 or Mary Kay Frech,
Branch Chief, (202) 551–6821 (Office of
Investment Company Regulation,
Division of Investment Management).
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 DWS Funds are each a
Massachusetts business trust (or, in the
case of Cash Reserve Fund Inc., a
Maryland corporation), each is
registered under the Act as an open-end
management investment company, and
each has one or more series that operate
as money market funds subject to rule
2a–7 under the Act (‘‘Rule 2a–7’’). In
addition to the DWS Funds and their
series that operate as money market
funds subject to Rule 2a–7, relief is
requested for any other existing or
future funds registered under the Act
that operate as money market funds
subject to Rule 2a–7 under the Act and
are advised or subadvised by an Adviser
(as defined below). All such investment
companies and their series that operate
as money market funds subject to Rule
2a–7 under the Act, including DWS
Funds and their series, are referred to
individually as a ‘‘Money Market
Portfolio’’ and collectively as the
‘‘Money Market Portfolios.’’ Any Money
Market Portfolios not existing as of the
date of the application or that currently
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do not intend to rely on the requested
order are referred to individually as a
‘‘Future Money Market Portfolio’’ and
collectively as the ‘‘Future Money
Market Portfolios.’’ 1
2. DIMA, a Delaware corporation and
wholly owned subsidiary of Deutsche
Bank Americas Holding Corporation, a
wholly owned subsidiary of Taunus
Corporation, which is a wholly owned
subsidiary of Deutsche Bank A.G.
(‘‘DB’’), is registered as an investment
adviser under the Investment Advisers
Act of 1940, as amended (the ‘‘Advisers
Act’’). Each Money Market Portfolio has
an investment advisory agreement with
DIMA, pursuant to which DIMA
provides investment advisory and
management services. In addition to
DIMA, applicants request relief for any
other existing or future investment
adviser registered under the Advisers
Act which acts as investment adviser or
sub-adviser to a DWS Fund and which
controls, is controlled by, or is under
common control (as defined in section
2(a)(9) of the Act) with DIMA
(individually, a ‘‘Future Adviser’’ and
collectively, the ‘‘Future Advisers’’).
DIMA and the Future Advisers are
referred to individually as an ‘‘Adviser’’
and collectively as the ‘‘Advisers.’’ 2
3. DBSI, a Delaware corporation and
wholly owned subsidiary of DB U.S.
Financial Markets Holding Corporation,
a wholly owned subsidiary of Taunus
Corporation, which, as noted above, is
a wholly owned subsidiary of DB, is
registered as a broker-dealer under the
Securities Exchange Act of 1934, as
amended (the ‘‘1934 Act’’).3 DBSI,
which is a primary dealer in U.S.
Government securities, is currently one
of the largest dealers in commercial
paper, repurchase agreements and other
money market instruments in the
United States (such money market
instruments and repurchase agreements
collectively are referred to as ‘‘Money
Market Instruments’’). Applicants
believe that DBSI’s extensive dealing in
Taxable Money Market Instruments (as
defined below) makes it a very
significant source for both investment
1 Any Money Market Portfolio that currently
intends to rely on the requested order is named as
an applicant. Any other Money Market Portfolio
that relies on the order in the future will comply
with the terms and conditions of the application.
2 Any Adviser that currently intends to rely on
the requested order is named as an applicant. Any
other Adviser that relies on the order in the future
will comply with the terms and conditions of the
application. Each Future Adviser will be registered
as an investment adviser under the Advisers Act.
3 DBSI also is registered as an investment adviser
under the Advisers Act. For purposes of the
application, the relief sought applies to DBSI as
broker-dealer only. The requested relief will not
extend to any investment company advised or subadvised by DBSI.
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opportunities and information and
expertise.4
4. Applicants state that DBSI and the
Adviser are functionally independent of
each other and operate as completely
separate entities under the umbrella of
DB. While each of these corporations is
under common control, DBSI and the
Adviser have their own separate officers
and employees, are separately
capitalized, and maintain their own
books and records, except for one dual
officer as more fully discussed in the
application. In addition, the Adviser
and DBSI operate on different sides of
appropriate information barriers with
respect to portfolio management
activities and investment banking
activities, and maintain physically
separate offices.
5. Investment management decisions
for the Money Market Portfolios are
determined solely by the Adviser. The
portfolio managers and other employees
that are responsible for portfolio
management for registered investment
companies are employed solely by the
Adviser (and not DBSI) and have lines
of reporting responsibility solely within
the Adviser. The compensation of
persons assigned to the Adviser will not
depend on the volume or nature of
trades effected by the Adviser for the
Money Market Portfolios with DBSI
under the requested exemption, except
to the extent that such trades may affect
the profits and losses of DB and its
subsidiaries as a whole.
6. Each Money Market Portfolio and
Future Money Market Portfolio,
consistent with its stated investment
objectives and practices, may invest in
Money Market Instruments. Practically
all trading in Taxable Money Market
Instruments takes place in over-thecounter markets consisting of groups of
dealers that are primarily major
securities firms or large commercial
banks. Taxable Money Market
Instruments are generally traded in lots
of $1,000,000 or more on a net basis and
do not normally involve either
brokerage commissions or transfer taxes.
The cost of portfolio transactions to the
Money Market Portfolios consists
primarily of dealer or underwriter
spreads. Spreads vary among Money
Market Instruments but generally spread
levels are in the range of 1 to 5 basis
points (.01% to .05%). In the Money
4 The term ‘‘Taxable Money Market Instruments’’
refers to taxable securities which are eligible for
purchase by money market funds under Rule 2a–
7, including short-term U.S. Government securities,
short-term U.S. Governmental agency securities,
bank money market instruments, bank notes,
commercial paper and other short-term fixed
income instruments, including appropriate
medium-term notes, asset-backed floating rate
notes, and repurchase agreements.
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Market Portfolios’ experience, there is
not a great deal of variation in the
spreads quoted by the various dealers,
except during turbulent market
conditions.
7. The money market consists of
elaborate communications networks
among dealer firms, principal issuers of
Taxable Money Market Instruments and
principal institutional buyers of such
instruments. Because the money market
is a dealer market rather than an auction
market, there is not a single obtainable
price for a given instrument that
generally prevails at any given time. A
dealer acts either as ‘‘agent’’ on behalf
of issuer clients or as ‘‘principal’’ for its
own account. In either capacity, a dealer
posts rates throughout its internal and
external distribution networks that are
intended to reflect ‘‘market clearing
price levels,’’ as determined by the
dealer. Only customers of dealers
seeking to purchase Money Market
Instruments have access to these
postings.
8. Because of the variety of types of
Taxable Money Market Instruments, the
money market tends to be somewhat
segmented. The markets for the various
types of instruments will vary in terms
of price, volatility, liquidity and
availability. Although the rates for the
different types of instruments tend to
fluctuate closely together, there may be
significant differences in yield among
the various types of instruments, and
even within a particular instrument
category, depending upon the maturity
date and the credit quality of the issuer.
Moreover, from time to time segmenting
exists within Money Market Instruments
with the same maturity date and rating.
The segmenting is based on such factors
as whether the issuer is an industrial or
financial company, whether the issuer is
domestic or foreign and whether the
securities are asset-backed or unsecured.
Because dealers tend to specialize in
certain types of Taxable Money Market
Instruments, the particular needs of a
potential buyer or seller in terms of type
of security, maturity or credit quality
may limit the number of dealers who
can provide optimum pricing and
execution. Hence, with respect to any
given type of instrument, there may be
only a few dealers that have the
instrument available and can be in a
position to quote an acceptable price.
