Citadel LLC (Formerly Citadel Investment Group, L.L.C.) and CEIF LLC; Notice of Application, 41438-41443 [2013-16537]
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41438
Federal Register / Vol. 78, No. 132 / Wednesday, July 10, 2013 / Notices
even if considered guidance which is
within the purview of the issue finality
provisions in 10 CFR part 52—need not
be evaluated as if it were a backfit or as
being inconsistent with issue finality
provisions. If, in the future, the staff
seeks to impose a position in the draft
SRP (if finalized) on holders of already
issued licenses in a manner which does
not provide issue finality as described
in the applicable issue finality
provision, then the staff must make the
showing as set forth in the Backfit Rule,
or address the criteria for avoiding issue
finality as described applicable issue
finality provision, as applicable.
Dated at Rockville, Maryland, this 28th day
of June 2013.
For the Nuclear Regulatory Commission.
Joseph Colaccino,
Chief, Policy Branch, Division of Advanced
Reactors and Rulemaking, Office of New
Reactors.
[FR Doc. 2013–16586 Filed 7–9–13; 8:45 am]
BILLING CODE 7590–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
30589; File No. 813–00383]
Citadel LLC (Formerly Citadel
Investment Group, L.L.C.) and CEIF
LLC; Notice of Application
July 3, 2013.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under sections 6(b) and 6(e) of the
Investment Company Act of 1940 (the
‘‘Act’’) granting an exemption from all
provisions of the Act, except section 9
and sections 36 through 53 and the rules
and regulations under those sections.
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 and
supersede a prior order (‘‘Prior Order’’) 1
to exempt certain limited liability
companies, limited partnerships,
companies and other investment
vehicles formed for the benefit of
eligible employees of Citadel LLC and
its affiliates (‘‘ESC Funds’’) from certain
provisions of the Act. Each ESC Fund
will be an ‘‘employees’ securities
company’’ within the meaning of
TKELLEY on DSK3SPTVN1PROD with NOTICES
SUMMARY OF APPLICATION:
1 Citadel LLC and CEIF LLC, Investment Company
Release Nos. IC–29851 (Oct. 27, 2011) (notice) and
IC–29869 (Nov. 22, 2011) (order).
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section 2(a)(13) of the Act. The
requested order would reflect the
amendment of certain mandatory
redemption terms of the ESC Funds to
allow voluntary deferral of redemption
of Vested Membership Interests beyond
the relevant Determination Date (as
these terms are defined below). The
terms and conditions of the application
are otherwise identical to the terms and
conditions of the Prior Order.
APPLICANTS: Citadel LLC and CEIF LLC
(‘‘CEIF’’).
DATES: Filing Dates: The application was
filed on January 31, 2013, and amended
on April 30, 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 July 29, 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;
Applicants, Citadel LLC and CEIF, 131
South Dearborn Street, Chicago, Illinois
60603.
FOR FURTHER INFORMATION CONTACT:
Emerson S. Davis, Senior Counsel, at
(202) 551–6868, or Daniele Marchesani,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
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’s name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Applicants’ Representations
1. Citadel is a global financial
institution with a diverse business
platform which includes alternative
asset management, strategic advisory
services and capital markets businesses
and services. Citadel LLC, a Delaware
limited liability company, and its
‘‘Affiliates,’’ as defined in rule 12b–2
under the Securities Exchange Act of
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1934 (‘‘Exchange Act’’) other than an
ESC Fund are referred to collectively as
‘‘Citadel’’ or ‘‘Citadel Entities.’’
2. Citadel has established CEIF, a
Delaware limited liability company and
will in the future establish any other
ESC Funds (collectively with CEIF, the
‘‘ESC Funds’’ and each, an ‘‘ESC Fund’’)
for the benefit of Eligible Employees
(defined below) as part of a program to
create capital building opportunities
that are competitive with those at other
financial services firms and to facilitate
the recruitment and retention of high
caliber professionals. Each of the ESC
Funds will be structured as a limited
liability company, limited partnership,
corporation, business trust or other
entity organized under the laws of the
state of Delaware or another U.S.
jurisdiction. Each ESC Fund will be
identical in all material respects (other
than investment objectives and
strategies, vesting terms, form of
organization and related structural and
operative provisions contained in the
constitutive documents of such funds).
Each ESC Fund will be an ‘‘employees’
security company’’ within the meaning
of section 2(a)(13) of the Act and will
operate as a diversified or nondiversified management investment
company. Citadel will control the ESC
Funds within the meaning of section
2(a)(9) of the Act.
3. Each managing member of an ESC
Fund or person acting in a similar
capacity will be an Affiliate of Citadel
LLC (a ‘‘Managing Member’’). Any
member or partner of, or otherwise
investor in, an ESC Fund is a
‘‘Member.’’ The Managing Member of
each ESC Fund will manage, operate
and control such ESC Fund and will
have the authority to delegate
investment management responsibility
with respect to the acquisition,
management and disposition of
Portfolio Investments, as defined below,
to a Citadel Entity. Any Citadel Entity
that is delegated the responsibility of
making investment decisions for an ESC
Fund will be registered as an investment
adviser under the Investment Advisers
Act of 1940 (the ‘‘Advisers Act’’), if
required under applicable law.
