The Royal Bank of Scotland plc, et al.; Notice of Application and Temporary Order, 23316-23318 [2013-09118]
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23316
Federal Register / Vol. 78, No. 75 / Thursday, April 18, 2013 / Notices
Dated: April 15, 2013.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2013–09139 Filed 4–17–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–30462; 812–14148]
The Royal Bank of Scotland plc, et al.;
Notice of Application and Temporary
Order
April 12, 2013.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Temporary order and notice of
application for a permanent order under
section 9(c) of the Investment Company
Act of 1940 (‘‘Act’’).
SUMMARY: Applicants have received a
temporary order exempting them from
section 9(a) of the Act, with respect to
a guilty plea entered on April 12, 2013,
by RBS Securities Japan Limited (the
‘‘Settling Firm’’) in the U.S. District
Court for the District of Connecticut
(‘‘District Court’’) in connection with a
plea agreement between the Settling
Firm and the U.S. Department of Justice
(‘‘DOJ’’), until the Commission takes
final action on an application for a
permanent order. Applicants have also
applied for a permanent order.
APPLICANTS: The Royal Bank of
Scotland plc (‘‘RBS plc’’), Citizens
Investment Advisors (‘‘Citizens IA’’), a
separately identifiable department of
RBS Citizens, N.A., and the Settling
Firm (each an ‘‘Applicant’’ and
collectively, the ‘‘Applicants’’).1
Filing Date: The application was filed
on April 12, 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 May 7, 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
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AGENCY:
1 Applicants request that any relief granted
pursuant to the application also apply to any
existing or future company of which the Settling
Firm is or may become an affiliated person within
the meaning of section 2(a)(3) of the Act (together
with the Applicants, the ‘‘Covered Persons’’) with
respect to any activity contemplated by section 9(a)
of the Act.
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18:54 Apr 17, 2013
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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: RBS plc, RBS, Gogarburn,
PO Box 1000, Edinburgh, EH12 1HQ,
Scotland; Citizens IA, c/o RBS Citizens,
N.A., Mail Stop RC 03–30, One Citizens
Plaza, Providence, Rhode Island 02903;
Settling Firm, Shin-Marunouchi Center
Building, 1–6–2 Marunouchi, Chiyodaku, Tokyo 100–0005, Japan.
FOR FURTHER INFORMATION CONTACT:
Bruce R. MacNeil, Senior Counsel, at
(202) 551–6817 or Daniele Marchesani,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Exemptive Applications Office).
SUPPLEMENTARY INFORMATION: The
following is a temporary order and a
summary of the application. The
complete application may be obtained
via the Commission’s Web site by
searching for the file number, or an
applicant using the Company name box,
at https://www.sec.gov/search/
search.htm or by calling (202) 551–
8090.
Applicants’ Representations
1. Each Applicant is either a direct or
indirect wholly-owned subsidiary of
The Royal Bank of Scotland Group plc
(‘‘RBSG’’). RBSG and RBS plc, a
company organized under the laws of
Scotland, are international banking and
financial services companies that
provide a wide range of products and
services to companies around the world.
Citizens IA, an investment adviser
registered under the Investment
Advisers Act of 1940, is a separately
identifiable department of RBS Citizens,
N.A. Citizens IA serves as investment
sub-adviser to Aquila Narragansett TaxFree Income Fund (the ‘‘Fund’’) (such
activity, ‘‘Fund Service Activities’’). The
Settling Firm, a company with its
principal place of business in Tokyo,
Japan, engages in securities business
operations, including derivatives
trading.
