Goldman Sachs Trust II, et al.; Notice of Application, 26407-26410 [2013-10606]
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Federal Register / Vol. 78, No. 87 / Monday, May 6, 2013 / Notices
SECURITIES AND EXCHANGE
COMMISSION
Any such communication or request
may be submitted by any of the
following methods:
[Release No. 34–69477; File No. 81–939]
Electronic Comments
Notice of an Application of W2007
Grace Acquisition I, Inc. Under Section
12(h) of the Securities Exchange Act of
1934
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/other.shtml); or
• Send an email to rulecomments@sec.gov. Please include File
Number 81–939 on the subject line.
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April 30, 2013.
The Securities and Exchange
Commission gives notice that W2007
Grace Acquisition I, Inc. (‘‘W2007
Grace’’) has filed an application under
Section 12(h) of the Securities Exchange
Act of 1934. W2007 Grace asks the
Commission to issue an order
conditionally exempting the company
from the requirement to file reports
under Section 15(d) of the Exchange
Act. In its application, W2007 Grace
asserts that exemptive relief would be
consistent with the standards
articulated in Section 12(h) because: (1)
As of January 1, 2013, W2007 Grace had
fewer than 300 holders of record of each
class of its securities after excluding
shares that the company believes are
beneficially owned by a single
beneficial owner through 300 trust
entities formed by such owner solely for
the purpose of attempting to cause the
termination of the suspension of the
company’s reporting obligations under
Section 15(d) of the Exchange Act; (2)
there is limited trading activity in, and
an absence of any regular market for,
W2007 Grace’s securities; (3) the
company is not directly engaged in
active operations as it is a real estate
investment firm with a small economic
interests in 130 hotels and no
employees; and (4) to impose the
reporting burdens of Section 15(d) of the
Exchange Act on the company under the
current circumstances would
contravene the intent of Section 15(d)
and Rule 12g5–1 under the Exchange
Act.
For a detailed statement of the
information presented, all persons are
referred to W2007 Grace’s application,
which is available on the Commission’s
Internet Web site at https://www.sec.gov/
rules/other.shtml and for Web site
viewing and printing in the
Commission’s Public Reference Room,
Station Place, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of 10
a.m. and 3 p.m.
The Commission also gives notice that
any interested person may submit to the
Commission in writing its views on any
substantial facts bearing on the
application or the desirability of a
hearing thereon.
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Paper Comments
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
Station Place, 100 F Street NE.,
Washington, DC 20549–1090.
All submissions should refer to File
Number 81–939. This file number
should be included on the subject line
if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/other.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the application filed
with the Commission, and all written
communications relating to the
application between the Commission
and any person, other than those that
may be withheld from the public in
accordance with the provisions of 5
U.S.C. 552, will be available for Web
site viewing and printing in the
Commission’s Public Reference Room,
Station Place, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of 10
a.m. and 3 p.m. All comments received
will be posted without change; the
Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should be submitted on or before June
5, 2013.
Persons who request a hearing or
advice as to whether a hearing is
ordered will receive any notices and
orders issued in this matter, including
the date of the hearing (if ordered) and
any postponements thereof. At any time
after said date, the Commission may
issue an order granting the application
upon request or upon the Commission’s
own motion.
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26407
For the Commission, by the Division of
Corporation Finance, pursuant to delegated
authority.
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2013–10564 Filed 5–3–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
30496; 812–14078]
Goldman Sachs Trust II, et al.; Notice
of Application
April 29, 2013.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application under
section 6(c) of the Investment Company
Act of 1940 (‘‘Act’’) for an exemption
from section 15(a) of the Act and rule
18f–2 under the Act, as well as from
certain disclosure requirements.
AGENCY:
Summary of Application:
Applicants request an order that would
permit them to enter into and materially
amend subadvisory agreements without
shareholder approval and would grant
relief from certain disclosure
requirements.
APPLICANTS: Goldman Sachs Trust II
(the ‘‘Trust’’), Goldman Sachs Asset
Management L.P. (‘‘GSAM’’) and
Goldman Sachs Asset Management
International (‘‘GSAMI’’, each of GSAM
and GSAMI an ‘‘Adviser’’ and
collectively, ‘‘Advisers,’’ and together
with the Trust, ‘‘Applicants’’).
DATES: Filing Dates: The application
was filed September 21, 2012, and
amended on March 8, 2013.
HEARING OR NOTIFICATION OF HEARING:
An order granting the application will
be issued unless the Commission orders
a hearing. Interested persons may
request a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on May 28, 2013 and
should be accompanied by proof of
service on the applicants, in the form of
an affidavit or, for lawyers, a certificate
of service. Hearing requests should state
the nature of the writer’s interest, the
reason for the request, and the issues
contested. Persons who wish to be
notified of a hearing may request
notification by writing to the
Commission’s Secretary.
ADDRESSES: Elizabeth M. Murphy,
Secretary, U.S. Securities and Exchange
Commission, 100 F Street NE.,
SUMMARY:
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Federal Register / Vol. 78, No. 87 / Monday, May 6, 2013 / Notices
Washington, DC 20549–1090.
Applicants: Caroline Kraus, Goldman
Sachs & Co., 200 West Street, 15th
Floor, New York, NY 10282.