4. The Managing Member, a Member,
Citadel, Citadel Entity or any employees
of the Managing Member or Citadel may
be entitled to receive a performancebased fee or profits allocation (a
‘‘carried interest’’).2 All ESC Fund
2 A ‘‘carried interest’’ is a fee paid or an allocation
made to the Managing Member, a Member or the
Citadel Entity acting as the investment adviser to an
ESC Fund based on net gains in addition to the
amount allocable to such entity in proportion to its
invested capital. A Managing Member, Member or
Citadel Entity that is registered as an investment
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investments are referred to as ‘‘Portfolio
Investments.’’
5. Interests in an ESC Fund will be
issued without registration in reliance
on section 4(2) of the Securities Act of
1933 (the ‘‘Securities Act’’), Regulation
D and/or Regulation S under the
Securities Act and may be acquired only
by ‘‘Eligible Employees’’ and ‘‘Qualified
Participants’’ in each case defined
below. Prior to issuing Interests to an
Eligible Employee either directly or
through a related Qualified Participant,
a Managing Member must reasonably
believe that the Eligible Employee will
be a sophisticated investor capable of
understanding and evaluating the risks
of participation in an ESC Fund without
the benefit of regulatory safeguards.
6. An ‘‘Eligible Employee’’ is an
individual who is a current or former
employee, officer or partner of Citadel
or a director of Citadel that is an
‘‘interested person’’ as defined under
the Act, and that is an ‘‘accredited
investor’’ under rule 501(a)(5) or rule
501(a)(6) of Regulation D (‘‘Accredited
Investor’’). A ‘‘Qualified Participant’’ is
an entity that is a Qualified Investment
Vehicle (as defined below) and, if
purchasing an Interest (as defined
below) directly from an ESC, comes
within one of the categories of an
‘‘accredited investor’’ under 501(a) of
Regulation D. A ‘‘Qualified Investment
Vehicle’’ is (a) a trust of which the
trustee, grantor and/or beneficiary is an
Eligible Employee or (b) a partnership,
corporation or other entity controlled by
an Eligible Employee. A Qualified
Investment Vehicle that is not an
Accredited Investor will not be
permitted to invest in an ESC Fund.
7. The terms of an ESC Fund will be
fully disclosed to each Eligible
Employee and, if applicable, to a
Qualified Participant, prior to admission
to the ESC Fund. Each Eligible
Employee and Qualified Participant will
be furnished with access to the offering
documents, including a copy of the
operating agreement or other
organizational documents of the
relevant ESC Fund (‘‘Operating
Agreement’’). The Managing Member
will send each person who was a
Member at any time during the fiscal
year then ended (except for the first year
of operations of an ESC Fund if no
investment activities took place in such
fiscal year), audited financial statements
within 180 days after the end of the
fiscal year. For purposes of this
requirement ‘‘audit’’ shall have the
meaning defined in rule 1–02(d) of
adviser under the Advisers Act may be paid or
allocated carried interest only if permitted by rule
205–3 under the Advisers Act.
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Regulation S–X. In addition, as soon as
practicable after the end of the ESC
Fund’s tax year, a report will be
transmitted to each Member showing
such Member’s share of income, gains,
losses, credits, deductions, and other tax
items for U.S. federal income tax
purposes, resulting from such ESC
Fund’s operations during that year.
8. Interests in the ESC Funds will be
non-transferable except (i) to the extent
cancelled or (ii) with the prior written
consent of the Managing Member and,
in any event, no person or entity will be
admitted into an ESC Fund as a Member
unless such person or entity is an
Eligible Employee, a Qualified
Participant of an Eligible Employee, or
a Citadel Entity. Interests in the ESC
Funds will be issued without a sales
load or similar fee.
9. Ownership interests (‘‘Interests’’) in
an ESC Fund may be acquired on a
voluntary basis or be offered through a
long-term incentive program to qualified
Eligible Employees (the ‘‘Long-Term
Points Program’’). Interests in a
‘‘Participation Points ESC Fund’’ may
only be acquired through the Long-Term
Points Program. Pursuant to the LongTerm Points Program, Eligible
Employees may be issued Participation
Points on the basis of, among other
things, personal performance and/or
firm-wide or relevant team performance
results. An Eligible Employee may also
voluntarily acquire an Interest in a
‘‘non-Participation Points ESC Fund.’’
An Eligible Employee and/or its
Qualified Participant may not make
additional capital contributions to the
ESC Fund in which it is invested after
such Eligible Employee’s employment
with Citadel has terminated.
10. Both Participation Points ESC
Funds and non-Participation Points ESC
Funds may be offered as part of an
investment program that includes
vesting and cancellation provisions. In
such circumstances, some or all of an
Eligible Employee’s Interest at the
commencement of the program will be
treated as being ‘‘unvested,’’ and
‘‘vesting’’ will occur only as certain
conditions are satisfied under the terms
of the investment program. The portion
of an Eligible Employee’s Interest that is
‘‘unvested’’ at the time of termination of
such Eligible Employee’s employment
by Citadel may be subject to (a)
cancellation and/or (b) the imposition of
different terms and conditions, which
would be described in the Operating
Agreement and/or offering documents of
the relevant ESC Fund and/or in other
written correspondence issued to such
Eligible Employee.
11. With respect to Participation
Points ESC Funds, a Member will
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become vested in his/her Interest
(‘‘Vested Membership Interests’’) if (a)
he/she remains employed by Citadel
through a specified date (the
‘‘Determination Date’’) and he/she has
satisfied, among other things, all of the
certain applicable employment and
post-employment obligations (including
non-competition, non-solicitation, nondisclosure and notice obligations). NonParticipation Points ESC Funds may or
may not provide for vesting provisions.