2. On April 12, 2013, the Fraud
Section of the Criminal Division and the
Antitrust Division of the DOJ filed a
one-count criminal information (the
‘‘Information’’) in the District Court
charging one count of wire fraud, in
violation of Title 18, United States
Code, Section 1343. The Information
charges that between approximately
2006 and at least 2010, the Settling Firm
engaged in a scheme to defraud
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counterparties to interest rate
derivatives trades executed on its behalf
by secretly manipulating benchmark
interest rates to which the profitability
of those trades was tied. The
Information charges that, in furtherance
of this scheme, on or about October 5,
2009, the Settling Firm committed wire
fraud in violation of Title 18, United
States Code, Section 1343 by
transmitting, or causing the
transmission of, (i) An electronic chat
between a derivatives trader employed
by the Settling Firm and an RBS plc
derivatives trader, (ii) a subsequent
submission for the London InterBank
Offered Rate for Japanese Yen (‘‘Yen
LIBOR’’) to Thomson Reuters, and (iii)
a subsequent publication of a Yen
LIBOR rate through international and
interstate wires.
3. Pursuant to a plea agreement (the
‘‘Plea Agreement’’), attached as exhibit
to the application, the Settling Firm
entered a plea of guilty (the ‘‘Guilty
Plea’’) on April 12, 2013, in the District
Court. In the Plea Agreement, the
Settling Firm, among other things,
agreed to a fine of $50 million.
Applicants expect that the District Court
will enter a judgment against the
Settling Firm that will require remedies
that are materially the same as set forth
in the Plea Agreement. In addition, RBS
plc entered into a deferred prosecution
agreement with DOJ (the ‘‘Deferred
Prosecution Agreement’’) relating to
submissions of the Yen LIBOR and other
benchmark interest rates. In the
Deferred Prosecution Agreement, RBS
plc has agreed to, among other things,
(i) Continue to provide full cooperation
with DOJ and any other law
enforcement or government agency
designated by DOJ until the conclusion
of all investigations and prosecutions
arising out of the conduct described in
the Deferred Prosecution Agreement; (ii)
strengthen its internal controls as
required by certain other U.S. and nonU.S. regulatory agencies that have
addressed the misconduct described in
the Deferred Prosecution Agreement;
and (iii) the payment of $150 million,
which includes amounts incurred by the
Settling Firm for criminal penalties
arising from the Judgment. The
individuals at the Settling Firm and at
any other Covered Person who were
identified by the Settling Firm, RBS plc
or any U.S. or non-U.S. regulatory or
enforcement agencies as being
responsible for the conduct underlying
the Plea Agreement, including the
conduct described in any of the exhibits
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Federal Register / Vol. 78, No. 75 / Thursday, April 18, 2013 / Notices
thereto (the ‘‘Conduct’’), have either
resigned or have been terminated.2
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Applicants’ Legal Analysis
1. Section 9(a)(1) of the Act provides,
in pertinent part, that a person may not
serve or act as an investment adviser or
depositor of any registered investment
company or a principal underwriter for
any registered open-end investment
company or registered unit investment
trust, if such person within ten years
has been convicted of any felony or
misdemeanor arising out of such
person’s conduct, as, among other
things, a broker or dealer. Section
2(a)(10) of the Act defines the term
‘‘convicted’’ to include a plea of guilty.
Section 9(a)(3) of the Act extends the
prohibitions of section 9(a)(1) to a
company any affiliated person of which
has been disqualified under the
provisions of section 9(a)(1). Section
2(a)(3) of the Act defines ‘‘affiliated
person’’ to include, among others, any
person directly or indirectly controlling,
controlled by, or under common control
with, the other person. Applicants state
that the Settling Firm is an affiliated
person of each of the other Applicants
within the meaning of section 2(a)(3).
Applicants state that the Guilty Plea
would result in a disqualification of
each Applicant for ten years under
section 9(a) of the Act because the
Settling Firm would become the subject
of a conviction described in 9(a)(1).
2. Section 9(c) of the Act provides that
the Commission shall grant an
application for exemption from the
disqualification provisions of section
9(a) if it is established that these
provisions, as applied to Applicants, are
unduly or disproportionately severe or
that the Applicants’ conduct has been
such as not to make it against the public
interest or the protection of investors to
grant the exemption. Applicants have
filed an application pursuant to section
9(c) seeking temporary and permanent
orders exempting the Applicants and
the other Covered Persons from the
disqualification provisions of section
9(a) of the Act.
