Wells Fargo Bank, N.A., et al.; Notice of Application and Temporary Order, 70193-70195 [2012-28385]
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Federal Register / Vol. 77, No. 226 / Friday, November 23, 2012 / Notices
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Secretary, Executive Resources Board,
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Dated at Bethesda, Maryland, this 23rd day
of October 2012.
For the U.S. Nuclear Regulatory
Commission.
Miriam L. Cohen,
Secretary, Executive Resources Board.
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[FR Doc. 2012–28441 Filed 11–21–12; 8:45 am]
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[Release No. IC–30266; 812–14074]
Wells Fargo Bank, N.A., et al.; Notice
of Application and Temporary Order
November 16, 2012.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Temporary order and notice of
application for a permanent order under
section 9(c) of the Investment Company
Act of 1940 (‘‘Act’’).
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AGENCY:
Applicants
have received a temporary order
exempting them from section 9(a) of the
Act, with respect to an injunction
SUMMARY OF APPLICATION:
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entered against Wells Fargo Bank, N.A.
(‘‘Wells Fargo Bank’’) on September 20,
2012, by the United States District Court
for the District of Columbia, until the
Commission takes final action on an
application for a permanent order.
Applicants have requested a permanent
order.
APPLICANTS: Wells Fargo Bank, First
International Advisors, LLC (‘‘First
International’’), Metropolitan West
Capital Management, LLC
(‘‘Metropolitan West’’), Golden Capital
Management, LLC (‘‘Golden Capital’’),
Alternative Strategies Brokerage
Services, Inc. (‘‘Alternative Strategies
Brokerage’’), Alternative Strategies
Group, Inc. (‘‘Alternative Strategies’’),
Wells Fargo Funds Management, LLC
(‘‘WF Funds Management’’), Wells
Capital Management Incorporated
(‘‘Wells Capital Management’’),
Peregrine Capital Management, Inc.
(‘‘Peregrine’’), Galliard Capital
Management, Inc. (‘‘Galliard’’), and
Wells Fargo Funds Distributor, LLC
(‘‘WF Funds Distributor’’) (each an
‘‘Applicant’’ and collectively, the
‘‘Applicants’’).1
FILING DATE: The application was filed
on August 31, 2012, and amended on
September 21, 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 December 11, 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: Wells Fargo Bank, 101
North Phillips Avenue, Sioux Falls, SD
57104; First International, 30 Fenchurch
Street, London, England, UK EC3M
3BD; Metropolitan West, 610 Newport
Center Drive, Suite 1000, Newport
1 Applicants request that any relief granted
pursuant to the application also apply to any
existing company of which Wells Fargo Bank is or
may become an affiliated person within the
meaning of section 2(a)(3) of the Act (together with
the Applicants, the ‘‘Covered Persons’’).
PO 00000
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70193
Beach, CA 92660; Golden Capital, 5
Resource Square, Suite 400, 10715
David Taylor Drive, Charlotte, NC
28262; Alternative Strategies Brokerage,
401 South Tryon Street, Charlotte, NC
28202; Alternative Strategies, 401 South
Tryon Street, TH 3, Charlotte, NC 28202;
WF Funds Management and WF Funds
Distributor, 525 Market Street, 12th
Floor, San Francisco, CA 94105; Wells
Capital Management, 525 Market Street,
10th Floor, San Francisco, CA 94105;
Peregrine, 800 LaSalle Avenue, Suite
1850, Minneapolis, MN 55402; and
Galliard, 800 LaSalle Avenue, Suite
1100, Minneapolis, MN 55402.
FOR FURTHER INFORMATION CONTACT:
Steven I. Amchan, Senior Counsel, at
(202) 551–6826 or Daniele Marchesani,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The
following is a temporary order and 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. Wells Fargo Bank is a national
banking association wholly-owned,
directly and indirectly, by Wells Fargo
& Company (‘‘Wells Fargo’’). Through
its direct and indirect subsidiaries,
Wells Fargo, a registered financial
holding company and bank holding
company under the Bank Holding
Company Act of 1956, as amended,
offers banking, brokerage, advisory and
other financial services to institutional
and individual customers worldwide.