An Eligible Employee that purchases an
Interest in a non-Participation Points
ESC Fund will be immediately vested in
such Interest to the extent of such
purchase.
12. With respect to a nonParticipation Points ESC Fund that does
not provide for vesting provisions, an
Eligible Employee’s entire Interest may
be subject to repurchase by the
Managing Member and/or the
imposition of different terms and
conditions upon termination of such
Eligible Employee’s employment by
Citadel, as described in the Operating
Agreement and/or offering documents of
the relevant ESC Fund and/or in other
written correspondence issued to such
Eligible Employee. Upon any
repurchase of an Eligible Employee’s
Vested Membership Interests, the
Managing Member will at a minimum
pay to the Eligible Employee the lesser
of (a) the amount actually paid by the
Eligible Employee to acquire the Interest
plus interest, less prior distributions
and (b) the fair market value of the
Interests determined at the time of
repurchase by the Managing Member.
The terms of any repurchase or
cancellation of Interests will apply
equally to an Eligible Employee and any
Qualified Participant of such Eligible
Employee.
13. The requested order would
supersede the Prior Order to reflect the
amendment of certain mandatory
redemption terms of the Participation
Points ESC Funds. A Member who
remains employed by Citadel may make
a request to defer redemption from the
relevant Participation Points ESC Fund
beyond the relevant Determination Date,
subject to approval by Citadel. If a
Member does not make such a request,
or Citadel does not approve such
request, that Member’s Interest will be
mandatorily redeemed as soon as
reasonably practicable following the
relevant Determination Date.3 Citadel
3 In the event of such a mandatory redemption,
subject to the availability of liquidity (including
suspensions on withdrawals) in respect of the
Citadel Third Party Funds in which the relevant
Participation Points ESC Fund is invested, the
balance of such Member’s capital account in such
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will endeavor to treat Members
consistently in making the
determination to approve such requests.
Such Vested Membership Interest may
be redeemed as of any calendar quarterend upon not less than seventy days’
prior written notice or according to such
other terms as may be described in such
Participation Points ESC Fund’s
Operating Agreement and/or Offering
Documents or election form, subject to
the availability of liquidity (including
suspensions on withdrawals) in respect
of the Citadel Third Party Funds in
which the relevant Participation Points
ESC Fund is invested.
14. Subject to the terms of the
applicable Fund Operating Agreement
and/or offering documents, an ESC
Fund will be permitted to enter into
transactions involving (i) a Citadel
Entity, (ii) any Member or person or
entity affiliated with a Member or (iii)
an investment fund or separate account,
organized in part for the benefit of
investors who are not Affiliates of
Citadel and over which a Citadel
Affiliate exercises investment discretion
(a ‘‘Citadel Third Party Fund’’). Prior to
entering into any of these transactions,
the Managing Member will make the
findings required in Condition 1 below.
A Citadel Entity (including the
Managing Member) also may be
compensated for providing services or
financing from entities in which an ESC
Fund (directly or indirectly) makes an
investment, from competitors of such
entities or from other unaffiliated
persons or entities.
15. The investment objective of each
ESC Fund will be set forth in the ESC
Fund’s offering documents. Each ESC
Fund (directly or indirectly through its
investments in Citadel Third Party
Funds) may engage in various
investment strategies implemented by
Citadel in markets around the world.4
An ESC Fund may invest directly in
securities and similar investments
(including, without limitation,
exchange-traded funds, mutual funds
and index funds) and/or may invest all
or substantially all of its assets in
Citadel Third Party Funds. An ESC
Fund will not acquire any security
issued by a registered investment
company if, immediately after the
acquisition, such ESC Fund will own
Participation Points ESC Fund relating to such
redeemed Interest, as adjusted through the date of
such redemption, will be distributed to such
Member.
4 Applicants are not requesting any exemption
from any provision of the Act or any rule
thereunder that may govern the eligibility of an ESC
Fund to invest in an entity relying on section 3(c)(1)
or 3(c)(7) of the Act or any such entity’s status
under the Act.
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more than 3% of the outstanding voting
stock of the registered investment
company.
16. If the Managing Manager or a
Citadel Entity makes a loan to an ESC
Fund, the loan would bear interest at a
rate no less favorable to the ESC Fund
than the rate that could be obtainable in
an arm’s-length transaction. An Eligible
Employee 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 outstanding
securities of the ESC Fund (other than
short-term paper). Any borrowing by an
ESC Fund will be non-recourse to the
Members.
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 employees’
securities companies 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 investment company
and other persons dealing with the
investment company as though the
investment company were registered
under the Act. Applicants request an
order under sections 6(b) and 6(e) of the
Act exempting the Applicants and any
ESC Funds from all provisions of the
Act, except section 9 and sections 36
through 53 and the rules and regulations
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under those sections. 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 investment
company. Applicants request an
exemption from section 17(a) to permit:
(a) A Citadel Entity or a Citadel Third
Party Fund (or any affiliated person of
such Third Party Fund), acting as
principal, to engage in any transaction
directly or indirectly with any ESC
Fund or any company controlled by
such ESC Fund; (b) any ESC Fund to
invest in or engage in any transaction
with any Citadel Entity, or Citadel Third
Party Fund, acting as principal, (i) in
which such ESC Fund, any company
controlled by such ESC Fund or any
Citadel Entity or Citadel Third Party
Fund has invested or will invest; or
(ii) with which such ESC Fund, any
company controlled by such ESC Fund
or any Citadel Entity or Citadel Third
Party Fund is or will otherwise become
affiliated.