3. Applicants believe they meet the
standard for exemption specified in
section 9(c). Applicants state that the
2 The Applicants note that a junior level
employee of a Covered Person (the ‘‘Employee’’)
who was not responsible for the Conduct remains
employed by a Covered Person. The Applicants
have concluded that the Employee was not
responsible for the Conduct and the Employee has
not been identified by any U.S. or non-U.S.
regulatory or enforcement agencies as being
responsible for the Conduct. The Applicants
acknowledge that the Commission has not been
asked to determine, and has not determined,
whether or not the Employee is responsible for the
Conduct.
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18:54 Apr 17, 2013
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prohibitions of section 9(a) as applied to
them would be unduly and
disproportionately severe and that the
conduct of Applicants has been such as
not to make it against the public interest
or the protection of investors to grant
the exemption from section 9(a).
4. Applicants assert that the Conduct
did not involve any of the Applicants’
Fund Service Activities, and that the
Settling Firm does not serve in any of
the capacities described in section 9(a)
of the Act. Additionally, Applicants
assert that the Conduct did not involve
the Fund or the assets of the Fund.
Applicants further assert that (i) None of
the current or former directors, officers
or employees of the Applicants (other
than certain personnel of the Settling
Firm and RBS plc who were not
involved in any of the Applicants’ Fund
Service Activities) had any knowledge
of, or had any involvement in, the
Conduct; (ii) no former employee of the
Settling Firm or of any other Covered
Person who previously has been or who
subsequently may be identified by the
Settling Firm, RBS plc or any U.S. or
non-U.S. regulatory or enforcement
agencies as having been responsible for
the Conduct will be an officer, director,
or employee of any Applicant or of any
other Covered Person; (iii) no employee
of the Settling Firm or of any Covered
Person who was involved in the
Conduct had any, or will not have any
future, involvement in the Covered
Persons’ activities in any capacity
described in section 9(a) of the Act; and
(iv) because the personnel of the
Applicants (other than certain personnel
of the Settling Firm and RBS plc who
were not involved in any of the
Applicants’ Fund Service Activities) did
not have any involvement in the
Conduct, shareholders of the Fund were
not affected any differently than if the
Fund had received services from any
other non-affiliated investment adviser.
Applicants have agreed that neither they
nor any of the other Covered Persons
will employ any of the former
employees of the Settling Firm or any
other Covered Person who previously
have been or who subsequently may be
identified by the Settling Firm, RBS plc
or any U.S. or non-U.S. regulatory or
enforcement agency as having been
responsible for the Conduct in any
capacity without first making a further
application to the Commission pursuant
to section 9(c).
5. Applicants further represent that
the inability of Citizens IA to continue
providing Fund Service Activities
would result in potential hardships for
both the Fund and its shareholders.
Applicants state that they will distribute
written materials, including an offer to
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23317
meet in person to discuss the materials,
to the board of trustees of the Fund,
including the directors who are not
‘‘interested persons,’’ as defined in
section 2(a)(19) of the Act, of such
Fund, and their independent legal
counsel as defined in rule 0–1(a)(6)
under the Act, if any, regarding the
Guilty Plea, any impact on the Fund,
and the application. The Applicants
will provide the Fund with all
information concerning the Plea
Agreement and the application that is
necessary for the Fund to fulfill its
disclosure and other obligations under
the federal securities laws.
6. Applicants also state that, if
Citizens IA was barred from providing
Fund Service Activities to the Fund, the
effect on its business and employees
would be severe.
7. Applicants state that none of the
Applicants has previously applied for
an exemptive order under section 9(c) of
the Act.