Wells Fargo also is the ultimate parent
of the other Applicants, who, as direct
or indirect, majority-owned or whollyowned, subsidiaries of the same
ultimate parent, are, or may be
considered to be, under common control
with Wells Fargo Bank.
2. Effective December 1, 2011, and
August 24, 2012, respectively, two
separately identifiable departments
within Wells Fargo Bank, Abbot
Downing Investment Advisors and
Wells Capital Management Singapore,
each became registered as an investment
adviser under the Investment Advisers
Act of 1940 (‘‘Advisers Act’’) and each
serves as an investment adviser to one
or more Funds (as defined below). First
International, Metropolitan West,
Golden Capital, Alternative Strategies,
WF Funds Management, Wells Capital
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70194
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Management, Peregrine, and Galliard
are registered as investment advisers
under the Advisers Act and serve as
investment advisers or sub-advisers to
various Funds. Alternative Strategies
Brokerage and WF Funds Distributor are
registered as broker-dealers under the
Securities Exchange Act of 1934, and
each serves as principal underwriter to
various Funds. ‘‘Fund’’ means any
registered investment company,
including a registered unit investment
trust (‘‘UIT’’) or registered face amount
certificate company, as well as a
business development company
(‘‘BDC’’) or employees’ securities
company (‘‘ESC’’). ‘‘Fund Servicing
Activities’’ means acting as an adviser,
sub-adviser or depositor to Funds, or
principal underwriter for any registered
open-end investment company, UIT,
registered face amount company or ESC.
3. On July 12, 2012, the U.S.
Department of Justice filed a complaint
(‘‘Complaint’’) against Wells Fargo Bank
in the United States District Court for
the District of Columbia (‘‘District
Court’’) in a civil action.2 The
Complaint alleged that Wells Fargo
Bank engaged in a pattern or practice of
discrimination on the basis of race and
national origin in violation of the Equal
Credit Opportunity Act (‘‘ECOA’’) and
the Fair Housing Act (‘‘FHA’’). More
specifically, the Complaint alleged that
Wells Fargo Bank’s policies caused
African-American and Hispanic
borrowers to be placed into subprime
loans at higher rates than similarlysituated white borrowers and to pay
higher costs, fees and interest rates than
similarly-situated white borrowers.
Applicants state that Wells Fargo Bank
has not been advised by the Department
of Justice that any employee of Wells
Fargo discriminated intentionally on the
basis of race or national origin. On July
12, 2012, Wells Fargo Bank executed a
Consent Order, in which it denied the
allegations of the Complaint other than
those facts deemed necessary to the
jurisdiction of the District Court.
Pursuant to that Consent Order, on
September 20, 2012, the District Court
entered a judgment that, among other
things, enjoins Wells Fargo Bank from
violating the anti-discrimination
provisions of the ECOA and the FHA in
connection with originating residential
mortgages (the ‘‘Injunction’’), and
requires Wells Fargo Bank to pay $125
million in compensation to borrowers
who may have suffered as a result of the
alleged ECOA and FHA violations,
contribute at least $50 million to a
homebuyer assistance program, and
2 United States v. Wells Fargo Bank, N.A., No.
1:12–cv–01150 (D.D.C., July 12, 2012).
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implement other measures that are
designed to ensure Wells Fargo Bank’s
future adherence to fair lending
practices.