4. Applicants submit that an
exemption from section 17(a) is
consistent with the purposes of each
ESC Fund and the protection of
investors and is necessary to promote
the basic purpose of such ESC Fund.
Applicants state that the Members of
each ESC Fund will be fully informed
of the possible extent of such ESC
Fund’s dealings with Citadel and, as
professionals with experience in
financial services businesses, Members
will be able to understand and evaluate
the attendant risks. Applicants assert
that the community of interest among
the Members in each ESC Fund and
Citadel is the best insurance against any
risk of abuse.
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
enterprise or joint arrangement with the
company unless authorized by the
Commission. Applicants request relief
to permit affiliated persons of each ESC
Fund or affiliated persons of such
persons to participate in, or effect any
transaction in connection with, any
joint enterprise or joint arrangement or
profit-sharing plan in which an ESC
Fund or a company controlled by such
ESC Fund is a participant.
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6. Applicants assert that compliance
with section 17(d) would cause an ESC
Fund to forego investment opportunities
simply because a Member or any other
affiliated person of the ESC Fund (or
any affiliate of such a person) also had,
or contemplated making, a similar
investment. Applicants also submit that
co-investment opportunities with
Citadel are advantageous to Eligible
Employees because (a) the resources of
Citadel enable it to analyze investment
opportunities to an extent that Eligible
Employees would have neither the time
nor resources to duplicate, (b)
investments made by Citadel will not be
generally available to investors even if
the financial status of the Eligible
Employees would enable them to
otherwise participate in such
opportunities and (c) Eligible
Employees will be able to pool their
resources in co-investments, thus
achieving greater diversification of their
individual portfolios. Applicants note
that each ESC Fund will be primarily
organized for the benefit of Eligible
Employees as an incentive for them to
remain with Citadel and for the
generation and maintenance of goodwill
through an investment in Citadel Third
Party Funds. 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. Side-by-side investments held by a
Citadel Third Party Fund, or by a
Citadel Entity in a transaction in which
the Citadel investment was made
pursuant to a contractual obligation to a
Citadel Third Party Fund will not be
subject to condition 3 below. Applicants
note that Citadel is likely to invest its
own capital in Citadel Third Party Fund
investments and that such investments
will be subject to substantially the same
terms as those applicable to such
Citadel Third Party Fund, except as
otherwise disclosed in the offering
documents and/or Operating Agreement
of the relevant ESC Fund. In addition,
applicants assert that the relationship of
an ESC Fund to a Citadel Third Party
Fund is fundamentally different from
such ESC Fund’s relationship to Citadel.
Applicants contend that the focus of,
and the rationale for, the protections
contained in the requested relief are to
protect the ESC Funds from any
overreaching by Citadel in the
employer/employee context, whereas
the same concerns are not present with
`
respect to the ESC Funds vis-a-vis the
investors in a Citadel Third Party Fund.
8. 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
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requirements when the custodian is a
member of a national securities
exchange. Applicants request an
exemption from section 17(f) and rule
17f–1 to permit a Citadel 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 ESC Fund
will otherwise comply with all the
provisions of rule 17f–1.
9. Applicants also request an
exemption from rule 17f–2 to permit the
following exceptions from the
requirements of rule 17f–2: (a) An ESC
Fund’s investments may be kept in the
locked files of the Managing Member (or
a Citadel Entity) for purposes of
paragraph (b) of the rule; (b) for
purposes of paragraph (d) of the rule,
(i) employees of the Managing Member
(or a Citadel Entity) will be deemed to
be employees of the ESC Funds, (ii)
officers or managers of the Managing
Member of an ESC Fund (or a Citadel
Entity) will be deemed to be officers of
the ESC Fund, and (iii) the Managing
Member will be deemed to be the board
of directors of the ESC Fund; and (c) in
place of the verification procedure
under paragraph (f) of the rule,
verification will be effected quarterly by
two high level employees of the
Managing Member (or another Citadel
Entity). Applicants expect that most of
their investments may be evidenced
only by partnership agreements,
participation agreements or similar
documents, rather than by negotiable
certificates that could be
misappropriated. Applicants believe
that these instruments are most suitably
kept in the files of the Managing
Member (or a Citadel Entity), where
they can be referred to as necessary.
10. 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.
Applicants request exemptive relief to
permit the Managing Member,
regardless of whether it is deemed an
interested person of the ESC Funds, to
take actions and make determinations
set forth in the rule. Applicants state
that the ESC Funds are unable to
comply with Rule 17g–1 because the
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ESC Funds will not have a board of
directors and the Managing Member of
the ESC Fund will be an interested
person of the ESC Funds. Applicants
also state that the ESC Funds will
comply with all other requirements of
rule 17g–1, except that the Applicants
request an exemption from the
requirements of paragraphs (g) and (h)
of rule 17g–1 (relating to the filing of
copies of fidelity bonds and related
information with the Commission and
relating to the provision of notices to the
board of directors), and an exemption
from the requirements of paragraph
(j)(3) of rule 17g–1 that the ESCs comply
with the fund governance standards
defined in rule 0–1(a)(7).
11. 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 unnecessary and burdensome
as applied to the ESC Funds.
12. 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 an ESC Fund and
would entail administrative and legal
costs that outweigh any benefit to the
Members of such ESC Fund. Applicants
request exemptive relief to the extent
necessary to permit each ESC Fund to
report annually to its Members.