Applicants’ Conditions
Applicants agree that any order
granted by the Commission pursuant to
the application will be subject to the
following conditions:
1. Any temporary exemption granted
pursuant to the application shall be
without prejudice to, and shall not limit
the Commission’s rights in any manner
with respect to, any Commission
investigation of, or administrative
proceedings involving or against,
Covered Persons, including, without
limitation, the consideration by the
Commission of a permanent exemption
from section 9(a) of the Act requested
pursuant to the application or the
revocation or removal of any temporary
exemptions granted under the Act in
connection with the application.
2. Neither the Applicants nor any of
the other Covered Persons will employ
any of the former employees of the
Settling Firm or of any other Covered
Person who previously has been or who
subsequently may be identified by the
Settling Firm, RBS plc or any U.S. or
non-U.S. regulatory or enforcement
agency as having been responsible for
the Conduct, in any capacity, without
first making a further application to the
Commission pursuant to section 9(c).
Temporary Order
The Commission has considered the
matter and finds that the Applicants
have made the necessary showing to
justify granting a temporary exemption.
Accordingly
It is hereby ordered, pursuant to
section 9(c) of the Act, that the
Applicants and the other Covered
Persons are granted a temporary
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Federal Register / Vol. 78, No. 75 / Thursday, April 18, 2013 / Notices
exemption from the provisions of
section 9(a), effective forthwith, solely
with respect to the Guilty Plea, subject
to the conditions in the application,
until the date the Commission takes
final action on their application for a
permanent order.
By the Commission.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2013–09118 Filed 4–17–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
30460; 812–14113]
Trust for Professional Managers and
Aurora Investment Management L.L.C.;
Notice of Application
April 12, 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:
Applicants
request an order that would permit them
to enter into and materially amend
subadvisory agreements without
shareholder approval and that would
grant relief from certain disclosure
requirements.
APPLICANTS: Trust for Professional
Managers (the ‘‘Trust’’) and Aurora
Investment Management L.L.C. (the
‘‘Initial Advisor’’).
FILING DATES: The application was filed
January 17, 2013, and amended on April
3, 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 May 7, 2013, and
should be accompanied by proof of
service on the applicants, in the form of
an affidavit or, for lawyers, a certificate
of service. Hearing requests should state
the nature of the writer’s interest, the
reason for the request, and the issues
contested. Persons who wish to be
notified of a hearing may request
notification by writing to the
Commission’s Secretary.
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SUMMARY OF APPLICATION:
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18:54 Apr 17, 2013
Jkt 229001
Elizabeth M. Murphy,
Secretary, U.S. Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
Applicants: John P. Buckel, Trust for
Professional Managers, 615 East
Michigan Street, Milwaukee, WI 53202;
Scott M. Montpas, Esq., Aurora
Investment Management L.L.C., 300
North LaSalle Street, 52nd Floor,
Chicago, IL 60654.
FOR FURTHER INFORMATION CONTACT:
Courtney S. Thornton, Senior Counsel,
at (202) 551–6812 or David P. Bartels,
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 for an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
ADDRESSES:
Applicants’ Representations
1. The Trust, a Delaware statutory
trust, is registered under the Act as an
open-end management investment
company. The Trust is organized as a
series investment company and
currently consists of 28 series, one of
which is advised by the Initial Advisor.1
The Initial Advisor is a limited liability
company organized under Delaware
law. The Initial Advisor is, and any
other Advisor will be, registered as an
investment adviser under the
Investment Advisers Act of 1940
(‘‘Advisers Act’’). The Advisor will
serve as the investment adviser to each
Fund pursuant to an investment
advisory agreement with the Trust (each
an ‘‘Advisory Agreement’’ and
1 Applicants are not requesting relief for any
series other than those advised by the Advisor (as
defined below). Applicants request relief with
respect to any existing and any future series of the
Trust or any other registered open-end management
company that: (a) Is advised by the Initial Advisor
or a person controlling, controlled by, or under
common control with the Initial Advisor or its
successor (each, an ‘‘Advisor’’); (b) uses the
manager of managers structure (‘‘Manager of
Managers Structure’’) described in the application;
and (c) complies with the terms and conditions of
the requested order (any such series, a ‘‘Fund’’ and
collectively, the ‘‘Funds’’). The only existing
registered open-end management investment
company that currently intends to rely on the
requested order is named as an applicant, and the
only Fund that currently intends to rely on the
requested order is the Aurora Horizons Fund. 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. If the name of
any Fund contains the name of a Subadvisor (as
defined below), that name will be preceded by the
name of the Advisor.