Applicants’ Legal Analysis
1. Section 9(a)(2) of the Act, in
relevant part, prohibits a person who
has been enjoined from acting as a bank,
or from engaging in or continuing any
conduct or practice in connection with
such activity, from acting, among other
things, as an investment adviser or
depositor of any registered investment
company, or a principal underwriter for
any registered open-end investment
company, UIT or registered face-amount
certificate company. Section 9(a)(3) of
the Act extends the prohibitions of
section 9(a)(2) to a company any
affiliated person of which has been
disqualified under the provisions of
section 9(a)(2). Section 2(a)(3) of the Act
defines ‘‘affiliated person’’ to include,
among others, any person directly or
indirectly controlling, controlled by, or
under common control with, the other
person. Applicants state that Wells
Fargo Bank is, or may be considered to
be, under common control with and
therefore an affiliated person of each of
the other Applicants. Applicants state
that the entry of the Injunction may
result in Applicants being subject to the
disqualification provisions of section
9(a) of the Act because Wells Fargo
Bank is enjoined from engaging in or
continuing certain conduct and/or
practices in connection with its banking
activity.3
2. Section 9(c) of the Act provides that
the Commission shall grant an
application for exemption from the
disqualification provisions of section
9(a) if it is established that these
provisions, as applied to Applicants, are
unduly or disproportionately severe or
that the Applicants’ conduct has been
such as not to make it against the public
interest or the protection of investors to
grant the exemption. Applicants have
filed an application pursuant to section
9(c) seeking temporary and permanent
orders exempting the Applicants and
the other Covered Persons from the
disqualification provisions of section
9(a) of the Act. On September 21, 2012,
Applicants received a temporary
conditional order from the Commission
exempting them from section 9(a) of the
Act with respect to the Injunction from
September 20, 2012 until the
Commission takes final action on an
3 Applicants believe that the conduct and/or
practices covered by the Injunction could be
deemed to be in connection with Wells Fargo
Bank’s banking activity.
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application for a permanent order or, if
earlier, November 16, 2012.
3. Applicants believe they meet the
standard for exemption specified in
section 9(c). Applicants state that the
prohibitions of section 9(a) as applied to
them would be unduly and
disproportionately severe and that the
conduct of Applicants has been such as
not to make it against the public interest
or the protection of investors to grant
the exemption from section 9(a).
4. Applicants state that the conduct
giving rise to the Injunction did not
involve any of the Applicants acting in
their capacity as investment adviser,
sub-adviser, or principal underwriter for
Funds. Applicants also state that the
alleged conduct giving rise to the
Injunction did not involve any Fund or
the assets of any Fund for which they
provided Fund Servicing Activities.
Applicants further state that to the best
of their reasonable knowledge: (i) None
of the Applicants’ (other than certain of
Wells Fargo Bank’s) current or former
directors, officers or employees had any
knowledge of, or had any involvement
in, the conduct alleged in the Complaint
to have constituted the alleged
violations that provided a basis for the
Injunction; (ii) the personnel who were
involved in the violations alleged in the
Complaint have had no involvement in,
and will not have any future
involvement in, providing advisory,
sub-advisory, depository or
underwriting services to Funds; and (iii)
because the personnel of the Applicants
involved in Fund Servicing Activities
did not have any involvement in the
alleged misconduct, shareholders of
Funds that received investment
advisory, depository and principal
underwriting services from the
Applicants were not affected any
differently than if those Funds had
received services from any other nonaffiliated investment adviser, depositor
or principal underwriter.
5. Applicants further represent that
the inability of Applicants to continue
providing Fund Servicing Activities
would result in potentially severe
financial hardships for both the Funds
and their shareholders. Applicants state
that they will distribute written
materials, including an offer to meet in
person to discuss the materials, to the
board of directors of each Fund,
including the directors who are not
‘‘interested persons,’’ as defined in
section 2(a)(19) of the Act, of such
Fund, and their independent legal
counsel as defined in rule 0–1(a)(6)
under the Act, if any, regarding the
Injunction, any impact on the Funds,
and the application. The Applicants
will provide the Funds with all
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Federal Register / Vol. 77, No. 226 / Friday, November 23, 2012 / Notices
information concerning the Injunction
and the application that is necessary for
the Funds to fulfill their disclosure and
other obligations under the federal
securities laws.
6. Applicants also assert that, if the
Applicants were barred from engaging
in Fund Servicing Activities, the effect
on their businesses and employees
would be severe. The Applicants state
that they have committed substantial
capital and resources to establishing
expertise in advising and sub-advising
Funds and in support of their principal
underwriting business.
7. Applicants state that several
Applicants and certain of their affiliates
have previously received orders under
section 9(c), as described in greater
detail in the application.
