JPMorgan Chase & Co., et al.; Notice of Application, 23800-23806 [2013-09344]
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its respective Master Fund) in an
Affiliated Underwriting, once an
investment by an Investing Fund in the
securities of the Fund exceeds the limit
of section 12(d)(1)(A)(i) of the Act,
including any purchases made directly
from an Underwriting Affiliate. The
Board will review these purchases
periodically, but no less frequently than
annually, to determine whether the
purchases were influenced by the
investment by the Investing Fund in the
Fund. The Board will consider, among
other things: (a) Whether the purchases
were consistent with the investment
objectives and policies of the Fund (or
its respective Master Fund); (b) how the
performance of securities purchased in
an Affiliated Underwriting compares to
the performance of comparable
securities purchased during a
comparable period of time in
underwritings other than Affiliated
Underwritings or to a benchmark such
as a comparable market index; and (c)
whether the amount of securities
purchased by the Fund (or its respective
Master Fund) in Affiliated
Underwritings and the amount
purchased directly from an
Underwriting Affiliate have changed
significantly from prior years. The
Board will take any appropriate actions
based on its review, including, if
appropriate, the institution of
procedures designed to assure that
purchases of securities in Affiliated
Underwritings are in the best interest of
shareholders of the Fund.
8. Each Fund (or its respective Master
Fund) will maintain and preserve
permanently in an easily accessible
place a written copy of the procedures
described in the preceding condition,
and any modifications to such
procedures, and will maintain and
preserve for a period of not less than six
years from the end of the fiscal year in
which any purchase in an Affiliated
Underwriting occurred, the first two
years in an easily accessible place, a
written record of each purchase of
securities in Affiliated Underwritings
once an investment by an Investing
Fund in the securities of the Fund
exceeds the limit of section
12(d)(1)(A)(i) of the Act, setting forth
from whom the securities were
acquired, the identity of the
underwriting syndicate’s members, the
terms of the purchase, and the
information or materials upon which
the Board’s determinations were made.
9. Before investing in a Fund in
excess of the limits in section
12(d)(1)(A), each Investing Fund and the
Trust will execute an FOF Participation
Agreement stating, without limitation,
that their respective boards of directors
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or trustees and their investment
advisers, or Trustee and Sponsor, as
applicable, understand the terms and
conditions of the order, and agree to
fulfill their responsibilities under the
order. At the time of its investment in
Shares of a Fund in excess of the limit
in section 12(d)(1)(A)(i), an Investing
Fund will notify the Fund of the
investment. At such time, the Investing
Fund will also transmit to the Fund a
list of the names of each Investing Fund
Affiliate and Underwriting Affiliate. The
Investing Fund will notify the Fund of
any changes to the list as soon as
reasonably practicable after a change
occurs. The Fund and the Investing
Fund will maintain and preserve a copy
of the order, the FOF Participation
Agreement, and the list with any
updated information for the duration of
the investment and for a period of not
less than six years thereafter, the first
two years in an easily accessible place.
10. Before approving any advisory
contract under section 15 of the Act, the
board of directors or trustees of each
Investing Management Company,
including a majority of the independent
directors or trustees, will find that the
advisory fees charged under such
contract are based on services provided
that will be in addition to, rather than
duplicative of, the services provided
under the advisory contract(s) of any
Fund (or its respective Master Fund) in
which the Investing Management
Company may invest. These findings
and their basis will be fully recorded in
the minute books of the appropriate
Investing Management Company.
11. Any sales charges and/or service
fees charged with respect to shares of an
Investing Fund will not exceed the
limits applicable to a fund of funds as
set forth in NASD Conduct Rule 2830.
12. No Fund (or its respective Master
Fund) relying on the Fund of Funds
Relief will acquire securities of any
investment company or company
relying on section 3(c)(1) or 3(c)(7) of
the Act in excess of the limits contained
in section 12(d)(1)(A) of the Act, except
to the extent (a) the Fund (or its
respective Master Fund) acquires
securities pursuant to exemptive relief
from the Commission permitting the
Fund (or its respective Master Fund) to
acquire securities of one or more
investment companies for short-term
cash management purposes or (b) the
Fund acquires securities of the Master
Fund pursuant to the Master-Feeder
Relief.
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For the Commission, by the Division of
Investment Management, under delegated
authority.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2013–09341 Filed 4–19–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
30465; 813–370]
JPMorgan Chase & Co., et al.; Notice
of Application
April 16, 2013.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application to
amend prior orders under sections 6(b)
and 6(e) of the Investment Company Act
of 1940 (‘‘Act’’) granting an exemption
from all provisions of the Act, except
section 9, and sections 36 through 53,
and the rules and regulations
thereunder. With respect to sections 17
and 30 of the Act, and the rules and
regulations thereunder, and rule 38a–1
under the Act, the exemption is limited
as set forth in the application.
AGENCY:
Applicants
request an order to amend prior orders
exempting certain limited partnerships
and other entities formed for the benefit
of eligible employees of JPMorgan Chase
& Co. and its affiliates from certain
provisions of the Act. Each partnership
will be an ‘‘employees’ securities
company’’ within the meaning of
section 2(a)(13) of the Act.
APPLICANTS: JPMorgan Chase & Co. (the
‘‘Company’’); Chase Co-Invest June 2000
Partners, LP, Chase Co-Invest March
2000 Partners, LP, J.P.Morgan Chase CoInvest Partners 2001 A–2, LP,
J.P.Morgan Chase Co-Invest Partners
2001 B–2, L.P., J.P.Morgan Chase CoInvest Partners 2002, LP, J.P.Morgan
Chase Co-Invest Partners 2003, LP,
J.P.Morgan Chase Co-Invest Partners
2004, LP, Sixty Wall Street Fund, L.P.,
522 Fifth Avenue Fund, L.P., OEP II CoInvestors, L.P., OEP III Co-Investors,
L.P., and Hambrecht & Quist Employee
Venture Fund, L.P. (collectively, the
‘‘Existing Partnerships’’); The BSC
Employee Fund, L.P., The BSC
Employee Fund II, L.P., The BSC
Employee Fund III, L.P., The BSC
Employee Fund IV, L.P., The BSC
Employee Fund V, L.P., The BSC
Employee Fund VI, L.P., The BSC
Employee Fund VII, L.P., The BSC
Employee Fund VIII (Cayman), L.P., and
Bear Stearns Health Innoventures
SUMMARY OF APPLICATION:
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Employee Fund, L.P. (collectively, the
‘‘Bear Stearns Partnerships’’).
FILING DATES: The application was filed
on February 8, 2008, and amended on
May 29, 2008, October 29, 2008, April
8, 2011, July 24, 2012, and January 18,
2013. Applicants have agreed to file an
amendment during the notice period,
the substance of which is reflected in
this notice.
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 13, 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, 270 Park Avenue, New
York, NY 10017.
FOR FURTHER INFORMATION CONTACT:
Christine Y. Greenlees, Senior Counsel,
at (202) 551–6879, or Dalia Osman
Blass, Assistant Director, at (202) 551–
6821 (Division of Investment
Management, Office of Investment
Company Regulation).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Applicants’ Representations
1. The Company is a financial holding
company and a Delaware corporation.
The Company and its ‘‘affiliates,’’ as
defined in rule 12b–2 under the
Securities Exchange Act of 1934 (the
‘‘Exchange Act’’) (each an ‘‘Affiliate’’),
are referred to collectively as ‘‘JPMorgan
Chase.’’ The Company is a leader in
investment banking, financial services
for consumers and businesses, financial
transaction processing and asset
management.
2. The Existing Partnerships are
operating in accordance with the terms
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and conditions of the Prior Orders.1 The
Bear Stearns Partnerships were formed
in reliance on an exemptive order
issued by the Commission.2 The
Existing Partnerships and the Bear
Stearns Partnerships are closed to new
investors. Applicants intend to offer
additional investment vehicles identical
in all material respects to the Existing
Partnerships (other than specific
investment terms, investment objectives
and strategies and form of organization)
(the ‘‘Partnerships’’). The Existing
Partnerships will continue to comply
with the terms and conditions of the
Prior Orders. Any Partnership formed
after the date of the initial filing of the
application and Bear Stearns
Partnership formed in reliance on the
BSC Order will comply with the terms
and conditions of the requested order.3
3. The Partnerships will be
established primarily for the benefit of
highly compensated employees of
JPMorgan Chase, as part of a program
designed to create capital building
opportunities that are competitive with
those at other financial services firms
and to facilitate the recruitment of high
caliber professionals. These programs
may be structured as different
Partnerships, or as separate plans within
the same Partnership. Each Partnership
will be an ‘‘employees’ securities
company’’ within the meaning of
1 The Prior Orders are: Chase Global Co-Invest
Partners 1997, L.P. and The Chase Manhattan
Corporation, Investment Company Act Release Nos.
23202 (May 21, 1998) (notice) and 23261 (June 17,
1998) (order), Hambrecht & Quist Employee
Venture Fund, L.P., et al., Investment Company Act
Release Nos. 23396 (August 21, 1998) (notice) and
23438 (September 16, 1998) (order), and Sixty Wall
Street Fund, L.P., et al., Investment Company Act
Release Nos. 23543 (November 20, 1998) (notice)
and 23601 (December 16, 1998) (order).
2 The BSC Employee Fund, LP. and BSCGP Inc.,
Investment Company Act Release Nos. 22656 (May
7, 1997) (notice) and 22695 (June 3, 1997) (order)
(the ‘‘BSC Order’’). On March 16, 2008, the
Company and The Bear Stearns Companies Inc.
(now The Bear Stearns Companies LLC) (‘‘Bear
Stearns’’) entered into an Agreement and Plan of
Merger, as amended (the ‘‘Merger Agreement’’). The
Merger Agreement provided that, upon the terms
and subject to the conditions set forth in the Merger
Agreement, a wholly-owned subsidiary of the
Company would merge with and into Bear Stearns
with Bear Stearns continuing as the surviving
corporation and as a wholly-owned subsidiary of
the Company (the ‘‘Bear Stearns Transaction’’). As
a result of the Bear Stearns Transaction, the general
partners of the Bear Stearns Partnerships are
Affiliates of the Company.
3 For purposes of this application, (i) a Bear
Stearns Partnership will be considered a
Partnership, (ii) any Bear Stearns Affiliate(s) acting
as general partners(s) to a Bear Stearns Partnership
will be considered a General Partner (as defined
below), (iii) Eligible Employees (as defined below)
of Bear Stearns and its Affiliates and their Qualified
Participants (as defined below) will be considered
Eligible Employees and Qualified Participants,
respectively, and (iv) all references to JPMorgan
Chase will be deemed to include Bear Stearns and
its Affiliates.
