Munder Series Trust, et al.;, 20701-20705 [2013-07947]
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Federal Register / Vol. 78, No. 66 / Friday, April 5, 2013 / Notices
Applicant’s Address: 100
International Dr., 7th Floor, Baltimore,
MD 21202.
BlackRock Credit Allocation Income
Trust II, Inc. [File No. 811–21286]
Summary: Applicant, a closed-end
investment company, seeks an order
declaring that it has ceased to be an
investment company. The applicant has
transferred its assets to BlackRock
Credit Allocation Income Trust IV and,
on December 10, 2012, made a final
distribution to its shareholders based on
net asset value. Expenses of $340,672
incurred in connection with the
reorganization were paid by BlackRock
Advisors, LLC, applicant’s investment
adviser.
Filing Dates: The application was
filed on January 15, 2013, and amended
on February 21, 2013 and March 25,
2013.
Applicant’s Address: 100 Bellevue
Parkway, Wilmington, DE 19809.
Excelsior Multi-Strategy Hedge Fund of
Funds (TE), LLC [File No. 811–22035]
Excelsior Multi-Strategy Hedge Fund of
Funds (TI), LLC [File No. 811–22036]
Excelsior Multi-Strategy Hedge Fund of
Funds (TE 2), LLC [File No. 811–22318]
Summary: Each applicant, a closedend investment company, seeks an
order declaring that it has ceased to be
an investment company. The applicants
have transferred their assets to Excelsior
Multi-Strategy Hedge Fund of Funds,
LLC (formerly named Excelsior MultiStrategy Hedge Fund of Funds Master
Fund, LLC) and, on December 31, 2012,
Excelsior Multi-Strategy Hedge Fund of
Funds (TE), LLC and Excelsior MultiStrategy Hedge Fund of Funds (TI), LLC,
and on January 31, 2013, Excelsior
Multi-Strategy Hedge Fund of Funds
(TE2), LLC, each made a final
distribution to its shareholders based on
net asset value. Each applicant incurred
expenses of approximately $75,000 in
connection with its reorganization.
Filing Date: The applications were
filed on February 21, 2013.
Applicant’s Address: 225 High Ridge
Rd., Stamford, CT 06905.
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Eclipse Funds [File No. 811–4847]
Summary: Applicant seeks an order
declaring that it has ceased to be an
investment company. Each series of
applicant has transferred its assets to a
corresponding shell series of MainStay
Funds Trust and, on May 25, 2012,
made a final distribution to its
shareholders based on net asset value.
Expenses of $142,330 incurred in
connection with the reorganization were
paid by applicant.
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Filing Date: The application was filed
on February 8, 2013.
Applicant’s Address: 51 Madison
Ave., New York, NY 10010.
NCM Capital Investment Trust [File No.
811–22015]
Summary: Applicant seeks an order
declaring that it has ceased to be an
investment company. On August 30,
2012, applicant made a liquidating
distribution to its shareholders, based
on net asset value. Expenses of $13,793
incurred in connection with the
liquidation were paid by NCM Capital
Advisers, Inc., applicant’s investment
adviser.
Filing Date: The application was filed
on February 22, 2013.
Applicant’s Address: 2634 DurhamChapel Hill Boulevard, Suite 206,
Durham, NC 27707.
DWS Value Equity Trust [File No. 811–
1444]
Summary: Applicant seeks an order
declaring that it has ceased to be an
investment company. Applicant has
transferred its assets to DWS S&P 500
Index Fund, a series of DWS
Institutional Funds, and on April 30,
2012, applicant made a final
distribution to its shareholders based on
net asset value. Expenses of $185,690
incurred in connection with the
reorganization were paid by Deutsche
Investment Management Americas Inc.,
applicant’s investment adviser.
Filing Date: The application was filed
on February 22, 2013.
Applicant’s Address: 345 Park Ave.,
New York, NY 10154.
Midas Perpetual Portfolio, Inc. [File No.
811–2474]
Midas Magic, Inc. [File No. 811–4625]
Summary: Each applicant seeks an
order declaring that it has ceased to be
an investment company. The applicants
have transferred their assets to Midas
Series Trust and, on October 12, 2012,
each made a final distribution to its
shareholders based on net asset value.
Expenses of approximately $79,092 and
$79,487, respectively, incurred in
connection with the reorganizations
were paid by each applicant.
Filing Date: The applications were
filed on March 4, 2013.
Applicant’s Address: 11 Hanover Sq.,
New York, NY 10005.
FBR Funds [File No. 811–21503]
Summary: Applicant seeks an order
declaring that it has ceased to be an
investment company. Each series of
applicant has transferred its assets to a
corresponding series of Hennessy Funds
Trust or Hennessy Mutual Funds, Inc.
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20701
and, on October 26, 2012, made a final
distribution to its shareholders based on
net asset value. Expenses of $1,175,000
incurred in connection with the
reorganization were paid by FBR Fund
Advisers, Inc., applicant’s investment
adviser, and Hennessy Advisors, Inc.,
investment adviser to the acquiring
funds.
Filing Date: The application was filed
on March 1, 2013.
Applicant’s Address: FBR Fund
Advisers, Inc., 1001 Nineteenth St.
North, Arlington, VA 22209.
YieldQuest Funds Trust [File No. 811–
21771]
Summary: Applicant seeks an order
declaring that it has ceased to be an
investment company. On August 31,
2012, applicant made a liquidating
distribution to its shareholders, based
on net asset value. Expenses of $31,250
incurred in connection with the
liquidation were paid by applicant and
YieldQuest Advisors, LLC, applicant’s
investment adviser.
Filing Date: The application was filed
on February 22, 2013.
Applicant’s Address: 3280 Peachtree
Rd., Suite 2600, Atlanta, GA 30305.
For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2013–07946 Filed 4–4–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
30441; File No. 812–14099]
Munder Series Trust, et al.; Notice of
Application
March 29, 2013.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application under
section 6(c) of the Investment Company
Act of 1940 (‘‘Act’’) for an exemption
from section 15(a) of the Act and rule
18f–2 under the Act, as well as from
certain disclosure requirements.
AGENCY:
Summary of Application:
Applicants request an order that would
permit them to enter into and materially
amend sub-advisory agreements with
Wholly-Owned Sub-Advisers (as
defined below) and non-affiliated subadvisers without shareholder approval
and would grant relief from certain
disclosure requirements.
SUMMARY:
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Federal Register / Vol. 78, No. 66 / Friday, April 5, 2013 / Notices
Applicants: Munder Series Trust (the
‘‘Trust’’) and Munder Capital
Management (‘‘MCM’’).
DATES: Filing Dates: The application
was filed on November 28, 2012, and
amended on December 31, 2012, March
15, 2013 and March 28, 2013.