FOR FURTHER INFORMATION CONTACT:
Barbara T. Heussler, Senior Counsel, at
(202) 551–6990, or Jennifer L. Sawin,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
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Applicants’ Representations
1. The Trust is organized as a
Delaware statutory trust and has
registered as an open-end management
investment company under the Act that
will offer one or more series of shares
(each a ‘‘Series’’). The Trust has filed a
registration statement on Form N–1A to
register the offering of shares of
Goldman Sachs Multi-Manager
Alternatives Fund, a series of the Trust.1
Each Subadvised Fund may offer shares
with its own distinct investment
objectives, policies and restrictions.
2. GSAM, a Delaware limited
partnership registered with the
Commission as an investment adviser
under the Investment Advisers Act of
1940 (‘‘Advisers Act’’), is expected to
serve as investment adviser to certain
Series, in each case pursuant to an
investment advisory agreement with the
Trust on behalf of the Series (each a
‘‘GSAM Investment Advisory
Agreement’’). GSAMI, a limited
partnership organized under the laws of
1 Applicants request that the relief sought herein
apply to the Applicants, as well as to any future
Series of the Trust and to any other existing or
future registered open-end investment company or
series thereof that: (a) is advised by either GSAM,
GSAMI or their successors (the foregoing advisers
being included in the term ‘‘Adviser,’’ and any such
series or investment company, including the Trust
and its Series, a ‘‘Fund’’); (b) uses the manager of
managers structure described in this Application
(‘‘Manager of Managers Structure’’); and (c)
complies with the terms and conditions of this
Application (the ‘‘Subadvised Funds,’’ and each a
‘‘Subadvised Fund’’). The only Trust that currently
intends to rely on the requested order is named as
an Applicant. For purposes of the requested order,
‘‘successor’’ is limited to an entity that results from
a reorganization into another jurisdiction or a
change in the type of business organization. If the
name of any Subadvised Fund contains the name
of a Subadviser, the name of the Adviser that serves
as the primary adviser to that Subadvised Fund or
a trademark or trade name that is owned by or
publicly used to identify that Adviser will precede
the name of the Subadviser.
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the United Kingdom and registered with
the Commission as an investment
adviser under the Advisers Act, may
also serve as investment adviser to
certain Series, in each case pursuant to
an investment advisory agreement with
the Trust on behalf of the Series (each
a ‘‘GSAMI Investment Advisory
Agreement’’).2 The GSAM Investment
Advisory Agreements and the GSAMI
Investment Advisory Agreements are
together referred to as the ‘‘Investment
Advisory Agreements’’. Each Investment
Advisory Agreement will be approved
by the board of trustees of the Trust (the
‘‘Board’’), including a majority of the
trustees who are not ‘‘interested
persons,’’ as defined in section 2(a)(19)
of the Act, of the Trust or the Adviser
(‘‘Independent Trustees’’) and by the
shareholders of the relevant Subadvised
Fund in the manner required by
sections 15(a) and 15(c) of the Act and
rule 18f–2 under the Act.3 Any future
Adviser also will be registered with the
Commission as an investment adviser
under the Advisers Act and will enter
into investment advisory agreements
with or on behalf of future Subadvised
Funds, and such future agreements shall
be included in the term ‘‘Investment
Advisory Agreements.’’
3. Under the terms of each Investment
Advisory Agreement, the Adviser to a
Subadvised Fund, subject to the
oversight of the applicable Board, shall
furnish a continuous investment
program for the Subadvised Fund. The
Adviser shall periodically review each
Subadvised Fund’s investment policies
and strategies and based on the need of
a particular Subadvised Fund may
recommend changes to the investment
policies and strategies of the Subadvised
Fund for consideration by its Board. For
its services to each Subadvised Fund,
the Adviser shall receive an investment
advisory fee from that Subadvised Fund
as specified in the applicable
Investment Advisory Agreement based
on each Subadvised Fund’s average
daily total or net assets. The terms of the
Investment Advisory Agreements also
permit the applicable Adviser, subject to
the approval of the relevant Board,
including a majority of the Independent
Trustees, and the shareholders of the
applicable Subadvised Fund (if required
by applicable law), to delegate portfolio
management responsibilities of all or a
portion of the assets of the Subadvised
Fund to one or more subadvisers
(‘‘Subadvisers’’). Each Subadviser will
be an investment adviser as defined in
2 GSAM and GSAMI are wholly-owned
subsidiaries of the Goldman Sachs Group, Inc.
3 The term ‘‘Board’’ also includes the board of
trustees or directors of a future Subadvised Fund.
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section 2(a)(20) of the Act, and either
registered with the Commission as an
investment adviser under the Advisers
Act or not subject to such registration.
The Adviser shall have overall
responsibility for the management and
investment of the assets of each
Subadvised Fund and, with respect to
each Subadvised Fund, the Adviser’s
responsibilities shall include, for
example, recommending the removal or
replacement of Subadvisers, and
determining the portion of that
Subadvised Fund’s assets to be managed
by any given Subadviser and
reallocating those assets as necessary
from time to time. The Adviser shall
evaluate, select and recommend
Subadvisers to manage the assets of
Subadvised Fund, and shall monitor
and review the Subadviser and its
performance and its compliance with
that Subadvised Fund’s investment
policies and restrictions. For services
provided under each Subadvisory
Agreement, it is currently intended that
the applicable Subadviser will receive
from the applicable Adviser a fee based
on a percentage of the Subadvised
Fund’s average daily total or net assets
(‘‘Subadvisory fees’’). All Subadvisers
are expected to be compensated by the
applicable Adviser out of the advisory
fees the Adviser receives pursuant to the
relevant Investment Advisory
Agreement. As a matter of convenience,
the applicable Adviser may request that
(a) amounts payable to a Subadviser by
the Adviser be transmitted directly to
the Subadviser by the Subadvised Fund
and (b) that such amount be deducted
from the amounts payable by the
Subadvised Fund to the Adviser.