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section 2(a)(13) of the Act. Each of the
Partnerships will operate as a
diversified or non-diversified, closedend investment company within the
meaning of the Act. JPMorgan Chase
will control the Partnerships within the
meaning of section 2(a)(9) of the Act.
4. Each Partnership will have a
general partner or manager that is an
Affiliate of the Company (‘‘General
Partner’’). The General Partner of each
Partnership will manage, operate and
control that Partnership. The General
Partner will be authorized to delegate
investment management responsibility
to a JPMorgan Chase entity or to a
committee of JPMorgan Chase
employees, provided that the ultimate
responsibility for and control of each
Partnership remain with the General
Partner. The General Partner will
delegate management responsibility
only to entities that control, are
controlled by, or are under common
control with JPMorgan Chase. Any
JPMorgan Chase entity that is delegated
the responsibility of making investment
decisions for the Partnership will be
registered as an investment adviser
under the Investment Advisers Act of
1940 (the ‘‘Advisers Act’’) if required
under applicable law. The General
Partner, JPMorgan Chase, or any
employees of the General Partner or
JPMorgan Chase may be entitled to
receive compensation or a performancebased fee (such as a ‘‘carried interest’’) 4
based on the gains and losses of the
investment program or of the
Partnership’s investment portfolio. All
Partnership investments are referred to
herein collectively as ‘‘Portfolio
Investments.’’
5. Interests in the Partnerships
(‘‘Interests’’) will be offered without
registration in reliance on section 4(2) of
the Securities Act of 1933 (the
‘‘Securities Act’’) or Regulation D under
the Securities Act, and will be sold only
(a) to Eligible Employees, (b) at the
request of Eligible Employees and the
discretion of the General Partner, to
Qualified Participants of such Eligible
Employees, or (c) to JP Morgan Chase
entities, each as defined below. Prior to
4 A ‘‘carried interest’’ is an allocation to the
General Partner, a Participant (as defined below) or
the JPMorgan Chase entity acting as the investment
adviser to a Partnership based on net gains in
addition to the amount allocable to any such entity
in proportion to its capital contributions. A General
Partner, Participant or JPMorgan Chase entity that
is registered as an investment adviser under the
Advisers Act may charge a carried interest only if
permitted by rule 205–3 under the Advisers Act.
Any carried interest paid to a General Partner,
Participant or JPMorgan Chase entity that is not
registered under the Advisers Act also may be paid
only if permitted by rule 205–3 under the Advisers
Act as if such entity were registered under the
Advisers Act.
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offering an Interest to an Eligible
Employee, the General Partner must
reasonably believe that each Eligible
Employee that is required to make an
investment decision with respect to
whether or not to participate in a
Partnership, or to request that a related
Qualified Participant be permitted to
participate, will be a sophisticated
investor capable of understanding and
evaluating the risks of participating in
the Partnership without the benefit of
regulatory safeguards. Participation in a
Partnership will be voluntary. The term
‘‘Partners’’ refers to all partners or
members of, or other investors in the
Partnerships, and the term
‘‘Participants’’ refers to all partners or
members of, or other investors in the
Partnerships other than the General
Partner.
6. Only those employees of JPMorgan
Chase who qualify as ‘‘Eligible
Employees’’ will be able to participate
in the Partnerships. In order to qualify
as an ‘‘Eligible Employee,’’ (a) an
individual must (i) be a current or
former employee or current Consultant
(as defined below) of JPMorgan Chase
and (b) except for certain individuals
who manage the day-to-day affairs of the
Partnership in question (‘‘Managing
Employees’’) 5 and a limited number of
other employees of JPMorgan Chase 6
(collectively, ‘‘Non-Accredited
Investors’’), meet the standards of an
‘‘accredited investor’’ under in rule
501(a)(5) or 501(a)(6) of Regulation D, or
(b) an entity must (i) be a current
Consultant of JPMorgan Chase 7 and (ii)
5 A Managing Employee may invest in a
Partnership if he or she meets the definition of
‘‘knowledgeable employee’’ in rule 3c–5(a)(4) under
the Act with the Partnership treated as though it
were a ‘‘Covered Company’’ for purposes of the
rule.
6 Such employees must meet the sophistication
requirements set forth in rule 506(b)(2)(ii) of
Regulation D under the Securities Act and may be
permitted to invest his or her own funds in the
Partnership if, at the time of the employee’s
investment in a Partnership, he or she (a) has a
graduate degree in business, law or accounting, (b)
has a minimum of five years of consulting,
investment banking or similar business experience,
and (c) has had reportable income from all sources
of at least $100,000 in each of the two most recent
years and a reasonable expectation of income from
all sources of at least $140,000 in each year in
which such person will be committed to make
investments in a Partnership. In addition, such an
employee will not be permitted to invest in any
year more than 10% of his or her income from all
sources for the immediately preceding year in the
aggregate in such Partnership and in all other
Partnerships in which he or she has previously
invested.
7 A ‘‘Consultant’’ is a person or entity whom
JPMorgan Chase has engaged on retainer to provide
services and professional expertise on an ongoing
basis as a regular consultant or as a business or legal
advisor to JPMorgan Chase and who shares a
community of interest with JPMorgan Chase and
JPMorgan Chase employees.
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meet the standards of an ‘‘accredited
investor under rule 501(a) of Regulation
D. A Partnership may not have more
than 35 Non-Accredited Investors. It is
anticipated that, at the sole discretion of
the General Partner, Consultants of
JPMorgan Chase may be offered the
opportunity to participate in the
Partnerships.8
7. In the discretion of the General
Partner and at the request of an Eligible
Employee, Interests may be assigned by
such Eligible Employee, or sold directly
by the Partnership, to a Qualified
Participant of an Eligible Employee. In
order to qualify as a ‘‘Qualified
Participants’’ an individual or entity
must (a) be an Eligible Family Member
or Qualified Investment Vehicle (in each
case as defined below), respectively, of
an Eligible Employee, and (b) if
purchasing an Interest from a
Partnership, come within one of the
categories of an ‘‘accredited Investor’’
under rule 501(a) of Regulation D. An
‘‘Eligible Family Member’’ is a spouse,
parent, child, spouse of child, brother,
sister or grandchild of an Eligible
Employee, including step and adoptive
relationships. A ‘‘Qualified Investment
Vehicle’’ is (a) a trust of which the
trustee, grantor and/or beneficiary is an
Eligible Employee, (b) a partnership,
corporation or other entity controlled by
an Eligible Employee, or (c) a trust or
other entity established solely for the
benefit of an Eligible Employee or
Eligible Family Members of an Eligible
Employee.9
8. The terms of a Partnership will be
fully disclosed to each Eligible
Employee, and, if applicable, to a
Qualified Participant, at the time they
are invited to participate in the
Partnership. Each Eligible Employee
and their Qualified Participants will be
8 In order to participate in the Partnerships,
Consultants will be required to be sophisticated
investors who qualify as ‘‘accredited investors’’
under rule 501(a)(5) or 501(a)(6) of Regulation D (if
a Consultant is an individual) or, if not an
individual, meet the standards of an ‘‘accredited
investor’’ under rule 501(a) of Regulation D.
Qualified Participants (as defined below) of
Consultants may invest in a Partnership.
9 The inclusion of partnerships, corporations, or
other entities that are controlled by Eligible
Employees who are individuals in the definition of
‘‘Qualified Investment Vehicle’’ is intended to
enable these individuals to make investments in the
Partnerships through personal investment vehicles
over which they exercise investment discretion or
other investment vehicles the management or affairs
of which they otherwise control. In the case of a
partnership, corporation, or other entity controlled
by a Consultant, individual participants will be
limited to senior level employees, members, or
partners of the Consultant who are responsible for
the activities of the Consultant, will be required to
qualify as ‘‘accredited investors’’ under rule
501(a)(5) or 501(a)(6) of Regulation D and will have
access to the directors and officers of the General
Partner.
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furnished with offering materials,
including a copy of the partnership
agreement or other organizational
document (the ‘‘Partnership
Agreement’’) for the relevant
Partnership. Each Partnership will send
its Partners annual financial statements
within 120 days after the end of the
fiscal year of such Partnership, or as
soon as practicable thereafter. The
annual financial statements of each
Partnership will be audited by
independent certified public
accountants,10 except under certain
circumstances in the case of
Partnerships formed to make a single
Portfolio Investment.11 As soon as
practicable after the end of each tax year
of a Partnership, a report will be
transmitted to each Partner showing
such Partner’s share of income, gains,
losses, credits, deductions, and other tax
items for U.S. federal income tax
purposes, resulting from the
Partnership’s operations during that
year.
9. Interests in each Partnership will be
non-transferable except with the prior
written consent of the General Partner,
and, in any event, no person or entity
will be admitted into a Partnership as a
Participant unless such person is (a) an
Eligible Employee, (b) a Qualified
Participant of an Eligible Employee, or
(c) a JPMorgan Chase entity. The
Interests in the Partnerships will be sold
without a sales load.
10. An Eligible Employee’s interest in
a Partnership may be subject to
repurchase or cancellation if: (a) The
Eligible Employee’s relationship with
JPMorgan Chase is terminated for cause;
(b) a former Eligible Employee becomes
employed by, or a partner in, consultant
to or otherwise joins any firm that the
General Partner determines, in its
reasonable discretion, to be competitive
with any business of JPMorgan Chase; or
(c) the Eligible Employee voluntarily
resigns his or her employment with
JPMorgan Chase or otherwise has his or
her employment terminated for any
other reason. Upon repurchase or
cancellation, the General Partner will
pay to the Eligible Employee at least the
lesser of (a) the amount actually paid by
the Eligible Employee to acquire the
Interest (less prior distributions, plus
interest), and (b) the fair market value of
the Interest as determined at the time of
repurchase or cancellation by the
10 ‘‘Audit’’ will have the meaning defined in rule
1–02(d) of Regulation S–X.
11 In such cases, audited financial statements will
be prepared for either the Partnership or the entity
that is the subject of the Portfolio Investment.
Where a Partnership is formed to make a single
investment, that investment will not be an entity
relying on section 3(c)(7) of the Act.
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General Partner. The terms of any
repurchase or cancellation will apply
equally to any Qualified Participant of
an Eligible Employee.