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Frm 00115
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Sfmt 4703
collectively, the ‘‘Advisory
Agreements’’).2 Each Advisory
Agreement was or will have been
approved by each Fund’s respective
shareholder(s) and the board of trustees
of the Trust (‘‘Board’’), including a
majority of the trustees who are not
‘‘interested persons,’’ as defined in
section 2(a)(19) of the Act, of the Trust,
the Fund, or the Advisor (‘‘Independent
Trustees’’) in the manner required by
sections 15(a) and 15(c) of the Act and
rule 18f–2 under the Act.
2. Under the terms of each Advisory
Agreement, the Advisor will provide
each Fund with overall management
services and, as it deems appropriate,
will continuously review, supervise and
administer each Fund’s investment
program, subject to the supervision of,
and policies established by, the Board.
For the investment management
services it will provide to each Fund,
the Advisor will receive the fee
specified in the Advisory Agreement
from such Fund, payable monthly at an
annual rate based on the average daily
net assets of the Fund. The Advisory
Agreement permits the Advisor to
delegate certain responsibilities to one
or more subadvisors (each a
‘‘Subadvisor’’), subject to the approval
of the Board.3
3. Each Subadvisor will be an
investment adviser as defined in section
2(a)(20) of the Act and will be registered
with the Commission as an ‘‘investment
adviser’’ under the Advisers Act. The
Advisor will evaluate, allocate assets to
and oversee the Subadvisors, and make
recommendations about their hiring,
termination, and replacement to the
Board, at all times subject to the
authority of the Board. The Advisor will
compensate the Subadvisors out of the
advisory fee paid by a Fund to the
Advisor under the Advisory Agreement.
4. Applicants request an order to
permit the Advisor, subject to Board
approval, to select certain Subadvisors
to manage all or a portion of the assets
of a Fund or Funds pursuant to a
Subadvisory Agreement and materially
2 Each future investment advisory agreement
between an Advisor and a Fund is also included in
the term ‘‘Advisory Agreement’’. The Initial
Advisor currently serves as investment advisor only
to the Aurora Horizons Fund, a series of the Trust,
under the Advisory Agreement.
3 As of the date of the amended application, the
Advisor has entered into subadvisory agreements
(‘‘Subadvisory Agreements’’) with Chicago
Fundamental Investment Partners, LLC, First Oak
Capital Management LLC, Graham Capital
Management, L.P., Kabouter Management, LLC,
Kingsford Capital Management, LLC, Kovitz
Investment Group, LLC, Lansdowne Partners
Limited Partnership, MPAM Credit Trading
Partners L.P., PEAK6 Advisors LLC, and York
Registered Holdings, L.P. None of the existing
Subadvisors is affiliated with the Advisor.
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Agencies
[Federal Register Volume 78, Number 75 (Thursday, April 18, 2013)]
[Notices]
[Pages 23316-23318]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-09118]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-30462; 812-14148]
The Royal Bank of Scotland plc, et al.; Notice of Application and
Temporary Order
April 12, 2013.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Temporary order and notice of application for a permanent
order under section 9(c) of the Investment Company Act of 1940
(``Act'').
SUMMARY: Applicants have received a temporary order exempting them
from section 9(a) of the Act, with respect to a guilty plea entered on
April 12, 2013, by RBS Securities Japan Limited (the ``Settling Firm'')
in the U.S. District Court for the District of Connecticut (``District
Court'') in connection with a plea agreement between the Settling Firm
and the U.S. Department of Justice (``DOJ''), until the Commission
takes final action on an application for a permanent order. Applicants
have also applied for a permanent order.