Subadvised Funds may directly pay
advisory fees to Subadvisers in the
future, although any amendment to a
Subadvisory Agreement that would
increase the total management and
advisory fees payable by a Subadvised
Fund would require shareholder
approval.
4. Applicants request an order to
permit the Adviser, subject to Board
approval, to select certain Subadvisers
to manage all or a portion of the assets
of a Subadvised Fund pursuant to a
Sub-Advisory Agreement and materially
amend Sub-Advisory Agreements
without obtaining shareholder approval.
The requested relief will not extend to
any Subadviser that is an affiliated
person, as defined in section 2(a)(3) of
the Act, of the Trust, a Subadvised Fund
or the Adviser, other than by reason of
serving as a Subadviser to a Subadvised
Fund (‘‘Affiliated Subadviser’’).
5. Applicants also request an order
exempting the Subadvised Funds from
certain disclosure provisions described
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below that may require the Applicants
to disclose fees paid to each Subadviser
by the Adviser or a Subadvised Fund.
Applicants seek an order to permit each
Subadvised Fund to disclose (as a dollar
amount and a percentage of a
Subadvised Fund’s total or net assets)
only: (a) The aggregate fees paid to the
Subadvised Fund’s Adviser and any
Affiliated Subadvisers; and (b) the
aggregate fees paid to Subadvisers other
than Affiliated Subadvisers
(collectively, the ‘‘Aggregate Fee
Disclosure’’). A Subadvised Fund that
employs an Affiliated Subadviser will
provide separate disclosure of any fees
paid to the Affiliated Subadviser.
Applicants’ Legal Analysis
1. Section 15(a) of the Act provides,
in relevant part, that it is unlawful for
any person to act as an investment
adviser to a registered investment
company except pursuant to a written
contract that has been approved by the
vote of a majority of the company’s
outstanding voting securities. Rule 18f–
2 under the Act provides that each
series or class of stock in a series
investment company affected by a
matter must approve that matter if the
Act requires shareholder approval.
2. Form N–1A is the registration
statement used by open-end investment
companies. Item 19(a)(3) of Form N–1A
requires disclosure of the method and
amount of the investment adviser’s
compensation.
3. Rule 20a–1 under the Act requires
proxies solicited with respect to an
investment company to comply with
Schedule 14A under the Securities
Exchange Act of 1934 (‘‘Exchange Act’’).
Items 22(c)(1)(ii), 22(c)(1)(iii), 22(c)(8)
and 22(c)(9) of Schedule 14A, taken
together, require a proxy statement for a
shareholder meeting at which the
advisory contract will be voted upon to
include the ‘‘rate of compensation of the
investment adviser,’’ the ‘‘aggregate
amount of the investment adviser’s
fees,’’ a description of the ‘‘terms of the
contract to be acted upon,’’ and, if a
change in the advisory fee is proposed,
the existing and proposed fees and the
difference between the two fees.
4. Regulation S–X sets forth the
requirements for financial statements
required to be included as part of a
registered investment company’s
registration statement and shareholder
reports filed with the Commission.
Sections 6–07(2)(a), (b) and (c) of
Regulation S–X require a registered
investment company to include in its
financial statement information about
the investment advisory fees.
5. Section 6(c) of the Act provides that
the Commission may exempt any
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person, security, or transaction or any
class or classes of persons, securities, or
transactions from any provisions of the
Act, or from any rule thereunder, if such
exemption is necessary or appropriate
in the public interest and consistent
with the protection of investors and the
purposes fairly intended by the policy
and provisions of the Act. Applicants
state that the requested relief meets this
standard for the reasons discussed
below.
6. Applicants assert that the
shareholders expect the Adviser, subject
to the review and approval of the Board,
to select the Subadvisers who are best
suited to achieve the Subadvised Fund’s
investment objective. Applicants assert
that, from the perspective of the
shareholder, the role of the Subadviser
is substantially equivalent to the role of
the individual portfolio managers
employed by an investment adviser to a
traditional investment company.
Applicants state that requiring
shareholder approval of each
Subadvisory Agreement would impose
unnecessary delays and expenses on the
Subadvised Funds and may preclude
the Subadvised Funds from acting
promptly when the Adviser and Board
consider it appropriate to hire
Subadvisers or amend Subadvisory
Agreements. Applicants note that the
Investment Advisory Agreement for
each Subadvised Fund and Subadvisory
Agreements with Affiliated Subadvisers
(if any) will continue to be subject to the
shareholder approval requirements of
section 15(a) of the Act and rule 18f–2
under the Act.
7. If new Subadvisers are hired, the
Subadvised Funds will inform
shareholders of the hiring of a new
Subadviser pursuant to the following
procedures (‘‘Modified Notice and
Access Procedures’’): (a) Within 90 days
after a new Subadviser is hired for any
Subadvised Fund, that Subadvised
Fund will send its shareholders either a
Multi-manager Notice or a Multimanager Notice and Multi-manager
Information Statement;4 and (b) the
4 A ‘‘Multi-manager Notice’’ will be modeled on
a Notice of Internet Availability as defined in rule
14a–16 under the Exchange Act, and specifically
will, among other things: (a) Summarize the
relevant information regarding the new Subadviser;
(b) inform shareholders that the Multi-manager
Information Statement is available on a Web site;
(c) provide the Web site address; (d) state the time
period during which the Multi-manager Information
Statement will remain available on that Web site;
(e) provide instructions for accessing and printing
the Multi-manager Information Statement; and (f)
instruct the shareholder that a paper or email copy
of the Multi-manager Information Statement may be
obtained, without charge, by contacting the
Subadvised Funds.