11. It is possible that an investment
program may be structured in which a
Partnership will co-invest in a portfolio
company (or a pooled investment
vehicle) with JPMorgan Chase or an
investment fund or separate account,
organized primarily for the benefit of
investors who are not affiliated with
JPMorgan Chase, over which a JPMorgan
Chase entity exercises investment
discretion or which is sponsored by a
JPMorgan Chase entity (a ‘‘JPMorgan
Chase Third Party Fund’’). It is also
possible that an investment program
may be structured in which a
Partnership will invest in an investment
fund or pooled investment vehicle for
which entities or persons unaffiliated
with JPMorgan Chase are the sponsors
or investment advisers (a ‘‘Third Party
Sponsored Fund’’). Any JPMorgan
Chase entity’s (other than a JPMorgan
Chase Third Party Fund’s) coinvestment in a Third Party Sponsored
Fund will be subject to the restrictions
contained in condition 3 below. The
General Partner will not delegate
management and investment discretion
for the Partnership to the sponsor of the
Third Party Sponsored Fund.
12. If a General Partner elects to
recommend that a Partnership enter into
any side-by-side investment with an
unaffiliated entity (including a Third
Party Sponsored Fund), the General
Partner will be permitted to engage as a
sub-investment adviser the unaffiliated
entity (an ‘‘Unaffiliated Subadviser’’),
which will be responsible for the
management of such side-by-side
investment. If an Unaffiliated
Subadviser is entitled to receive a
carried interest, it may also act as an
additional General Partner of a
Partnership solely in order to address
certain tax issues relating to such
carried interest. In all such instances,
however, a JPMorgan Chase entity will
also be a General Partner of the
Partnership and will have exclusive
responsibility for making the
determinations required to be made by
the General Partner under the requested
order. No Unaffiliated Subadviser will
beneficially own any outstanding
securities of any Partnership.
13. Subject to the terms of the
applicable Partnership Agreement, a
Partnership will be permitted to enter
into transactions involving (a) a
JPMorgan Chase entity, (b) a portfolio
company, (c) any Participant or person
or entity affiliated with a Participant, (d)
a JPMorgan Chase Third Party Fund, or
(e) any person or entity who is not
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affiliated with JPMorgan Chase and is a
partner or other investor in a JPMorgan
Chase Third Party Fund or a Third Party
Sponsored Fund (a ‘‘Third Party
Investor’’).
14. If the General Partner or a
JPMorgan Chase entity makes a loan to
a Partnership, the loan would bear
interest at a rate no less favorable than
the rate obtainable in an arm’s length
transaction. Any indebtedness of a
Partnership will be without recourse to
the Participants. A Partnership will not
borrow from any person if the
borrowing would cause any person not
named in section 2(a)(13) of the Act to
own securities of the Partnership (other
than short term paper).
15. A Partnership will not acquire any
security issued by a registered
investment company if, immediately
after such acquisition, the Partnership
will own more than 3% of the
outstanding voting stock of the
registered investment company.
Applicants’ Legal Analysis
1. Section 6(b) of the Act provides, in
part, that the Commission will exempt
employees’ securities companies from
the provisions of the Act to the extent
that the exemption is consistent with
the protection of investors. Section 6(b)
provides that the Commission will
consider, in determining the provisions
of the Act from which the company
should be exempt, the company’s form
of organization and capital structure, the
persons owning and controlling its
securities, the price of the company’s
securities and the amount of any sales
load, how the company’s funds are
invested, and the relationship between
the company and the issuers of the
securities in which it invests. Section
2(a)(13) defines an employees’ securities
company, in relevant part, as any
investment company all of whose
securities (other than short-term paper)
are beneficially owned (a) by current or
former employees, or persons on
retainer, of one or more affiliated
employers, (b) by immediate family
members of such persons, or (c) by such
employer or employers together with
any of the persons in (a) or (b).
2. Section 7 of the Act generally
prohibits investment companies that are
not registered under section 8 of the Act
from selling or redeeming their
securities. Section 6(e) of the Act
provides that, in connection with any
order exempting an investment
company from any provision of section
7, certain provisions of the Act, as
specified by the Commission, will be
applicable to the company and other
persons dealing with the company as
though the company were registered
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23803
under the Act. Applicants request an
order under sections 6(b) and 6(e) of the
Act exempting the Partnerships from all
the provisions of the Act, except section
9, and sections 36 through 53, and the
rules and regulations under the Act.
With respect to sections 17 and 30 of the
Act, and the rules and regulations
thereunder, and rule 38a-1 under the
Act, the exemption is limited as set
forth in the application.
3. Section 17(a) generally prohibits
any affiliated person of a registered
investment company, or any affiliated
person of an affiliated person, acting as
principal, from knowingly selling or
purchasing any security or other
property to or from the company.
Applicants request an exemption from
section 17(a) of the Act to permit a
JPMorgan Chase entity or a Third Party
Fund (or any ‘‘affiliated person,’’ as
defined in the Act, of any such entity or
Third Party Fund), acting as principal,
to purchase or sell securities or other
property to or from any Partnership or
any company controlled by such
Partnership. Applicants state that the
relief is requested to permit each
Partnership the flexibility to deal with
its Portfolio Investments in the manner
the General Partner deems most
advantageous to all Participants,
including borrowing funds from a
JPMorgan Chase entity, restructuring its
investments, having its investments
redeemed, tendering such Partnership’s
securities or negotiating options or
implementing exit strategies with
respect to its investments. Applicants
state the requested exemption is sought
to ensure that a JPMorgan Chase Third
Party Fund or a Third Party Investor
will not directly or indirectly become
subject to a burden, restriction, or other
adverse effect by virtue of a
Partnership’s participation in an
investment opportunity.
4. Applicants believe an exemption
from section 17(a) is consistent with the
policy of each Partnership and the
protection of investors and necessary to
promote the basic purpose of such
Partnership. Applicants state that the
Participants in each Partnership will be
fully informed of the possible extent of
such Partnership’s dealings with
JPMorgan Chase, and, as successful
professionals employed in investment
and financial planning, will be able to
understand and evaluate the attendant
risks. Applicants assert that the
community of interest among the
Participants in each Partnership, on the
one hand, and JPMorgan Chase, on the
other hand, is the best insurance against
any risk of abuse. Applicants, on behalf
of the Partnerships, acknowledge that
any transactions otherwise subject to
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section 17(a) of the Act, for which
exemptive relief has not been requested,
would require approval of the
Commission. Applicants further
acknowledge that the requested relief
will not extend to any transactions
between a Partnership and an
Unaffiliated Subadviser or an affiliated
person of the Unaffiliated Subadviser, or
between a Partnership and any person
who is not an employee, officer or
director of JPMorgan Chase or is an
entity outside of JPMorgan Chase and is
an affiliated person of the Partnership as
defined in Section 2(a)(3)(E) of the Act
(‘‘Advisory Person’’) or any affiliated
person of such person.
5. Section 17(d) of the Act and rule
17d–1 under the Act prohibit any
affiliated person of a registered
investment company, or any affiliated
person of such person, acting as
principal, from participating in any joint
arrangement with the company unless
authorized by the Commission.
Applicants request relief to permit
affiliated persons of each Partnership, or
affiliated persons of any of these
persons, to participate in, or effect any
transaction in connection with, any
joint enterprise or other joint
arrangement or profit-sharing plan in
which a Partnership or a company
controlled by the Partnership is a
participant. The exemption requested
would permit, among other things, coinvestments by each Partnership and by
individual members or employees,
officers, directors, or Consultants of
JPMorgan Chase making their own
individual investment decisions apart
from JPMorgan Chase. Applicants
acknowledge that the requested relief
will not extend to any transaction in
which an Unaffiliated Subadviser or an
Advisory Person or an affiliated person
of either has an interest.
6. Applicants assert that compliance
with section 17(d) would cause a
Partnership to forego investment
opportunities simply because a
Participant in such Partnership or other
affiliated person of such Partnership (or
any affiliate of such a person) also had,
or contemplated making, a similar
investment. Applicants further assert
that attractive investment opportunities
of the types considered by a Partnership
often require each participant in the
transaction to make available funds in
an amount that may be substantially
greater than those that may be available
to such Partnership alone. Applicants
contend that, as a result, the only way
in which a Partnership may be able to
participate in such opportunities may be
to co-invest with other persons,
including its affiliates. Applicants assert
that the flexibility to structure co-
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investments and joint investments will
not involve abuses of the type section
17(d) and rule 17d–1 were designed to
prevent.
7. Applicants state that side-by-side
investments held by a JPMorgan Chase
Third Party Fund, or by a JPMorgan
Chase entity in a transaction in which
the JPMorgan Chase investment was
made pursuant to a contractual
obligation to a JPMorgan Chase Third
Party Fund, will not be subject to
condition 3 below. All other side-byside investments held by JPMorgan
Chase entities will be subject to
condition 3 below. Applicants assert
that in structuring a JPMorgan Chase
Third Party Fund, it is common for the
unaffiliated investors of such fund to
require that JPMorgan Chase invest its
own capital in Third Party Fund
investments, either through the Third
Party Fund or on a side-by-side basis,
and that such JPMorgan Chase
investments be subject to substantially
the same terms as those applicable to
the Third Party Fund’s investments.
Applicants state that it is important that
the interests of the JPMorgan Chase
Third Party Fund take priority over the
interests of the Partnerships, and that
the activities of the JPMorgan Chase
Third Party Fund not be burdened or
otherwise affected by activities of the
Partnerships. Applicants also state that
the relationship of a Partnership to a
JPMorgan Chase Third Party Fund is
fundamentally different from such
Partnership’s relationship to JPMorgan
Chase. Applicants contend that the
focus of, and the rationale for, the
protections contained in the application
are to protect the Partnerships from any
overreaching by JPMorgan Chase in the
employer/employee context, whereas
the same concerns are not present with
`
respect to the Partnerships vis-a-vis the
investors of a JPMorgan Chase Third
Party Fund.
8. Section 17(e) of the Act and rule
17e–1 under the Act limit the
compensation an affiliated person may
receive when acting as agent or broker
for a registered investment company.
Applicants request an exemption from
section 17(e) to permit a JPMorgan
Chase entity (including the General
Partner), acting as an agent or broker, to
receive placement fees, advisory fees, or
other compensation from a Partnership
in connection with the purchase or sale
by the Partnership of securities,
provided that such placement fees,
advisory fees, or other compensation are
deemed ‘‘usual and customary.’’
Applicants state that for purposes of the
application, fees or other compensation
that are charged or received by a
JPMorgan Chase entity will be deemed
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‘‘usual and customary’’ only if (a) the
Partnership is purchasing or selling
securities with other unaffiliated third
parties, including JPMorgan Chase
Third Party Funds or Third Party
Investors who are also similarly
purchasing or selling securities, (b) the
fees or compensation being charged to
the Partnership are also being charged to
the unaffiliated third parties, including
JPMorgan Chase Third Party Funds or
Third Party Investors, and (c) the
amount of securities being purchased or
sold by the Partnership does not exceed
50% of the total amount of securities
being purchased or sold by the
Partnership and the unaffiliated third
parties, including JPMorgan Chase
Third Party Funds or Third Party
Investors. Applicants assert that,
because JPMorgan Chase does not wish
to appear to be favoring the
Partnerships, compliance with section
17(e) would prevent a Partnership from
participating in transactions where the
Partnership is being charged lower fees
than unaffiliated third parties.