Applicants also request an exemption
from section 30(h) of the Act to the
extent necessary to exempt the
Managing Member of each ESC Fund,
directors and officers of the Managing
Member and any other persons who
may be deemed to be members of an
advisory board or an investment adviser
(and affiliated persons thereof) of such
ESC Fund from filing Forms 3, 4, and
5 under section 16 of the Exchange Act
with respect to such ESC Fund.
Applicants assert that, because there
will be no trading market and the
transfers of Interests will be severely
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restricted, these filings are unnecessary
for the protection of investors and
burdensome to those required to make
them.
13. Rule 38a–1 requires investment
companies to adopt, implement and
periodically review written policies and
procedures reasonably designed to
prevent violation of the federal
securities laws and to appoint a chief
compliance officer. Each ESC Fund will
comply will rule 38a–1(a), (c) and (d),
except that (a) because the ESC Funds
do not have a board of directors, the
Managing Member will fulfill the
responsibilities assigned to a board of
directors under the rule, (b) because the
Managing Member 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) because the ESC
Funds do not have any independent
directors, the ESC Funds 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
Managing Member.
TKELLEY on DSK3SPTVN1PROD with NOTICES
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
1. Each proposed transaction to which
an ESC Fund is a party otherwise
prohibited by section 17(a) or section
17(d) of the Act and rule 17d–1 under
the Act (the ‘‘Section 17 Transactions’’)
will be effected only if the Managing
Member determines that: (a) The terms
of the Section 17 Transaction, including
the consideration to be paid or received,
are fair and reasonable to the Members
of the ESC Fund and do not involve
overreaching of the ESC Fund or its
Members on the part of any person
concerned and (b) the Section 17
Transaction is consistent with the
interests of the Members of the ESC
Fund, the ESC Fund’s organizational
documents and the ESC Fund’s reports
to its Members.
In addition, the Managing Member
will record and will preserve a
description of all Section 17
Transactions, the Managing Member’s
findings, the information or materials
upon which the findings are based and
the basis for the findings. All such
records will be maintained for the life
of the ESC Fund and at least six years
thereafter, and will be subject to
examination by the Commission and its
staff. Each ESC Fund will preserve the
accounts, books and other documents
required to be maintained in an easily
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accessible place for at least the first two
years.
2. The Managing Member 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 any ESC Fund,
or any affiliated person of such affiliated
person, promoter or principal
underwriter.
3. The Managing Member of each ESC
Fund will not invest the funds of the
ESC Fund in 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 and where the investment
involves a joint enterprise or other joint
arrangement within the meaning of rule
17d–1 in which the ESC Fund and the
Co-Investor are participants, unless any
such Co-Investor, prior to disposing of
all or part of its investment: Agrees to
(a) give the Managing Member
sufficient, but not less than one day’s
notice of its intent to dispose of its
investment; and (b) refrain from
disposing of its investment unless the
ESC Fund has the opportunity to
dispose of its investment prior to or
concurrently with, and on the same
terms as, and pro rata with, the CoInvestor. The term ‘‘Co-Investor’’ with
respect to any ESC Fund means any
person who is: (a) An ‘‘affiliated
person’’ (as defined in section 2(a)(3) of
the Act) of the ESC Fund (other than a
Citadel Third Party Fund); (b) a Citadel
Entity; (c) an officer, director or
employee of a Citadel Entity; or (d) an
entity (other than a Citadel Third Party
Fund) in which a Managing Member or
an Affiliate of Citadel acts as a managing
member or in a similar capacity so as to
control the sale or other disposition of
the entity’s investments. 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 the Co-Investor is a direct or
indirect wholly-owned subsidiary or to
a direct or indirect wholly-owned
subsidiary of such Parent; (b) to
immediate family members of the CoInvestor or a trust or other investment
vehicle established for any such family
member; or (c) when the investment is
comprised of securities that are (i) listed
on any exchange registered as a national
exchange under section 6 of the
Exchange Act; (ii) NMS stocks, pursuant
to section 11A(a)(2) of the Exchange Act
PO 00000
Frm 00091
Fmt 4703
Sfmt 4703
and rule 600(a) of Regulation NMS
thereunder; (iii) government securities
as defined in section 2(a)(16) of the Act,
or (iv) listed 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 ESC Fund and its Managing
Member will maintain and preserve, for
the life of such ESC Fund and at least
six years thereafter, such accounts,
books, and other documents
constituting the record forming the basis
for the audited financial statements that
are to be provided to the Members of
such ESC Fund, and each annual report
of such ESC Fund required to be sent to
such Members, and agree that all such
records will be subject to examination
by the Commission and its staff. Each
ESC Fund will preserve the accounts,
books and other documents required to
be maintained in an easily accessible
place for the first two years after the life
of such ESC Fund.
5. The Managing Member of each ESC
Fund will send to each person who was
a Member having an Interest in the ESC
Fund at any time during the fiscal year
then ended (except for the first fiscal
year of operations of an ESC Fund if no
investment activities took place in such
fiscal year), audited financial statements
with respect to those ESC Funds in
which the Member held Interests. At the
end of each fiscal year, the Managing
Member will make a valuation or have
a valuation made of all of the assets of
the ESC Fund 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 ESC Fund.
In addition, within 180 days after the
end of each fiscal year of each ESC Fund
or as soon as practicable thereafter, the
Managing Member will send a report to
each person who was a Member at any
time during the fiscal year then ended,
setting forth such tax information as
shall be necessary for the preparation by
the Member of his, her or its U.S. federal
and state income tax returns and a
report of the investment activities of the
ESC Fund during that fiscal year.