A ‘‘Multi-manager Information Statement’’ will
meet the requirements of Regulation 14C, Schedule
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26409
Subadvised Fund will make the Multimanager Information Statement
available on the Web site identified in
the Multi-manager Notice no later than
when the Multi-manager Notice (or
Multi-manager Notice and Multimanager Information Statement) is first
sent to shareholders, and will maintain
it on that Web site for at least 90 days.
In the circumstances described in this
Application, a proxy solicitation to
approve the appointment of new
Subadvisers provides no more
meaningful information to shareholders
than the proposed Multi-manager
Information Statement. Moreover, as
indicated above, the applicable Board
would comply with the requirements of
Sections 15(a) and 15(c) of the Act
before entering into or amending SubAdvisory Agreements.
8. Applicants assert that the requested
disclosure relief would benefit
shareholders of the Subadvised Funds
because it would improve each
Adviser’s ability to negotiate the fees
paid to Subadvisers. Applicants state
that if the Adviser is not required to
disclose the Subadvisers’ fees to the
public, the Adviser may be able to
negotiate rates that are below a
Subadviser’s ‘‘posted’’ amounts.
Applicants submit that the requested
relief will also encourage Subadvisers to
negotiate lower subadvisory fees with
the Adviser(s) if the lower fees are not
required to be made public.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
1. Before a Subadvised Fund may rely
on the order requested herein, the
operation of the Subadvised Fund in the
manner described in the Application
will be approved by a majority of the
Subadvised Fund’s outstanding voting
securities as defined in the Act or, in the
case of a Subadvised Fund whose public
shareholders purchase shares on the
basis of a prospectus containing the
disclosure contemplated by condition 2
below, by the initial shareholder before
such Subadvised Fund’s shares are
offered to the public.
2. The prospectus for each
Subadvised Fund will disclose the
existence, substance, and effect of any
order granted pursuant to the
Application. In addition, each
Subadvised Fund will hold itself out to
the public as employing the Manager of
14C and Item 22 of Schedule 14A under the
Exchange Act for an information statement, except
as modified by the requested order to permit
Aggregate Fee Disclosure. Multi-manager
Information Statements will be filed electronically
with the Commission via the EDGAR system.
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Managers Structure. The prospectus will
prominently disclose that the Adviser
has the ultimate responsibility, subject
to oversight by the Board, to oversee the
Subadvisers and recommend their
hiring, termination, and replacement.
3. Subadvised Funds will inform
shareholders of the hiring of a new
Subadviser within 90 days after the
hiring of the new Subadviser pursuant
to the Modified Notice and Access
Procedures.
4. An Adviser will not enter into a
Subadvisory Agreement with any
Affiliated Subadviser unless such
agreement, including the compensation
to be paid thereunder, has been
approved by the shareholders of the
applicable Subadvised Fund.
5. At all times, at least a majority of
the Board will be Independent Trustees,
and the nomination of new or additional
Independent Trustees will be placed
within the discretion of the thenexisting Independent Trustees.
6. Independent legal counsel, as
defined in rule 0–1(a)(6) under the Act,
will be engaged to represent the
Independent Trustees. The selection of
such counsel will be within the
discretion of the then-existing
Independent Trustees.
7. Whenever a Subadviser change is
proposed for a Subadvised Fund with
an Affiliated Subadviser, the Board,
including a majority of the Independent
Trustees, will make a separate finding,
reflected in the Board minutes, that the
change is in the best interests of the
Subadvised Fund and its shareholders,
and does not involve a conflict of
interest from which the applicable
Adviser or the Affiliated Subadviser
derives an inappropriate advantage.
8. Whenever a Subadviser is hired or
terminated, the applicable Adviser will
provide the Board with information
showing the expected impact on the
profitability of the Adviser.
9. Each Adviser will provide the
Board, no less frequently than quarterly,
with information about the profitability
of the Adviser on a per Subadvised
Fund basis. The information will reflect
the impact on profitability of the hiring
or termination of any Subadviser during
the applicable quarter.
10. Each applicable Adviser will
provide general management services to
each Subadvised Fund, including
overall supervisory responsibility for
the general management and investment
of the Subadvised Fund’s assets and,
subject to review and approval of the
Board, will: (i) Set the Subadvised
Fund’s overall investment strategies; (ii)
evaluate, select, and recommend
Subadvisers to manage all or a portion
of the Subadvised Fund’s assets; (iii)
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allocate and, when appropriate,
reallocate the Subadvised Fund’s assets
among Subadvisers; (iv) monitor and
evaluate the Subadvisers’ performance;
and (v) implement procedures
reasonably designed to ensure that
Subadvisers comply with the
Subadvised Fund’s investment
objective, policies and restrictions.
11. No Trustee or officer of a Trust or
of a Fund or director or officer of the
applicable Adviser will own directly or
indirectly (other than through a pooled
investment vehicle that is not controlled
by such person) any interest in a
Subadviser except for (i) ownership of
interests in the Adviser or any entity
that controls, is controlled by or is
under common control with the
Adviser; or (ii) ownership of less than
1% of the outstanding securities of any
class of equity or debt of any publicly
traded company that is either a
Subadviser or an entity that controls, is
controlled by or is under common
control with a Subadviser.