Applicants assert that the fees or other
compensation paid by a Partnership to
a JPMorgan Chase entity will be the
same as those negotiated at arm’s length
with unaffiliated third parties.
9. Rule 17e–1(b) under the Act
requires that a majority of directors who
are not ‘‘interested persons’’ (as defined
in section 2(a)(19) of the Act) take
actions and make approvals regarding
commissions, fees, or other
remuneration. Rule 17e–1(c) under the
Act requires each investment company
relying on the rule to satisfy the fund
governance standards defined in rule
0–1(a)(7) under the Act. Applicants
request an exemption from rule 17e–1 to
the extent necessary to permit each
Partnership to comply with the rule
without having a majority of the
directors of the General Partner who are
not interested persons take actions and
make approvals as set forth in paragraph
(b) of the rule, and without having to
satisfy the standards set forth in
paragraph (c) of the rule. Applicants
state that because all the directors of the
General Partner will be affiliated
persons, without the relief requested, a
Partnership could not comply with rule
17e–1. Applicants state that each
Partnership will comply with rule 17e–
1 by having a majority of the directors
of the General Partner take actions and
make approvals as set forth in the rule.
Applicants state that each Partnership
will otherwise comply with rule 17e–1.
10. Section 17(f) of the Act designates
the entities that may act as investment
company custodians, and rule 17f–1
under the Act imposes certain
requirements when the custodian is a
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member of a national securities
exchange. Applicants request an
exemption from section 17(f) and rule
17f–1 to permit a JPMorgan Chase entity
to act as custodian without a written
contract. Applicants also request an
exemption from the rule 17f–1(b)(4)
requirement that an independent
accountant periodically verify the assets
held by the custodian. Applicants state
that, given the community of interest of
all the parties involved and the existing
requirement for an independent audit,
compliance with the rule’s requirement
would be unnecessary. Each Partnership
will otherwise comply with the
provisions of rule 17f–1.
11. Rule 17f–2 under the Act specifies
requirements that must be satisfied for
a registered management investment
company to act as custodian of its own
investments. Applicants request an
exemption from rule 17f–2 to permit the
following exceptions from the
requirements of rule 17f–2: (a) A
Partnership’s investments may be kept
in the locked files of the General Partner
(or a JPMorgan Chase entity) for
purposes of paragraph (b) of the rule; (b)
for purposes of paragraph (d) of the rule,
(i) employees of the General Partner (or
a JPMorgan Chase entity) will be
deemed to be employees of the
Partnerships, (ii) officers or managers of
the General Partner of a Partnership (or
a JPMorgan Chase entity) will be
deemed to be officers of the Partnership,
and (iii) the General Partner of a
Partnership (or a JPMorgan Chase entity)
or its board of directors will be deemed
to be the board of directors of the
Partnership; and (c) in place of the
verification procedure under paragraph
(f) of the rule, verification will be
effected quarterly by two employees of
the General Partner (or a JPMorgan
Chase entity) each of whom shall have
sufficient knowledge, sophistication and
experience in business matters to
perform such examination. Applicants
expect that some of the Partnerships’
investments may be evidenced only by
partnership agreements, participation
agreements or similar documents, rather
than by negotiable certificates that could
be misappropriated. Applicants assert
that these instruments are most suitably
kept in the files of the General Partner
(or a JPMorgan Chase entity), where
they can be referred to as necessary.
Applicants will comply with all other
provisions of rule 17f–2.
12. Section 17(g) of the Act and rule
17g–1 under the Act generally require
the bonding of officers and employees of
a registered investment company who
have access to its securities or funds.
Rule 17g–1 requires that a majority of
directors who are not interested persons
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take certain actions and give certain
approvals relating to fidelity bonding.
The rule also requires that the board of
directors of an investment company
relying on the rule satisfy the fund
governance standards, as defined in rule
0–1(a)(7). Applicants request relief to
permit the General Partner, who may be
deemed to be an interested person, to
take actions and make approvals as set
forth in the rule. Applicants state that,
because the General Partner will be an
interested person of the Partnerships,
the Partnerships could not comply with
rule 17g–1 without the requested relief.
Applicants also request an exemption
from the requirements of rule 17g–l(g)
and (h) relating to the filing of copies of
fidelity bonds and related information
with the Commission and the provision
of notices to the board of directors and
an exemption from the requirements of
rule 17g–1(j)(3) relating to compliance
with the fund governance standards.
The Partnerships will comply with all
other requirements of rule 17g–1.
13. Section 17(j) of the Act and
paragraph (b) of rule 17j–1 under the
Act make it unlawful for certain
enumerated persons to engage in
fraudulent or deceptive practices in
connection with the purchase or sale of
a security held or to be acquired by a
registered investment company. Rule
17j–1 also requires that every registered
investment company adopt a written
code of ethics and that every access
person of a registered investment
company report personal securities
transactions. Applicants request an
exemption from the provisions of rule
17j–1, except for the anti-fraud
provisions of paragraph (b), because
they are burdensome and unnecessary
as applied to the Partnerships. The relief
requested will extend only to entities
within JPMorgan Chase and is not
requested with respect to any
Unaffiliated Subadviser or Advisory
Person.
14. Applicants request an exemption
from the requirements in sections 30(a),
30(b), and 30(e) of the Act, and the rules
under those sections, that registered
investment companies prepare and file
with the Commission and mail to their
shareholders certain periodic reports
and financial statements. Applicants
contend that the forms prescribed by the
Commission for periodic reports have
little relevance to a Partnership and
would entail administrative and legal
costs that outweigh any benefit to the
Participants in such Partnership.
Applicants request relief to the extent
necessary to permit each Partnership to
report annually to its Participants.
Applicants also request relief from the
requirements of section 30(h), to the
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23805
extent necessary to exempt the General
Partner of each Partnership, directors
and officers of the General Partner and
any other persons who may be deemed
members of an advisory board or
investment adviser (and affiliated
persons thereof) of such Partnership
from filing Forms 3, 4 and 5 under
Section 16 of the Exchange Act with
respect to their ownership of Interests in
such Partnership. Applicants believe
that, because there will be no trading
market and the transfers of Interests will
be severely restricted, these filings are
unnecessary for the protection of
investors and burdensome to those
required to make them.
15. Rule 38a–1 requires investment
companies to adopt, implement and
periodically review written policies
reasonably designed to prevent violation
of the federal securities laws and to
appoint a chief compliance officer.
Applicants state that each Partnership
will comply with rule 38a–1(a), (c) and
(d), except that (a) since the Partnership
does not have a board of directors, the
board of directors (or similar body) of
the General Partner will fulfill the
responsibilities assigned to the
Partnership’s board of directors under
the rule, (b) since the board of directors
of the General Partner does not have any
disinterested members, approval by a
majority of the disinterested board
members required by rule 38a–1 will
not be obtained, and (c) since the board
of directors of the General Partner does
not have any disinterested directors, the
Partnerships will comply with the
requirement in rule 38a–1(a)(4)(iv) that
the chief compliance officer meet with
the independent directors by having the
chief compliance officer meet with the
board of directors of the General Partner
as constituted.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
1. Each proposed transaction
otherwise prohibited by section 17(a) or
section 17(d) and rule 17d–1 to which
a Partnership is a party (the ‘‘Section 17
Transactions’’) will be effected only if
the General Partner determines that:
(a) The terms of the Section 17
Transaction, including the
consideration to be paid or received, are
fair and reasonable to the Participants of
the participating Partnership and do not
involve overreaching of such
Partnership or its Participants on the
part of any person concerned, and
(b) the Section 17 Transaction is
consistent with the interests of the
Participants of the participating
Partnership, such Partnership’s
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organizational documents and such
Partnership’s reports to its Participants.
In addition, the General Partner will
record and will preserve a description of
all Section 17 Transactions, the General
Partner’s findings and the information
or materials upon which the General
Partner’s findings are based and the
basis for the findings. All such records
will be maintained for the life of the
Partnership and at least six years
thereafter, and will be subject to
examination by the Commission and its
staff. Each Partnership will preserve the
accounts, books and other documents
required to be maintained in an easily
accessible place for the first two years.
2. The General Partner will adopt, and
periodically review and update,
procedures designed to ensure that
reasonable inquiry is made, prior to the
consummation of any Section 17
Transaction, with respect to the possible
involvement in the transaction of any
affiliated person or promoter of or
principal underwriter for such
Partnership, or any affiliated person of
such a person, promoter or principal
underwriter.
3. The General Partner will not make
on behalf of a Partnership any
investment in which a Co-Investor (as
defined below) has acquired or proposes
to acquire the same class of securities of
the same issuer, where the investment
involves a joint enterprise or other joint
arrangement within the meaning of rule
17d–1 in which such Partnership and
the Co-Investor are participants, unless
any such Co-Investor, prior to disposing
of all or part of its investment, (a) gives
such General Partner sufficient, but not
less than one day’s, notice of its intent
to dispose of its investment, and (b)
refrains from disposing of its investment
unless the participating Partnership
holding such investment has the
opportunity to dispose of its investment
prior to or concurrently with, on the
same terms as, and on a pro rata basis
with, the Co-Investor. The term ‘‘CoInvestor’’ with respect to any
Partnership means any person who is:
(a) An ‘‘affiliated person’’ (as defined in
section 2(a)(3) of the Act) of such
Partnership (other than a JPMorgan
Chase Third Party Fund); (b) a JPMorgan
Chase entity; (c) an officer, director or
partner of a JPMorgan Chase entity; or
(d) an entity (other than a JPMorgan
Chase Third Party Fund) in which the
General Partner acts as a general partner
or has a similar capacity to control the
sale or other disposition of the entity’s
securities. The restrictions contained in
this condition, however, shall not be
deemed to limit or prevent the
disposition of an investment by a CoInvestor: (a) To its direct or indirect
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wholly-owned subsidiary, to any
company (a ‘‘Parent’’) of which such CoInvestor is a direct or indirect whollyowned subsidiary, or to a direct or
indirect wholly-owned subsidiary of its
Parent; (b) to immediate family
members of such Co-Investor, including
step and adoptive relationships, or to a
trust or other investment vehicle
established for any such immediate
family member; or (c) when the
investment is comprised of securities
that are (i) listed on any exchange
registered as a national securities
exchange under section 6 of the 1934
Act; (ii) NMS stocks pursuant to section
11A(a)(2) of the 1934 Act and rule
600(b) of Regulation NMS thereunder;
(iii) government securities as defined in
section 2(a)(16) of the Act or other
securities that meet the definition of
‘‘Eligible Security’’ in rule 2a–7 under
the Act; or (iv) listed on or traded on
any foreign securities exchange or board
of trade that satisfies regulatory
requirements under the law of the
jurisdiction in which such foreign
securities exchange or board of trade is
organized similar to those that apply to
a national securities exchange or a
national market system for securities.