Applicants’ Condition
Applicants agree that any order
granted by the Commission pursuant to
the application will be subject to the
following condition:
Any temporary exemption granted
pursuant to the application shall be without
prejudice to, and shall not limit the
Commission’s rights in any manner with
respect to, any Commission investigation of,
or administrative proceedings involving or
against, Covered Persons, including without
limitation, the consideration by the
Commission of a permanent exemption from
section 9(a) of the Act requested pursuant to
the application, or the revocation or removal
of any temporary exemptions granted under
the Act in connection with the application.
mstockstill on DSK4VPTVN1PROD with NOTICES
Temporary Order
The Commission has considered the
matter and finds that Applicants have
made the necessary showing to justify
granting a temporary exemption.
Accordingly,
It is hereby ordered, pursuant to
section 9(c) of the Act, that the
Applicants and the other Covered
Persons are granted a temporary
exemption from the provisions of
section 9(a), effective forthwith, solely
with respect to the Injunction, subject to
the condition in the application, until
the date the Commission takes final
action on their application for a
permanent order.
By the Commission.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2012–28385 Filed 11–21–12; 8:45 am]
17:03 Nov 21, 2012
[Release No. 34–68243; File No. SR–NYSE–
2012–62]
Self-Regulatory Organizations; New
York Stock Exchange LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change Amending
NYSE Rule 123C To Add New
Supplementary Material .40 To Clarify
That All Times Specified in Rule 123C
Are Adjusted When the Scheduled
Close of Trading Is Before 4:00 p.m.
November 15, 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 November
6, 2012, New York Stock Exchange LLC
(the ‘‘Exchange’’ or ‘‘NYSE’’) filed with
the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Item I below, which Item has been
prepared by the Exchange. The
Exchange filed the proposal as a ‘‘noncontroversial’’ proposed rule change
pursuant to Section 19(b)(3)(A)(iii) of
the Act 3 and Rule 19b–4(f)(6)
thereunder.4 The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend
NYSE Rule 123C to add new
Supplementary Material .40 to clarify
that all times specified in Rule 123C are
adjusted when the scheduled close of
trading is before 4:00 p.m. The text of
the proposed rule change is available on
the Exchange’s Web site at
www.nyse.com, at the principal office of
the Exchange, and at the Commission’s
Public Reference Room.
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
self-regulatory organization 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 those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 15 U.S.C. 78s(b)(3)(A)(iii).
4 17 CFR 240.19b–4(f)(6).
2 17
BILLING CODE 8011–01–P
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70195
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and the
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to amend
Rule 123C to add new Supplementary
Material .40 to clarify that all times
specified in Rule 123C are adjusted
when the scheduled close of trading is
before 4:00 p.m.5
Pursuant to Rule 51, except as may be
otherwise determined by the Board of
Directors as to particular days, the
Exchange shall be open for the
transaction of business on every
business day for a 9:30 a.m. to 4:00 p.m.
trading session. Each year, the Exchange
announces which trading days shall
have an early scheduled close. For
example, for the years 2012, 2013, and
2014, the Exchange has announced an
early scheduled close of 1:00 p.m. for
the day after Thanksgiving, on
December 24, and on July 3.6
Rule 123C specifies a number of times
that are keyed off of the 4:00 p.m.
closing time. For example, Rule
123C(1)(b) defines an Informational
Imbalance Publication that is
disseminated between 3:00 p.m. and
3:45 p.m.; Rule 123C(2) discusses order
entry for MOC, LOC, and CO Orders
before and after 3:45 p.m. However,
these sections of the rule do not specify
what happens in the case of an early
scheduled close. Some subsections of
Rule 123C specify what time is
applicable when there is an early
scheduled close. For example, Rule
123C(6)(a)(v) specifies that on any day
that the scheduled close of trading on
the Exchange is earlier than 4:00 p.m.,
the dissemination of Order Imbalance
Information prior to the closing
transaction will commence
approximately 15 minutes before the
scheduled close of trading.