12. Each Subadvised Fund will
disclose in its registration statement the
Aggregate Fee Disclosure.
13. In the event the Commission
adopts a rule under the Act providing
substantially similar relief to that in the
order requested in the Application, the
requested order will expire on the
effective date of that rule.
14. For Subadvised Funds that pay
fees to a Subadviser directly from fund
assets, any changes to a Subadvisory
Agreement that would result in an
increase in the total management and
advisory fees payable by a Subadvised
Fund will be required to be approved by
the shareholders of the Subadvised
Fund.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2013–10606 Filed 5–3–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
30497; 812–14135]
Beverly Hills Bancorp Inc.; Notice of
Application
April 30, 2013.
Securities and Exchange
Commission (the ‘‘Commission’’).
ACTION: Notice of application for an
order under sections 6(c) and 6(e) of the
Investment Company Act of 1940
(‘‘Act’’) for an exemption from all
AGENCY:
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provisions of the Act, except sections 9,
17(a), 17(d), 17(e), 17(f), 36 through 45,
and 47 through 51 of the Act and the
rules thereunder, modified as discussed
in the application.
Summary of Application: The
requested order would exempt the
applicant, Beverly Hills Bancorp Inc.
(‘‘BHBC’’), from certain provisions of
the Act until the earlier of one year from
the date of the requested order or such
time as BHBC would no longer be
required to register as an investment
company under the Act. The requested
exemption would extend an exemption
originally granted until May 15, 2013.1
DATES: Filing Dates: The application was
filed on March 15, 2013 and amended
on April 26, 2013.
HEARING OR NOTIFICATION OF HEARING: An
order granting the application will be
issued unless the Commission orders a
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on May 23, 2013 and
should be accompanied by proof of
service on applicants, in the form of an
affidavit or, for lawyers, a certificate of
service. Hearing requests should state
the nature of the writer’s interest, the
reason for the request, and the issues
contested. Persons who wish to be
notified of a hearing may request
notification by writing to the
Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
Applicant, Post Office Box 8280,
Calabasas, CA 91372.
FOR FURTHER INFORMATION CONTACT:
Deepak Pai, Senior Counsel, at (202)
551–6876, or Mary Kay Frech, Branch
Chief, at (202) 551–6821 (Division of
Investment Management, Exemptive
Applications Office).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
SUMMARY:
Applicant’s Representations
1. BHBC is a bank holding company
that conducted its banking and lending
1 Beverly Hills Bancorp Inc., Investment
Company Act Release Nos. 30036 (April 18, 2012)
(notice) and 30064 (May 15, 2012) (order) (‘‘Original
Order’’).
E:\FR\FM\06MYN1.SGM
06MYN1
Agencies
[Federal Register Volume 78, Number 87 (Monday, May 6, 2013)]
[Notices]
[Pages 26407-26410]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-10606]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 30496; 812-14078]
Goldman Sachs Trust II, et al.; Notice of Application
April 29, 2013.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application under section 6(c) of the Investment
Company Act of 1940 (``Act'') for an exemption from section 15(a) of
the Act and rule 18f-2 under the Act, as well as from certain
disclosure requirements.
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SUMMARY: Summary of Application: Applicants request an order that
would permit them to enter into and materially amend subadvisory
agreements without shareholder approval and would grant relief from
certain disclosure requirements.
APPLICANTS: Goldman Sachs Trust II (the ``Trust''), Goldman Sachs
Asset Management L.P. (``GSAM'') and Goldman Sachs Asset Management
International (``GSAMI'', each of GSAM and GSAMI an ``Adviser'' and
collectively, ``Advisers,'' and together with the Trust,
``Applicants'').
DATES: Filing Dates: The application was filed September 21, 2012, and
amended on March 8, 2013.
HEARING OR NOTIFICATION OF HEARING: An order granting the application
will be issued unless the Commission orders a hearing. Interested
persons may request a hearing by writing to the Commission's Secretary
and serving applicants with a copy of the request, personally or by
mail. Hearing requests should be received by the Commission by 5:30
p.m. on May 28, 2013 and should be accompanied by proof of service on
the applicants, in the form of an affidavit or, for lawyers, a
certificate of service. Hearing requests should state the nature of the
writer's interest, the reason for the request, and the issues
contested. Persons who wish to be notified of a hearing may request
notification by writing to the Commission's Secretary.
ADDRESSES: Elizabeth M. Murphy, Secretary, U.S. Securities and Exchange
Commission, 100 F Street NE.,
[[Page 26408]]
Washington, DC 20549-1090. Applicants: Caroline Kraus, Goldman Sachs &
Co., 200 West Street, 15th Floor, New York, NY 10282.
FOR FURTHER INFORMATION CONTACT: Barbara T. Heussler, Senior Counsel,
at (202) 551-6990, or Jennifer L. Sawin, Branch Chief, at (202) 551-
6821 (Division of Investment Management, Office of Investment Company
Regulation).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or an applicant
using the Company name box, at https://www.sec.gov/search/search.htm or
by calling (202) 551-8090.