9. DBSI is one of the world’s largest
dealers in Taxable Money Market
Instruments, ranking among the top
firms in each of the major markets and
product areas, as more fully discussed
in the application. For the calendar year
ended 2011, DBSI ranked seventh in
terms of market share in commercial
paper, conducting business with 51% of
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the market. Applicants state that DBSI
plays a relatively significant role in the
repurchase agreement market and that
DBSI’s market position is among the ten
leading dealers. For the calendar year
ended 2010, DBSI’s average daily
repurchase agreement sales volume was
$165 billion. The U.S. Treasury market
consists of U.S. government obligations
that are sold through public auctions.
According to the Federal Reserve Bank
of New York, there are currently only 21
primary dealers. DBSI’s primary dealer
desk actively participates in the U.S.
Treasury market and is a leading
primary dealer. For the calendar year
ended 2011, DBSI bid on average for 8%
to 20% of all the Treasury securities
auctioned and received on average 2%
to 8% of the primary distribution of
Treasury securities. DBSI actively
transacts in securities issued by U.S.
Government agencies and government
sponsored enterprises (‘‘GSEs’’). DBSI
serves as a primary distributor for each
of the GSEs for their unsecured debt and
mortgage-backed securities. DBSI
ranked sixth in underwriting primary
issuances of agency and GSE securities
in 2011 with a market share of 6.3%.
DBSI is also one of the leading
participants in the market for mediumterm notes (‘‘MTNs’’). MTNs are offered
continuously in public or private
offerings, with maturities beginning at
nine months. MTNs represent a
significant portion of the longer-term
money market investment alternatives
because commercial paper is not issued
with maturities greater than nine
months. DBSI is a very significant dealer
in the MTN market, and through
December 31, 2011, ranked as the tenth
largest manager or co-manager of MTNs,
bank notes and CD programs in the
United States with a 5.5% market share.
10. Applicants state that in recent
years mergers and acquisitions in the
investment banking and commercial
banking industries have caused dealers
that were formerly independent and
competing with one another to combine
their operations. As a result, there is a
substantially smaller number of major
dealers who are active in the money
market than was the case a decade ago.
Applicants also state that the reduction
in the number of participants has
generally decreased the liquidity
available in the market, since fewer
dealers will make a market in any
particular security. Applicants further
state that, as the number of dealers with
whom the Money Market Portfolios can
transact business has decreased, it has
become even more important for the
Money Market Portfolios to have access
to all of the major dealers in Money
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Market Instruments in order to diversify
each Money Market Portfolio’s
investments, to maintain portfolio
liquidity, and to increase opportunities
for obtaining best price and execution
with respect to portfolio trades. In
addition, applicants state that, given the
relative significance of DBSI in the
market for Money Market Instruments in
which the Money Market Portfolios
invest, not having access to DBSI may
place the Money Market Portfolios at a
competitive disadvantage.
11. Subject to the general oversight of
the board of directors/trustees of each
DWS Fund (each a ‘‘Board’’), the
Adviser is responsible for portfolio
decisions and executing transactions in
Money Market Instruments. The Money
Market Portfolios have no obligation to
deal with any dealer or group of dealers
in the execution of their portfolio
transactions. When placing orders, the
Adviser must attempt to obtain the best
net price and the most favorable
execution of its orders. In doing so, it
takes into account such factors as price,
the size, type and difficulty of the
transaction involved and the dealer’s
general execution and operational
facilities. For repurchase agreements in
particular, the Adviser places great
emphasis on the creditworthiness of the
counterparty.
Applicants’ Legal Analysis
1. Applicants request an order
pursuant to sections 6(c) and 17(b) of
the Act exempting certain transactions
from the provisions of section 17(a) of
the Act to permit DBSI, acting as
principal, to sell Taxable Money Market
Instruments to, or purchase Taxable
Money Market Instruments from, the
Money Market Portfolios, and to engage
in repurchase agreement transactions
with the Money Market Portfolios,
subject to the conditions set forth below.
2. Section 17(a) of the Act generally
prohibits an affiliated person or
principal underwriter of a registered
investment company, or any affiliated
person of such a person, acting as
principal, from selling to or purchasing
from such registered company, or any
company controlled by such registered
company, any security or other
property. Because DBSI and the Adviser
are under common control of DB, DBSI
and the Adviser are affiliated persons of
each other within the meaning of
section 2(a)(3)(C) of the Act.
Accordingly, DBSI could be deemed to
be an affiliated person of an affiliated
person of the Money Market Portfolios,
because the Adviser, as the investment
adviser of the Money Market Portfolios,
could be deemed to be an affiliated
person of the Money Market Portfolios
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under section 2(a)(3)(E) of the Act.
Thus, section 17(a) would prohibit the
Money Market Portfolios from selling or
purchasing Taxable Money Market
Instruments to or from DBSI to the
extent DBSI is deemed an affiliated
person of an affiliated person of the
Money Market Portfolios.
3. Section 17(b) of the Act provides
that the Commission, upon application,
may exempt a transaction from the
provisions of section 17(a) if evidence
establishes that the terms of the
proposed transaction, including the
consideration to be paid, are reasonable
and fair, and do not involve
overreaching on the part of any person
concerned, and that the proposed
transaction is consistent with the policy
of the registered investment company
concerned and with the general
purposes of the Act. Section 6(c) of the
Act provides that the Commission may
conditionally or unconditionally
exempt any person, security, or
transaction, or any class or classes of
persons, securities, or transactions, from
any provision or provisions of the Act
or of any rule or regulation thereunder,
if and to the extent that such exemption
is necessary or appropriate in the public
interest and consistent with the
protection of investors and the purposes
fairly intended by the policy and
provisions of the Act.
4. Applicants contend that the
rationale behind the proposed order is
based upon the reduction in the number
of participants in the money market, the
growing and significant role played in
the money market by DBSI and the
growing investment requirements of the
Money Market Portfolios. In particular,
applicants note the following:
(a) With over $59.15 billion invested
in Money Market Instruments as of June
30, 2012, the Money Market Portfolios
are major buyers and sellers in the
money market with a strong need for
access to large quantities of high quality
Money Market Instruments. Applicants
believe that access to a major dealer,
such as DBSI, would increase the
Money Market Portfolios’ ability to
obtain suitable portfolio securities.
(b) The policy of the Money Market
Portfolios of investing in securities with
short maturities and repurchase
agreements, combined with the active
portfolio management techniques
employed by the Adviser, results in
high portfolio activity and the need to
make numerous purchases and sales of
Money Market Instruments. This high
portfolio activity likewise emphasizes
the importance of increasing
opportunities to obtain suitable
portfolio securities and best price and
execution.
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(c) The money market, including the
market for repurchase agreements, is
highly competitive and maintaining a
dealer as prominent as DBSI in the pool
of dealers with which the Money Market
Portfolios could conduct principal
transactions may provide the Money
Market Portfolios with improved
opportunities to purchase and sell
Money Market Instruments, including
Money Market Instruments not available
from any other source.
(d) DBSI is such a major factor in the
money market that removing DBSI from
the dealers with which the Money
Market Portfolios may conduct principal
transactions may indirectly deprive the
Money Market Portfolios of obtaining
best price and execution even when the
Money Market Portfolios trade with
unaffiliated dealers.
5. Applicants believe that the
requested order will provide the Money
Market Portfolios with broader and
more complete access to the money
market, which is necessary to carry out
the policies and objectives of each of the
Money Market Portfolios in seeking the
best price, execution and quality in all
portfolio transactions. In addition,
applicants respectfully submit that the
requested relief will provide the Money
Market Portfolios with important
information sources in the money
market, to the direct benefit of the
investors in the Money Market
Portfolios. Applicants believe that the
transactions contemplated by the
application are identical to those in
which they are currently engaged except
for the proposed participation of DBSI,
and that such transactions are consistent
with the policies of the Money Market
Portfolios as recited in their registration
statements and reports filed under the
Act. Applicants also submit that the
procedures to be followed with respect
to transactions with DBSI are structured
in such a way as to ensure that the
transactions will be, in all instances,
reasonable and fair, will not involve
overreaching on the part of any person
concerned, and that the requested
exemption is appropriate in the public
interest and consistent with the
protection of investors and the purposes
fairly intended by the policy and
provisions of the Act.
