ING Investments, LLC, et al.; Notice of Application, 74245-74247 [2012-30050]
Download as PDF
Federal Register / Vol. 77, No. 240 / Thursday, December 13, 2012 / Notices
the waiver will be passed through to the
Acquiring Management Company.
16. Any sales charges and/or service
fees charged with respect to shares of an
Acquiring Fund will not exceed the
limits applicable to a fund of funds as
set forth in NASD Conduct Rule 2830.
17. No Non-FOF (or in the case of a
Feeder Fund, the Master Fund) will
acquire securities of any investment
company or company relying on section
3(c)(1) or 3(c)(7) of the Act in excess of
the limits contained in section
12(d)(1)(A) of the Act, except to the
extent that the Non-FOF acquires such
securities in compliance with section
12(d)(1)(E) of the Act or the Feeder
Relief in this order; or the Non-FOF (or
in the case of a Feeder Fund, the Master
Fund) (a) receives securities of another
investment company as a dividend or as
a result of a plan of reorganization of a
company (other than a plan devised for
the purpose of evading section 12(d)(1)
of the Act), or (b) acquires securities of
another investment company pursuant
to exemptive relief from the
Commission permitting such Non-FOF
(or in the case of a Feeder Fund, the
Master Fund) to (i) acquire securities of
one or more investment companies for
short-term cash management purposes
or (ii) engage in interfund borrowing
and lending transactions.
18. Before approving any advisory
contract under section 15 of the Act, the
board of directors or trustees of each
Acquiring Management Company,
including a majority of the independent
directors or trustees, will find that the
advisory fees charged under such
advisory contract are based on services
provided that will be in addition to,
rather than duplicative of, the services
provided under the advisory contract(s)
of any Non-FOF (or in the case of a
Feeder Fund, the Master Fund) in which
the Acquiring Management Company
may invest. These findings and their
basis will be recorded fully in the
minute books of the appropriate
Acquiring Management Company.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
srobinson on DSK4SPTVN1PROD with
[FR Doc. 2012–30054 Filed 12–12–12; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
30295; 812–14013]
ING Investments, LLC, et al.; Notice of
Application
December 6, 2012.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under section 17(d) of the
Investment Company Act of 1940
(‘‘Act’’) and rule 17d–1 under the Act.
AGENCY:
Applicants
request an order to permit certain
registered open-end investment
companies in the same group of
investment companies to enter into a
special servicing agreement (‘‘Special
Servicing Agreement’’).
APPLICANTS: ING Investments, LLC
(‘‘IIL’’), Directed Services LLC (‘‘DSL’’)
and ING Investment Management Co.
LLC (‘‘IIM’’) (each, an ‘‘Adviser,’’ and
collectively, the ‘‘Advisers’’) and ING
Balanced Portfolio, Inc., ING Equity
Trust, ING Funds Trust, ING
Intermediate Bond Portfolio, ING
Investors Trust, ING Mayflower Trust,
ING Money Market Portfolio, ING
Mutual Funds, ING Partners, Inc., ING
Separate Portfolios Trust, ING Series
Fund, Inc., ING Strategic Allocation
Portfolios, Inc., ING Variable Funds,
ING Variable Portfolios, Inc., ING
Variable Insurance Trust and ING
Variable Products Trust (collectively,
the ‘‘Registrants’’) and the series thereof
(the Registrants and their series,
collectively with the Advisers, the
‘‘Applicants.’’).1
FILING DATES: The application was filed
on March 9, 2012, and amended on June
18, 2012, and October 26, 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 31, 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
SUMMARY OF APPLICATION:
1 All entities that currently intend to rely on the
order have been named as applicants. Any other
entity that relies on the order in the future will
comply with the terms and conditions of the
application.
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74245
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, Huey P. Falgout, Jr., Chief
Counsel, ING Funds, 7337 East
Doubletree Ranch Road, Suite 100,
Scottsdale, Arizona 85255.