Applicants' Representations
1. The Trust is organized as a Delaware statutory trust and has
registered as an open-end management investment company under the Act
that will offer one or more series of shares (each a ``Series''). The
Trust has filed a registration statement on Form N-1A to register the
offering of shares of Goldman Sachs Multi-Manager Alternatives Fund, a
series of the Trust.\1\ Each Subadvised Fund may offer shares with its
own distinct investment objectives, policies and restrictions.
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\1\ Applicants request that the relief sought herein apply to
the Applicants, as well as to any future Series of the Trust and to
any other existing or future registered open-end investment company
or series thereof that: (a) is advised by either GSAM, GSAMI or
their successors (the foregoing advisers being included in the term
``Adviser,'' and any such series or investment company, including
the Trust and its Series, a ``Fund''); (b) uses the manager of
managers structure described in this Application (``Manager of
Managers Structure''); and (c) complies with the terms and
conditions of this Application (the ``Subadvised Funds,'' and each a
``Subadvised Fund''). The only Trust that currently intends to rely
on the requested order is named as an Applicant. For purposes of the
requested order, ``successor'' is limited to an entity that results
from a reorganization into another jurisdiction or a change in the
type of business organization. If the name of any Subadvised Fund
contains the name of a Subadviser, the name of the Adviser that
serves as the primary adviser to that Subadvised Fund or a trademark
or trade name that is owned by or publicly used to identify that
Adviser will precede the name of the Subadviser.
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2. GSAM, a Delaware limited partnership registered with the
Commission as an investment adviser under the Investment Advisers Act
of 1940 (``Advisers Act''), is expected to serve as investment adviser
to certain Series, in each case pursuant to an investment advisory
agreement with the Trust on behalf of the Series (each a ``GSAM
Investment Advisory Agreement''). GSAMI, a limited partnership
organized under the laws of the United Kingdom and registered with the
Commission as an investment adviser under the Advisers Act, may also
serve as investment adviser to certain Series, in each case pursuant to
an investment advisory agreement with the Trust on behalf of the Series
(each a ``GSAMI Investment Advisory Agreement'').\2\ The GSAM
Investment Advisory Agreements and the GSAMI Investment Advisory
Agreements are together referred to as the ``Investment Advisory
Agreements''. Each Investment Advisory Agreement will be approved by
the board of trustees of the Trust (the ``Board''), including a
majority of the trustees who are not ``interested persons,'' as defined
in section 2(a)(19) of the Act, of the Trust or the Adviser
(``Independent Trustees'') and by the shareholders of the relevant
Subadvised Fund in the manner required by sections 15(a) and 15(c) of
the Act and rule 18f-2 under the Act.\3\ Any future Adviser also will
be registered with the Commission as an investment adviser under the
Advisers Act and will enter into investment advisory agreements with or
on behalf of future Subadvised Funds, and such future agreements shall
be included in the term ``Investment Advisory Agreements.''
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\2\ GSAM and GSAMI are wholly-owned subsidiaries of the Goldman
Sachs Group, Inc.
\3\ The term ``Board'' also includes the board of trustees or
directors of a future Subadvised Fund.
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3. Under the terms of each Investment Advisory Agreement, the
Adviser to a Subadvised Fund, subject to the oversight of the
applicable Board, shall furnish a continuous investment program for the
Subadvised Fund. The Adviser shall periodically review each Subadvised
Fund's investment policies and strategies and based on the need of a
particular Subadvised Fund may recommend changes to the investment
policies and strategies of the Subadvised Fund for consideration by its
Board. For its services to each Subadvised Fund, the Adviser shall
receive an investment advisory fee from that Subadvised Fund as
specified in the applicable Investment Advisory Agreement based on each
Subadvised Fund's average daily total or net assets. The terms of the
Investment Advisory Agreements also permit the applicable Adviser,
subject to the approval of the relevant Board, including a majority of
the Independent Trustees, and the shareholders of the applicable
Subadvised Fund (if required by applicable law), to delegate portfolio
management responsibilities of all or a portion of the assets of the
Subadvised Fund to one or more subadvisers (``Subadvisers''). Each
Subadviser will be an investment adviser as defined in section 2(a)(20)
of the Act, and either registered with the Commission as an investment
adviser under the Advisers Act or not subject to such registration. The
Adviser shall have overall responsibility for the management and
investment of the assets of each Subadvised Fund and, with respect to
each Subadvised Fund, the Adviser's responsibilities shall include, for
example, recommending the removal or replacement of Subadvisers, and
determining the portion of that Subadvised Fund's assets to be managed
by any given Subadviser and reallocating those assets as necessary from
time to time. The Adviser shall evaluate, select and recommend
Subadvisers to manage the assets of Subadvised Fund, and shall monitor
and review the Subadviser and its performance and its compliance with
that Subadvised Fund's investment policies and restrictions. For
services provided under each Subadvisory Agreement, it is currently
intended that the applicable Subadviser will receive from the
applicable Adviser a fee based on a percentage of the Subadvised Fund's
average daily total or net assets (``Subadvisory fees''). All
Subadvisers are expected to be compensated by the applicable Adviser
out of the advisory fees the Adviser receives pursuant to the relevant
Investment Advisory Agreement. As a matter of convenience, the
applicable Adviser may request that (a) amounts payable to a Subadviser
by the Adviser be transmitted directly to the Subadviser by the
Subadvised Fund and (b) that such amount be deducted from the amounts
payable by the Subadvised Fund to the Adviser. Subadvised Funds may
directly pay advisory fees to Subadvisers in the future, although any
amendment to a Subadvisory Agreement that would increase the total
management and advisory fees payable by a Subadvised Fund would require
shareholder approval.