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 April 23, 2013, 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, 480 Pierce Street,
Birmingham, MI 48009.
FOR FURTHER INFORMATION CONTACT:
Bruce R. MacNeil, Senior Counsel, at
(202) 551–6876, or Daniele Marchesani,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Exemptive Applications Office).
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.
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Applicants’ Representations
1. The Trust is organized as a
Delaware statutory trust and is
registered under the Act as an open-end
management investment company. The
Trust may offer one or more series of
shares (each, a ‘‘Series’’) with its own
distinct investment objective, policies
and restrictions.1 MCM is organized as
a Delaware general partnership and is
registered as an investment adviser
1 The current Series of the Trust are: Munder
Bond Fund, Munder Growth Opportunities Fund,
Munder Index 500 Fund, Munder Integrity Mid-Cap
Value Fund, Munder Integrity Small/Mid-Cap
Value Fund, Munder International Fund-Core
Equity, Munder International Small-Cap Fund,
Munder Large-Cap Value Fund, Munder Micro-Cap
Equity Fund, Munder Mid-Cap Core Growth Fund,
and Munder Veracity Small-Cap Value Fund.
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under the Investment Advisers Act of
1940 (‘‘Advisers Act’’). Each Series has,
or will have, as its investment adviser,
MCM, or another investment adviser
controlling, controlled by or under
common control with MCM or its
successors (each, an ‘‘Adviser’’).2 Any
future Adviser will also be registered as
an investment adviser under the
Advisers Act.3
2. The Adviser serves as the
investment adviser to each Series
pursuant to an investment advisory
agreement with the Trust (‘‘Investment
Advisory Agreement’’). The Investment
Advisory Agreement was approved by
the board of trustees of the Trust
(‘‘Board’’),4 including a majority of the
members of the Board who are not
‘‘interested persons,’’ as defined in
section 2(a)(19) of the Act, of the Trust,
of a Series or the Adviser (‘‘Independent
Trustees’’) and by the shareholders of
the relevant Series as required by
sections 15(a) and 15(c) of the Act and
rule 18f-2 thereunder. The terms of the
Investment Advisory Agreement comply
with section 15(a) of the Act.
3. Under the terms of the Investment
Advisory Agreement, the Adviser,
subject to the supervision of the Board,
will provide continuous investment
management of the assets of each Series.
The Adviser periodically reviews each
Series’ investment objective, policies
and strategies, and based on the need of
a Series may recommend changes to the
investment objective, policies and
strategies of the Series for consideration
by the Board. For its services to each
Series under the Investment Advisory
Agreement, the Adviser receives an
advisory fee from that Series based on
the average daily net assets of that
Series. The Investment Advisory
Agreement provides that the Adviser
may, subject to the approval of the
Board, including a majority of the
Independent Trustees, and the
shareholders of the applicable Series (if
required), delegate portfolio
2 For purposes of the requested order, ‘‘successor’’
is limited to an entity that results from a
reorganization into another jurisdiction or a change
in the type of business organization.
3 Applicants request that the relief apply to
applicants, as well as to any future Series and any
other existing or future registered open-end
management investment company or series thereof
that (a) is advised by an Adviser, (b) uses the
manager of managers structure described in the
application (‘‘Manager of Managers Structure’’), and
(c) complies with the terms and conditions of the
application (‘‘Sub-Advised Series’’). All registered
open-end investment companies that currently
intend to rely on the requested order are named as
applicants. Any entity that relies on the requested
order will do so only in accordance with the terms
and conditions contained in the application.
4 The term ‘‘Board’’ also includes the board of
trustees or directors of a future Series.
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management responsibilities of all or a
portion of the assets of a Series to a SubAdviser.5
4. Applicants request an order to
permit the Adviser, subject to the
approval of the Board, including a
majority of the Independent Trustees,
to, without obtaining shareholder
approval: (a) Select Sub-Advisers to
manage all or a portion of the assets of
a Series and enter into Sub-Advisory
Agreements (as defined below) with the
Sub-Advisers, and (b) materially amend
Sub-Advisory Agreements with the SubAdvisers.6 The requested relief will not
extend to any sub-adviser, other than a
Wholly-Owned Sub-Adviser, who is an
affiliated person, as defined in section
2(a)(3) of the Act, of the Sub-Advised
Series, of the Trust, or of the Adviser,
other than by reason of serving as a subadviser to one or more of the SubAdvised Series (‘‘Affiliated SubAdviser’’).
5. Pursuant to the terms of the
Investment Advisory Agreement, the
Adviser will have overall responsibility
for the management and investment of
each Series’ assets. These
responsibilities include recommending
the removal or replacement of SubAdvisers, determining the portion of
that Sub-Advised Series’ assets to be
managed by any given Sub-Adviser and
reallocating those assets as necessary
from time to time.
6. The Adviser has entered into subadvisory agreements with various SubAdvisers (‘‘Sub-Advisory Agreements’’)
to provide investment management
services to the Sub-Advised Series.7 The
terms of the Sub-Advisory Agreements
comply fully with the requirements of
5 As used herein, a ‘‘Sub-Adviser’’ is (a) an
indirect or direct ‘‘wholly-owned subsidiary’’ (as
such term is defined in the Act) of the Adviser for
that Series; (b) a sister company of the Adviser for
that Series that is an indirect or direct ‘‘whollyowned subsidiary’’ (as such term is defined in the
Act) of the same company that, indirectly or
directly, wholly owns the Adviser (each of (a) and
(b), a ‘‘Wholly-Owned Sub-Adviser’’ and
collectively, the ‘‘Wholly-Owned Sub-Advisers’’),
or (c) not an ‘‘affiliated person’’ (as such term is
defined in section 2(a)(3) of the Act) of the
applicable Series, the Trust, or the Adviser, except
to the extent that an affiliation arises solely because
the Sub-adviser serves as a sub-adviser to a Series
(each, a ‘‘Non-Affiliated Sub-Adviser’’).
6 Shareholder approval will continue to be
required for any other sub-adviser change (not
otherwise permitted by rule or other action of the
Commission or staff) and material amendments to
an existing Sub-Advisory Agreement with any subadviser other than a Non-Affiliated Sub-Adviser or
a Wholly-Owned Sub-Adviser (all such changes
referred to as ‘‘Ineligible Sub-Adviser Changes’’).
7 If the name of any Sub-Advised Series contains
the name of a Sub-Adviser, the name of the Adviser
that serves as the primary adviser to the SubAdvised Series, or a trademark or trade name that
is owned by that Adviser, will precede the name of
the Sub-Adviser.