Applicants’ Conditions
Applicants agree that the order
granting the requested relief will be
subject to the following conditions:
1. Transactions Subject to the
Exemption—The exemption shall be
applicable to principal transactions in
the secondary market and primary or
secondary fixed-price dealer offerings
not made pursuant to underwriting
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syndicates. The principal transactions
that may be conducted pursuant to the
exemption will be limited to
transactions in Eligible Securities.5 As
the Money Market Portfolios are subject
to Rule 2a–7, such Eligible Securities
must meet the portfolio maturity and
credit quality requirements of
paragraphs (c)(2) and (c)(3) of Rule 2a–
7. Additionally:
(a) No Money Market Portfolio shall
make portfolio purchases pursuant to
the exemption that would result directly
or indirectly in the Money Market
Portfolio investing pursuant to the
exemption more than 2% of its Total
Assets in securities which, when
acquired by the Money Market Portfolio
(either initially or upon any subsequent
rollover) are Second Tier Securities;
provided that any Money Market
Portfolio may make portfolio sales of
Second Tier Securities pursuant to the
exemption without regard to this
limitation.
(b) The exemption shall not apply to
an Unrated Security other than a
Government Security.
(c) The exemption shall not apply to
any instrument, other than a repurchase
agreement, issued by DB or any
affiliated person thereof or to any
instrument subject to a Demand Feature
or Guarantee issued by DB or any
affiliated person thereof.
2. Repurchase Agreement
Requirements—The Money Market
Portfolios may engage in repurchase
agreements with DBSI only if DBSI has:
(a) net capital, as defined in rule 15c3–
1 under the 1934 Act, of at least $100
million and (b) a record (including the
record of predecessors) of at least five
years continuous operations as a dealer
during which time it engaged in
repurchase agreements relating to the
kind of instrument subject to the
repurchase agreement. DBSI shall
furnish the Adviser with financial
statements for its most recent fiscal year
and the most recent semi-annual
financial statements made available to
its customers. The Adviser shall
determine that DBSI complies with the
above requirements and with other
repurchase agreement guidelines
adopted by the Board. Each repurchase
agreement will be Collateralized Fully.
3. Price Test—In the case of purchase
and sale transactions, a determination
will be required in each instance, based
upon the information available to the
Money Market Portfolios and the
Adviser, that the price available from
DBSI is at least as favorable as that
5 Underlined terms are defined as set forth in
paragraph (a) of Rule 2a–7 under the Act, unless
otherwise indicated.
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available from other sources. In the case
of ‘‘swaps’’ involving trades of one
instrument for another, the price test
shall be based upon the transaction
viewed as a whole, and not upon the
two components thereof individually.
With respect to transactions involving
repurchase agreements, a determination
will be required in each instance, based
on the information available to the
Money Market Portfolios and the
Adviser, that the income to be earned
from the repurchase agreement is at
least equal to that available from other
sources in connection with comparable
repurchase agreements.
4. Information Required to Document
Compliance with Price Test—Before any
transaction may be conducted pursuant
to the exemption, the relevant Money
Market Portfolio or Adviser must obtain
such information as it deems reasonably
necessary to determine that the price
test (as defined in condition 3 above)
applicable to such transaction has been
satisfied. In the case of each purchase or
sale transaction, the relevant Money
Market Portfolio or Adviser must make
and document a good faith
determination with respect to
compliance with the price test based on
current price information obtained
through the contemporaneous
solicitation of bona fide offers in
connection with the type of instrument
involved (comparable security falling
within the same category of instrument,
credit rating, maturity and segment, if
any, but not necessarily the identical
instrument or issuer). With respect to
prospective purchases of securities by a
Money Market Portfolio, these dealers
must be those who have, in their
inventories, or who otherwise have
access to taxable money market
instruments of the categories and the
types desired and who are in a position
to quote favorable prices with respect
thereto. With respect to the prospective
sale of securities by a Money Market
Portfolio, these dealer firms must be
those who, in the experience of the
Money Market Portfolios and the
Adviser, are in a position to quote
favorable prices. Before any repurchase
agreements are entered into pursuant to
the exemption, the Money Market
Portfolios or the Adviser must obtain
and document competitive quotations
from at least two other dealers with
respect to repurchase agreements
comparable to the type of repurchase
agreement involved, except that if
quotations are unavailable from two
such dealers, only one other competitive
quotation is required.
5. Volume Limitations on
Transactions—Transactions other than
repurchase agreements conducted
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pursuant to the exemption shall be
limited to no more than 25% of (a) the
direct or indirect purchases or sales, as
the case may be, by each Money Market
Portfolio of Eligible Securities other than
repurchase agreements; and (b) the
purchases or sales, as the case may be,
by DBSI of Eligible Securities other than
repurchase agreements. Transactions
comprising repurchase agreements
conducted pursuant to the exemption
shall be limited to no more than 10% of
(a) the repurchase agreements directly
or indirectly entered into by the relevant
Money Market Portfolio and (b) the
repurchase agreements transacted by
DBSI. These calculations shall be
measured on an annual basis (the fiscal
year of each Money Market Portfolio
and of DBSI) and shall be computed
with respect to the dollar volume
thereof.
6. Permissible Dealer Spread—DBSI’s
spreads in regard to any transaction
with the Money Market Portfolios will
be no greater than its customary dealer
spreads, which will in turn be
consistent with the average or standard
spread charged by dealers in taxable
money market instruments for the type
of instrument and the size of transaction
involved.
7. The Parties Must Be Factually
Independent—The Adviser, on the one
hand, and DBSI, on the other, will
operate on different sides of appropriate
walls of separation with respect to the
Money Market Portfolios and Eligible
Securities. The walls of separation will
include all of the following
characteristics, and such others that
DBSI and the Adviser consider
reasonable to facilitate the factual
independence of the Adviser from DBSI:
(a) The Adviser will maintain offices
physically separate from those of DBSI.
(b) The compensation of persons
assigned to the Adviser (i.e., executive,
administrative or investment personnel)
will not depend on the volume or nature
of trades effected by the Adviser for the
Money Market Portfolios with DBSI
under the exemption, except to the
extent that such trades may affect the
profits and losses of DB and its
subsidiaries as a whole.
(c) DBSI will not share any of its
respective profits or losses on such
transactions with the Adviser, except to
the extent that such profits and losses
affect the general firm-wide
compensation of DB and its subsidiaries
as a whole.
(d) Personnel assigned to the
Adviser’s investment advisory
operations on behalf of the Money
Market Portfolios will be exclusively
devoted to the business and affairs of
the Adviser. Personnel assigned to DBSI
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will not participate in the decisionmaking process for the Adviser or
otherwise seek to influence the Adviser
other than in the normal course of sales
and dealer activities of the same nature
as are simultaneously being carried out
with respect to nonaffiliated
institutional clients. The Adviser, on the
one hand, and DBSI, on the other, may
nonetheless maintain affiliations other
than with respect to the Money Market
Portfolios, and in addition with respect
to the Money Market Portfolios as
follows:
(i) Adviser personnel may rely on
research, including credit analysis and
reports prepared internally by various
subsidiaries and divisions of DBSI.
(ii) Certain senior executives of DB
that have responsibility for overseeing
operations of various divisions,
subsidiaries and affiliates of DB are not
precluded from exercising those
functions over the Adviser because they
oversee DBSI as well, provided that
such persons shall not have any
involvement with respect to proposed
transactions pursuant to the exemption
and will not in any way attempt to
influence or control the placing by the
Money Market Portfolios or the Adviser
of orders in respect of Eligible Securities
with DBSI.