4. Applicants request an order to permit the Adviser, subject to
Board approval, to select certain Subadvisers to manage all or a
portion of the assets of a Subadvised Fund pursuant to a Sub-Advisory
Agreement and materially amend Sub-Advisory Agreements without
obtaining shareholder approval. The requested relief will not extend to
any Subadviser that is an affiliated person, as defined in section
2(a)(3) of the Act, of the Trust, a Subadvised Fund or the Adviser,
other than by reason of serving as a Subadviser to a Subadvised Fund
(``Affiliated Subadviser'').
5. Applicants also request an order exempting the Subadvised Funds
from certain disclosure provisions described
[[Page 26409]]
below that may require the Applicants to disclose fees paid to each
Subadviser by the Adviser or a Subadvised Fund. Applicants seek an
order to permit each Subadvised Fund to disclose (as a dollar amount
and a percentage of a Subadvised Fund's total or net assets) only: (a)
The aggregate fees paid to the Subadvised Fund's Adviser and any
Affiliated Subadvisers; and (b) the aggregate fees paid to Subadvisers
other than Affiliated Subadvisers (collectively, the ``Aggregate Fee
Disclosure''). A Subadvised Fund that employs an Affiliated Subadviser
will provide separate disclosure of any fees paid to the Affiliated
Subadviser.
Applicants' Legal Analysis
1. Section 15(a) of the Act provides, in relevant part, that it is
unlawful for any person to act as an investment adviser to a registered
investment company except pursuant to a written contract that has been
approved by the vote of a majority of the company's outstanding voting
securities. Rule 18f-2 under the Act provides that each series or class
of stock in a series investment company affected by a matter must
approve that matter if the Act requires shareholder approval.
2. Form N-1A is the registration statement used by open-end
investment companies. Item 19(a)(3) of Form N-1A requires disclosure of
the method and amount of the investment adviser's compensation.
3. Rule 20a-1 under the Act requires proxies solicited with respect
to an investment company to comply with Schedule 14A under the
Securities Exchange Act of 1934 (``Exchange Act''). Items 22(c)(1)(ii),
22(c)(1)(iii), 22(c)(8) and 22(c)(9) of Schedule 14A, taken together,
require a proxy statement for a shareholder meeting at which the
advisory contract will be voted upon to include the ``rate of
compensation of the investment adviser,'' the ``aggregate amount of the
investment adviser's fees,'' a description of the ``terms of the
contract to be acted upon,'' and, if a change in the advisory fee is
proposed, the existing and proposed fees and the difference between the
two fees.
4. Regulation S-X sets forth the requirements for financial
statements required to be included as part of a registered investment
company's registration statement and shareholder reports filed with the
Commission. Sections 6-07(2)(a), (b) and (c) of Regulation S-X require
a registered investment company to include in its financial statement
information about the investment advisory fees.
5. Section 6(c) of the Act provides that the Commission may exempt
any person, security, or transaction or any class or classes of
persons, securities, or transactions from any provisions of the Act, or
from any rule thereunder, if such exemption is necessary or appropriate
in the public interest and consistent with the protection of investors
and the purposes fairly intended by the policy and provisions of the
Act. Applicants state that the requested relief meets this standard for
the reasons discussed below.
6. Applicants assert that the shareholders expect the Adviser,
subject to the review and approval of the Board, to select the
Subadvisers who are best suited to achieve the Subadvised Fund's
investment objective. Applicants assert that, from the perspective of
the shareholder, the role of the Subadviser is substantially equivalent
to the role of the individual portfolio managers employed by an
investment adviser to a traditional investment company. Applicants
state that requiring shareholder approval of each Subadvisory Agreement
would impose unnecessary delays and expenses on the Subadvised Funds
and may preclude the Subadvised Funds from acting promptly when the
Adviser and Board consider it appropriate to hire Subadvisers or amend
Subadvisory Agreements. Applicants note that the Investment Advisory
Agreement for each Subadvised Fund and Subadvisory Agreements with
Affiliated Subadvisers (if any) will continue to be subject to the
shareholder approval requirements of section 15(a) of the Act and rule
18f-2 under the Act.
7. If new Subadvisers are hired, the Subadvised Funds will inform
shareholders of the hiring of a new Subadviser pursuant to the
following procedures (``Modified Notice and Access Procedures''): (a)
Within 90 days after a new Subadviser is hired for any Subadvised Fund,
that Subadvised Fund will send its shareholders either a Multi-manager
Notice or a Multi-manager Notice and Multi-manager Information
Statement;\4\ and (b) the Subadvised Fund will make the Multi-manager
Information Statement available on the Web site identified in the
Multi-manager Notice no later than when the Multi-manager Notice (or
Multi-manager Notice and Multi-manager Information Statement) is first
sent to shareholders, and will maintain it on that Web site for at
least 90 days. In the circumstances described in this Application, a
proxy solicitation to approve the appointment of new Subadvisers
provides no more meaningful information to shareholders than the
proposed Multi-manager Information Statement. Moreover, as indicated
above, the applicable Board would comply with the requirements of
Sections 15(a) and 15(c) of the Act before entering into or amending
Sub-Advisory Agreements.