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section 15(a) of the Act and were
approved by the Board, including a
majority of the Independent Trustees
and the shareholders of the applicable
Series, in accordance with sections 15(a)
and 15(c) of the Act and rule 18f-2
thereunder. The specific day-to-day
investment decisions for each
applicable Series are made by that
Series’ Sub-Adviser, which has
discretionary authority to invest the
assets or a portion of the assets of that
Series subject to the general supervision
of the Adviser and the Board. The
Adviser currently compensates each
Sub-Adviser out of the advisory fees
paid to the Adviser under the
Investment Advisory Agreement; in the
future, Sub-Advised Series may directly
pay advisory fees to the Sub-Advisers.
7. Sub-Advised Series will inform
shareholders of the hiring of a new SubAdviser pursuant to the following
procedures (‘‘Notice and Access
Procedures’’): (a) Within 90 days after a
new Sub-Adviser is hired for any SubAdvised Series, that Sub-Advised Series
will send its shareholders either a
Multi-Manager Notice or a MultiManager Notice and Multi-Manager
Information Statement; 8 and (b) the
Sub-Advised Series will make the
Multi-Manager Information Statement
available on the Web site identified in
the Multi-Manager Notice no later than
when the Multi-Manager Notice (or
Multi-Manager Notice and MultiManager Information Statement) is first
sent to shareholders, and will maintain
it on that Web site for at least 90 days
thereafter. In the circumstances
described in the application, a proxy
solicitation to approve the appointment
of new Sub-Advisers provides no more
meaningful information to shareholders
than the proposed Multi-Manager
Information Statement. Applicants state
8 A ‘‘Multi-Manager Notice’’ will be modeled on
a Notice of Internet Availability as defined in rule
14a–16 under the Securities Exchange Act of 1934
(‘‘Exchange Act’’), and specifically will, among
other things: (a) summarize the relevant information
regarding the new Sub-Adviser; (b) inform
shareholders that the Multi-Manager Information
Statement is available on a Web site; (c) provide the
Web site address; (d) state the time period during
which the Multi-Manager Information Statement
will remain available on that Web site; (e) provide
instructions for accessing and printing the MultiManager Information Statement; and (f) instruct the
shareholder that a paper or email copy of the MultiManager Information Statement may be obtained,
without charge, by contacting the Sub-Advised
Series.
A ‘‘Multi-Manager Information Statement’’ will
meet the requirements of Regulation 14C, Schedule
14C and Item 22 of Schedule 14A under the
Exchange Act for an information statement, except
as modified by the order to permit Aggregate Fee
Disclosure (as defined below). Multi-Manager
Information Statements will be filed with the
Commission via the EDGAR system.
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that each Board would comply with the
requirements of sections 15(a) and 15(c)
of the Act before entering into or
amending a Sub-Advisory Agreement.
8. Applicants also request an order
exempting the Sub-Advised Series from
certain disclosure obligations that may
require each Sub-Advised Series to
disclose fees paid by the Adviser to each
Sub-Adviser. Applicants seek relief to
permit each Sub-Advised Series to
disclose (as a dollar amount and a
percentage of the Sub-Advised Series’
net assets): (a) The aggregate fees paid
to the Adviser and any Wholly-Owned
Sub-Advisers; (b) the aggregate fees paid
to Non-Affiliated Sub-Advisers; and (c)
the fee paid to each Affiliated SubAdviser (collectively, the ‘‘Aggregate
Fee Disclosure’’).
Applicants’ Legal Analysis
1. Section 15(a) of the Act states, in
part, that it is unlawful for any person
to act as an investment adviser to a
registered investment company ‘‘except
pursuant to a written contract, which
contract, whether with such registered
company or with an investment adviser
of such registered company, has been
approved by the vote of a majority of the
outstanding voting securities of such
registered company.’’ Rule 18f–2 under
the Act provides that each series or class
of stock in a series investment company
affected by a matter must approve that
matter if the Act requires shareholder
approval.
2. Form N–1A is the registration
statement used by open-end investment
companies. Item 19(a)(3) of Form N–1A
requires a registered investment
company to disclose in its statement of
additional information the method of
computing the ‘‘advisory fee payable’’
by the investment company, including
the total dollar amounts that the
investment company ‘‘paid to the
adviser (aggregated with amounts paid
to affiliated advisers, if any), and any
advisers who are not affiliated persons
of the adviser, under the investment
advisory contract for the last three fiscal
years.’’
3. Rule 20a–1 under the Act requires
proxies solicited with respect to a
registered investment company to
comply with Schedule 14A under the
Exchange Act. Items 22(c)(1)(ii),
22(c)(1)(iii), 22(c)(8) and 22(c)(9) of
Schedule 14A, taken together, require a
proxy statement for a shareholder
meeting at which the advisory contract
will be voted upon to include the ‘‘rate
of compensation of the investment
adviser,’’ the ‘‘aggregate amount of the
investment adviser’s fee,’’ a description
of the ‘‘terms of the contract to be acted
upon,’’ and, if a change in the advisory
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fee is proposed, the existing and
proposed fees and the difference
between the two fees.
4. Regulation S–X sets forth the
requirements for financial statements
required to be included as part of a
registered investment company’s
registration statement and shareholder
reports filed with the Commission.
Sections 6–07(2)(a), (b), and (c) of
Regulation S–X require a registered
investment company to include in its
financial statement information about
the investment advisory fees.
5. Section 6(c) of the Act provides that
the Commission by order upon
application may conditionally or
unconditionally exempt any person,
security, or transaction or any class or
classes of persons, securities, or
transactions from any provisions of the
Act, or from any rule thereunder, if such
exemption is necessary or appropriate
in the public interest and consistent
with the protection of investors and the
purposes fairly intended by the policy
and provisions of the Act. Applicants
state that their requested relief meets
this standard for the reasons discussed
below.
6. Applicants assert that the
shareholders expect the Adviser, subject
to the review and approval of the Board,
to select the Sub-Advisers that are
suited to achieve the Series’ investment
objective. Applicants assert that, from
the perspective of the shareholder, the
role of the Sub-Adviser is substantially
equivalent to the role of the individual
portfolio managers employed by an
investment adviser to a traditional
investment company. Applicants
believe that permitting the Adviser to
perform the duties for which the
shareholders of the Sub-Advised Series
are paying the Adviser—the selection,
supervision and evaluation of the SubAdviser—without incurring
unnecessary delays or expenses is
appropriate in the interest of the Series’
shareholders and will allow the Series
to operate more efficiently. Applicants
state that the Investment Advisory
Agreement will continue to be fully
subject to section 15(a) of the Act and
rule 18f–2 under the Act and approved
by the Board, including a majority of the
Independent Trustees, in the manner
required by sections 15(a) and 15(c) of
the Act. Applicants are not seeking an
exemption with respect to the
Investment Advisory Agreement.