FOR FURTHER INFORMATION CONTACT:
Emerson S. Davis, Senior Counsel, at
(202) 551–6868, or Daniele Marchesani,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Office of Investment Company
Regulation).
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.
SUPPLEMENTARY INFORMATION:
Applicants’ Representations
1. The Advisers are investment
advisers registered under the Investment
Advisers Act of 1940 and serve as
investment advisers to the Funds. Each
Adviser is a direct or indirect subsidiary
of ING Groep, N.V.
2. Each Registrant is registered under
the Act as an open-end management
investment company. Certain of the
Funds, as defined below, currently
serve, and others in the future may
serve, in ‘‘fund-of-funds’’ arrangements
whereby a Fund (each, a ‘‘Top-Tier
Fund,’’ and collectively, the ‘‘Top-Tier
Funds’’) invests their assets in other
Funds (‘‘Underlying Funds’’).2
3. Applicants request that the order
also apply to each existing or future
registered open-end management
investment company or series thereof
that is part of the same ‘‘group of
investment companies’’ as the
Registrants under Section 12(d)(1)(G)(ii)
of the Act, and is advised or sub-advised
now or in the future by an Adviser or
any entity controlling, controlled by, or
under common control with an Adviser
(such entity included in the term
‘‘Adviser’’ and such investment
companies or series thereof, collectively
with the Registrants and their series, the
‘‘Funds’’).
4. Applicants propose that the Funds
enter into a Special Servicing
2 The Top-Tier Funds will not be Underlying
Funds. Exhibit A to the application identifies the
current Top-Tier Funds and Underlying Funds.
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Agreement that would allow an
Underlying Fund to bear the expenses of
a Top-Tier Fund (other than investment
management fees, rule 12b–1 fees and
class-specific administrative service
fees). Under the Special Servicing
Agreement, each Underlying Fund will
bear expenses of a Top-Tier Fund in
proportion to the estimated benefits to
the Underlying Fund arising from the
investment in the Underlying Fund by
the Top-Tier Fund (‘‘Underlying Fund
Benefits’’).
5. Applicants state that the
Underlying Fund Benefits are expected
to result primarily from the incremental
increase in assets resulting from
investments in the Underlying Funds by
the Top-Tier Funds and the large size of
a Top-Tier Fund’s holdings of shares in
a shareholder account relative to the
average size of the share balances held
in other Underlying Fund shareholder
accounts. A Top-Tier Fund’s
shareholder account will experience
fewer shareholder transactions and
greater predictability of transaction
activity than other shareholder
accounts. As a result, the shareholder
servicing costs to any Underlying Fund
for servicing one account registered to a
Top-Tier Fund will be significantly less
than the cost to that same Underlying
Fund of servicing the same pool of
assets contributed by a large group of
shareholders owning relatively small
accounts in one or more Underlying
Funds. In addition, by reducing TopTier Fund expenses, the Special
Servicing Agreement may lead to
increased assets being invested in the
Top-Tier Funds, which in turn would
lead to increased assets being invested
in the Underlying Funds. Further,
increased assets could enable the
Underlying Funds to control and reduce
their expense ratios because their
operating expenses will be spread over
a larger asset base.