4. Each Partnership and its General
Partner will maintain and preserve, for
the life of such Partnership and at least
six years thereafter, such accounts,
books, and other documents as
constitute the record forming the basis
for the audited financial statements that
are to be provided to the Participants in
such Partnership, and each annual
report of such Partnership required to be
sent to such Participants, and agree that
all such records will be subject to
examination by the Commission and its
staff. Each Partnership will preserve the
accounts, books and other documents
required to be maintained in an easily
accessible place for the first two years.
5. The General Partner of each
Partnership will send to each
Participant in that Partnership, at any
time during the fiscal year then ended,
Partnership financial statements audited
by such Partnership’s independent
accountants, except in the case of a
Partnership formed to make a single
Portfolio Investment. In such cases, the
partnership may send unaudited
financial statements, but each
Participant will receive financial
statements of the single Portfolio
Investment audited by such entity’s
independent accountants. At the end of
each fiscal year, the General Partner will
make a valuation or have a valuation
made of all of the assets of the
Partnership as of such fiscal year end in
a manner consistent with customary
practice with respect to the valuation of
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assets of the kind held by the
Partnership. In addition, within 120
days after the end of each fiscal year of
each Partnership or as soon as
practicable thereafter, the General
Partner will send a report to each person
who was a Participant at any time
during the fiscal year then ended,
setting forth such tax information as
shall be necessary for the preparation by
the Participant of his, her or its U.S.
federal and state income tax returns and
a report of the investment activities of
the Partnership during that fiscal year.
6. If a Partnership makes purchases or
sales from or to an entity affiliated with
the Partnership by reason of an officer,
director or employee of JPMorgan Chase
(a) serving as an officer, director, general
partner or investment adviser of the
entity, or (b) having a 5% or more
investment in the entity, such
individual will not participate in the
Partnership’s determination of whether
or not to effect the purchase or sale.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2013–09344 Filed 4–19–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–69381; File No. SR–MIAX–
2013–16 ]
Self-Regulatory Organizations; Miami
International Securities Exchange LLC;
Notice of Filing and Immediate
Effectiveness of a Proposed Rule
Change To Modify the MIAX Fee
Schedule
April 16, 2013.
Pursuant to the provisions of Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Act’’) 1 and Rule 19b–4
thereunder,2 notice is hereby given that
on April 5, 2013, Miami International
Securities Exchange LLC (‘‘MIAX’’ or
‘‘Exchange’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’) a proposed rule change
as described in Items I, II, and III below,
which Items have been prepared by the
Exchange. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
1 15
2 17
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U.S.C. 78s(b)(1).
CFR 240.19b–4.
22APN1
Agencies
[Federal Register Volume 78, Number 77 (Monday, April 22, 2013)]
[Notices]
[Pages 23800-23806]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-09344]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 30465; 813-370]
JPMorgan Chase & Co., et al.; Notice of Application
April 16, 2013.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application to amend prior orders under sections
6(b) and 6(e) of the Investment Company Act of 1940 (``Act'') granting
an exemption from all provisions of the Act, except section 9, and
sections 36 through 53, and the rules and regulations thereunder. With
respect to sections 17 and 30 of the Act, and the rules and regulations
thereunder, and rule 38a-1 under the Act, the exemption is limited as
set forth in the application.
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SUMMARY OF APPLICATION: Applicants request an order to amend prior
orders exempting certain limited partnerships and other entities formed
for the benefit of eligible employees of JPMorgan Chase & Co. and its
affiliates from certain provisions of the Act. Each partnership will be
an ``employees' securities company'' within the meaning of section
2(a)(13) of the Act.
APPLICANTS: JPMorgan Chase & Co. (the ``Company''); Chase Co-Invest
June 2000 Partners, LP, Chase Co-Invest March 2000 Partners, LP,
J.P.Morgan Chase Co-Invest Partners 2001 A-2, LP, J.P.Morgan Chase Co-
Invest Partners 2001 B-2, L.P., J.P.Morgan Chase Co-Invest Partners
2002, LP, J.P.Morgan Chase Co-Invest Partners 2003, LP, J.P.Morgan
Chase Co-Invest Partners 2004, LP, Sixty Wall Street Fund, L.P., 522
Fifth Avenue Fund, L.P., OEP II Co-Investors, L.P., OEP III Co-
Investors, L.P., and Hambrecht & Quist Employee Venture Fund, L.P.
(collectively, the ``Existing Partnerships''); The BSC Employee Fund,
L.P., The BSC Employee Fund II, L.P., The BSC Employee Fund III, L.P.,
The BSC Employee Fund IV, L.P., The BSC Employee Fund V, L.P., The BSC
Employee Fund VI, L.P., The BSC Employee Fund VII, L.P., The BSC
Employee Fund VIII (Cayman), L.P., and Bear Stearns Health Innoventures
[[Page 23801]]
Employee Fund, L.P. (collectively, the ``Bear Stearns Partnerships'').
FILING DATES: The application was filed on February 8, 2008, and
amended on May 29, 2008, October 29, 2008, April 8, 2011, July 24,
2012, and January 18, 2013. Applicants have agreed to file an amendment
during the notice period, the substance of which is reflected in this
notice.
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 13, 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,
270 Park Avenue, New York, NY 10017.
FOR FURTHER INFORMATION CONTACT: Christine Y. Greenlees, Senior
Counsel, at (202) 551-6879, or Dalia Osman Blass, Assistant Director,
at (202) 551-6821 (Division of Investment Management, Office of
Investment Company Regulation).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or an applicant
using the Company name box, at https://www.sec.gov/search/search.htm or
by calling (202) 551-8090.
Applicants' Representations
1. The Company is a financial holding company and a Delaware
corporation. The Company and its ``affiliates,'' as defined in rule
12b-2 under the Securities Exchange Act of 1934 (the ``Exchange Act'')
(each an ``Affiliate''), are referred to collectively as ``JPMorgan
Chase.'' The Company is a leader in investment banking, financial
services for consumers and businesses, financial transaction processing
and asset management.
2. The Existing Partnerships are operating in accordance with the
terms and conditions of the Prior Orders.\1\ The Bear Stearns
Partnerships were formed in reliance on an exemptive order issued by
the Commission.\2\ The Existing Partnerships and the Bear Stearns
Partnerships are closed to new investors. Applicants intend to offer
additional investment vehicles identical in all material respects to
the Existing Partnerships (other than specific investment terms,
investment objectives and strategies and form of organization) (the
``Partnerships''). The Existing Partnerships will continue to comply
with the terms and conditions of the Prior Orders. Any Partnership
formed after the date of the initial filing of the application and Bear
Stearns Partnership formed in reliance on the BSC Order will comply
with the terms and conditions of the requested order.\3\
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\1\ The Prior Orders are: Chase Global Co-Invest Partners 1997,
L.P. and The Chase Manhattan Corporation, Investment Company Act
Release Nos. 23202 (May 21, 1998) (notice) and 23261 (June 17, 1998)
(order), Hambrecht & Quist Employee Venture Fund, L.P., et al.,
Investment Company Act Release Nos. 23396 (August 21, 1998) (notice)
and 23438 (September 16, 1998) (order), and Sixty Wall Street Fund,
L.P., et al., Investment Company Act Release Nos. 23543 (November
20, 1998) (notice) and 23601 (December 16, 1998) (order).
\2\ The BSC Employee Fund, LP. and BSCGP Inc., Investment
Company Act Release Nos. 22656 (May 7, 1997) (notice) and 22695
(June 3, 1997) (order) (the ``BSC Order''). On March 16, 2008, the
Company and The Bear Stearns Companies Inc. (now The Bear Stearns
Companies LLC) (``Bear Stearns'') entered into an Agreement and Plan
of Merger, as amended (the ``Merger Agreement''). The Merger
Agreement provided that, upon the terms and subject to the
conditions set forth in the Merger Agreement, a wholly-owned
subsidiary of the Company would merge with and into Bear Stearns
with Bear Stearns continuing as the surviving corporation and as a
wholly-owned subsidiary of the Company (the ``Bear Stearns
Transaction''). As a result of the Bear Stearns Transaction, the
general partners of the Bear Stearns Partnerships are Affiliates of
the Company.
\3\ For purposes of this application, (i) a Bear Stearns
Partnership will be considered a Partnership, (ii) any Bear Stearns
Affiliate(s) acting as general partners(s) to a Bear Stearns
Partnership will be considered a General Partner (as defined below),
(iii) Eligible Employees (as defined below) of Bear Stearns and its
Affiliates and their Qualified Participants (as defined below) will
be considered Eligible Employees and Qualified Participants,
respectively, and (iv) all references to JPMorgan Chase will be
deemed to include Bear Stearns and its Affiliates.
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3. The Partnerships will be established primarily for the benefit
of highly compensated employees of JPMorgan Chase, as part of a program
designed to create capital building opportunities that are competitive
with those at other financial services firms and to facilitate the
recruitment of high caliber professionals. These programs may be
structured as different Partnerships, or as separate plans within the
same Partnership. Each Partnership will be an ``employees' securities
company'' within the meaning of section 2(a)(13) of the Act. Each of
the Partnerships will operate as a diversified or non-diversified,
closed-end investment company within the meaning of the Act. JPMorgan
Chase will control the Partnerships within the meaning of section
2(a)(9) of the Act.
4. Each Partnership will have a general partner or manager that is
an Affiliate of the Company (``General Partner''). The General Partner
of each Partnership will manage, operate and control that Partnership.
The General Partner will be authorized to delegate investment
management responsibility to a JPMorgan Chase entity or to a committee
of JPMorgan Chase employees, provided that the ultimate responsibility
for and control of each Partnership remain with the General Partner.
The General Partner will delegate management responsibility only to
entities that control, are controlled by, or are under common control
with JPMorgan Chase. Any JPMorgan Chase entity that is delegated the
responsibility of making investment decisions for the Partnership will
be registered as an investment adviser under the Investment Advisers
Act of 1940 (the ``Advisers Act'') if required under applicable law.
The General Partner, JPMorgan Chase, or any employees of the General
Partner or JPMorgan Chase may be entitled to receive compensation or a
performance-based fee (such as a ``carried interest'') \4\ based on the
gains and losses of the investment program or of the Partnership's
investment portfolio. All Partnership investments are referred to
herein collectively as ``Portfolio Investments.''