7. Applicants assert that disclosure of
the individual fees that the Adviser
would pay to the Sub-Advisers of SubAdvised Series that operate under the
Manager of Managers Structure would
not serve any meaningful purpose.
Applicants contend that the primary
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reasons for requiring disclosure of
individual fees paid to Sub-Advisers are
to inform shareholders of expenses to be
charged by a particular Sub-Advised
Series and to enable shareholders to
compare the fees to those of other
comparable investment companies.
Applicants believe that the requested
relief satisfies these objectives because
the advisory fee paid to the Adviser, or
the Aggregate Fee Disclosure, in the case
of a Sub-Advised Series that directly
compensates a Sub-Adviser, will be
fully disclosed and, therefore,
shareholders will know what the SubAdvised Series’ fees and expenses are
and will be able to compare the advisory
fees a Sub-Advised Series is charged to
those of other investment companies.
Applicants assert that the requested
disclosure relief would benefit
shareholders of the Sub-Advised Series
because it would improve the Adviser’s
ability to negotiate the fees paid to SubAdvisers. Applicants state that the
Adviser may be able to negotiate rates
that are below a Sub-Adviser’s ‘‘posted’’
amounts if the Adviser is not required
to disclose the Sub-Advisers’ fees to the
public. Applicants submit that the relief
requested to use Aggregate Fee
Disclosure will encourage Sub-Advisers
to negotiate lower sub-advisory fees
with the Adviser if the lower fees are
not required to be made public.
8. For the reasons discussed above,
applicants submit that the requested
relief meets the standards for relief
under section 6(c) of the Act. Applicants
state that the operation of the SubAdvised Series in the manner described
in the application must be approved by
shareholders of a Sub-Advised Series
before that Sub-Advised Series may rely
on the requested relief. In addition,
applicants state that the proposed
conditions to the requested relief are
designed to address any potential
conflicts of interest, including any
posed by the use of Wholly-Owned SubAdvisers, and provide that shareholders
are informed when new Sub-Advisers
are hired. Applicants assert that
conditions 6, 7, 9, 10 and 11 are
designed to provide the Board with
sufficient independence and the
resources and information it needs to
monitor and address any conflicts of
interest with affiliated persons of the
Adviser, including Wholly-Owned SubAdvisers. Applicants state that,
accordingly, they believe the requested
relief 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.
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Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
1. Before a Sub-Advised Series may
rely on the order requested in the
application, the operation of the SubAdvised Series in the manner described
in the application, including the hiring
of Wholly-Owned Sub-Advisers, will be
approved by a majority of the SubAdvised Series’ outstanding voting
securities as defined in the Act, or, in
the case of a Sub-Advised Series whose
public shareholders purchase shares on
the basis of a prospectus containing the
disclosure contemplated by condition 2
below, by the sole initial shareholder
before offering the Sub-Advised Series’
shares to the public.
2. The prospectus for each SubAdvised Series will disclose the
existence, substance, and effect of any
order granted pursuant to the
application. Each Sub-Advised Series
will hold itself out to the public as
employing the Manager of Managers
Structure. Each prospectus will
prominently disclose that the Adviser
has the ultimate responsibility, subject
to oversight by the Board, to oversee the
Sub-Advisers and recommend their
hiring, termination and replacement.
3. The Adviser will provide general
management services to each SubAdvised Series, including overall
supervisory responsibility for the
general management and investment of
the Sub-Advised Series’ assets, and,
subject to review and approval by the
Board, the Adviser will: (a) Set the SubAdvised Series’ overall investment
strategies; (b) evaluate, select, and
recommend Sub-Advisers to manage all
or a portion of the Sub-Advised Series’
assets; and (c) implement procedures
reasonably designed to ensure that the
Sub-Advisers comply with a SubAdvised Series’ investment objectives,
policies and restrictions. Subject to
review by the Board, the Adviser will (a)
when appropriate, allocate and
reallocate the Sub-Advised Series’ assets
among multiple Sub-Advisers; and (b)
monitor and evaluate the performance
of Sub-Advisers.
4. A Sub-Advised Series will not
make any Ineligible Sub-Adviser
Changes without the approval of the
shareholders of the applicable SubAdvised Series.
5. A Sub-Advised Series will inform
shareholders of the hiring of a new SubAdviser within 90 days after the hiring
of the new Sub-Adviser pursuant to the
Notice and Access Procedures.
6. At all times, at least a majority of
the Board will be Independent Trustees,
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Frm 00093
Fmt 4703
Sfmt 4703
and the selection and nomination of
new or additional Independent Trustees
will be placed within the discretion of
the then-existing Independent Trustees.
7. Independent Legal Counsel, as
defined in rule 0–1(a)(6) under the Act,
will be engaged to represent the
Independent Trustees. The selection of
such counsel will be within the
discretion of the then-existing
Independent Trustees.
8. The Adviser will provide the
Board, no less frequently than quarterly,
with information about the profitability
of the Adviser on a per Sub-Advised
Series basis. The information will reflect
the impact on profitability of the hiring
or termination of any Sub-Adviser
during the applicable quarter.
9. Whenever a Sub-Adviser is hired or
terminated, the Adviser will provide the
Board with information showing the
expected impact on the profitability of
the Adviser.
10. Whenever a Sub-Adviser change is
proposed for a Sub-Advised Series with
an Affiliated Sub-Adviser or a WhollyOwned Sub-Adviser, the Board,
including a majority of the Independent
Trustees, will make a separate finding,
reflected in the Trust’s Board minutes,
that such change is in the best interests
of the Sub-Advised Series and its
shareholders and does not involve a
conflict of interest from which the
Adviser or the Affiliated Sub-Adviser or
Wholly-Owned Sub-Adviser derives an
inappropriate advantage.
11. No trustee or officer of the Trust
or of a Sub-Advised Series or any
partner, director, manager or officer of
the Adviser will own directly or
indirectly (other than through a pooled
investment vehicle that is not controlled
by such person) any interest in a SubAdviser except for: (a) Ownership of
interests in the Adviser or any entity
that controls, is controlled by, or is
under common control with the
Adviser; or (b) ownership of less than
1% of the outstanding securities of any
class of equity or debt of a publicly
traded company that is either a SubAdviser or an entity that controls, is
controlled by, or is under common
control with a Sub-Adviser.
12. Each Sub-Advised Series will
disclose the Aggregate Fee Disclosure in
its registration statement.
13. In the event the Commission
adopts a rule under the Act providing
substantially similar relief to that
requested in the application, the
requested order will expire on the
effective date of that rule.