The Exchange notes that even if not
specified, all times in Rule 123C are
adjusted when there is an early
scheduled close. Accordingly, the
Exchange proposes to add new
Supplementary Material .40 to Rule
123C to clarify that if not otherwise
specified, when the scheduled close of
trading is before 4:00 p.m., the times
specified in the Rule shall be adjusted
based on the early scheduled closing
5 The Exchange notes that parallel changes are
proposed to be made to the rules of NYSE MKT
LLC. See SR–NYSEMKT–2012–63.
6 See https://usequities.nyx.com/markets/holidaysand-hours/nyse.
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Agencies
[Federal Register Volume 77, Number 226 (Friday, November 23, 2012)]
[Notices]
[Pages 70193-70195]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-28385]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-30266; 812-14074]
Wells Fargo Bank, N.A., et al.; Notice of Application and
Temporary Order
November 16, 2012.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Temporary order and notice of application for a permanent order
under section 9(c) of the Investment Company Act of 1940 (``Act'').
-----------------------------------------------------------------------
SUMMARY OF APPLICATION: Applicants have received a temporary order
exempting them from section 9(a) of the Act, with respect to an
injunction entered against Wells Fargo Bank, N.A. (``Wells Fargo
Bank'') on September 20, 2012, by the United States District Court for
the District of Columbia, until the Commission takes final action on an
application for a permanent order. Applicants have requested a
permanent order.
APPLICANTS: Wells Fargo Bank, First International Advisors, LLC
(``First International''), Metropolitan West Capital Management, LLC
(``Metropolitan West''), Golden Capital Management, LLC (``Golden
Capital''), Alternative Strategies Brokerage Services, Inc.
(``Alternative Strategies Brokerage''), Alternative Strategies Group,
Inc. (``Alternative Strategies''), Wells Fargo Funds Management, LLC
(``WF Funds Management''), Wells Capital Management Incorporated
(``Wells Capital Management''), Peregrine Capital Management, Inc.
(``Peregrine''), Galliard Capital Management, Inc. (``Galliard''), and
Wells Fargo Funds Distributor, LLC (``WF Funds Distributor'') (each an
``Applicant'' and collectively, the ``Applicants'').\1\
---------------------------------------------------------------------------
\1\ Applicants request that any relief granted pursuant to the
application also apply to any existing company of which Wells Fargo
Bank is or may become an affiliated person within the meaning of
section 2(a)(3) of the Act (together with the Applicants, the
``Covered Persons'').
FILING DATE: The application was filed on August 31, 2012, and amended
---------------------------------------------------------------------------
on September 21, 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 December 11, 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:
Wells Fargo Bank, 101 North Phillips Avenue, Sioux Falls, SD 57104;
First International, 30 Fenchurch Street, London, England, UK EC3M 3BD;
Metropolitan West, 610 Newport Center Drive, Suite 1000, Newport Beach,
CA 92660; Golden Capital, 5 Resource Square, Suite 400, 10715 David
Taylor Drive, Charlotte, NC 28262; Alternative Strategies Brokerage,
401 South Tryon Street, Charlotte, NC 28202; Alternative Strategies,
401 South Tryon Street, TH 3, Charlotte, NC 28202; WF Funds Management
and WF Funds Distributor, 525 Market Street, 12th Floor, San Francisco,
CA 94105; Wells Capital Management, 525 Market Street, 10th Floor, San
Francisco, CA 94105; Peregrine, 800 LaSalle Avenue, Suite 1850,
Minneapolis, MN 55402; and Galliard, 800 LaSalle Avenue, Suite 1100,
Minneapolis, MN 55402.
FOR FURTHER INFORMATION CONTACT: Steven I. Amchan, Senior Counsel, at
(202) 551-6826 or Daniele Marchesani, Branch Chief, at (202) 551-6821
(Division of Investment Management, Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The following is a temporary order and 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. Wells Fargo Bank is a national banking association wholly-owned,
directly and indirectly, by Wells Fargo & Company (``Wells Fargo'').
Through its direct and indirect subsidiaries, Wells Fargo, a registered
financial holding company and bank holding company under the Bank
Holding Company Act of 1956, as amended, offers banking, brokerage,
advisory and other financial services to institutional and individual
customers worldwide. Wells Fargo also is the ultimate parent of the
other Applicants, who, as direct or indirect, majority-owned or wholly-
owned, subsidiaries of the same ultimate parent, are, or may be
considered to be, under common control with Wells Fargo Bank.