8. Record-Keeping Requirements—
The Money Market Portfolios and the
Adviser will maintain such records with
respect to those transactions conducted
pursuant to the exemption as may be
necessary to confirm compliance with
the conditions to the requested relief. In
this regard:
(a) Each Money Market Portfolio shall
maintain an itemized daily record of all
purchases and sales of securities
pursuant to the exemption, showing for
each transaction: (i) The name and
quantity of securities; (ii) the unit
purchase or sale price; (iii) the time and
date of the transaction; and (iv) whether
the security was a First Tier Security or
a Second Tier Security. For each
transaction, these records shall
document two quotations received from
other dealers for comparable securities
(except that, in the case of repurchase
agreements and consistent with
condition 4, if quotations are
unavailable from two such dealers only
one other competitive quotation is
required), including the following: (i)
The name of the dealers; (ii) the name
of the securities; (iii) the prices quoted;
(iv) the times and dates the quotations
were received; and (v) whether such
securities were First Tier Securities or
Second Tier Securities.
(b) Each Money Market Portfolio shall
maintain records sufficient to verify
compliance with the volume limitations
PO 00000
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Sfmt 4703
55239
contained in condition 5 above. DBSI
will provide the Money Market
Portfolios with all records and
information necessary to implement this
requirement.
(c) Each Money Market Portfolio shall
maintain a ledger or other record
showing, on a daily basis, the
percentage of the Money Market
Portfolio’s Total Assets represented by
Second Tier Securities acquired from
DBSI.
(d) Each Money Market Portfolio shall
maintain records sufficient to verify
compliance with the repurchase
agreement requirements contained in
condition 4 above.
The records required by this
condition 8 will be maintained and
preserved in the same manner as
records required under rule 31a–1(b)(1)
under the Act.
9. Guidelines—The Adviser and DBSI,
with the assistance of their compliance
departments, will prepare and
administer guidelines for personnel of
DBSI and the Adviser to make certain
that transactions conducted pursuant to
the exemption comply with the
conditions set forth in the exemption
and that the parties generally maintain
arm’s length relationships. In the
training of DBSI’s personnel, particular
emphasis will be given to the fact that
the Money Market Portfolios are to
receive rates as favorable as other
institutional purchasers buying the
same quantities. The compliance
departments will periodically monitor
the activities of DBSI and the Adviser to
make certain that the conditions set
forth in the exemption are adhered to.
10. Audit Committee Review—The
audit committee or another committee
which, in each case, consists of
members of the Board who are not
interested persons as defined in section
2(a)(19) of the Act (‘‘Independent
Trustees’’), will approve, periodically
review and update as necessary,
guidelines for the Adviser and DBSI
reasonably designed to ensure that
transactions conducted pursuant to the
exemption comply with the conditions
set forth herein and that the procedures
described herein are followed in all
respects. The respective audit
committees will periodically monitor
the activities of the Money Market
Portfolios, the Adviser and DBSI in this
regard to ensure that these matters are
being accomplished.
11. Board Review—The Board,
including a majority of the Independent
Trustees, will have approved each
Money Market Portfolio’s participation
in transactions conducted pursuant to
the exemption and determined that such
participation by the Money Market
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Portfolio is in the best interests of the
Money Market Portfolio and its
shareholders. The minutes of the
meeting of the Board at which this
approval was given must reflect in
detail the reasons for the Board’s
determination. The Board will review
no less frequently than annually each
Money Market Portfolio’s participation
in transactions conducted pursuant to
the exemption during the prior year and
determine whether the Money Market
Portfolio’s participation in such
transactions continues to be in the best
interests of the Money Market Portfolio
and its shareholders. Such review will
include (but not be limited to): (a) A
comparison of the volume of
transactions in each type of security
conducted pursuant to the exemption to
the market presence of DBSI in the
market for that type of instrument,
which market data may be based on
good faith estimates to the extent that
current formal data is not reasonably
available, and (b) a determination that
the Money Market Portfolios are
maintaining appropriate trading
relationships with other sources for
each type of security to ensure that there
are appropriate sources for the
quotations required by condition 4. The
minutes of the meeting of the Board at
which such determinations are made
will reflect in detail the reasons for the
Board’s determinations.
12. Scope of Exemption—Applicants
expressly acknowledge that any order
issued on the application would grant
relief from section 17(a) of the Act only,
and would not grant relief from any
other section of, or rule under, the Act
including, without limitation, Rule 2a–
7.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2012–22017 Filed 9–6–12; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
on the registration of securities.1 Section
13(e) of the Securities Exchange Act of
1934 (‘‘Exchange Act’’) requires the
Commission to collect fees on specified
repurchases of securities.2 Section 14(g)
of the Exchange Act requires the
Commission to collect fees on proxy
solicitations and statements in corporate
control transactions.3
The Investor and Capital Markets Fee
Relief Act of 2002 (‘‘Fee Relief Act’’) 4
required the Commission to make
annual adjustments to the fee rates
applicable under these sections for each
of the fiscal years 2003 through 2011 in
an attempt to generate collections equal
to yearly targets specified in the
statute.5 Under the Fee Relief Act, each
year’s fee rate was announced on the
preceding April 30, and took effect five
days after the date of enactment of the
Commission’s regular appropriation.
The Dodd-Frank Wall Street Reform
and Consumer Protection Act (‘‘DoddFrank Act’’) 6 changed many of the
provisions related to these fees. The
Dodd-Frank Act created new annual
collection targets for FY 2012 and
thereafter. It also changed the date by
which the Commission must announce
a new fiscal year’s fee rate (August 31)
and the date on which the new rate
takes effect (October 1).
II. Fiscal Year 2013 Annual Adjustment
to the Fee Rate
Section 6(b)(2) of the Securities Act,
as amended by the Dodd-Frank Act,
requires the Commission to make an
annual adjustment to the fee rate
applicable under Section 6(b).7 The
annual adjustment to the fee rate under
Section 6(b) of the Securities Act also
sets the annual adjustment to the fee
rates under Sections 13(e) and 14(g) of
the Exchange Act.8
Section 6(b)(2) sets forth the method
for determining the annual adjustment
to the fee rate under Section 6(b) for
fiscal year 2013. Specifically, the
Commission must adjust the fee rate
under Section 6(b) to a ‘‘rate that, when
applied to the baseline estimate of the
aggregate maximum offering prices for
1 15
U.S.C. 77f(b).
U.S.C. 78m(e).
3 15 U.S.C. 78n(g).
4 Public Law 107–123, 115 Stat. 2390 (2002).
5 See 15 U.S.C. 77f(b)(5), 77f(b)(6), 78m(e)(5),
78m(e)(6), 78n(g)(5) and 78n(g)(6).
6 Public Law 111–203, 124 Stat.1376 (2010).
7 15 U.S.C. 77f(b)(2). The annual adjustments are
designed to adjust the fee rate in a given fiscal year
so that, when applied to the aggregate maximum
offering price at which securities are proposed to
be offered for the fiscal year, it is reasonably likely
to produce total fee collections under Section 6(b)
equal to the ‘‘target fee collection amount’’ specified
in Section 6(b)(6)(A) for that fiscal year.
8 15 U.S.C. 78m(e)(4) and 15 U.S.C. 78n(g)(4).
2 15
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[Release Nos. 33–9357; 34–67771/August
31, 2012]
Order Making Fiscal Year 2013 Annual
Adjustments to Registration Fee Rates
I. Background
The Commission collects fees under
various provisions of the securities
laws. Section 6(b) of the Securities Act
of 1933 (‘‘Securities Act’’) requires the
Commission to collect fees from issuers
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[fiscal year 2013], is reasonably likely to
produce aggregate fee collections under
[Section 6(b)] that are equal to the target
fee collection amount for [fiscal year
2013].’’ That is, the adjusted rate is
determined by dividing the ‘‘target fee
collection amount’’ for fiscal year 2013
by the ‘‘baseline estimate of the
aggregate maximum offering prices’’ for
fiscal year 2013.