14. For Sub-Advised Series that pay
fees to a Sub-Adviser directly from fund
assets, any changes to a Sub-Advisory
Agreement that would result in an
E:\FR\FM\05APN1.SGM
05APN1
Federal Register / Vol. 78, No. 66 / Friday, April 5, 2013 / Notices
increase in the total management and
advisory fees payable by a Sub-Advised
Series will be required to be approved
by the shareholders of the Sub-Advised
Series.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2013–07947 Filed 4–4–13; 8:45 am]
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–69275; File No. 4–660]
Fixed Income Roundtable
Securities and Exchange
Commission.
ACTION: Notice of roundtable discussion;
request for comment.
AGENCY:
The Securities and Exchange
Commission will host a one day
roundtable to discuss the current market
structure and potential ways to improve
the transparency, liquidity, efficiency,
and other aspects of fixed income
markets. The roundtable will focus on
the municipal securities, corporate
bonds, and asset-backed securities
markets.
The roundtable discussion will be
held in the multi-purpose room of the
Securities and Exchange Commission
headquarters at 100 F Street NE., in
Washington, DC on April 16, 2013
beginning at 8:45 a.m. and ending at
approximately 4:15 p.m. The public is
invited to observe the roundtable
discussion. Seating will be available on
a first-come, first-served basis. The
roundtable discussion also will be
available via webcast on the
Commission’s Web site at www.sec.gov.
The roundtable will consist of four
panels. The participants in the first
panel will discuss the current market
structure for municipal securities. The
participants in the second panel will
discuss the current market structure for
corporate bonds and asset-backed
securities. The participants in the third
panel will discuss potential
improvements to the market structure
for municipal securities. The
participants in the fourth panel will
discuss potential improvements to the
market structure for corporate bonds
and asset-backed securities.
DATES: The roundtable discussion will
take place on April 16, 2013. The
Commission will accept comments
regarding issues addressed at the
roundtable until May 7, 2013.
mstockstill on DSK4VPTVN1PROD with NOTICES
SUMMARY:
17:14 Apr 04, 2013
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/other.shtml); or
• Send an email to rulecomments@sec.gov. Please include File
Number 4–660 on the subject line.
Paper Comments
BILLING CODE 8011–01–P
VerDate Mar<15>2010
Comments may be
submitted by any of the following
methods:
ADDRESSES:
Jkt 229001
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
100 F Street NE., Washington, DC
20549–1090.
All submission should refer to File
Number 4–660. This file number should
be included on the subject line if email
is used. To help us process and review
your comments more efficiently, please
use only one method. The Commission
will post all comments on the
Commission’s Internet Web site (https://
www.sec.gov/rules/other.shtml).
Comments are also available for Web
site viewing and printing in the
Commission’s Public Reference Room,
100 F Street NE., Washington, DC
20549, on official business days
between the hours of 10:00 a.m. and
3:00 p.m. All comments received will be
posted without change; we do not edit
personal identifying information from
submissions. You should submit only
information that you wish to make
available publicly.
FOR FURTHER INFORMATION CONTACT:
Ronesha A. Butler, Special Counsel, at
(202) 551–5629, Division of Trading and
Markets, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–7010.
Dated: April 2, 2013.
By the Commission.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2013–07983 Filed 4–4–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 9398; Release No. 69265]
Securities Act of 1933; Securities
Exchange Act of 1934; Order
Regarding Review of FASB Accounting
Support Fee for 2013 Under Section
109 of the Sarbanes-Oxley Act of 2002
April 2, 2013.
The Sarbanes-Oxley Act of 2002 (the
‘‘Act’’) provides that the Securities and
Exchange Commission (the
‘‘Commission’’) may recognize, as
PO 00000
Frm 00094
Fmt 4703
Sfmt 4703
20705
generally accepted for purposes of the
securities laws, any accounting
principles established by a standard
setting body that meets certain criteria.
Consequently, Section 109 of the Act
provides that all of the budget of such
a standard setting body shall be payable
from an annual accounting support fee
assessed and collected against each
issuer, as may be necessary or
appropriate to pay for the budget and
provide for the expenses of the standard
setting body, and to provide for an
independent, stable source of funding,
subject to review by the Commission.
Under Section 109(f) of the Act, the
amount of fees collected for a fiscal year
shall not exceed the ‘‘recoverable budget
expenses’’ of the standard setting body.
Section 109(h) amends Section 13(b)(2)
of the Securities Exchange Act of 1934
to require issuers to pay the allocable
share of a reasonable annual accounting
support fee or fees, determined in
accordance with Section 109 of the Act.
On April 25, 2003, the Commission
issued a policy statement concluding
that the Financial Accounting Standards
Board (‘‘FASB’’) and its parent
organization, the Financial Accounting
Foundation (‘‘FAF’’), satisfied the
criteria for an accounting standardsetting body under the Act, and
recognizing the FASB’s financial
accounting and reporting standards as
‘‘generally accepted’’ under Section 108
of the Act.1 As a consequence of that
recognition, the Commission undertook
a review of the FASB’s accounting
support fee for calendar year 2013. In
connection with its review, the
Commission also reviewed the budget
for the FAF and the FASB for calendar
year 2013.
Section 109 of the Act also provides
that the standard setting body can have
additional sources of revenue for its
activities, such as earnings from sales of
publications, provided that each
additional source of revenue shall not
jeopardize, in the judgment of the
Commission, the actual or perceived
independence of the standard setter. In
this regard, the Commission also
considered the interrelation of the
operating budgets of the FAF, the FASB,
and the Governmental Accounting
Standards Board (‘‘GASB’’), the FASB’s
sister organization, which sets
accounting standards used by state and
local government entities. The
Commission has been advised by the
FAF that neither the FAF, the FASB, nor
the GASB accept contributions from the
accounting profession.
The Commission understands that the
Office of Management and Budget
1 Financial
E:\FR\FM\05APN1.SGM
Reporting Release No. 70.
05APN1
Agencies
[Federal Register Volume 78, Number 66 (Friday, April 5, 2013)]
[Notices]
[Pages 20701-20705]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-07947]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 30441; File No. 812-14099]
Munder Series Trust, et al.; Notice of Application
March 29, 2013.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application under section 6(c) of the Investment
Company Act of 1940 (``Act'') for an exemption from section 15(a) of
the Act and rule 18f-2 under the Act, as well as from certain
disclosure requirements.
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SUMMARY: Summary of Application: Applicants request an order that would
permit them to enter into and materially amend sub-advisory agreements
with Wholly-Owned Sub-Advisers (as defined below) and non-affiliated
sub-advisers without shareholder approval and would grant relief from
certain disclosure requirements.
[[Page 20702]]
Applicants: Munder Series Trust (the ``Trust'') and Munder Capital
Management (``MCM'').
DATES: Filing Dates: The application was filed on November 28, 2012,
and amended on December 31, 2012, March 15, 2013 and March 28, 2013.