APPLICANTS: The Royal Bank of Scotland plc (``RBS plc''), Citizens
Investment Advisors (``Citizens IA''), a separately identifiable
department of RBS Citizens, N.A., and the Settling Firm (each an
``Applicant'' and collectively, the ``Applicants'').\1\
---------------------------------------------------------------------------
\1\ Applicants request that any relief granted pursuant to the
application also apply to any existing or future company of which
the Settling Firm is or may become an affiliated person within the
meaning of section 2(a)(3) of the Act (together with the Applicants,
the ``Covered Persons'') with respect to any activity contemplated
by section 9(a) of the Act.
---------------------------------------------------------------------------
Filing Date: The application was filed on April 12, 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 May 7, 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: RBS plc, RBS, Gogarburn, PO Box 1000, Edinburgh, EH12 1HQ,
Scotland; Citizens IA, c/o RBS Citizens, N.A., Mail Stop RC 03-30, One
Citizens Plaza, Providence, Rhode Island 02903; Settling Firm, Shin-
Marunouchi Center Building, 1-6-2 Marunouchi, Chiyoda-ku, Tokyo 100-
0005, Japan.
FOR FURTHER INFORMATION CONTACT: Bruce R. MacNeil, Senior Counsel, at
(202) 551-6817 or Daniele Marchesani, Branch Chief, at (202) 551-6821
(Division of Investment Management, Exemptive Applications Office).
SUPPLEMENTARY INFORMATION: The following is a temporary order and a
summary of the application. The complete application may be obtained
via the Commission's Web site by searching for the file number, or an
applicant using the Company name box, at https://www.sec.gov/search/search.htm or by calling (202) 551-8090.
Applicants' Representations
1. Each Applicant is either a direct or indirect wholly-owned
subsidiary of The Royal Bank of Scotland Group plc (``RBSG''). RBSG and
RBS plc, a company organized under the laws of Scotland, are
international banking and financial services companies that provide a
wide range of products and services to companies around the world.
Citizens IA, an investment adviser registered under the Investment
Advisers Act of 1940, is a separately identifiable department of RBS
Citizens, N.A. Citizens IA serves as investment sub-adviser to Aquila
Narragansett Tax-Free Income Fund (the ``Fund'') (such activity, ``Fund
Service Activities''). The Settling Firm, a company with its principal
place of business in Tokyo, Japan, engages in securities business
operations, including derivatives trading.
2. On April 12, 2013, the Fraud Section of the Criminal Division
and the Antitrust Division of the DOJ filed a one-count criminal
information (the ``Information'') in the District Court charging one
count of wire fraud, in violation of Title 18, United States Code,
Section 1343. The Information charges that between approximately 2006
and at least 2010, the Settling Firm engaged in a scheme to defraud
counterparties to interest rate derivatives trades executed on its
behalf by secretly manipulating benchmark interest rates to which the
profitability of those trades was tied. The Information charges that,
in furtherance of this scheme, on or about October 5, 2009, the
Settling Firm committed wire fraud in violation of Title 18, United
States Code, Section 1343 by transmitting, or causing the transmission
of, (i) An electronic chat between a derivatives trader employed by the
Settling Firm and an RBS plc derivatives trader, (ii) a subsequent
submission for the London InterBank Offered Rate for Japanese Yen
(``Yen LIBOR'') to Thomson Reuters, and (iii) a subsequent publication
of a Yen LIBOR rate through international and interstate wires.
3. Pursuant to a plea agreement (the ``Plea Agreement''), attached
as exhibit to the application, the Settling Firm entered a plea of
guilty (the ``Guilty Plea'') on April 12, 2013, in the District Court.