6. If an ESC Fund makes purchases
from, or sales to, an entity affiliated
with the ESC Fund by reason of an
officer, director or employee of Citadel
(a) serving as an officer, director,
managing member, 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 ESC Fund’s
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Federal Register / Vol. 78, No. 132 / Wednesday, July 10, 2013 / Notices
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. 2013–16537 Filed 7–9–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
30590; 812–14096]
BofA Funds Series Trust, et al., Notice
of Application
July 3, 2013.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under sections 6(c) and 17(b) of
the Investment Company Act of 1940
(the ‘‘Act’’) for an exemption from
section 17(a) of the Act.
AGENCY:
BofA Advisors, LLC
(together with any successor,1 the
‘‘Advisor’’),2 BofA Funds Series Trust
(‘‘Trust’’ and each series of the Trust, a
‘‘Current Fund,’’ and collectively, the
‘‘Current Funds’’),3 any existing or
future registered management
investment companies and their series
that are advised or subadvised by the
Advisor (‘‘Future Funds,’’ Future Funds
and Current Funds are collectively the
‘‘Funds’’),4 and Merrill Lynch, Pierce,
TKELLEY on DSK3SPTVN1PROD with NOTICES
APPLICANTS:
1 The term ‘‘successor’’ is limited to an entity that
results from a reorganization into another
jurisdiction, a change in the type of business
organization or a combination, consolidation or
reorganization of any of the entities referred to
above, including any such combination,
consolidation or reorganization effected through the
use of a ‘‘shell’’ entity controlled by any of the
foregoing entities, provided that such combination,
consolidation or reorganization does not result in a
change of direct or indirect control of such entity.
2 For purposes of the relief sought by the
Applicants, the term ‘‘Advisor’’ also includes any
other existing or future investment adviser
registered under the Investment Advisers Act of
1940 (‘‘Advisers Act’’) which controls, is controlled
by, or is under common control with (as defined in
Section 2(a)(9) of the Act) the Advisor. Any Advisor
that currently intends to rely on the requested order
is named as an Applicant in this Application. Any
other Advisor that relies on the order in the future
will comply with the terms and conditions of the
application.
3 The Trust offers eleven series: BofA Cash
Reserves, BofA Money Market Reserves, BofA
Treasury Reserves, BofA Government Reserves,
BofA Government Plus Reserves, BofA Tax-Exempt
Reserves, BofA Municipal Reserves, BofA California
Tax-Exempt Reserves, BofA New York Tax-Exempt
Reserves, BofA Connecticut Municipal Reserves
and BofA Massachusetts Municipal Reserves.
4 Any Fund that currently intends to rely on the
requested order is named as an applicant in the
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17:42 Jul 09, 2013
Jkt 229001
Fenner & Smith Incorporated (together
with any successor, ‘‘MLPF&S’’). All the
Funds are money market funds subject
to rule 2a–7 under the Act.
SUMMARY OF APPLICATION: Applicants
request an order to permit the Funds to
engage in principal transactions in
certain tax-exempt money market
instruments with MLPF&S.
FILING DATES: The application was filed
on November 19, 2012, and amended on
May 14, 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 July 29, 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 may request
notification of a hearing by writing to
the Commission’s Secretary.
ADDRESSES: Elizabeth M. Murphy,
Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
Applicants: c/o Robert M. Kurucza, Esq.,
Goodwin Procter LLP, 901 New York
Avenue NW., Washington, DC 20001.
FOR FURTHER INFORMATION CONTACT:
Emerson S. Davis, Senior Counsel, (202)
551–6868 or Daniele Marchesani,
Branch Chief, (202) 551–6821 (Division
of Investment Management, Exemptive
Applications Office).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Applicants’ Representations
1. The Trust, an open-end
management company registered under
the Act, is organized as a Delaware
statutory trust and is comprised of
eleven series that are Funds. The
Advisor, an investment adviser
registered under the Advisers Act, is a
direct wholly-owned subsidiary of BofA
Global Capital Management Group, LLC,
application. Any Future Fund that relies on the
order in the future will comply with the terms and
conditions of the application.
PO 00000
Frm 00092
Fmt 4703
Sfmt 4703
41443
which is a direct wholly-owned
subsidiary of Bank of America, which in
turn is an indirect, wholly-owned
banking subsidiary of Bank of America
Corporation (‘‘BAC’’). Each Fund has an
investment advisory agreement with the
Advisor pursuant to which the Advisor
provides investment advisory and
management services. MLPF&S, a
broker-dealer registered under the
Securities Exchange Act of 1934,
provides retail brokerage customer
services and operates as a full service
investment banking firm with a broad
range of investment banking services,
among which are the public
underwriting and private placement of
equity and debt securities, including a
wide variety of Tax-Exempt Money
Market Instruments (as defined below).
MLPF&S is a wholly-owned subsidiary
of Merrill Lynch & Co. (‘‘ML&Co’’),
which is a wholly-owned subsidiary of
BAC.
2. Applicants state that the Advisor
and MLPF&S are functionally
independent of each other and operate
as completely separate entities. While
MLPF&S and the Advisor could be
deemed second-tier affiliates through
their relationship with BAC, each entity
has its own separate directors, officers
and employees, is separately
capitalized, maintains its own books
and records and operates on different
sides of walls of separation with respect
to the Funds and Tax-Exempt Money
Market Instruments. The Advisor also
maintains offices physically separate
from MLPF&S.