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 April 23, 2013, 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,
480 Pierce Street, Birmingham, MI 48009.
FOR FURTHER INFORMATION CONTACT: Bruce R. MacNeil, Senior Counsel, at
(202) 551-6876, or Daniele Marchesani, Branch Chief, at (202) 551-6821
(Division of Investment Management, Exemptive Applications Office).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number or an applicant
using the Company name box, at https://www.sec.gov/search/search.htm or
by calling (202) 551-8090.
Applicants' Representations
1. The Trust is organized as a Delaware statutory trust and is
registered under the Act as an open-end management investment company.
The Trust may offer one or more series of shares (each, a ``Series'')
with its own distinct investment objective, policies and
restrictions.\1\ MCM is organized as a Delaware general partnership and
is registered as an investment adviser under the Investment Advisers
Act of 1940 (``Advisers Act''). Each Series has, or will have, as its
investment adviser, MCM, or another investment adviser controlling,
controlled by or under common control with MCM or its successors (each,
an ``Adviser'').\2\ Any future Adviser will also be registered as an
investment adviser under the Advisers Act.\3\
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\1\ The current Series of the Trust are: Munder Bond Fund,
Munder Growth Opportunities Fund, Munder Index 500 Fund, Munder
Integrity Mid-Cap Value Fund, Munder Integrity Small/Mid-Cap Value
Fund, Munder International Fund-Core Equity, Munder International
Small-Cap Fund, Munder Large-Cap Value Fund, Munder Micro-Cap Equity
Fund, Munder Mid-Cap Core Growth Fund, and Munder Veracity Small-Cap
Value Fund.
\2\ For purposes of the requested order, ``successor'' is
limited to an entity that results from a reorganization into another
jurisdiction or a change in the type of business organization.
\3\ Applicants request that the relief apply to applicants, as
well as to any future Series and any other existing or future
registered open-end management investment company or series thereof
that (a) is advised by an Adviser, (b) uses the manager of managers
structure described in the application (``Manager of Managers
Structure''), and (c) complies with the terms and conditions of the
application (``Sub-Advised Series''). All registered open-end
investment companies that currently intend to rely on the requested
order are named as applicants. Any entity that relies on the
requested order will do so only in accordance with the terms and
conditions contained in the application.
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2. The Adviser serves as the investment adviser to each Series
pursuant to an investment advisory agreement with the Trust
(``Investment Advisory Agreement''). The Investment Advisory Agreement
was approved by the board of trustees of the Trust (``Board''),\4\
including a majority of the members of the Board who are not
``interested persons,'' as defined in section 2(a)(19) of the Act, of
the Trust, of a Series or the Adviser (``Independent Trustees'') and by
the shareholders of the relevant Series as required by sections 15(a)
and 15(c) of the Act and rule 18f-2 thereunder. The terms of the
Investment Advisory Agreement comply with section 15(a) of the Act.
---------------------------------------------------------------------------
\4\ The term ``Board'' also includes the board of trustees or
directors of a future Series.
---------------------------------------------------------------------------
3. Under the terms of the Investment Advisory Agreement, the
Adviser, subject to the supervision of the Board, will provide
continuous investment management of the assets of each Series. The
Adviser periodically reviews each Series' investment objective,
policies and strategies, and based on the need of a Series may
recommend changes to the investment objective, policies and strategies
of the Series for consideration by the Board. For its services to each
Series under the Investment Advisory Agreement, the Adviser receives an
advisory fee from that Series based on the average daily net assets of
that Series. The Investment Advisory Agreement provides that the
Adviser may, subject to the approval of the Board, including a majority
of the Independent Trustees, and the shareholders of the applicable
Series (if required), delegate portfolio management responsibilities of
all or a portion of the assets of a Series to a Sub-Adviser.\5\
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\5\ As used herein, a ``Sub-Adviser'' is (a) an indirect or
direct ``wholly-owned subsidiary'' (as such term is defined in the
Act) of the Adviser for that Series; (b) a sister company of the
Adviser for that Series that is an indirect or direct ``wholly-owned
subsidiary'' (as such term is defined in the Act) of the same
company that, indirectly or directly, wholly owns the Adviser (each
of (a) and (b), a ``Wholly-Owned Sub-Adviser'' and collectively, the
``Wholly-Owned Sub-Advisers''), or (c) not an ``affiliated person''
(as such term is defined in section 2(a)(3) of the Act) of the
applicable Series, the Trust, or the Adviser, except to the extent
that an affiliation arises solely because the Sub-adviser serves as
a sub-adviser to a Series (each, a ``Non-Affiliated Sub-Adviser'').
---------------------------------------------------------------------------
4. Applicants request an order to permit the Adviser, subject to
the approval of the Board, including a majority of the Independent
Trustees, to, without obtaining shareholder approval: (a) Select Sub-
Advisers to manage all or a portion of the assets of a Series and enter
into Sub-Advisory Agreements (as defined below) with the Sub-Advisers,
and (b) materially amend Sub-Advisory Agreements with the Sub-
Advisers.\6\ The requested relief will not extend to any sub-adviser,
other than a Wholly-Owned Sub-Adviser, who is an affiliated person, as
defined in section 2(a)(3) of the Act, of the Sub-Advised Series, of
the Trust, or of the Adviser, other than by reason of serving as a sub-
adviser to one or more of the Sub-Advised Series (``Affiliated Sub-
Adviser'').
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\6\ Shareholder approval will continue to be required for any
other sub-adviser change (not otherwise permitted by rule or other
action of the Commission or staff) and material amendments to an
existing Sub-Advisory Agreement with any sub-adviser other than a
Non-Affiliated Sub-Adviser or a Wholly-Owned Sub-Adviser (all such
changes referred to as ``Ineligible Sub-Adviser Changes'').
---------------------------------------------------------------------------
5. Pursuant to the terms of the Investment Advisory Agreement, the
Adviser will have overall responsibility for the management and
investment of each Series' assets. These responsibilities include
recommending the removal or replacement of Sub-Advisers, determining
the portion of that Sub-Advised Series' assets to be managed by any
given Sub-Adviser and reallocating those assets as necessary from time
to time.
6. The Adviser has entered into sub-advisory agreements with
various Sub-Advisers (``Sub-Advisory Agreements'') to provide
investment management services to the Sub-Advised Series.\7\ The terms
of the Sub-Advisory Agreements comply fully with the requirements of
[[Page 20703]]
section 15(a) of the Act and were approved by the Board, including a
majority of the Independent Trustees and the shareholders of the
applicable Series, in accordance with sections 15(a) and 15(c) of the
Act and rule 18f-2 thereunder. The specific day-to-day investment
decisions for each applicable Series are made by that Series' Sub-
Adviser, which has discretionary authority to invest the assets or a
portion of the assets of that Series subject to the general supervision
of the Adviser and the Board. The Adviser currently compensates each
Sub-Adviser out of the advisory fees paid to the Adviser under the
Investment Advisory Agreement; in the future, Sub-Advised Series may
directly pay advisory fees to the Sub-Advisers.