6. No Fund will enter into a Special
Servicing Agreement unless the Special
Servicing Agreement: (a) Precisely
describes the services provided to the
Top-Tier Funds and the expenses
incurred by a Top-Tier Fund that may
be reimbursed by an Underlying Fund
(‘‘Underlying Fund Payments’’); (b)
provides that no affiliated person of the
Top-Tier Funds, or affiliated person of
such person, will receive, directly or
indirectly, any portion of the
Underlying Fund Payments; (c) provides
that the Underlying Fund Payments may
not exceed the amount of actual
expenses incurred by the Top-Tier
Funds; (d) provides that no Underlying
Fund will reimburse transfer agent
expenses of a Top-Tier Fund, including
out-of-pocket expenses and other
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16:21 Dec 12, 2012
Jkt 229001
expenses, at a rate in excess of the
average per account transfer agent
expenses of the Underlying Fund,
including out-of-pocket and other
expenses, expressed as a basis point
charge (for purposes of calculating the
Underlying Fund’s average per account
transfer agent expense, the Top-Tier
Fund’s investment in the Underlying
Fund will be excluded); and (e) has
been approved by the Fund’s board of
trustees (‘‘Board’’), including a majority
of trustees who are not ‘‘interested
persons’’ (within the meaning of section
2(a)(19) of the Act) (‘‘Independent
Directors/Trustees’’), as being in the best
interests of any Fund and its
shareholders and not involving
overreaching on the part of any person
concerned.
Applicants’ Legal Analysis
1. Section 17(d) of the Act and rule
17d–1 under the Act provide that an
affiliated person of, or a principal
underwriter for, a registered investment
company, or an affiliate of such person
or principal underwriter, acting as
principal, shall not participate in, or
effect any transaction in connection
with, any joint enterprise or other joint
arrangement in which the registered
investment company is a participant
unless the Commission has issued an
order approving the arrangement. Each
Adviser, as investment adviser, is an
affiliated person of each of the
Underlying Funds and Top-Tier Funds,
which in turn could be deemed to be
under common control of the Advisers
and therefore affiliated persons of each
other. The Top-Tier Funds and the
Underlying Funds also may be affiliated
persons by virtue of a Top-Tier Fund’s
ownership of more than 5% of the
outstanding voting securities of an
Underlying Fund. Consequently, the
Special Servicing Agreement could be
deemed to be a joint transaction among
the Top-Tier Funds, the Underlying
Funds and Advisers.
2. Rule 17d–1 under the Act provides
that, in passing upon a joint
arrangement under the rule, the
Commission will consider whether
participation of the investment
company in the joint enterprise or joint
arrangement on the basis proposed is
consistent with the provisions, policies,
and purposes of the Act and the extent
to which the participation is on a basis
different from or less advantageous than
that of other participants.
3. Applicants request an order under
section 17(d) and rule 17d–1 to permit
the proposed expense sharing
arrangements. Applicants state that
participation by the Top-Tier Funds, the
Underlying Funds and Advisers in the
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Frm 00083
Fmt 4703
Sfmt 4703
proposed expense sharing arrangements
is consistent with the provisions,
policies and purposes of the Act, and
that the terms of the Special Servicing
Agreement and the conditions set forth
below will ensure that no participant
will participate on a basis less
advantageous than that of other
participants.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
1. No Fund will enter into a Special
Servicing Agreement unless the Special
Servicing Agreement: (a) Precisely
describes the services provided to the
Top-Tier Funds and the Underlying
Fund Payments; (b) provides that no
affiliated person of the Top-Tier Funds,
or affiliated person of such person, will
receive, directly or indirectly, any
portion of the Underlying Fund
Payments; (c) provides that the
Underlying Fund Payments may not
exceed the amount of actual expenses
incurred by the Top-Tier Funds; (d)
provides that no Underlying Fund will
reimburse transfer agent expenses of a
Top-Tier Fund, including out-of-pocket
expenses and other expenses, at a rate
in excess of the average per account
transfer agent expenses of the
Underlying Fund, including out-ofpocket expenses and other expenses,
expressed as a basis point charge (for
purposes of calculating the Underlying
Fund’s average per account transfer
agent expense, the Top-Tier Funds’
investment in the Underlying Fund will
be excluded); and (e) has been approved
by the Funds’ Board, including a
majority of the Independent Directors/
Trustees, as being in the best interests
of the Fund and its shareholders and not
involving overreaching on the part of
any person concerned.