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\4\ A ``carried interest'' is an allocation to the General
Partner, a Participant (as defined below) or the JPMorgan Chase
entity acting as the investment adviser to a Partnership based on
net gains in addition to the amount allocable to any such entity in
proportion to its capital contributions. A General Partner,
Participant or JPMorgan Chase entity that is registered as an
investment adviser under the Advisers Act may charge a carried
interest only if permitted by rule 205-3 under the Advisers Act. Any
carried interest paid to a General Partner, Participant or JPMorgan
Chase entity that is not registered under the Advisers Act also may
be paid only if permitted by rule 205-3 under the Advisers Act as if
such entity were registered under the Advisers Act.
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5. Interests in the Partnerships (``Interests'') will be offered
without registration in reliance on section 4(2) of the Securities Act
of 1933 (the ``Securities Act'') or Regulation D under the Securities
Act, and will be sold only (a) to Eligible Employees, (b) at the
request of Eligible Employees and the discretion of the General
Partner, to Qualified Participants of such Eligible Employees, or (c)
to JP Morgan Chase entities, each as defined below. Prior to
[[Page 23802]]
offering an Interest to an Eligible Employee, the General Partner must
reasonably believe that each Eligible Employee that is required to make
an investment decision with respect to whether or not to participate in
a Partnership, or to request that a related Qualified Participant be
permitted to participate, will be a sophisticated investor capable of
understanding and evaluating the risks of participating in the
Partnership without the benefit of regulatory safeguards. Participation
in a Partnership will be voluntary. The term ``Partners'' refers to all
partners or members of, or other investors in the Partnerships, and the
term ``Participants'' refers to all partners or members of, or other
investors in the Partnerships other than the General Partner.
6. Only those employees of JPMorgan Chase who qualify as ``Eligible
Employees'' will be able to participate in the Partnerships. In order
to qualify as an ``Eligible Employee,'' (a) an individual must (i) be a
current or former employee or current Consultant (as defined below) of
JPMorgan Chase and (b) except for certain individuals who manage the
day-to-day affairs of the Partnership in question (``Managing
Employees'') \5\ and a limited number of other employees of JPMorgan
Chase \6\ (collectively, ``Non-Accredited Investors''), meet the
standards of an ``accredited investor'' under in rule 501(a)(5) or
501(a)(6) of Regulation D, or (b) an entity must (i) be a current
Consultant of JPMorgan Chase \7\ and (ii) meet the standards of an
``accredited investor under rule 501(a) of Regulation D. A Partnership
may not have more than 35 Non-Accredited Investors. It is anticipated
that, at the sole discretion of the General Partner, Consultants of
JPMorgan Chase may be offered the opportunity to participate in the
Partnerships.\8\
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\5\ A Managing Employee may invest in a Partnership if he or she
meets the definition of ``knowledgeable employee'' in rule 3c-
5(a)(4) under the Act with the Partnership treated as though it were
a ``Covered Company'' for purposes of the rule.
\6\ Such employees must meet the sophistication requirements set
forth in rule 506(b)(2)(ii) of Regulation D under the Securities Act
and may be permitted to invest his or her own funds in the
Partnership if, at the time of the employee's investment in a
Partnership, he or she (a) has a graduate degree in business, law or
accounting, (b) has a minimum of five years of consulting,
investment banking or similar business experience, and (c) has had
reportable income from all sources of at least $100,000 in each of
the two most recent years and a reasonable expectation of income
from all sources of at least $140,000 in each year in which such
person will be committed to make investments in a Partnership. In
addition, such an employee will not be permitted to invest in any
year more than 10% of his or her income from all sources for the
immediately preceding year in the aggregate in such Partnership and
in all other Partnerships in which he or she has previously
invested.
\7\ A ``Consultant'' is a person or entity whom JPMorgan Chase
has engaged on retainer to provide services and professional
expertise on an ongoing basis as a regular consultant or as a
business or legal advisor to JPMorgan Chase and who shares a
community of interest with JPMorgan Chase and JPMorgan Chase
employees.
\8\ In order to participate in the Partnerships, Consultants
will be required to be sophisticated investors who qualify as
``accredited investors'' under rule 501(a)(5) or 501(a)(6) of
Regulation D (if a Consultant is an individual) or, if not an
individual, meet the standards of an ``accredited investor'' under
rule 501(a) of Regulation D. Qualified Participants (as defined
below) of Consultants may invest in a Partnership.
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7. In the discretion of the General Partner and at the request of
an Eligible Employee, Interests may be assigned by such Eligible
Employee, or sold directly by the Partnership, to a Qualified
Participant of an Eligible Employee. In order to qualify as a
``Qualified Participants'' an individual or entity must (a) be an
Eligible Family Member or Qualified Investment Vehicle (in each case as
defined below), respectively, of an Eligible Employee, and (b) if
purchasing an Interest from a Partnership, come within one of the
categories of an ``accredited Investor'' under rule 501(a) of
Regulation D. An ``Eligible Family Member'' is a spouse, parent, child,
spouse of child, brother, sister or grandchild of an Eligible Employee,
including step and adoptive relationships. A ``Qualified Investment
Vehicle'' is (a) a trust of which the trustee, grantor and/or
beneficiary is an Eligible Employee, (b) a partnership, corporation or
other entity controlled by an Eligible Employee, or (c) a trust or
other entity established solely for the benefit of an Eligible Employee
or Eligible Family Members of an Eligible Employee.\9\
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\9\ The inclusion of partnerships, corporations, or other
entities that are controlled by Eligible Employees who are
individuals in the definition of ``Qualified Investment Vehicle'' is
intended to enable these individuals to make investments in the
Partnerships through personal investment vehicles over which they
exercise investment discretion or other investment vehicles the
management or affairs of which they otherwise control. In the case
of a partnership, corporation, or other entity controlled by a
Consultant, individual participants will be limited to senior level
employees, members, or partners of the Consultant who are
responsible for the activities of the Consultant, will be required
to qualify as ``accredited investors'' under rule 501(a)(5) or
501(a)(6) of Regulation D and will have access to the directors and
officers of the General Partner.
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8. The terms of a Partnership will be fully disclosed to each
Eligible Employee, and, if applicable, to a Qualified Participant, at
the time they are invited to participate in the Partnership. Each
Eligible Employee and their Qualified Participants will be furnished
with offering materials, including a copy of the partnership agreement
or other organizational document (the ``Partnership Agreement'') for
the relevant Partnership. Each Partnership will send its Partners
annual financial statements within 120 days after the end of the fiscal
year of such Partnership, or as soon as practicable thereafter. The
annual financial statements of each Partnership will be audited by
independent certified public accountants,\10\ except under certain
circumstances in the case of Partnerships formed to make a single
Portfolio Investment.\11\ As soon as practicable after the end of each
tax year of a Partnership, a report will be transmitted to each Partner
showing such Partner's share of income, gains, losses, credits,
deductions, and other tax items for U.S. federal income tax purposes,
resulting from the Partnership's operations during that year.
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\10\ ``Audit'' will have the meaning defined in rule 1-02(d) of
Regulation S-X.
\11\ In such cases, audited financial statements will be
prepared for either the Partnership or the entity that is the
subject of the Portfolio Investment. Where a Partnership is formed
to make a single investment, that investment will not be an entity
relying on section 3(c)(7) of the Act.
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9. Interests in each Partnership will be non-transferable except
with the prior written consent of the General Partner, and, in any
event, no person or entity will be admitted into a Partnership as a
Participant unless such person is (a) an Eligible Employee, (b) a
Qualified Participant of an Eligible Employee, or (c) a JPMorgan Chase
entity. The Interests in the Partnerships will be sold without a sales
load.
10. An Eligible Employee's interest in a Partnership may be subject
to repurchase or cancellation if: (a) The Eligible Employee's
relationship with JPMorgan Chase is terminated for cause; (b) a former
Eligible Employee becomes employed by, or a partner in, consultant to
or otherwise joins any firm that the General Partner determines, in its
reasonable discretion, to be competitive with any business of JPMorgan
Chase; or (c) the Eligible Employee voluntarily resigns his or her
employment with JPMorgan Chase or otherwise has his or her employment
terminated for any other reason. Upon repurchase or cancellation, the
General Partner will pay to the Eligible Employee at least the lesser
of (a) the amount actually paid by the Eligible Employee to acquire the
Interest (less prior distributions, plus interest), and (b) the fair
market value of the Interest as determined at the time of repurchase or
cancellation by the
[[Page 23803]]
General Partner. The terms of any repurchase or cancellation will apply
equally to any Qualified Participant of an Eligible Employee.
11. It is possible that an investment program may be structured in
which a Partnership will co-invest in a portfolio company (or a pooled
investment vehicle) with JPMorgan Chase or an investment fund or
separate account, organized primarily for the benefit of investors who
are not affiliated with JPMorgan Chase, over which a JPMorgan Chase
entity exercises investment discretion or which is sponsored by a
JPMorgan Chase entity (a ``JPMorgan Chase Third Party Fund''). It is
also possible that an investment program may be structured in which a
Partnership will invest in an investment fund or pooled investment
vehicle for which entities or persons unaffiliated with JPMorgan Chase
are the sponsors or investment advisers (a ``Third Party Sponsored
Fund''). Any JPMorgan Chase entity's (other than a JPMorgan Chase Third
Party Fund's) co-investment in a Third Party Sponsored Fund will be
subject to the restrictions contained in condition 3 below. The General
Partner will not delegate management and investment discretion for the
Partnership to the sponsor of the Third Party Sponsored Fund.
12. If a General Partner elects to recommend that a Partnership
enter into any side-by-side investment with an unaffiliated entity
(including a Third Party Sponsored Fund), the General Partner will be
permitted to engage as a sub-investment adviser the unaffiliated entity
(an ``Unaffiliated Subadviser''), which will be responsible for the
management of such side-by-side investment. If an Unaffiliated
Subadviser is entitled to receive a carried interest, it may also act
as an additional General Partner of a Partnership solely in order to
address certain tax issues relating to such carried interest. In all
such instances, however, a JPMorgan Chase entity will also be a General
Partner of the Partnership and will have exclusive responsibility for
making the determinations required to be made by the General Partner
under the requested order. No Unaffiliated Subadviser will beneficially
own any outstanding securities of any Partnership.
13. Subject to the terms of the applicable Partnership Agreement, a
Partnership will be permitted to enter into transactions involving (a)
a JPMorgan Chase entity, (b) a portfolio company, (c) any Participant
or person or entity affiliated with a Participant, (d) a JPMorgan Chase
Third Party Fund, or (e) any person or entity who is not affiliated
with JPMorgan Chase and is a partner or other investor in a JPMorgan
Chase Third Party Fund or a Third Party Sponsored Fund (a ``Third Party
Investor'').