Section 6(b)(6)(A) specifies that the
‘‘target fee collection amount’’ for fiscal
year 2013 is $455,000,000. Section
6(b)(6)(B) defines the ‘‘baseline estimate
of the aggregate maximum offering
price’’ for fiscal year 2013 as ‘‘the
baseline estimate of the aggregate
maximum offering price at which
securities are proposed to be offered
pursuant to registration statements filed
with the Commission during [fiscal year
2013] as determined by the
Commission, after consultation with the
Congressional Budget Office and the
Office of Management and
Budget * * * .’’
To make the baseline estimate of the
aggregate maximum offering price for
fiscal year 2013, the Commission used
a methodology similar to that developed
in consultation with the Congressional
Budget Office (‘‘CBO’’) and Office of
Management and Budget (‘‘OMB’’) to
project the aggregate offering price for
purposes of the fiscal year 2012 annual
adjustment.9 Using this methodology,
the Commission determines the
‘‘baseline estimate of the aggregate
maximum offering price’’ for fiscal year
2013 to be $3,336,846,226,098.10 Based
on this estimate, the Commission
calculates the fee rate for fiscal 2013 to
be $136.40 per million. This adjusted
fee rate applies to Section 6(b) of the
Securities Act, as well as to Sections
13(e) and 14(g) of the Exchange Act.
III. Effective Dates of the Annual
Adjustments
The fiscal year 2013 annual
adjustments to the fee rates applicable
under Section 6(b) of the Securities Act
and Sections 13(e) and 14(g) of the
9 For the fiscal year 2011 estimate, the
Commission used a ten-year series of monthly
observations ending in March 2011. For fiscal year
2012, the Commission used a ten-year series ending
in July 2011. For fiscal year 2013, the Commission
used a ten-year series ending in July 2012.
10 Appendix A explains how we determined the
‘‘baseline estimate of the aggregate maximum
offering price’’ for fiscal year 2013 using our
methodology, and then shows the purely
arithmetical process of calculating the fiscal year
2013 annual adjustment based on that estimate. The
appendix includes the data used by the
Commission in making its ‘‘baseline estimate of the
aggregate maximum offering price’’ for fiscal year
2013.
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Agencies
[Federal Register Volume 77, Number 174 (Friday, September 7, 2012)]
[Notices]
[Pages 55235-55240]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-22017]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 30188; 812-13933]
Cash Account Trust, et al.; Notice of Application
August 31, 2012.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application for an order under sections 6(c) and
17(b) of the Investment Company Act of 1940 (the ``Act'') for an
exemption from section 17(a) of the Act.
-----------------------------------------------------------------------
Applicants: Cash Account Trust, on behalf of its series, Government
& Agency Securities Portfolio and Money Market Portfolio; Cash
Management Portfolio; Cash Reserve Fund, Inc., on behalf of its series,
Prime Series; DWS Money Funds, on behalf of its series, DWS Money
Market Prime Series; DWS Money Market Trust, on behalf of its series,
DWS Money Market Series, Cash Management Fund, Cash Reserves Fund
Institutional, and Daily Assets Fund Institutional; DWS Variable Series
II, on behalf of its series, DWS Money Market VIP; and Investors Cash
Trust, on behalf of its series, Treasury Portfolio, Central Cash
Management Fund and DWS Variable NAV Money Fund (collectively, the
``DWS Funds''), Deutsche Investment Management Americas Inc.
(``DIMA''), and Deutsche Bank Securities, Inc. (``DBSI'').
SUMMARY: Summary of Application: Applicants request an order to permit
the Money Market Portfolios (as defined below) to engage in principal
transactions in certain taxable money market instruments including
repurchase agreements with DBSI.
DATES: Filing Dates: The application was filed on August 1, 2011, and
amended on January 27, 2012, and July 20, 2012.
Hearing or Notification of Hearing: An order granting the
application will be issued unless the Commission orders a hearing.
Interested persons may request a hearing by writing to the Commission's
Secretary and serving applicants with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 p.m. on September 24, 2012, and should be accompanied by proof of
service on the 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 may request notification of a hearing by writing to
the Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street NE., Washington, DC 20549-1090. Applicants: the DWS Funds and
DIMA, 345 Park Avenue, New York, NY 10154; DBSI, 60 Wall Street, New
York, NY 10005.
FOR FURTHER INFORMATION CONTACT: Christine Y. Greenlees, Senior
Counsel, (202) 551-6879 or Mary Kay Frech, Branch Chief, (202) 551-6821
(Office of Investment Company Regulation, Division of Investment
Management).
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 DWS Funds are each a Massachusetts business trust (or, in
the case of Cash Reserve Fund Inc., a Maryland corporation), each is
registered under the Act as an open-end management investment company,
and each has one or more series that operate as money market funds
subject to rule 2a-7 under the Act (``Rule 2a-7''). In addition to the
DWS Funds and their series that operate as money market funds subject
to Rule 2a-7, relief is requested for any other existing or future
funds registered under the Act that operate as money market funds
subject to Rule 2a-7 under the Act and are advised or subadvised by an
Adviser (as defined below). All such investment companies and their
series that operate as money market funds subject to Rule 2a-7 under
the Act, including DWS Funds and their series, are referred to
individually as a ``Money Market Portfolio'' and collectively as the
``Money Market Portfolios.'' Any Money Market Portfolios not existing
as of the date of the application or that currently
[[Page 55236]]
do not intend to rely on the requested order are referred to
individually as a ``Future Money Market Portfolio'' and collectively as
the ``Future Money Market Portfolios.'' \1\
---------------------------------------------------------------------------
\1\ Any Money Market Portfolio that currently intends to rely on
the requested order is named as an applicant. Any other Money Market
Portfolio that relies on the order in the future will comply with
the terms and conditions of the application.
---------------------------------------------------------------------------
2. DIMA, a Delaware corporation and wholly owned subsidiary of
Deutsche Bank Americas Holding Corporation, a wholly owned subsidiary
of Taunus Corporation, which is a wholly owned subsidiary of Deutsche
Bank A.G. (``DB''), is registered as an investment adviser under the
Investment Advisers Act of 1940, as amended (the ``Advisers Act'').
Each Money Market Portfolio has an investment advisory agreement with
DIMA, pursuant to which DIMA provides investment advisory and
management services. In addition to DIMA, applicants request relief for
any other existing or future investment adviser registered under the
Advisers Act which acts as investment adviser or sub-adviser to a DWS
Fund and which controls, is controlled by, or is under common control
(as defined in section 2(a)(9) of the Act) with DIMA (individually, a
``Future Adviser'' and collectively, the ``Future Advisers''). DIMA and
the Future Advisers are referred to individually as an ``Adviser'' and
collectively as the ``Advisers.'' \2\
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\2\ Any Adviser that currently intends to rely on the requested
order is named as an applicant. Any other Adviser that relies on the
order in the future will comply with the terms and conditions of the
application. Each Future Adviser will be registered as an investment
adviser under the Advisers Act.
---------------------------------------------------------------------------
3. DBSI, a Delaware corporation and wholly owned subsidiary of DB
U.S. Financial Markets Holding Corporation, a wholly owned subsidiary
of Taunus Corporation, which, as noted above, is a wholly owned
subsidiary of DB, is registered as a broker-dealer under the Securities
Exchange Act of 1934, as amended (the ``1934 Act'').\3\ DBSI, which is
a primary dealer in U.S. Government securities, is currently one of the
largest dealers in commercial paper, repurchase agreements and other
money market instruments in the United States (such money market
instruments and repurchase agreements collectively are referred to as
``Money Market Instruments''). Applicants believe that DBSI's extensive
dealing in Taxable Money Market Instruments (as defined below) makes it
a very significant source for both investment opportunities and
information and expertise.\4\
---------------------------------------------------------------------------
\3\ DBSI also is registered as an investment adviser under the
Advisers Act. For purposes of the application, the relief sought
applies to DBSI as broker-dealer only. The requested relief will not
extend to any investment company advised or sub-advised by DBSI.