2. In approving a Special Servicing
Agreement, the Board of an Underlying
Fund will consider, without limitation:
(a) The reasons for the Underlying
Fund’s entering into the Special
Servicing Agreement; (b) information
quantifying the Underlying Fund
Benefits; (c) the extent to which
investors in the Top-Tier Fund could
have purchased shares of the
Underlying Fund; (d) the extent to
which an investment in the Top-Tier
Fund represents or would represent a
consolidation of accounts in the
Underlying Funds, through exchanges
or otherwise, or a reduction in the rate
of increase in the number of accounts in
the Underlying Funds; (e) the extent to
which the expense ratio of the
Underlying Fund was reduced following
investment in the Underlying Fund by
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Federal Register / Vol. 77, No. 240 / Thursday, December 13, 2012 / Notices
the Top-Tier Fund and the reasonably
foreseeable effects of the investment by
the Top-Tier Fund on the Underlying
Fund’s expense ratio; (f) the reasonably
foreseeable effects of participation in the
Special Servicing Agreement on the
Underlying Fund’s expense ratio; and
(g) any conflicts of interest that the
Advisers, any affiliated person of the
Advisers, or any other affiliated person
of the Underlying Fund may have
relating to the Underlying Fund’s
participation in the Special Servicing
Agreement.
3. Prior to approving a Special
Servicing Agreement on behalf of an
Underlying Fund, the Board of the
Underlying Fund, including a majority
of the Independent Directors/Trustees,
will determine that: (a) The Underlying
Fund Payments under the Special
Servicing Agreement are expenses that
the Underlying Fund would have
incurred if the shareholders of the TopTier Fund had instead purchased shares
of the Underlying Fund through the
same broker-dealer or other financial
intermediary; (b) the amount of the
Underlying Fund Payments is less than
the amount of Underlying Fund
Benefits; and (c) by entering into the
Special Servicing Agreement, the
Underlying Fund is not engaging,
directly or indirectly, in financing any
activity which is primarily intended to
result in the sale of shares issued by the
Underlying Fund.
4. In approving a Special Servicing
Agreement, the Board of a Fund will
request and evaluate, and Advisers will
furnish, such information as may
reasonably be necessary to evaluate the
terms of the Special Servicing
Agreement and the factors set forth in
condition 2 above, and make the
determinations set forth in conditions 1
and 3 above.
5. Approval by the Fund’s Board,
including a majority of the Independent
Directors/Trustees, in accordance with
conditions 1 through 4 above, will be
required at least annually after the
Fund’s entering into a Special Servicing
Agreement and prior to any material
amendment to a Special Servicing
Agreement.
6. To the extent Underlying Fund
Payments are treated, in whole or in
part, as a class expense of an Underlying
Fund, or are used to pay a class-based
expense of a Top-Tier Fund, conditions
1 through 5 above must be met with
respect to each class of a Fund as well
as the Fund as a whole.
7. Each Fund will maintain and
preserve the Board’s findings and
determinations set forth in conditions 1
and 3 above, and the information and
considerations on which they were
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16:21 Dec 12, 2012
Jkt 229001
based, for the duration of the Special
Servicing Agreement, and for a period
not less than six years thereafter, the
first two years in an easily accessible
place.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2012–30050 Filed 12–12–12; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–68382; File No. SR–
NYSEARCA–2012–136]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Filing And
Immediate Effectiveness of Proposed
Rule Change to Allow for the SplitPrice Priority Provisions to Apply to
Open Outcry Trading of Cabinet
Trades
December 7, 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 30, 2012, NYSE Arca, Inc.
(the ‘‘Exchange’’ or ‘‘NYSE Arca’’) filed
with the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the Exchange. The
Commission is 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 Arca Options Rule 6.80 to allow
for the split-price priority provisions to
apply to open outcry trading of cabinet
trades. 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
1 15
2 17
PO 00000
U.S.C. 78s(b)(1).
CFR 240.19b–4.