In the Plea Agreement, the Settling Firm, among other things, agreed to
a fine of $50 million. Applicants expect that the District Court will
enter a judgment against the Settling Firm that will require remedies
that are materially the same as set forth in the Plea Agreement. In
addition, RBS plc entered into a deferred prosecution agreement with
DOJ (the ``Deferred Prosecution Agreement'') relating to submissions of
the Yen LIBOR and other benchmark interest rates. In the Deferred
Prosecution Agreement, RBS plc has agreed to, among other things, (i)
Continue to provide full cooperation with DOJ and any other law
enforcement or government agency designated by DOJ until the conclusion
of all investigations and prosecutions arising out of the conduct
described in the Deferred Prosecution Agreement; (ii) strengthen its
internal controls as required by certain other U.S. and non-U.S.
regulatory agencies that have addressed the misconduct described in the
Deferred Prosecution Agreement; and (iii) the payment of $150 million,
which includes amounts incurred by the Settling Firm for criminal
penalties arising from the Judgment. The individuals at the Settling
Firm and at any other Covered Person who were identified by the
Settling Firm, RBS plc or any U.S. or non-U.S. regulatory or
enforcement agencies as being responsible for the conduct underlying
the Plea Agreement, including the conduct described in any of the
exhibits
[[Page 23317]]
thereto (the ``Conduct''), have either resigned or have been
terminated.\2\
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\2\ The Applicants note that a junior level employee of a
Covered Person (the ``Employee'') who was not responsible for the
Conduct remains employed by a Covered Person. The Applicants have
concluded that the Employee was not responsible for the Conduct and
the Employee has not been identified by any U.S. or non-U.S.
regulatory or enforcement agencies as being responsible for the
Conduct. The Applicants acknowledge that the Commission has not been
asked to determine, and has not determined, whether or not the
Employee is responsible for the Conduct.
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Applicants' Legal Analysis
1. Section 9(a)(1) of the Act provides, in pertinent part, that a
person may not serve or act as an investment adviser or depositor of
any registered investment company or a principal underwriter for any
registered open-end investment company or registered unit investment
trust, if such person within ten years has been convicted of any felony
or misdemeanor arising out of such person's conduct, as, among other
things, a broker or dealer. Section 2(a)(10) of the Act defines the
term ``convicted'' to include a plea of guilty. Section 9(a)(3) of the
Act extends the prohibitions of section 9(a)(1) to a company any
affiliated person of which has been disqualified under the provisions
of section 9(a)(1). Section 2(a)(3) of the Act defines ``affiliated
person'' to include, among others, any person directly or indirectly
controlling, controlled by, or under common control with, the other
person. Applicants state that the Settling Firm is an affiliated person
of each of the other Applicants within the meaning of section 2(a)(3).
Applicants state that the Guilty Plea would result in a
disqualification of each Applicant for ten years under section 9(a) of
the Act because the Settling Firm would become the subject of a
conviction described in 9(a)(1).
2. Section 9(c) of the Act provides that the Commission shall grant
an application for exemption from the disqualification provisions of
section 9(a) if it is established that these provisions, as applied to
Applicants, are unduly or disproportionately severe or that the
Applicants' conduct has been such as not to make it against the public
interest or the protection of investors to grant the exemption.
Applicants have filed an application pursuant to section 9(c) seeking
temporary and permanent orders exempting the Applicants and the other
Covered Persons from the disqualification provisions of section 9(a) of
the Act.
3. Applicants believe they meet the standard for exemption
specified in section 9(c). Applicants state that the prohibitions of
section 9(a) as applied to them would be unduly and disproportionately
severe and that the conduct of Applicants has been such as not to make
it against the public interest or the protection of investors to grant
the exemption from section 9(a).