\4\ The term ``Taxable Money Market Instruments'' refers to
taxable securities which are eligible for purchase by money market
funds under Rule 2a-7, including short-term U.S. Government
securities, short-term U.S. Governmental agency securities, bank
money market instruments, bank notes, commercial paper and other
short-term fixed income instruments, including appropriate medium-
term notes, asset-backed floating rate notes, and repurchase
agreements.
---------------------------------------------------------------------------
4. Applicants state that DBSI and the Adviser are functionally
independent of each other and operate as completely separate entities
under the umbrella of DB. While each of these corporations is under
common control, DBSI and the Adviser have their own separate officers
and employees, are separately capitalized, and maintain their own books
and records, except for one dual officer as more fully discussed in the
application. In addition, the Adviser and DBSI operate on different
sides of appropriate information barriers with respect to portfolio
management activities and investment banking activities, and maintain
physically separate offices.
5. Investment management decisions for the Money Market Portfolios
are determined solely by the Adviser. The portfolio managers and other
employees that are responsible for portfolio management for registered
investment companies are employed solely by the Adviser (and not DBSI)
and have lines of reporting responsibility solely within the Adviser.
The compensation of persons assigned to the Adviser will not depend on
the volume or nature of trades effected by the Adviser for the Money
Market Portfolios with DBSI under the requested exemption, except to
the extent that such trades may affect the profits and losses of DB and
its subsidiaries as a whole.
6. Each Money Market Portfolio and Future Money Market Portfolio,
consistent with its stated investment objectives and practices, may
invest in Money Market Instruments. Practically all trading in Taxable
Money Market Instruments takes place in over-the-counter markets
consisting of groups of dealers that are primarily major securities
firms or large commercial banks. Taxable Money Market Instruments are
generally traded in lots of $1,000,000 or more on a net basis and do
not normally involve either brokerage commissions or transfer taxes.
The cost of portfolio transactions to the Money Market Portfolios
consists primarily of dealer or underwriter spreads. Spreads vary among
Money Market Instruments but generally spread levels are in the range
of 1 to 5 basis points (.01% to .05%). In the Money Market Portfolios'
experience, there is not a great deal of variation in the spreads
quoted by the various dealers, except during turbulent market
conditions.
7. The money market consists of elaborate communications networks
among dealer firms, principal issuers of Taxable Money Market
Instruments and principal institutional buyers of such instruments.
Because the money market is a dealer market rather than an auction
market, there is not a single obtainable price for a given instrument
that generally prevails at any given time. A dealer acts either as
``agent'' on behalf of issuer clients or as ``principal'' for its own
account. In either capacity, a dealer posts rates throughout its
internal and external distribution networks that are intended to
reflect ``market clearing price levels,'' as determined by the dealer.
Only customers of dealers seeking to purchase Money Market Instruments
have access to these postings.
8. Because of the variety of types of Taxable Money Market
Instruments, the money market tends to be somewhat segmented. The
markets for the various types of instruments will vary in terms of
price, volatility, liquidity and availability. Although the rates for
the different types of instruments tend to fluctuate closely together,
there may be significant differences in yield among the various types
of instruments, and even within a particular instrument category,
depending upon the maturity date and the credit quality of the issuer.
Moreover, from time to time segmenting exists within Money Market
Instruments with the same maturity date and rating. The segmenting is
based on such factors as whether the issuer is an industrial or
financial company, whether the issuer is domestic or foreign and
whether the securities are asset-backed or unsecured. Because dealers
tend to specialize in certain types of Taxable Money Market
Instruments, the particular needs of a potential buyer or seller in
terms of type of security, maturity or credit quality may limit the
number of dealers who can provide optimum pricing and execution. Hence,
with respect to any given type of instrument, there may be only a few
dealers that have the instrument available and can be in a position to
quote an acceptable price.
9. DBSI is one of the world's largest dealers in Taxable Money
Market Instruments, ranking among the top firms in each of the major
markets and product areas, as more fully discussed in the application.
For the calendar year ended 2011, DBSI ranked seventh in terms of
market share in commercial paper, conducting business with 51% of
[[Page 55237]]
the market. Applicants state that DBSI plays a relatively significant
role in the repurchase agreement market and that DBSI's market position
is among the ten leading dealers. For the calendar year ended 2010,
DBSI's average daily repurchase agreement sales volume was $165
billion. The U.S. Treasury market consists of U.S. government
obligations that are sold through public auctions. According to the
Federal Reserve Bank of New York, there are currently only 21 primary
dealers. DBSI's primary dealer desk actively participates in the U.S.
Treasury market and is a leading primary dealer. For the calendar year
ended 2011, DBSI bid on average for 8% to 20% of all the Treasury
securities auctioned and received on average 2% to 8% of the primary
distribution of Treasury securities. DBSI actively transacts in
securities issued by U.S. Government agencies and government sponsored
enterprises (``GSEs''). DBSI serves as a primary distributor for each
of the GSEs for their unsecured debt and mortgage-backed securities.
DBSI ranked sixth in underwriting primary issuances of agency and GSE
securities in 2011 with a market share of 6.3%. DBSI is also one of the
leading participants in the market for medium-term notes (``MTNs'').
MTNs are offered continuously in public or private offerings, with
maturities beginning at nine months. MTNs represent a significant
portion of the longer-term money market investment alternatives because
commercial paper is not issued with maturities greater than nine
months. DBSI is a very significant dealer in the MTN market, and
through December 31, 2011, ranked as the tenth largest manager or co-
manager of MTNs, bank notes and CD programs in the United States with a
5.5% market share.
10. Applicants state that in recent years mergers and acquisitions
in the investment banking and commercial banking industries have caused
dealers that were formerly independent and competing with one another
to combine their operations. As a result, there is a substantially
smaller number of major dealers who are active in the money market than
was the case a decade ago. Applicants also state that the reduction in
the number of participants has generally decreased the liquidity
available in the market, since fewer dealers will make a market in any
particular security. Applicants further state that, as the number of
dealers with whom the Money Market Portfolios can transact business has
decreased, it has become even more important for the Money Market
Portfolios to have access to all of the major dealers in Money Market
Instruments in order to diversify each Money Market Portfolio's
investments, to maintain portfolio liquidity, and to increase
opportunities for obtaining best price and execution with respect to
portfolio trades. In addition, applicants state that, given the
relative significance of DBSI in the market for Money Market
Instruments in which the Money Market Portfolios invest, not having
access to DBSI may place the Money Market Portfolios at a competitive
disadvantage.
11. Subject to the general oversight of the board of directors/
trustees of each DWS Fund (each a ``Board''), the Adviser is
responsible for portfolio decisions and executing transactions in Money
Market Instruments. The Money Market Portfolios have no obligation to
deal with any dealer or group of dealers in the execution of their
portfolio transactions. When placing orders, the Adviser must attempt
to obtain the best net price and the most favorable execution of its
orders. In doing so, it takes into account such factors as price, the
size, type and difficulty of the transaction involved and the dealer's
general execution and operational facilities. For repurchase agreements
in particular, the Adviser places great emphasis on the
creditworthiness of the counterparty.
Applicants' Legal Analysis
1. Applicants request an order pursuant to sections 6(c) and 17(b)
of the Act exempting certain transactions from the provisions of
section 17(a) of the Act to permit DBSI, acting as principal, to sell
Taxable Money Market Instruments to, or purchase Taxable Money Market
Instruments from, the Money Market Portfolios, and to engage in
repurchase agreement transactions with the Money Market Portfolios,
subject to the conditions set forth below.
2. Section 17(a) of the Act generally prohibits an affiliated
person or principal underwriter of a registered investment company, or
any affiliated person of such a person, acting as principal, from
selling to or purchasing from such registered company, or any company
controlled by such registered company, any security or other property.