Frm 00084
Fmt 4703
74247
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,
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
Statutory Basis for, Proposed Rule
Change
1. Purpose
The Exchange proposes to amend
Rule 6.80 to provide that the split-price
priority provisions in Rule 6.75(h) apply
to accommodation trades (‘‘cabinet
trades’’) in open outcry.3
3 See Rule 6.75(h). Rule 6.75(h) regarding priority
on split-price transaction occurring in open outcry
specifically provides the following: (1) If an OTP
Holder or OTP Firm purchases (sells) one or more
option contracts of a particular series at a particular
price or prices, the OTP Holder or OTP Firm must,
at the next lower (higher) price at which another
OTP Holder or OTP Firm bids (offers), have priority
in purchasing (selling) up to the equivalent number
of option contracts of the same series that the OTP
Holder or OTP Firm purchased (sold) at the higher
(lower) price or prices, provided that the OTP
Holder or OTP Firm’s bid (offer) is made promptly
and continuously and that the purchase (sale) so
effected represents the opposite side of a
transaction with the same order or offer (bid) as the
earlier purchase or purchases (sale or sales). This
paragraph only applies to transactions effected in
open outcry; (2) If an OTP Holder or OTP Firm
purchases (sells) fifty or more option contracts of
a particular series at a particular price or prices, he/
she shall, at the next lower (higher) price have
priority in purchasing (selling) up to the equivalent
number of option contracts of the same series that
he/she purchased (sold) at the higher (lower) price
or prices, but only if his/her bid (offer) is made
promptly and the purchase (sale) so effected
represents the opposite side of the transaction with
the same order or offer (bid) as the earlier purchase
or purchases (sale or sales). The Exchange may
increase the ‘‘minimum qualifying order size’’
above 100 contracts for all products.
Announcements regarding changes to the minimum
qualifying order size shall be made via an Exchange
Bulletin. This paragraph only applies to
transactions effected in open outcry; (3) If the bids
or offers of two or more OTP Holders or OTP Firms
are both entitled to priority in accordance with
subsections (1) or (2), it shall be afforded them,
insofar as practicable, on an equal basis; (4) Except
for the provisions set forth in Rule 6.75(h)(2), the
priority afforded by this rule is effective only
insofar as it does not conflict with customer limit
orders represented in the Consolidated Book. Such
orders have precedence over OTP Holders’ or OTP
Firms’ orders at a particular price; customer limit
orders in the Consolidated Book also have
precedence over OTP Holders’ or OTP Firms’ orders
that are not superior in price by at least the MPV;
and (5) Floor Brokers are able to achieve split price
priority in accordance with paragraphs (1) and (2)
above.
Example: Market quote is $1.00–1.20, with
customer interest in the book at the offer price.
Floor Broker announces a market order to buy 100
contracts. Market Maker A (‘‘MM–A’’) is alone in
responding ‘‘Sell 50 at $1.15 and 50 at $1.20’’ (for
an equivalent net price of $1.175).
Because MM–A is willing to sell contracts at the
lower price of $1.15, MM–A then has priority over
Continued
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Agencies
[Federal Register Volume 77, Number 240 (Thursday, December 13, 2012)]
[Notices]
[Pages 74245-74247]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-30050]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 30295; 812-14013]
ING Investments, LLC, et al.; Notice of Application
December 6, 2012.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application for an order under section 17(d) of the
Investment Company Act of 1940 (``Act'') and rule 17d-1 under the Act.
-----------------------------------------------------------------------
Summary of Application: Applicants request an order to permit certain
registered open-end investment companies in the same group of
investment companies to enter into a special servicing agreement
(``Special Servicing Agreement'').