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\7\ If the name of any Sub-Advised Series contains the name of a
Sub-Adviser, the name of the Adviser that serves as the primary
adviser to the Sub-Advised Series, or a trademark or trade name that
is owned by that Adviser, will precede the name of the Sub-Adviser.
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7. Sub-Advised Series will inform shareholders of the hiring of a
new Sub-Adviser pursuant to the following procedures (``Notice and
Access Procedures''): (a) Within 90 days after a new Sub-Adviser is
hired for any Sub-Advised Series, that Sub-Advised Series will send its
shareholders either a Multi-Manager Notice or a Multi-Manager Notice
and Multi-Manager Information Statement; \8\ and (b) the Sub-Advised
Series will make the Multi-Manager Information Statement available on
the Web site identified in the Multi-Manager Notice no later than when
the Multi-Manager Notice (or Multi-Manager Notice and Multi-Manager
Information Statement) is first sent to shareholders, and will maintain
it on that Web site for at least 90 days thereafter. In the
circumstances described in the application, a proxy solicitation to
approve the appointment of new Sub-Advisers provides no more meaningful
information to shareholders than the proposed Multi-Manager Information
Statement. Applicants state that each Board would comply with the
requirements of sections 15(a) and 15(c) of the Act before entering
into or amending a Sub-Advisory Agreement.
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\8\ A ``Multi-Manager Notice'' will be modeled on a Notice of
Internet Availability as defined in rule 14a-16 under the Securities
Exchange Act of 1934 (``Exchange Act''), and specifically will,
among other things: (a) summarize the relevant information regarding
the new Sub-Adviser; (b) inform shareholders that the Multi-Manager
Information Statement is available on a Web site; (c) provide the
Web site address; (d) state the time period during which the Multi-
Manager Information Statement will remain available on that Web
site; (e) provide instructions for accessing and printing the Multi-
Manager Information Statement; and (f) instruct the shareholder that
a paper or email copy of the Multi-Manager Information Statement may
be obtained, without charge, by contacting the Sub-Advised Series.
A ``Multi-Manager Information Statement'' will meet the
requirements of Regulation 14C, Schedule 14C and Item 22 of Schedule
14A under the Exchange Act for an information statement, except as
modified by the order to permit Aggregate Fee Disclosure (as defined
below). Multi-Manager Information Statements will be filed with the
Commission via the EDGAR system.
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8. Applicants also request an order exempting the Sub-Advised
Series from certain disclosure obligations that may require each Sub-
Advised Series to disclose fees paid by the Adviser to each Sub-
Adviser. Applicants seek relief to permit each Sub-Advised Series to
disclose (as a dollar amount and a percentage of the Sub-Advised
Series' net assets): (a) The aggregate fees paid to the Adviser and any
Wholly-Owned Sub-Advisers; (b) the aggregate fees paid to Non-
Affiliated Sub-Advisers; and (c) the fee paid to each Affiliated Sub-
Adviser (collectively, the ``Aggregate Fee Disclosure'').
Applicants' Legal Analysis
1. Section 15(a) of the Act states, in part, that it is unlawful
for any person to act as an investment adviser to a registered
investment company ``except pursuant to a written contract, which
contract, whether with such registered company or with an investment
adviser of such registered company, has been approved by the vote of a
majority of the outstanding voting securities of such registered
company.'' Rule 18f-2 under the Act provides that each series or class
of stock in a series investment company affected by a matter must
approve that matter if the Act requires shareholder approval.
2. Form N-1A is the registration statement used by open-end
investment companies. Item 19(a)(3) of Form N-1A requires a registered
investment company to disclose in its statement of additional
information the method of computing the ``advisory fee payable'' by the
investment company, including the total dollar amounts that the
investment company ``paid to the adviser (aggregated with amounts paid
to affiliated advisers, if any), and any advisers who are not
affiliated persons of the adviser, under the investment advisory
contract for the last three fiscal years.''
3. Rule 20a-1 under the Act requires proxies solicited with respect
to a registered investment company to comply with Schedule 14A under
the Exchange Act. Items 22(c)(1)(ii), 22(c)(1)(iii), 22(c)(8) and
22(c)(9) of Schedule 14A, taken together, require a proxy statement for
a shareholder meeting at which the advisory contract will be voted upon
to include the ``rate of compensation of the investment adviser,'' the
``aggregate amount of the investment adviser's fee,'' a description of
the ``terms of the contract to be acted upon,'' and, if a change in the
advisory fee is proposed, the existing and proposed fees and the
difference between the two fees.
4. Regulation S-X sets forth the requirements for financial
statements required to be included as part of a registered investment
company's registration statement and shareholder reports filed with the
Commission. Sections 6-07(2)(a), (b), and (c) of Regulation S-X require
a registered investment company to include in its financial statement
information about the investment advisory fees.
5. Section 6(c) of the Act provides that the Commission by order
upon application may conditionally or unconditionally exempt any
person, security, or transaction or any class or classes of persons,
securities, or transactions from any provisions of the Act, or from any
rule thereunder, if such exemption is necessary or appropriate in the
public interest and consistent with the protection of investors and the
purposes fairly intended by the policy and provisions of the Act.
Applicants state that their requested relief meets this standard for
the reasons discussed below.
6. Applicants assert that the shareholders expect the Adviser,
subject to the review and approval of the Board, to select the Sub-
Advisers that are suited to achieve the Series' investment objective.
Applicants assert that, from the perspective of the shareholder, the
role of the Sub-Adviser is substantially equivalent to the role of the
individual portfolio managers employed by an investment adviser to a
traditional investment company. Applicants believe that permitting the
Adviser to perform the duties for which the shareholders of the Sub-
Advised Series are paying the Adviser--the selection, supervision and
evaluation of the Sub-Adviser--without incurring unnecessary delays or
expenses is appropriate in the interest of the Series' shareholders and
will allow the Series to operate more efficiently. Applicants state
that the Investment Advisory Agreement will continue to be fully
subject to section 15(a) of the Act and rule 18f-2 under the Act and
approved by the Board, including a majority of the Independent
Trustees, in the manner required by sections 15(a) and 15(c) of the
Act. Applicants are not seeking an exemption with respect to the
Investment Advisory Agreement.