14. If the General Partner or a JPMorgan Chase entity makes a loan
to a Partnership, the loan would bear interest at a rate no less
favorable than the rate obtainable in an arm's length transaction. Any
indebtedness of a Partnership will be without recourse to the
Participants. A Partnership will not borrow from any person if the
borrowing would cause any person not named in section 2(a)(13) of the
Act to own securities of the Partnership (other than short term paper).
15. A Partnership will not acquire any security issued by a
registered investment company if, immediately after such acquisition,
the Partnership will own more than 3% of the outstanding voting stock
of the registered investment company.
Applicants' Legal Analysis
1. Section 6(b) of the Act provides, in part, that the Commission
will exempt employees' securities companies from the provisions of the
Act to the extent that the exemption is consistent with the protection
of investors. Section 6(b) provides that the Commission will consider,
in determining the provisions of the Act from which the company should
be exempt, the company's form of organization and capital structure,
the persons owning and controlling its securities, the price of the
company's securities and the amount of any sales load, how the
company's funds are invested, and the relationship between the company
and the issuers of the securities in which it invests. Section 2(a)(13)
defines an employees' securities company, in relevant part, as any
investment company all of whose securities (other than short-term
paper) are beneficially owned (a) by current or former employees, or
persons on retainer, of one or more affiliated employers, (b) by
immediate family members of such persons, or (c) by such employer or
employers together with any of the persons in (a) or (b).
2. Section 7 of the Act generally prohibits investment companies
that are not registered under section 8 of the Act from selling or
redeeming their securities. Section 6(e) of the Act provides that, in
connection with any order exempting an investment company from any
provision of section 7, certain provisions of the Act, as specified by
the Commission, will be applicable to the company and other persons
dealing with the company as though the company were registered under
the Act. Applicants request an order under sections 6(b) and 6(e) of
the Act exempting the Partnerships from all the provisions of the Act,
except section 9, and sections 36 through 53, and the rules and
regulations under the Act. With respect to sections 17 and 30 of the
Act, and the rules and regulations thereunder, and rule 38a-1 under the
Act, the exemption is limited as set forth in the application.
3. Section 17(a) generally prohibits any affiliated person of a
registered investment company, or any affiliated person of an
affiliated person, acting as principal, from knowingly selling or
purchasing any security or other property to or from the company.
Applicants request an exemption from section 17(a) of the Act to permit
a JPMorgan Chase entity or a Third Party Fund (or any ``affiliated
person,'' as defined in the Act, of any such entity or Third Party
Fund), acting as principal, to purchase or sell securities or other
property to or from any Partnership or any company controlled by such
Partnership. Applicants state that the relief is requested to permit
each Partnership the flexibility to deal with its Portfolio Investments
in the manner the General Partner deems most advantageous to all
Participants, including borrowing funds from a JPMorgan Chase entity,
restructuring its investments, having its investments redeemed,
tendering such Partnership's securities or negotiating options or
implementing exit strategies with respect to its investments.
Applicants state the requested exemption is sought to ensure that a
JPMorgan Chase Third Party Fund or a Third Party Investor will not
directly or indirectly become subject to a burden, restriction, or
other adverse effect by virtue of a Partnership's participation in an
investment opportunity.
4. Applicants believe an exemption from section 17(a) is consistent
with the policy of each Partnership and the protection of investors and
necessary to promote the basic purpose of such Partnership. Applicants
state that the Participants in each Partnership will be fully informed
of the possible extent of such Partnership's dealings with JPMorgan
Chase, and, as successful professionals employed in investment and
financial planning, will be able to understand and evaluate the
attendant risks. Applicants assert that the community of interest among
the Participants in each Partnership, on the one hand, and JPMorgan
Chase, on the other hand, is the best insurance against any risk of
abuse. Applicants, on behalf of the Partnerships, acknowledge that any
transactions otherwise subject to
[[Page 23804]]
section 17(a) of the Act, for which exemptive relief has not been
requested, would require approval of the Commission. Applicants further
acknowledge that the requested relief will not extend to any
transactions between a Partnership and an Unaffiliated Subadviser or an
affiliated person of the Unaffiliated Subadviser, or between a
Partnership and any person who is not an employee, officer or director
of JPMorgan Chase or is an entity outside of JPMorgan Chase and is an
affiliated person of the Partnership as defined in Section 2(a)(3)(E)
of the Act (``Advisory Person'') or any affiliated person of such
person.
5. Section 17(d) of the Act and rule 17d-1 under the Act prohibit
any affiliated person of a registered investment company, or any
affiliated person of such person, acting as principal, from
participating in any joint arrangement with the company unless
authorized by the Commission. Applicants request relief to permit
affiliated persons of each Partnership, or affiliated persons of any of
these persons, to participate in, or effect any transaction in
connection with, any joint enterprise or other joint arrangement or
profit-sharing plan in which a Partnership or a company controlled by
the Partnership is a participant. The exemption requested would permit,
among other things, co-investments by each Partnership and by
individual members or employees, officers, directors, or Consultants of
JPMorgan Chase making their own individual investment decisions apart
from JPMorgan Chase. Applicants acknowledge that the requested relief
will not extend to any transaction in which an Unaffiliated Subadviser
or an Advisory Person or an affiliated person of either has an
interest.
6. Applicants assert that compliance with section 17(d) would cause
a Partnership to forego investment opportunities simply because a
Participant in such Partnership or other affiliated person of such
Partnership (or any affiliate of such a person) also had, or
contemplated making, a similar investment. Applicants further assert
that attractive investment opportunities of the types considered by a
Partnership often require each participant in the transaction to make
available funds in an amount that may be substantially greater than
those that may be available to such Partnership alone. Applicants
contend that, as a result, the only way in which a Partnership may be
able to participate in such opportunities may be to co-invest with
other persons, including its affiliates. Applicants assert that the
flexibility to structure co-investments and joint investments will not
involve abuses of the type section 17(d) and rule 17d-1 were designed
to prevent.
7. Applicants state that side-by-side investments held by a
JPMorgan Chase Third Party Fund, or by a JPMorgan Chase entity in a
transaction in which the JPMorgan Chase investment was made pursuant to
a contractual obligation to a JPMorgan Chase Third Party Fund, will not
be subject to condition 3 below. All other side-by-side investments
held by JPMorgan Chase entities will be subject to condition 3 below.
Applicants assert that in structuring a JPMorgan Chase Third Party
Fund, it is common for the unaffiliated investors of such fund to
require that JPMorgan Chase invest its own capital in Third Party Fund
investments, either through the Third Party Fund or on a side-by-side
basis, and that such JPMorgan Chase investments be subject to
substantially the same terms as those applicable to the Third Party
Fund's investments. Applicants state that it is important that the
interests of the JPMorgan Chase Third Party Fund take priority over the
interests of the Partnerships, and that the activities of the JPMorgan
Chase Third Party Fund not be burdened or otherwise affected by
activities of the Partnerships. Applicants also state that the
relationship of a Partnership to a JPMorgan Chase Third Party Fund is
fundamentally different from such Partnership's relationship to
JPMorgan Chase. Applicants contend that the focus of, and the rationale
for, the protections contained in the application are to protect the
Partnerships from any overreaching by JPMorgan Chase in the employer/
employee context, whereas the same concerns are not present with
respect to the Partnerships vis-[agrave]-vis the investors of a
JPMorgan Chase Third Party Fund.
8. Section 17(e) of the Act and rule 17e-1 under the Act limit the
compensation an affiliated person may receive when acting as agent or
broker for a registered investment company. Applicants request an
exemption from section 17(e) to permit a JPMorgan Chase entity
(including the General Partner), acting as an agent or broker, to
receive placement fees, advisory fees, or other compensation from a
Partnership in connection with the purchase or sale by the Partnership
of securities, provided that such placement fees, advisory fees, or
other compensation are deemed ``usual and customary.'' Applicants state
that for purposes of the application, fees or other compensation that
are charged or received by a JPMorgan Chase entity will be deemed
``usual and customary'' only if (a) the Partnership is purchasing or
selling securities with other unaffiliated third parties, including
JPMorgan Chase Third Party Funds or Third Party Investors who are also
similarly purchasing or selling securities, (b) the fees or
compensation being charged to the Partnership are also being charged to
the unaffiliated third parties, including JPMorgan Chase Third Party
Funds or Third Party Investors, and (c) the amount of securities being
purchased or sold by the Partnership does not exceed 50% of the total
amount of securities being purchased or sold by the Partnership and the
unaffiliated third parties, including JPMorgan Chase Third Party Funds
or Third Party Investors. Applicants assert that, because JPMorgan
Chase does not wish to appear to be favoring the Partnerships,
compliance with section 17(e) would prevent a Partnership from
participating in transactions where the Partnership is being charged
lower fees than unaffiliated third parties. Applicants assert that the
fees or other compensation paid by a Partnership to a JPMorgan Chase
entity will be the same as those negotiated at arm's length with
unaffiliated third parties.
9. Rule 17e-1(b) under the Act requires that a majority of
directors who are not ``interested persons'' (as defined in section
2(a)(19) of the Act) take actions and make approvals regarding
commissions, fees, or other remuneration. Rule 17e-1(c) under the Act
requires each investment company relying on the rule to satisfy the
fund governance standards defined in rule 0-1(a)(7) under the Act.
Applicants request an exemption from rule 17e-1 to the extent necessary
to permit each Partnership to comply with the rule without having a
majority of the directors of the General Partner who are not interested
persons take actions and make approvals as set forth in paragraph (b)
of the rule, and without having to satisfy the standards set forth in
paragraph (c) of the rule. Applicants state that because all the
directors of the General Partner will be affiliated persons, without
the relief requested, a Partnership could not comply with rule 17e-1.
Applicants state that each Partnership will comply with rule 17e-1 by
having a majority of the directors of the General Partner take actions
and make approvals as set forth in the rule. Applicants state that each
Partnership will otherwise comply with rule 17e-1.
10. Section 17(f) of the Act designates the entities that may act
as investment company custodians, and rule 17f-1 under the Act imposes
certain requirements when the custodian is a
[[Page 23805]]
member of a national securities exchange. Applicants request an
exemption from section 17(f) and rule 17f-1 to permit a JPMorgan Chase
entity to act as custodian without a written contract. Applicants also
request an exemption from the rule 17f-1(b)(4) requirement that an
independent accountant periodically verify the assets held by the
custodian. Applicants state that, given the community of interest of
all the parties involved and the existing requirement for an
independent audit, compliance with the rule's requirement would be
unnecessary. Each Partnership will otherwise comply with the provisions
of rule 17f-1.