3. Investment decisions for the Funds
are determined solely by the Advisor.
The portfolio managers and other
employees that are responsible for the
investment of the Funds are employed
solely by the Advisor, and not MLPF&S,
and have lines of reporting
responsibility solely within the Advisor.
The compensation of persons employed
by the Advisor will not depend on the
volume or nature of trades with
MLPF&S, except to the extent that such
trades may affect the profits and losses
of BAC and its affiliates as a whole and
such trades affect the investment
performance of a Fund.
4. As used in the application, the term
‘‘Tax-Exempt Money Market
Instruments’’ refers to tax-exempt
securities which are eligible for
purchase by money market funds under
rule 2a–7, including conventional
municipal notes, tax-exempt
commercial paper, and variable rate
demand bonds. The term ‘‘Tax-Exempt
Money Market Instruments’’ does not
include ‘‘Government Securities’’ as
defined under Section 2(a)(16) of the
Investment Company Act. Each Fund is
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Agencies
[Federal Register Volume 78, Number 132 (Wednesday, July 10, 2013)]
[Notices]
[Pages 41438-41443]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-16537]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 30589; File No. 813-00383]
Citadel LLC (Formerly Citadel Investment Group, L.L.C.) and CEIF
LLC; Notice of Application
July 3, 2013.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application for an order under sections 6(b) and 6(e)
of the Investment Company Act of 1940 (the ``Act'') granting an
exemption from all provisions of the Act, except section 9 and sections
36 through 53 and the rules and regulations under those sections. 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.
-----------------------------------------------------------------------
Summary of Application: Applicants request an order to amend and
supersede a prior order (``Prior Order'') \1\ to exempt certain limited
liability companies, limited partnerships, companies and other
investment vehicles formed for the benefit of eligible employees of
Citadel LLC and its affiliates (``ESC Funds'') from certain provisions
of the Act. Each ESC Fund will be an ``employees' securities company''
within the meaning of section 2(a)(13) of the Act. The requested order
would reflect the amendment of certain mandatory redemption terms of
the ESC Funds to allow voluntary deferral of redemption of Vested
Membership Interests beyond the relevant Determination Date (as these
terms are defined below). The terms and conditions of the application
are otherwise identical to the terms and conditions of the Prior Order.
---------------------------------------------------------------------------
\1\ Citadel LLC and CEIF LLC, Investment Company Release Nos.
IC-29851 (Oct. 27, 2011) (notice) and IC-29869 (Nov. 22, 2011)
(order).
---------------------------------------------------------------------------
Applicants: Citadel LLC and CEIF LLC (``CEIF'').
DATES: Filing Dates: The application was filed on January 31, 2013, and
amended on April 30, 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 July 29, 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; Applicants, Citadel LLC and
CEIF, 131 South Dearborn Street, Chicago, Illinois 60603.
FOR FURTHER INFORMATION CONTACT: Emerson S. Davis, Senior Counsel, at
(202) 551-6868, or Daniele Marchesani, Branch Chief, at (202) 551-6821
(Division of Investment Management, 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's name box, at https://www.sec.gov/search/search.htm
or by calling (202) 551-8090.
Applicants' Representations
1. Citadel is a global financial institution with a diverse
business platform which includes alternative asset management,
strategic advisory services and capital markets businesses and
services. Citadel LLC, a Delaware limited liability company, and its
``Affiliates,'' as defined in rule 12b-2 under the Securities Exchange
Act of 1934 (``Exchange Act'') other than an ESC Fund are referred to
collectively as ``Citadel'' or ``Citadel Entities.''
2. Citadel has established CEIF, a Delaware limited liability
company and will in the future establish any other ESC Funds
(collectively with CEIF, the ``ESC Funds'' and each, an ``ESC Fund'')
for the benefit of Eligible Employees (defined below) as part of a
program to create capital building opportunities that are competitive
with those at other financial services firms and to facilitate the
recruitment and retention of high caliber professionals. Each of the
ESC Funds will be structured as a limited liability company, limited
partnership, corporation, business trust or other entity organized
under the laws of the state of Delaware or another U.S. jurisdiction.
Each ESC Fund will be identical in all material respects (other than
investment objectives and strategies, vesting terms, form of
organization and related structural and operative provisions contained
in the constitutive documents of such funds). Each ESC Fund will be an
``employees' security company'' within the meaning of section 2(a)(13)
of the Act and will operate as a diversified or non-diversified
management investment company. Citadel will control the ESC Funds
within the meaning of section 2(a)(9) of the Act.
3. Each managing member of an ESC Fund or person acting in a
similar capacity will be an Affiliate of Citadel LLC (a ``Managing
Member''). Any member or partner of, or otherwise investor in, an ESC
Fund is a ``Member.'' The Managing Member of each ESC Fund will manage,
operate and control such ESC Fund and will have the authority to
delegate investment management responsibility with respect to the
acquisition, management and disposition of Portfolio Investments, as
defined below, to a Citadel Entity. Any Citadel Entity that is
delegated the responsibility of making investment decisions for an ESC
Fund will be registered as an investment adviser under the Investment
Advisers Act of 1940 (the ``Advisers Act''), if required under
applicable law.
4. The Managing Member, a Member, Citadel, Citadel Entity or any
employees of the Managing Member or Citadel may be entitled to receive
a performance-based fee or profits allocation (a ``carried
interest'').\2\ All ESC Fund
[[Page 41439]]
investments are referred to as ``Portfolio Investments.''