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\4\ A ``Multi-manager Notice'' will be modeled on a Notice of
Internet Availability as defined in rule 14a-16 under the Exchange
Act, and specifically will, among other things: (a) Summarize the
relevant information regarding the new Subadviser; (b) inform
shareholders that the Multi-manager Information Statement is
available on a Web site; (c) provide the Web site address; (d) state
the time period during which the Multi-manager Information Statement
will remain available on that Web site; (e) provide instructions for
accessing and printing the Multi-manager Information Statement; and
(f) instruct the shareholder that a paper or email copy of the
Multi-manager Information Statement may be obtained, without charge,
by contacting the Subadvised Funds.
A ``Multi-manager Information Statement'' will meet the
requirements of Regulation 14C, Schedule 14C and Item 22 of Schedule
14A under the Exchange Act for an information statement, except as
modified by the requested order to permit Aggregate Fee Disclosure.
Multi-manager Information Statements will be filed electronically
with the Commission via the EDGAR system.
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8. Applicants assert that the requested disclosure relief would
benefit shareholders of the Subadvised Funds because it would improve
each Adviser's ability to negotiate the fees paid to Subadvisers.
Applicants state that if the Adviser is not required to disclose the
Subadvisers' fees to the public, the Adviser may be able to negotiate
rates that are below a Subadviser's ``posted'' amounts. Applicants
submit that the requested relief will also encourage Subadvisers to
negotiate lower subadvisory fees with the Adviser(s) if the lower fees
are not required to be made public.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
1. Before a Subadvised Fund may rely on the order requested herein,
the operation of the Subadvised Fund in the manner described in the
Application will be approved by a majority of the Subadvised Fund's
outstanding voting securities as defined in the Act or, in the case of
a Subadvised Fund whose public shareholders purchase shares on the
basis of a prospectus containing the disclosure contemplated by
condition 2 below, by the initial shareholder before such Subadvised
Fund's shares are offered to the public.
2. The prospectus for each Subadvised Fund will disclose the
existence, substance, and effect of any order granted pursuant to the
Application. In addition, each Subadvised Fund will hold itself out to
the public as employing the Manager of
[[Page 26410]]
Managers Structure. The prospectus will prominently disclose that the
Adviser has the ultimate responsibility, subject to oversight by the
Board, to oversee the Subadvisers and recommend their hiring,
termination, and replacement.
3. Subadvised Funds will inform shareholders of the hiring of a new
Subadviser within 90 days after the hiring of the new Subadviser
pursuant to the Modified Notice and Access Procedures.
4. An Adviser will not enter into a Subadvisory Agreement with any
Affiliated Subadviser unless such agreement, including the compensation
to be paid thereunder, has been approved by the shareholders of the
applicable Subadvised Fund.
5. At all times, at least a majority of the Board will be
Independent Trustees, and the nomination of new or additional
Independent Trustees will be placed within the discretion of the then-
existing Independent Trustees.
6. Independent legal counsel, as defined in rule 0-1(a)(6) under
the Act, will be engaged to represent the Independent Trustees. The
selection of such counsel will be within the discretion of the then-
existing Independent Trustees.
7. Whenever a Subadviser change is proposed for a Subadvised Fund
with an Affiliated Subadviser, the Board, including a majority of the
Independent Trustees, will make a separate finding, reflected in the
Board minutes, that the change is in the best interests of the
Subadvised Fund and its shareholders, and does not involve a conflict
of interest from which the applicable Adviser or the Affiliated
Subadviser derives an inappropriate advantage.
8. Whenever a Subadviser is hired or terminated, the applicable
Adviser will provide the Board with information showing the expected
impact on the profitability of the Adviser.
9. Each Adviser will provide the Board, no less frequently than
quarterly, with information about the profitability of the Adviser on a
per Subadvised Fund basis. The information will reflect the impact on
profitability of the hiring or termination of any Subadviser during the
applicable quarter.
10. Each applicable Adviser will provide general management
services to each Subadvised Fund, including overall supervisory
responsibility for the general management and investment of the
Subadvised Fund's assets and, subject to review and approval of the
Board, will: (i) Set the Subadvised Fund's overall investment
strategies; (ii) evaluate, select, and recommend Subadvisers to manage
all or a portion of the Subadvised Fund's assets; (iii) allocate and,
when appropriate, reallocate the Subadvised Fund's assets among
Subadvisers; (iv) monitor and evaluate the Subadvisers' performance;
and (v) implement procedures reasonably designed to ensure that
Subadvisers comply with the Subadvised Fund's investment objective,
policies and restrictions.
11. No Trustee or officer of a Trust or of a Fund or director or
officer of the applicable Adviser will own directly or indirectly
(other than through a pooled investment vehicle that is not controlled
by such person) any interest in a Subadviser except for (i) ownership
of interests in the Adviser or any entity that controls, is controlled
by or is under common control with the Adviser; or (ii) ownership of
less than 1% of the outstanding securities of any class of equity or
debt of any publicly traded company that is either a Subadviser or an
entity that controls, is controlled by or is under common control with
a Subadviser.
12. Each Subadvised Fund will disclose in its registration
statement the Aggregate Fee Disclosure.
13. In the event the Commission adopts a rule under the Act
providing substantially similar relief to that in the order requested
in the Application, the requested order will expire on the effective
date of that rule.
14. For Subadvised Funds that pay fees to a Subadviser directly
from fund assets, any changes to a Subadvisory Agreement that would
result in an increase in the total management and advisory fees payable
by a Subadvised Fund will be required to be approved by the
shareholders of the Subadvised Fund.
For the Commission, by the Division of Investment Management,
under delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2013-10606 Filed 5-3-13; 8:45 am]
BILLING CODE 8011-01-P