Because DBSI and the Adviser are under common control of DB, DBSI and
the Adviser are affiliated persons of each other within the meaning of
section 2(a)(3)(C) of the Act. Accordingly, DBSI could be deemed to be
an affiliated person of an affiliated person of the Money Market
Portfolios, because the Adviser, as the investment adviser of the Money
Market Portfolios, could be deemed to be an affiliated person of the
Money Market Portfolios under section 2(a)(3)(E) of the Act. Thus,
section 17(a) would prohibit the Money Market Portfolios from selling
or purchasing Taxable Money Market Instruments to or from DBSI to the
extent DBSI is deemed an affiliated person of an affiliated person of
the Money Market Portfolios.
3. Section 17(b) of the Act provides that the Commission, upon
application, may exempt a transaction from the provisions of section
17(a) if evidence establishes that the terms of the proposed
transaction, including the consideration to be paid, are reasonable and
fair, and do not involve overreaching on the part of any person
concerned, and that the proposed transaction is consistent with the
policy of the registered investment company concerned and with the
general purposes of the Act. Section 6(c) of the Act provides that the
Commission may conditionally or unconditionally exempt any person,
security, or transaction, or any class or classes of persons,
securities, or transactions, from any provision or provisions of the
Act or of any rule or regulation thereunder, if and to the extent that
such exemption is necessary or appropriate in the public interest and
consistent with the protection of investors and the purposes fairly
intended by the policy and provisions of the Act.
4. Applicants contend that the rationale behind the proposed order
is based upon the reduction in the number of participants in the money
market, the growing and significant role played in the money market by
DBSI and the growing investment requirements of the Money Market
Portfolios. In particular, applicants note the following:
(a) With over $59.15 billion invested in Money Market Instruments
as of June 30, 2012, the Money Market Portfolios are major buyers and
sellers in the money market with a strong need for access to large
quantities of high quality Money Market Instruments. Applicants believe
that access to a major dealer, such as DBSI, would increase the Money
Market Portfolios' ability to obtain suitable portfolio securities.
(b) The policy of the Money Market Portfolios of investing in
securities with short maturities and repurchase agreements, combined
with the active portfolio management techniques employed by the
Adviser, results in high portfolio activity and the need to make
numerous purchases and sales of Money Market Instruments. This high
portfolio activity likewise emphasizes the importance of increasing
opportunities to obtain suitable portfolio securities and best price
and execution.
[[Page 55238]]
(c) The money market, including the market for repurchase
agreements, is highly competitive and maintaining a dealer as prominent
as DBSI in the pool of dealers with which the Money Market Portfolios
could conduct principal transactions may provide the Money Market
Portfolios with improved opportunities to purchase and sell Money
Market Instruments, including Money Market Instruments not available
from any other source.
(d) DBSI is such a major factor in the money market that removing
DBSI from the dealers with which the Money Market Portfolios may
conduct principal transactions may indirectly deprive the Money Market
Portfolios of obtaining best price and execution even when the Money
Market Portfolios trade with unaffiliated dealers.
5. Applicants believe that the requested order will provide the
Money Market Portfolios with broader and more complete access to the
money market, which is necessary to carry out the policies and
objectives of each of the Money Market Portfolios in seeking the best
price, execution and quality in all portfolio transactions. In
addition, applicants respectfully submit that the requested relief will
provide the Money Market Portfolios with important information sources
in the money market, to the direct benefit of the investors in the
Money Market Portfolios. Applicants believe that the transactions
contemplated by the application are identical to those in which they
are currently engaged except for the proposed participation of DBSI,
and that such transactions are consistent with the policies of the
Money Market Portfolios as recited in their registration statements and
reports filed under the Act. Applicants also submit that the procedures
to be followed with respect to transactions with DBSI are structured in
such a way as to ensure that the transactions will be, in all
instances, reasonable and fair, will not involve overreaching on the
part of any person concerned, and that the requested exemption is
appropriate in the public interest and consistent with the protection
of investors and the purposes fairly intended by the policy and
provisions of the Act.
Applicants' Conditions
Applicants agree that the order granting the requested relief will
be subject to the following conditions:
1. Transactions Subject to the Exemption--The exemption shall be
applicable to principal transactions in the secondary market and
primary or secondary fixed-price dealer offerings not made pursuant to
underwriting syndicates. The principal transactions that may be
conducted pursuant to the exemption will be limited to transactions in
Eligible Securities.\5\ As the Money Market Portfolios are subject to
Rule 2a-7, such Eligible Securities must meet the portfolio maturity
and credit quality requirements of paragraphs (c)(2) and (c)(3) of Rule
2a-7. Additionally:
---------------------------------------------------------------------------
\5\ Underlined terms are defined as set forth in paragraph (a)
of Rule 2a-7 under the Act, unless otherwise indicated.
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(a) No Money Market Portfolio shall make portfolio purchases
pursuant to the exemption that would result directly or indirectly in
the Money Market Portfolio investing pursuant to the exemption more
than 2% of its Total Assets in securities which, when acquired by the
Money Market Portfolio (either initially or upon any subsequent
rollover) are Second Tier Securities; provided that any Money Market
Portfolio may make portfolio sales of Second Tier Securities pursuant
to the exemption without regard to this limitation.
(b) The exemption shall not apply to an Unrated Security other than
a Government Security.
(c) The exemption shall not apply to any instrument, other than a
repurchase agreement, issued by DB or any affiliated person thereof or
to any instrument subject to a Demand Feature or Guarantee issued by DB
or any affiliated person thereof.
2. Repurchase Agreement Requirements--The Money Market Portfolios
may engage in repurchase agreements with DBSI only if DBSI has: (a) net
capital, as defined in rule 15c3-1 under the 1934 Act, of at least $100
million and (b) a record (including the record of predecessors) of at
least five years continuous operations as a dealer during which time it
engaged in repurchase agreements relating to the kind of instrument
subject to the repurchase agreement. DBSI shall furnish the Adviser
with financial statements for its most recent fiscal year and the most
recent semi-annual financial statements made available to its
customers. The Adviser shall determine that DBSI complies with the
above requirements and with other repurchase agreement guidelines
adopted by the Board. Each repurchase agreement will be Collateralized
Fully.
3. Price Test--In the case of purchase and sale transactions, a
determination will be required in each instance, based upon the
information available to the Money Market Portfolios and the Adviser,
that the price available from DBSI is at least as favorable as that
available from other sources. In the case of ``swaps'' involving trades
of one instrument for another, the price test shall be based upon the
transaction viewed as a whole, and not upon the two components thereof
individually. With respect to transactions involving repurchase
agreements, a determination will be required in each instance, based on
the information available to the Money Market Portfolios and the
Adviser, that the income to be earned from the repurchase agreement is
at least equal to that available from other sources in connection with
comparable repurchase agreements.
4. Information Required to Document Compliance with Price Test--
Before any transaction may be conducted pursuant to the exemption, the
relevant Money Market Portfolio or Adviser must obtain such information
as it deems reasonably necessary to determine that the price test (as
defined in condition 3 above) applicable to such transaction has been
satisfied. In the case of each purchase or sale transaction, the
relevant Money Market Portfolio or Adviser must make and document a
good faith determination with respect to compliance with the price test
based on current price information obtained through the contemporaneous
solicitation of bona fide offers in connection with the type of
instrument involved (comparable security falling within the same
category of instrument, credit rating, maturity and segment, if any,
but not necessarily the identical instrument or issuer). With respect
to prospective purchases of securities by a Money Market Portfolio,
these dealers must be those who have, in their inventories, or who
otherwise have access to taxable money market instruments of the
categories and the types desired and who are in a position to quote
favorable prices with respect thereto. With respect to the prospective
sale of securities by a Money Market Portfolio, these dealer firms must
be those who, in the experience of the Money Market Portfolios and the
Adviser, are in a position to quote favorable prices. Before any
repurchase agreements are entered into pursuant to the exemption, the
Money Market Portfolios or the Adviser must obtain and document
competitive quotations from at least two other dealers with respect to
repurchase agreements comparable to the type of repurchase agreement
involved, except that if quotations are unavailable from two such
dealers, only one other competitive quotation is required.