4. Applicants assert that the Conduct did not involve any of the
Applicants' Fund Service Activities, and that the Settling Firm does
not serve in any of the capacities described in section 9(a) of the
Act. Additionally, Applicants assert that the Conduct did not involve
the Fund or the assets of the Fund. Applicants further assert that (i)
None of the current or former directors, officers or employees of the
Applicants (other than certain personnel of the Settling Firm and RBS
plc who were not involved in any of the Applicants' Fund Service
Activities) had any knowledge of, or had any involvement in, the
Conduct; (ii) no former employee of the Settling Firm or of any other
Covered Person who previously has been or who subsequently may be
identified by the Settling Firm, RBS plc or any U.S. or non-U.S.
regulatory or enforcement agencies as having been responsible for the
Conduct will be an officer, director, or employee of any Applicant or
of any other Covered Person; (iii) no employee of the Settling Firm or
of any Covered Person who was involved in the Conduct had any, or will
not have any future, involvement in the Covered Persons' activities in
any capacity described in section 9(a) of the Act; and (iv) because the
personnel of the Applicants (other than certain personnel of the
Settling Firm and RBS plc who were not involved in any of the
Applicants' Fund Service Activities) did not have any involvement in
the Conduct, shareholders of the Fund were not affected any differently
than if the Fund had received services from any other non-affiliated
investment adviser. Applicants have agreed that neither they nor any of
the other Covered Persons will employ any of the former employees of
the Settling Firm or any other Covered Person who previously have been
or who subsequently may be identified by the Settling Firm, RBS plc or
any U.S. or non-U.S. regulatory or enforcement agency as having been
responsible for the Conduct in any capacity without first making a
further application to the Commission pursuant to section 9(c).
5. Applicants further represent that the inability of Citizens IA
to continue providing Fund Service Activities would result in potential
hardships for both the Fund and its shareholders. Applicants state that
they will distribute written materials, including an offer to meet in
person to discuss the materials, to the board of trustees of the Fund,
including the directors who are not ``interested persons,'' as defined
in section 2(a)(19) of the Act, of such Fund, and their independent
legal counsel as defined in rule 0-1(a)(6) under the Act, if any,
regarding the Guilty Plea, any impact on the Fund, and the application.
The Applicants will provide the Fund with all information concerning
the Plea Agreement and the application that is necessary for the Fund
to fulfill its disclosure and other obligations under the federal
securities laws.
6. Applicants also state that, if Citizens IA was barred from
providing Fund Service Activities to the Fund, the effect on its
business and employees would be severe.
7. Applicants state that none of the Applicants has previously
applied for an exemptive order under section 9(c) of the Act.
Applicants' Conditions
Applicants agree that any order granted by the Commission pursuant
to the application will be subject to the following conditions:
1. Any temporary exemption granted pursuant to the application
shall be without prejudice to, and shall not limit the Commission's
rights in any manner with respect to, any Commission investigation of,
or administrative proceedings involving or against, Covered Persons,
including, without limitation, the consideration by the Commission of a
permanent exemption from section 9(a) of the Act requested pursuant to
the application or the revocation or removal of any temporary
exemptions granted under the Act in connection with the application.
2. Neither the Applicants nor any of the other Covered Persons will
employ any of the former employees of the Settling Firm or of any other
Covered Person who previously has been or who subsequently may be
identified by the Settling Firm, RBS plc or any U.S. or non-U.S.
regulatory or enforcement agency as having been responsible for the
Conduct, in any capacity, without first making a further application to
the Commission pursuant to section 9(c).
Temporary Order
The Commission has considered the matter and finds that the
Applicants have made the necessary showing to justify granting a
temporary exemption.
Accordingly
It is hereby ordered, pursuant to section 9(c) of the Act, that the
Applicants and the other Covered Persons are granted a temporary
[[Page 23318]]
exemption from the provisions of section 9(a), effective forthwith,
solely with respect to the Guilty Plea, subject to the conditions in
the application, until the date the Commission takes final action on
their application for a permanent order.
By the Commission.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2013-09118 Filed 4-17-13; 8:45 am]
BILLING CODE 8011-01-P