2. Effective December 1, 2011, and August 24, 2012, respectively,
two separately identifiable departments within Wells Fargo Bank, Abbot
Downing Investment Advisors and Wells Capital Management Singapore,
each became registered as an investment adviser under the Investment
Advisers Act of 1940 (``Advisers Act'') and each serves as an
investment adviser to one or more Funds (as defined below). First
International, Metropolitan West, Golden Capital, Alternative
Strategies, WF Funds Management, Wells Capital
[[Page 70194]]
Management, Peregrine, and Galliard are registered as investment
advisers under the Advisers Act and serve as investment advisers or
sub-advisers to various Funds. Alternative Strategies Brokerage and WF
Funds Distributor are registered as broker-dealers under the Securities
Exchange Act of 1934, and each serves as principal underwriter to
various Funds. ``Fund'' means any registered investment company,
including a registered unit investment trust (``UIT'') or registered
face amount certificate company, as well as a business development
company (``BDC'') or employees' securities company (``ESC''). ``Fund
Servicing Activities'' means acting as an adviser, sub-adviser or
depositor to Funds, or principal underwriter for any registered open-
end investment company, UIT, registered face amount company or ESC.
3. On July 12, 2012, the U.S. Department of Justice filed a
complaint (``Complaint'') against Wells Fargo Bank in the United States
District Court for the District of Columbia (``District Court'') in a
civil action.\2\ The Complaint alleged that Wells Fargo Bank engaged in
a pattern or practice of discrimination on the basis of race and
national origin in violation of the Equal Credit Opportunity Act
(``ECOA'') and the Fair Housing Act (``FHA''). More specifically, the
Complaint alleged that Wells Fargo Bank's policies caused African-
American and Hispanic borrowers to be placed into subprime loans at
higher rates than similarly-situated white borrowers and to pay higher
costs, fees and interest rates than similarly-situated white borrowers.
Applicants state that Wells Fargo Bank has not been advised by the
Department of Justice that any employee of Wells Fargo discriminated
intentionally on the basis of race or national origin. On July 12,
2012, Wells Fargo Bank executed a Consent Order, in which it denied the
allegations of the Complaint other than those facts deemed necessary to
the jurisdiction of the District Court. Pursuant to that Consent Order,
on September 20, 2012, the District Court entered a judgment that,
among other things, enjoins Wells Fargo Bank from violating the anti-
discrimination provisions of the ECOA and the FHA in connection with
originating residential mortgages (the ``Injunction''), and requires
Wells Fargo Bank to pay $125 million in compensation to borrowers who
may have suffered as a result of the alleged ECOA and FHA violations,
contribute at least $50 million to a homebuyer assistance program, and
implement other measures that are designed to ensure Wells Fargo Bank's
future adherence to fair lending practices.
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\2\ United States v. Wells Fargo Bank, N.A., No. 1:12-cv-01150
(D.D.C., July 12, 2012).
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Applicants' Legal Analysis
1. Section 9(a)(2) of the Act, in relevant part, prohibits a person
who has been enjoined from acting as a bank, or from engaging in or
continuing any conduct or practice in connection with such activity,
from acting, among other things, as an investment adviser or depositor
of any registered investment company, or a principal underwriter for
any registered open-end investment company, UIT or registered face-
amount certificate company. Section 9(a)(3) of the Act extends the
prohibitions of section 9(a)(2) to a company any affiliated person of
which has been disqualified under the provisions of section 9(a)(2).
Section 2(a)(3) of the Act defines ``affiliated person'' to include,
among others, any person directly or indirectly controlling, controlled
by, or under common control with, the other person. Applicants state
that Wells Fargo Bank is, or may be considered to be, under common
control with and therefore an affiliated person of each of the other
Applicants. Applicants state that the entry of the Injunction may
result in Applicants being subject to the disqualification provisions
of section 9(a) of the Act because Wells Fargo Bank is enjoined from
engaging in or continuing certain conduct and/or practices in
connection with its banking activity.\3\
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\3\ Applicants believe that the conduct and/or practices covered
by the Injunction could be deemed to be in connection with Wells
Fargo Bank's banking activity.
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2. Section 9(c) of the Act provides that the Commission shall grant
an application for exemption from the disqualification provisions of
section 9(a) if it is established that these provisions, as applied to
Applicants, are unduly or disproportionately severe or that the
Applicants' conduct has been such as not to make it against the public
interest or the protection of investors to grant the exemption.