5. Volume Limitations on Transactions--Transactions other than
repurchase agreements conducted
[[Page 55239]]
pursuant to the exemption shall be limited to no more than 25% of (a)
the direct or indirect purchases or sales, as the case may be, by each
Money Market Portfolio of Eligible Securities other than repurchase
agreements; and (b) the purchases or sales, as the case may be, by DBSI
of Eligible Securities other than repurchase agreements. Transactions
comprising repurchase agreements conducted pursuant to the exemption
shall be limited to no more than 10% of (a) the repurchase agreements
directly or indirectly entered into by the relevant Money Market
Portfolio and (b) the repurchase agreements transacted by DBSI. These
calculations shall be measured on an annual basis (the fiscal year of
each Money Market Portfolio and of DBSI) and shall be computed with
respect to the dollar volume thereof.
6. Permissible Dealer Spread--DBSI's spreads in regard to any
transaction with the Money Market Portfolios will be no greater than
its customary dealer spreads, which will in turn be consistent with the
average or standard spread charged by dealers in taxable money market
instruments for the type of instrument and the size of transaction
involved.
7. The Parties Must Be Factually Independent--The Adviser, on the
one hand, and DBSI, on the other, will operate on different sides of
appropriate walls of separation with respect to the Money Market
Portfolios and Eligible Securities. The walls of separation will
include all of the following characteristics, and such others that DBSI
and the Adviser consider reasonable to facilitate the factual
independence of the Adviser from DBSI:
(a) The Adviser will maintain offices physically separate from
those of DBSI.
(b) The compensation of persons assigned to the Adviser (i.e.,
executive, administrative or investment personnel) will not depend on
the volume or nature of trades effected by the Adviser for the Money
Market Portfolios with DBSI under the exemption, except to the extent
that such trades may affect the profits and losses of DB and its
subsidiaries as a whole.
(c) DBSI will not share any of its respective profits or losses on
such transactions with the Adviser, except to the extent that such
profits and losses affect the general firm-wide compensation of DB and
its subsidiaries as a whole.
(d) Personnel assigned to the Adviser's investment advisory
operations on behalf of the Money Market Portfolios will be exclusively
devoted to the business and affairs of the Adviser. Personnel assigned
to DBSI will not participate in the decision-making process for the
Adviser or otherwise seek to influence the Adviser other than in the
normal course of sales and dealer activities of the same nature as are
simultaneously being carried out with respect to nonaffiliated
institutional clients. The Adviser, on the one hand, and DBSI, on the
other, may nonetheless maintain affiliations other than with respect to
the Money Market Portfolios, and in addition with respect to the Money
Market Portfolios as follows:
(i) Adviser personnel may rely on research, including credit
analysis and reports prepared internally by various subsidiaries and
divisions of DBSI.
(ii) Certain senior executives of DB that have responsibility for
overseeing operations of various divisions, subsidiaries and affiliates
of DB are not precluded from exercising those functions over the
Adviser because they oversee DBSI as well, provided that such persons
shall not have any involvement with respect to proposed transactions
pursuant to the exemption and will not in any way attempt to influence
or control the placing by the Money Market Portfolios or the Adviser of
orders in respect of Eligible Securities with DBSI.
8. Record-Keeping Requirements--The Money Market Portfolios and the
Adviser will maintain such records with respect to those transactions
conducted pursuant to the exemption as may be necessary to confirm
compliance with the conditions to the requested relief. In this regard:
(a) Each Money Market Portfolio shall maintain an itemized daily
record of all purchases and sales of securities pursuant to the
exemption, showing for each transaction: (i) The name and quantity of
securities; (ii) the unit purchase or sale price; (iii) the time and
date of the transaction; and (iv) whether the security was a First Tier
Security or a Second Tier Security. For each transaction, these records
shall document two quotations received from other dealers for
comparable securities (except that, in the case of repurchase
agreements and consistent with condition 4, if quotations are
unavailable from two such dealers only one other competitive quotation
is required), including the following: (i) The name of the dealers;
(ii) the name of the securities; (iii) the prices quoted; (iv) the
times and dates the quotations were received; and (v) whether such
securities were First Tier Securities or Second Tier Securities.
(b) Each Money Market Portfolio shall maintain records sufficient
to verify compliance with the volume limitations contained in condition
5 above. DBSI will provide the Money Market Portfolios with all records
and information necessary to implement this requirement.
(c) Each Money Market Portfolio shall maintain a ledger or other
record showing, on a daily basis, the percentage of the Money Market
Portfolio's Total Assets represented by Second Tier Securities acquired
from DBSI.
(d) Each Money Market Portfolio shall maintain records sufficient
to verify compliance with the repurchase agreement requirements
contained in condition 4 above.
The records required by this condition 8 will be maintained and
preserved in the same manner as records required under rule 31a-1(b)(1)
under the Act.
9. Guidelines--The Adviser and DBSI, with the assistance of their
compliance departments, will prepare and administer guidelines for
personnel of DBSI and the Adviser to make certain that transactions
conducted pursuant to the exemption comply with the conditions set
forth in the exemption and that the parties generally maintain arm's
length relationships. In the training of DBSI's personnel, particular
emphasis will be given to the fact that the Money Market Portfolios are
to receive rates as favorable as other institutional purchasers buying
the same quantities. The compliance departments will periodically
monitor the activities of DBSI and the Adviser to make certain that the
conditions set forth in the exemption are adhered to.
10. Audit Committee Review--The audit committee or another
committee which, in each case, consists of members of the Board who are
not interested persons as defined in section 2(a)(19) of the Act
(``Independent Trustees''), will approve, periodically review and
update as necessary, guidelines for the Adviser and DBSI reasonably
designed to ensure that transactions conducted pursuant to the
exemption comply with the conditions set forth herein and that the
procedures described herein are followed in all respects. The
respective audit committees will periodically monitor the activities of
the Money Market Portfolios, the Adviser and DBSI in this regard to
ensure that these matters are being accomplished.
11. Board Review--The Board, including a majority of the
Independent Trustees, will have approved each Money Market Portfolio's
participation in transactions conducted pursuant to the exemption and
determined that such participation by the Money Market
[[Page 55240]]
Portfolio is in the best interests of the Money Market Portfolio and
its shareholders. The minutes of the meeting of the Board at which this
approval was given must reflect in detail the reasons for the Board's
determination. The Board will review no less frequently than annually
each Money Market Portfolio's participation in transactions conducted
pursuant to the exemption during the prior year and determine whether
the Money Market Portfolio's participation in such transactions
continues to be in the best interests of the Money Market Portfolio and
its shareholders. Such review will include (but not be limited to): (a)
A comparison of the volume of transactions in each type of security
conducted pursuant to the exemption to the market presence of DBSI in
the market for that type of instrument, which market data may be based
on good faith estimates to the extent that current formal data is not
reasonably available, and (b) a determination that the Money Market
Portfolios are maintaining appropriate trading relationships with other
sources for each type of security to ensure that there are appropriate
sources for the quotations required by condition 4. The minutes of the
meeting of the Board at which such determinations are made will reflect
in detail the reasons for the Board's determinations.
12. Scope of Exemption--Applicants expressly acknowledge that any
order issued on the application would grant relief from section 17(a)
of the Act only, and would not grant relief from any other section of,
or rule under, the Act including, without limitation, Rule 2a-7.
For the Commission, by the Division of Investment Management,
under delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2012-22017 Filed 9-6-12; 8:45 am]
BILLING CODE 8011-01-P