Applicants: ING Investments, LLC (``IIL''), Directed Services LLC
(``DSL'') and ING Investment Management Co. LLC (``IIM'') (each, an
``Adviser,'' and collectively, the ``Advisers'') and ING Balanced
Portfolio, Inc., ING Equity Trust, ING Funds Trust, ING Intermediate
Bond Portfolio, ING Investors Trust, ING Mayflower Trust, ING Money
Market Portfolio, ING Mutual Funds, ING Partners, Inc., ING Separate
Portfolios Trust, ING Series Fund, Inc., ING Strategic Allocation
Portfolios, Inc., ING Variable Funds, ING Variable Portfolios, Inc.,
ING Variable Insurance Trust and ING Variable Products Trust
(collectively, the ``Registrants'') and the series thereof (the
Registrants and their series, collectively with the Advisers, the
``Applicants.'').\1\
---------------------------------------------------------------------------
\1\ All entities that currently intend to rely on the order have
been named as applicants. Any other entity that relies on the order
in the future will comply with the terms and conditions of the
application.
Filing Dates: The application was filed on March 9, 2012, and amended
---------------------------------------------------------------------------
on June 18, 2012, and October 26, 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 31, 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,
Huey P. Falgout, Jr., Chief Counsel, ING Funds, 7337 East Doubletree
Ranch Road, Suite 100, Scottsdale, Arizona 85255.
FOR FURTHER INFORMATION CONTACT: Emerson S. Davis, Senior Counsel, at
(202) 551-6868, or Daniele Marchesani, Branch Chief, at (202) 551-6821
(Division of Investment Management, Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or an applicant
using the Company name box, at https://www.sec.gov/search/search.htm or
by calling (202) 551-8090.
Applicants' Representations
1. The Advisers are investment advisers registered under the
Investment Advisers Act of 1940 and serve as investment advisers to the
Funds. Each Adviser is a direct or indirect subsidiary of ING Groep,
N.V.
2. Each Registrant is registered under the Act as an open-end
management investment company. Certain of the Funds, as defined below,
currently serve, and others in the future may serve, in ``fund-of-
funds'' arrangements whereby a Fund (each, a ``Top-Tier Fund,'' and
collectively, the ``Top-Tier Funds'') invests their assets in other
Funds (``Underlying Funds'').\2\
---------------------------------------------------------------------------
\2\ The Top-Tier Funds will not be Underlying Funds. Exhibit A
to the application identifies the current Top-Tier Funds and
Underlying Funds.
---------------------------------------------------------------------------
3. Applicants request that the order also apply to each existing or
future registered open-end management investment company or series
thereof that is part of the same ``group of investment companies'' as
the Registrants under Section 12(d)(1)(G)(ii) of the Act, and is
advised or sub-advised now or in the future by an Adviser or any entity
controlling, controlled by, or under common control with an Adviser
(such entity included in the term ``Adviser'' and such investment
companies or series thereof, collectively with the Registrants and
their series, the ``Funds'').
4. Applicants propose that the Funds enter into a Special Servicing
[[Page 74246]]
Agreement that would allow an Underlying Fund to bear the expenses of a
Top-Tier Fund (other than investment management fees, rule 12b-1 fees
and class-specific administrative service fees). Under the Special
Servicing Agreement, each Underlying Fund will bear expenses of a Top-
Tier Fund in proportion to the estimated benefits to the Underlying
Fund arising from the investment in the Underlying Fund by the Top-Tier
Fund (``Underlying Fund Benefits'').
5. Applicants state that the Underlying Fund Benefits are expected
to result primarily from the incremental increase in assets resulting
from investments in the Underlying Funds by the Top-Tier Funds and the
large size of a Top-Tier Fund's holdings of shares in a shareholder
account relative to the average size of the share balances held in
other Underlying Fund shareholder accounts. A Top-Tier Fund's
shareholder account will experience fewer shareholder transactions and
greater predictability of transaction activity than other shareholder
accounts. As a result, the shareholder servicing costs to any
Underlying Fund for servicing one account registered to a Top-Tier Fund
will be significantly less than the cost to that same Underlying Fund
of servicing the same pool of assets contributed by a large group of
shareholders owning relatively small accounts in one or more Underlying
Funds. In addition, by reducing Top-Tier Fund expenses, the Special
Servicing Agreement may lead to increased assets being invested in the
Top-Tier Funds, which in turn would lead to increased assets being
invested in the Underlying Funds. Further, increased assets could
enable the Underlying Funds to control and reduce their expense ratios
because their operating expenses will be spread over a larger asset
base.