11. Rule 17f-2 under the Act specifies requirements that must be
satisfied for a registered management investment company to act as
custodian of its own investments. Applicants request an exemption from
rule 17f-2 to permit the following exceptions from the requirements of
rule 17f-2: (a) A Partnership's investments may be kept in the locked
files of the General Partner (or a JPMorgan Chase entity) for purposes
of paragraph (b) of the rule; (b) for purposes of paragraph (d) of the
rule, (i) employees of the General Partner (or a JPMorgan Chase entity)
will be deemed to be employees of the Partnerships, (ii) officers or
managers of the General Partner of a Partnership (or a JPMorgan Chase
entity) will be deemed to be officers of the Partnership, and (iii) the
General Partner of a Partnership (or a JPMorgan Chase entity) or its
board of directors will be deemed to be the board of directors of the
Partnership; and (c) in place of the verification procedure under
paragraph (f) of the rule, verification will be effected quarterly by
two employees of the General Partner (or a JPMorgan Chase entity) each
of whom shall have sufficient knowledge, sophistication and experience
in business matters to perform such examination. Applicants expect that
some of the Partnerships' investments may be evidenced only by
partnership agreements, participation agreements or similar documents,
rather than by negotiable certificates that could be misappropriated.
Applicants assert that these instruments are most suitably kept in the
files of the General Partner (or a JPMorgan Chase entity), where they
can be referred to as necessary. Applicants will comply with all other
provisions of rule 17f-2.
12. Section 17(g) of the Act and rule 17g-1 under the Act generally
require the bonding of officers and employees of a registered
investment company who have access to its securities or funds. Rule
17g-1 requires that a majority of directors who are not interested
persons take certain actions and give certain approvals relating to
fidelity bonding. The rule also requires that the board of directors of
an investment company relying on the rule satisfy the fund governance
standards, as defined in rule 0-1(a)(7). Applicants request relief to
permit the General Partner, who may be deemed to be an interested
person, to take actions and make approvals as set forth in the rule.
Applicants state that, because the General Partner will be an
interested person of the Partnerships, the Partnerships could not
comply with rule 17g-1 without the requested relief. Applicants also
request an exemption from the requirements of rule 17g-l(g) and (h)
relating to the filing of copies of fidelity bonds and related
information with the Commission and the provision of notices to the
board of directors and an exemption from the requirements of rule 17g-
1(j)(3) relating to compliance with the fund governance standards. The
Partnerships will comply with all other requirements of rule 17g-1.
13. Section 17(j) of the Act and paragraph (b) of rule 17j-1 under
the Act make it unlawful for certain enumerated persons to engage in
fraudulent or deceptive practices in connection with the purchase or
sale of a security held or to be acquired by a registered investment
company. Rule 17j-1 also requires that every registered investment
company adopt a written code of ethics and that every access person of
a registered investment company report personal securities
transactions. Applicants request an exemption from the provisions of
rule 17j-1, except for the anti-fraud provisions of paragraph (b),
because they are burdensome and unnecessary as applied to the
Partnerships. The relief requested will extend only to entities within
JPMorgan Chase and is not requested with respect to any Unaffiliated
Subadviser or Advisory Person.
14. Applicants request an exemption from the requirements in
sections 30(a), 30(b), and 30(e) of the Act, and the rules under those
sections, that registered investment companies prepare and file with
the Commission and mail to their shareholders certain periodic reports
and financial statements. Applicants contend that the forms prescribed
by the Commission for periodic reports have little relevance to a
Partnership and would entail administrative and legal costs that
outweigh any benefit to the Participants in such Partnership.
Applicants request relief to the extent necessary to permit each
Partnership to report annually to its Participants. Applicants also
request relief from the requirements of section 30(h), to the extent
necessary to exempt the General Partner of each Partnership, directors
and officers of the General Partner and any other persons who may be
deemed members of an advisory board or investment adviser (and
affiliated persons thereof) of such Partnership from filing Forms 3, 4
and 5 under Section 16 of the Exchange Act with respect to their
ownership of Interests in such Partnership. Applicants believe that,
because there will be no trading market and the transfers of Interests
will be severely restricted, these filings are unnecessary for the
protection of investors and burdensome to those required to make them.
15. Rule 38a-1 requires investment companies to adopt, implement
and periodically review written policies reasonably designed to prevent
violation of the federal securities laws and to appoint a chief
compliance officer. Applicants state that each Partnership will comply
with rule 38a-1(a), (c) and (d), except that (a) since the Partnership
does not have a board of directors, the board of directors (or similar
body) of the General Partner will fulfill the responsibilities assigned
to the Partnership's board of directors under the rule, (b) since the
board of directors of the General Partner does not have any
disinterested members, approval by a majority of the disinterested
board members required by rule 38a-1 will not be obtained, and (c)
since the board of directors of the General Partner does not have any
disinterested directors, the Partnerships will comply with the
requirement in rule 38a-1(a)(4)(iv) that the chief compliance officer
meet with the independent directors by having the chief compliance
officer meet with the board of directors of the General Partner as
constituted.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
1. Each proposed transaction otherwise prohibited by section 17(a)
or section 17(d) and rule 17d-1 to which a Partnership is a party (the
``Section 17 Transactions'') will be effected only if the General
Partner determines that:
(a) The terms of the Section 17 Transaction, including the
consideration to be paid or received, are fair and reasonable to the
Participants of the participating Partnership and do not involve
overreaching of such Partnership or its Participants on the part of any
person concerned, and
(b) the Section 17 Transaction is consistent with the interests of
the Participants of the participating Partnership, such Partnership's
[[Page 23806]]
organizational documents and such Partnership's reports to its
Participants.
In addition, the General Partner will record and will preserve a
description of all Section 17 Transactions, the General Partner's
findings and the information or materials upon which the General
Partner's findings are based and the basis for the findings. All such
records will be maintained for the life of the Partnership and at least
six years thereafter, and will be subject to examination by the
Commission and its staff. Each Partnership will preserve the accounts,
books and other documents required to be maintained in an easily
accessible place for the first two years.
2. The General Partner will adopt, and periodically review and
update, procedures designed to ensure that reasonable inquiry is made,
prior to the consummation of any Section 17 Transaction, with respect
to the possible involvement in the transaction of any affiliated person
or promoter of or principal underwriter for such Partnership, or any
affiliated person of such a person, promoter or principal underwriter.
3. The General Partner will not make on behalf of a Partnership any
investment in which a Co-Investor (as defined below) has acquired or
proposes to acquire the same class of securities of the same issuer,
where the investment involves a joint enterprise or other joint
arrangement within the meaning of rule 17d-1 in which such Partnership
and the Co-Investor are participants, unless any such Co-Investor,
prior to disposing of all or part of its investment, (a) gives such
General Partner sufficient, but not less than one day's, notice of its
intent to dispose of its investment, and (b) refrains from disposing of
its investment unless the participating Partnership holding such
investment has the opportunity to dispose of its investment prior to or
concurrently with, on the same terms as, and on a pro rata basis with,
the Co-Investor. The term ``Co-Investor'' with respect to any
Partnership means any person who is: (a) An ``affiliated person'' (as
defined in section 2(a)(3) of the Act) of such Partnership (other than
a JPMorgan Chase Third Party Fund); (b) a JPMorgan Chase entity; (c) an
officer, director or partner of a JPMorgan Chase entity; or (d) an
entity (other than a JPMorgan Chase Third Party Fund) in which the
General Partner acts as a general partner or has a similar capacity to
control the sale or other disposition of the entity's securities. The
restrictions contained in this condition, however, shall not be deemed
to limit or prevent the disposition of an investment by a Co-Investor:
(a) To its direct or indirect wholly-owned subsidiary, to any company
(a ``Parent'') of which such Co-Investor is a direct or indirect
wholly-owned subsidiary, or to a direct or indirect wholly-owned
subsidiary of its Parent; (b) to immediate family members of such Co-
Investor, including step and adoptive relationships, or to a trust or
other investment vehicle established for any such immediate family
member; or (c) when the investment is comprised of securities that are
(i) listed on any exchange registered as a national securities exchange
under section 6 of the 1934 Act; (ii) NMS stocks pursuant to section
11A(a)(2) of the 1934 Act and rule 600(b) of Regulation NMS thereunder;
(iii) government securities as defined in section 2(a)(16) of the Act
or other securities that meet the definition of ``Eligible Security''
in rule 2a-7 under the Act; or (iv) listed on or traded on any foreign
securities exchange or board of trade that satisfies regulatory
requirements under the law of the jurisdiction in which such foreign
securities exchange or board of trade is organized similar to those
that apply to a national securities exchange or a national market
system for securities.
4. Each Partnership and its General Partner will maintain and
preserve, for the life of such Partnership and at least six years
thereafter, such accounts, books, and other documents as constitute the
record forming the basis for the audited financial statements that are
to be provided to the Participants in such Partnership, and each annual
report of such Partnership required to be sent to such Participants,
and agree that all such records will be subject to examination by the
Commission and its staff. Each Partnership will preserve the accounts,
books and other documents required to be maintained in an easily
accessible place for the first two years.
5. The General Partner of each Partnership will send to each
Participant in that Partnership, at any time during the fiscal year
then ended, Partnership financial statements audited by such
Partnership's independent accountants, except in the case of a
Partnership formed to make a single Portfolio Investment. In such
cases, the partnership may send unaudited financial statements, but
each Participant will receive financial statements of the single
Portfolio Investment audited by such entity's independent accountants.
At the end of each fiscal year, the General Partner will make a
valuation or have a valuation made of all of the assets of the
Partnership as of such fiscal year end in a manner consistent with
customary practice with respect to the valuation of assets of the kind
held by the Partnership. In addition, within 120 days after the end of
each fiscal year of each Partnership or as soon as practicable
thereafter, the General Partner will send a report to each person who
was a Participant at any time during the fiscal year then ended,
setting forth such tax information as shall be necessary for the
preparation by the Participant of his, her or its U.S. federal and
state income tax returns and a report of the investment activities of
the Partnership during that fiscal year.
6. If a Partnership makes purchases or sales from or to an entity
affiliated with the Partnership by reason of an officer, director or
employee of JPMorgan Chase (a) serving as an officer, director, general
partner or investment adviser of the entity, or (b) having a 5% or more
investment in the entity, such individual will not participate in the
Partnership's determination of whether or not to effect the purchase or
sale.
For the Commission, by the Division of Investment Management,
under delegated authority.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2013-09344 Filed 4-19-13; 8:45 am]
BILLING CODE 8011-01-P