Applicants have filed an application pursuant to section 9(c) seeking
temporary and permanent orders exempting the Applicants and the other
Covered Persons from the disqualification provisions of section 9(a) of
the Act. On September 21, 2012, Applicants received a temporary
conditional order from the Commission exempting them from section 9(a)
of the Act with respect to the Injunction from September 20, 2012 until
the Commission takes final action on an application for a permanent
order or, if earlier, November 16, 2012.
3. Applicants believe they meet the standard for exemption
specified in section 9(c). Applicants state that the prohibitions of
section 9(a) as applied to them would be unduly and disproportionately
severe and that the conduct of Applicants has been such as not to make
it against the public interest or the protection of investors to grant
the exemption from section 9(a).
4. Applicants state that the conduct giving rise to the Injunction
did not involve any of the Applicants acting in their capacity as
investment adviser, sub-adviser, or principal underwriter for Funds.
Applicants also state that the alleged conduct giving rise to the
Injunction did not involve any Fund or the assets of any Fund for which
they provided Fund Servicing Activities. Applicants further state that
to the best of their reasonable knowledge: (i) None of the Applicants'
(other than certain of Wells Fargo Bank's) current or former directors,
officers or employees had any knowledge of, or had any involvement in,
the conduct alleged in the Complaint to have constituted the alleged
violations that provided a basis for the Injunction; (ii) the personnel
who were involved in the violations alleged in the Complaint have had
no involvement in, and will not have any future involvement in,
providing advisory, sub-advisory, depository or underwriting services
to Funds; and (iii) because the personnel of the Applicants involved in
Fund Servicing Activities did not have any involvement in the alleged
misconduct, shareholders of Funds that received investment advisory,
depository and principal underwriting services from the Applicants were
not affected any differently than if those Funds had received services
from any other non-affiliated investment adviser, depositor or
principal underwriter.
5. Applicants further represent that the inability of Applicants to
continue providing Fund Servicing Activities would result in
potentially severe financial hardships for both the Funds and their
shareholders. Applicants state that they will distribute written
materials, including an offer to meet in person to discuss the
materials, to the board of directors of each Fund, including the
directors who are not ``interested persons,'' as defined in section
2(a)(19) of the Act, of such Fund, and their independent legal counsel
as defined in rule 0-1(a)(6) under the Act, if any, regarding the
Injunction, any impact on the Funds, and the application. The
Applicants will provide the Funds with all
[[Page 70195]]
information concerning the Injunction and the application that is
necessary for the Funds to fulfill their disclosure and other
obligations under the federal securities laws.
6. Applicants also assert that, if the Applicants were barred from
engaging in Fund Servicing Activities, the effect on their businesses
and employees would be severe. The Applicants state that they have
committed substantial capital and resources to establishing expertise
in advising and sub-advising Funds and in support of their principal
underwriting business.
7. Applicants state that several Applicants and certain of their
affiliates have previously received orders under section 9(c), as
described in greater detail in the application.
Applicants' Condition
Applicants agree that any order granted by the Commission pursuant
to the application will be subject to the following condition:
Any temporary exemption granted pursuant to the application
shall be without prejudice to, and shall not limit the Commission's
rights in any manner with respect to, any Commission investigation
of, or administrative proceedings involving or against, Covered
Persons, including without limitation, the consideration by the
Commission of a permanent exemption from section 9(a) of the Act
requested pursuant to the application, or the revocation or removal
of any temporary exemptions granted under the Act in connection with
the application.
Temporary Order
The Commission has considered the matter and finds that Applicants
have made the necessary showing to justify granting a temporary
exemption.
Accordingly,
It is hereby ordered, pursuant to section 9(c) of the Act, that the
Applicants and the other Covered Persons are granted a temporary
exemption from the provisions of section 9(a), effective forthwith,
solely with respect to the Injunction, subject to the condition in the
application, until the date the Commission takes final action on their
application for a permanent order.
By the Commission.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2012-28385 Filed 11-21-12; 8:45 am]
BILLING CODE 8011-01-P