6. No Fund will enter into a Special Servicing Agreement unless the
Special Servicing Agreement: (a) Precisely describes the services
provided to the Top-Tier Funds and the expenses incurred by a Top-Tier
Fund that may be reimbursed by an Underlying Fund (``Underlying Fund
Payments''); (b) provides that no affiliated person of the Top-Tier
Funds, or affiliated person of such person, will receive, directly or
indirectly, any portion of the Underlying Fund Payments; (c) provides
that the Underlying Fund Payments may not exceed the amount of actual
expenses incurred by the Top-Tier Funds; (d) provides that no
Underlying Fund will reimburse transfer agent expenses of a Top-Tier
Fund, including out-of-pocket expenses and other expenses, at a rate in
excess of the average per account transfer agent expenses of the
Underlying Fund, including out-of-pocket and other expenses, expressed
as a basis point charge (for purposes of calculating the Underlying
Fund's average per account transfer agent expense, the Top-Tier Fund's
investment in the Underlying Fund will be excluded); and (e) has been
approved by the Fund's board of trustees (``Board''), including a
majority of trustees who are not ``interested persons'' (within the
meaning of section 2(a)(19) of the Act) (``Independent Directors/
Trustees''), as being in the best interests of any Fund and its
shareholders and not involving overreaching on the part of any person
concerned.
Applicants' Legal Analysis
1. Section 17(d) of the Act and rule 17d-1 under the Act provide
that an affiliated person of, or a principal underwriter for, a
registered investment company, or an affiliate of such person or
principal underwriter, acting as principal, shall not participate in,
or effect any transaction in connection with, any joint enterprise or
other joint arrangement in which the registered investment company is a
participant unless the Commission has issued an order approving the
arrangement. Each Adviser, as investment adviser, is an affiliated
person of each of the Underlying Funds and Top-Tier Funds, which in
turn could be deemed to be under common control of the Advisers and
therefore affiliated persons of each other. The Top-Tier Funds and the
Underlying Funds also may be affiliated persons by virtue of a Top-Tier
Fund's ownership of more than 5% of the outstanding voting securities
of an Underlying Fund. Consequently, the Special Servicing Agreement
could be deemed to be a joint transaction among the Top-Tier Funds, the
Underlying Funds and Advisers.
2. Rule 17d-1 under the Act provides that, in passing upon a joint
arrangement under the rule, the Commission will consider whether
participation of the investment company in the joint enterprise or
joint arrangement on the basis proposed is consistent with the
provisions, policies, and purposes of the Act and the extent to which
the participation is on a basis different from or less advantageous
than that of other participants.
3. Applicants request an order under section 17(d) and rule 17d-1
to permit the proposed expense sharing arrangements. Applicants state
that participation by the Top-Tier Funds, the Underlying Funds and
Advisers in the proposed expense sharing arrangements is consistent
with the provisions, policies and purposes of the Act, and that the
terms of the Special Servicing Agreement and the conditions set forth
below will ensure that no participant will participate on a basis less
advantageous than that of other participants.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
1. No Fund will enter into a Special Servicing Agreement unless the
Special Servicing Agreement: (a) Precisely describes the services
provided to the Top-Tier Funds and the Underlying Fund Payments; (b)
provides that no affiliated person of the Top-Tier Funds, or affiliated
person of such person, will receive, directly or indirectly, any
portion of the Underlying Fund Payments; (c) provides that the
Underlying Fund Payments may not exceed the amount of actual expenses
incurred by the Top-Tier Funds; (d) provides that no Underlying Fund
will reimburse transfer agent expenses of a Top-Tier Fund, including
out-of-pocket expenses and other expenses, at a rate in excess of the
average per account transfer agent expenses of the Underlying Fund,
including out-of-pocket expenses and other expenses, expressed as a
basis point charge (for purposes of calculating the Underlying Fund's
average per account transfer agent expense, the Top-Tier Funds'
investment in the Underlying Fund will be excluded); and (e) has been
approved by the Funds' Board, including a majority of the Independent
Directors/Trustees, as being in the best interests of the Fund and its
shareholders and not involving overreaching on the part of any person
concerned.