7. Applicants assert that disclosure of the individual fees that
the Adviser would pay to the Sub-Advisers of Sub-Advised Series that
operate under the Manager of Managers Structure would not serve any
meaningful purpose. Applicants contend that the primary
[[Page 20704]]
reasons for requiring disclosure of individual fees paid to Sub-
Advisers are to inform shareholders of expenses to be charged by a
particular Sub-Advised Series and to enable shareholders to compare the
fees to those of other comparable investment companies. Applicants
believe that the requested relief satisfies these objectives because
the advisory fee paid to the Adviser, or the Aggregate Fee Disclosure,
in the case of a Sub-Advised Series that directly compensates a Sub-
Adviser, will be fully disclosed and, therefore, shareholders will know
what the Sub-Advised Series' fees and expenses are and will be able to
compare the advisory fees a Sub-Advised Series is charged to those of
other investment companies. Applicants assert that the requested
disclosure relief would benefit shareholders of the Sub-Advised Series
because it would improve the Adviser's ability to negotiate the fees
paid to Sub-Advisers. Applicants state that the Adviser may be able to
negotiate rates that are below a Sub-Adviser's ``posted'' amounts if
the Adviser is not required to disclose the Sub-Advisers' fees to the
public. Applicants submit that the relief requested to use Aggregate
Fee Disclosure will encourage Sub-Advisers to negotiate lower sub-
advisory fees with the Adviser if the lower fees are not required to be
made public.
8. For the reasons discussed above, applicants submit that the
requested relief meets the standards for relief under section 6(c) of
the Act. Applicants state that the operation of the Sub-Advised Series
in the manner described in the application must be approved by
shareholders of a Sub-Advised Series before that Sub-Advised Series may
rely on the requested relief. In addition, applicants state that the
proposed conditions to the requested relief are designed to address any
potential conflicts of interest, including any posed by the use of
Wholly-Owned Sub-Advisers, and provide that shareholders are informed
when new Sub-Advisers are hired. Applicants assert that conditions 6,
7, 9, 10 and 11 are designed to provide the Board with sufficient
independence and the resources and information it needs to monitor and
address any conflicts of interest with affiliated persons of the
Adviser, including Wholly-Owned Sub-Advisers. Applicants state that,
accordingly, they believe the requested relief is necessary or
appropriate in the public interest and consistent with the protection
of investors and the purposes fairly intended by the policy and
provisions of the Act.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
1. Before a Sub-Advised Series may rely on the order requested in
the application, the operation of the Sub-Advised Series in the manner
described in the application, including the hiring of Wholly-Owned Sub-
Advisers, will be approved by a majority of the Sub-Advised Series'
outstanding voting securities as defined in the Act, or, in the case of
a Sub-Advised Series whose public shareholders purchase shares on the
basis of a prospectus containing the disclosure contemplated by
condition 2 below, by the sole initial shareholder before offering the
Sub-Advised Series' shares to the public.
2. The prospectus for each Sub-Advised Series will disclose the
existence, substance, and effect of any order granted pursuant to the
application. Each Sub-Advised Series will hold itself out to the public
as employing the Manager of Managers Structure. Each prospectus will
prominently disclose that the Adviser has the ultimate responsibility,
subject to oversight by the Board, to oversee the Sub-Advisers and
recommend their hiring, termination and replacement.
3. The Adviser will provide general management services to each
Sub-Advised Series, including overall supervisory responsibility for
the general management and investment of the Sub-Advised Series'
assets, and, subject to review and approval by the Board, the Adviser
will: (a) Set the Sub-Advised Series' overall investment strategies;
(b) evaluate, select, and recommend Sub-Advisers to manage all or a
portion of the Sub-Advised Series' assets; and (c) implement procedures
reasonably designed to ensure that the Sub-Advisers comply with a Sub-
Advised Series' investment objectives, policies and restrictions.
Subject to review by the Board, the Adviser will (a) when appropriate,
allocate and reallocate the Sub-Advised Series' assets among multiple
Sub-Advisers; and (b) monitor and evaluate the performance of Sub-
Advisers.
4. A Sub-Advised Series will not make any Ineligible Sub-Adviser
Changes without the approval of the shareholders of the applicable Sub-
Advised Series.
5. A Sub-Advised Series will inform shareholders of the hiring of a
new Sub-Adviser within 90 days after the hiring of the new Sub-Adviser
pursuant to the Notice and Access Procedures.
6. At all times, at least a majority of the Board will be
Independent Trustees, and the selection and nomination of new or
additional Independent Trustees will be placed within the discretion of
the then-existing Independent Trustees.
7. Independent Legal Counsel, as defined in rule 0-1(a)(6) under
the Act, will be engaged to represent the Independent Trustees. The
selection of such counsel will be within the discretion of the then-
existing Independent Trustees.
8. The Adviser will provide the Board, no less frequently than
quarterly, with information about the profitability of the Adviser on a
per Sub-Advised Series basis. The information will reflect the impact
on profitability of the hiring or termination of any Sub-Adviser during
the applicable quarter.
9. Whenever a Sub-Adviser is hired or terminated, the Adviser will
provide the Board with information showing the expected impact on the
profitability of the Adviser.
10. Whenever a Sub-Adviser change is proposed for a Sub-Advised
Series with an Affiliated Sub-Adviser or a Wholly-Owned Sub-Adviser,
the Board, including a majority of the Independent Trustees, will make
a separate finding, reflected in the Trust's Board minutes, that such
change is in the best interests of the Sub-Advised Series and its
shareholders and does not involve a conflict of interest from which the
Adviser or the Affiliated Sub-Adviser or Wholly-Owned Sub-Adviser
derives an inappropriate advantage.
11. No trustee or officer of the Trust or of a Sub-Advised Series
or any partner, director, manager or officer of the Adviser will own
directly or indirectly (other than through a pooled investment vehicle
that is not controlled by such person) any interest in a Sub-Adviser
except for: (a) Ownership of interests in the Adviser or any entity
that controls, is controlled by, or is under common control with the
Adviser; or (b) ownership of less than 1% of the outstanding securities
of any class of equity or debt of a publicly traded company that is
either a Sub-Adviser or an entity that controls, is controlled by, or
is under common control with a Sub-Adviser.
12. Each Sub-Advised Series will disclose the Aggregate Fee
Disclosure in its registration statement.
13. In the event the Commission adopts a rule under the Act
providing substantially similar relief to that requested in the
application, the requested order will expire on the effective date of
that rule.
14. For Sub-Advised Series that pay fees to a Sub-Adviser directly
from fund assets, any changes to a Sub-Advisory Agreement that would
result in an
[[Page 20705]]
increase in the total management and advisory fees payable by a Sub-
Advised Series will be required to be approved by the shareholders of
the Sub-Advised Series.
For the Commission, by the Division of Investment Management,
under delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2013-07947 Filed 4-4-13; 8:45 am]
BILLING CODE 8011-01-P