2. In approving a Special Servicing Agreement, the Board of an
Underlying Fund will consider, without limitation: (a) The reasons for
the Underlying Fund's entering into the Special Servicing Agreement;
(b) information quantifying the Underlying Fund Benefits; (c) the
extent to which investors in the Top-Tier Fund could have purchased
shares of the Underlying Fund; (d) the extent to which an investment in
the Top-Tier Fund represents or would represent a consolidation of
accounts in the Underlying Funds, through exchanges or otherwise, or a
reduction in the rate of increase in the number of accounts in the
Underlying Funds; (e) the extent to which the expense ratio of the
Underlying Fund was reduced following investment in the Underlying Fund
by
[[Page 74247]]
the Top-Tier Fund and the reasonably foreseeable effects of the
investment by the Top-Tier Fund on the Underlying Fund's expense ratio;
(f) the reasonably foreseeable effects of participation in the Special
Servicing Agreement on the Underlying Fund's expense ratio; and (g) any
conflicts of interest that the Advisers, any affiliated person of the
Advisers, or any other affiliated person of the Underlying Fund may
have relating to the Underlying Fund's participation in the Special
Servicing Agreement.
3. Prior to approving a Special Servicing Agreement on behalf of an
Underlying Fund, the Board of the Underlying Fund, including a majority
of the Independent Directors/Trustees, will determine that: (a) The
Underlying Fund Payments under the Special Servicing Agreement are
expenses that the Underlying Fund would have incurred if the
shareholders of the Top-Tier Fund had instead purchased shares of the
Underlying Fund through the same broker-dealer or other financial
intermediary; (b) the amount of the Underlying Fund Payments is less
than the amount of Underlying Fund Benefits; and (c) by entering into
the Special Servicing Agreement, the Underlying Fund is not engaging,
directly or indirectly, in financing any activity which is primarily
intended to result in the sale of shares issued by the Underlying Fund.
4. In approving a Special Servicing Agreement, the Board of a Fund
will request and evaluate, and Advisers will furnish, such information
as may reasonably be necessary to evaluate the terms of the Special
Servicing Agreement and the factors set forth in condition 2 above, and
make the determinations set forth in conditions 1 and 3 above.
5. Approval by the Fund's Board, including a majority of the
Independent Directors/Trustees, in accordance with conditions 1 through
4 above, will be required at least annually after the Fund's entering
into a Special Servicing Agreement and prior to any material amendment
to a Special Servicing Agreement.
6. To the extent Underlying Fund Payments are treated, in whole or
in part, as a class expense of an Underlying Fund, or are used to pay a
class-based expense of a Top-Tier Fund, conditions 1 through 5 above
must be met with respect to each class of a Fund as well as the Fund as
a whole.
7. Each Fund will maintain and preserve the Board's findings and
determinations set forth in conditions 1 and 3 above, and the
information and considerations on which they were based, for the
duration of the Special Servicing Agreement, and for a period not less
than six years thereafter, the first two years in an easily accessible
place.
For the Commission, by the Division of Investment Management,
pursuant to delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2012-30050 Filed 12-12-12; 8:45 am]
BILLING CODE 8011-01-P