---------------------------------------------------------------------------
\2\ A ``carried interest'' is a fee paid or an allocation made
to the Managing Member, a Member or the Citadel Entity acting as the
investment adviser to an ESC Fund based on net gains in addition to
the amount allocable to such entity in proportion to its invested
capital. A Managing Member, Member or Citadel Entity that is
registered as an investment adviser under the Advisers Act may be
paid or allocated carried interest only if permitted by rule 205-3
under the Advisers Act.
---------------------------------------------------------------------------
5. Interests in an ESC Fund will be issued without registration in
reliance on section 4(2) of the Securities Act of 1933 (the
``Securities Act''), Regulation D and/or Regulation S under the
Securities Act and may be acquired only by ``Eligible Employees'' and
``Qualified Participants'' in each case defined below. Prior to issuing
Interests to an Eligible Employee either directly or through a related
Qualified Participant, a Managing Member must reasonably believe that
the Eligible Employee will be a sophisticated investor capable of
understanding and evaluating the risks of participation in an ESC Fund
without the benefit of regulatory safeguards.
6. An ``Eligible Employee'' is an individual who is a current or
former employee, officer or partner of Citadel or a director of Citadel
that is an ``interested person'' as defined under the Act, and that is
an ``accredited investor'' under rule 501(a)(5) or rule 501(a)(6) of
Regulation D (``Accredited Investor''). A ``Qualified Participant'' is
an entity that is a Qualified Investment Vehicle (as defined below)
and, if purchasing an Interest (as defined below) directly from an ESC,
comes within one of the categories of an ``accredited investor'' under
501(a) of Regulation D. A ``Qualified Investment Vehicle'' is (a) a
trust of which the trustee, grantor and/or beneficiary is an Eligible
Employee or (b) a partnership, corporation or other entity controlled
by an Eligible Employee. A Qualified Investment Vehicle that is not an
Accredited Investor will not be permitted to invest in an ESC Fund.
7. The terms of an ESC Fund will be fully disclosed to each
Eligible Employee and, if applicable, to a Qualified Participant, prior
to admission to the ESC Fund. Each Eligible Employee and Qualified
Participant will be furnished with access to the offering documents,
including a copy of the operating agreement or other organizational
documents of the relevant ESC Fund (``Operating Agreement''). The
Managing Member will send each person who was a Member at any time
during the fiscal year then ended (except for the first year of
operations of an ESC Fund if no investment activities took place in
such fiscal year), audited financial statements within 180 days after
the end of the fiscal year. For purposes of this requirement ``audit''
shall have the meaning defined in rule 1-02(d) of Regulation S-X. In
addition, as soon as practicable after the end of the ESC Fund's tax
year, a report will be transmitted to each Member showing such Member's
share of income, gains, losses, credits, deductions, and other tax
items for U.S. federal income tax purposes, resulting from such ESC
Fund's operations during that year.
8. Interests in the ESC Funds will be non-transferable except (i)
to the extent cancelled or (ii) with the prior written consent of the
Managing Member and, in any event, no person or entity will be admitted
into an ESC Fund as a Member unless such person or entity is an
Eligible Employee, a Qualified Participant of an Eligible Employee, or
a Citadel Entity. Interests in the ESC Funds will be issued without a
sales load or similar fee.
9. Ownership interests (``Interests'') in an ESC Fund may be
acquired on a voluntary basis or be offered through a long-term
incentive program to qualified Eligible Employees (the ``Long-Term
Points Program''). Interests in a ``Participation Points ESC Fund'' may
only be acquired through the Long-Term Points Program. Pursuant to the
Long-Term Points Program, Eligible Employees may be issued
Participation Points on the basis of, among other things, personal
performance and/or firm-wide or relevant team performance results. An
Eligible Employee may also voluntarily acquire an Interest in a ``non-
Participation Points ESC Fund.'' An Eligible Employee and/or its
Qualified Participant may not make additional capital contributions to
the ESC Fund in which it is invested after such Eligible Employee's
employment with Citadel has terminated.
10. Both Participation Points ESC Funds and non-Participation
Points ESC Funds may be offered as part of an investment program that
includes vesting and cancellation provisions. In such circumstances,
some or all of an Eligible Employee's Interest at the commencement of
the program will be treated as being ``unvested,'' and ``vesting'' will
occur only as certain conditions are satisfied under the terms of the
investment program. The portion of an Eligible Employee's Interest that
is ``unvested'' at the time of termination of such Eligible Employee's
employment by Citadel may be subject to (a) cancellation and/or (b) the
imposition of different terms and conditions, which would be described
in the Operating Agreement and/or offering documents of the relevant
ESC Fund and/or in other written correspondence issued to such Eligible
Employee.
11. With respect to Participation Points ESC Funds, a Member will
become vested in his/her Interest (``Vested Membership Interests'') if
(a) he/she remains employed by Citadel through a specified date (the
``Determination Date'') and he/she has satisfied, among other things,
all of the certain applicable employment and post-employment
obligations (including non-competition, non-solicitation, non-
disclosure and notice obligations). Non-Participation Points ESC Funds
may or may not provide for vesting provisions. An Eligible Employee
that purchases an Interest in a non-Participation Points ESC Fund will
be immediately vested in such Interest to the extent of such purchase.
12. With respect to a non-Participation Points ESC Fund that does
not provide for vesting provisions, an Eligible Employee's entire
Interest may be subject to repurchase by the Managing Member and/or the
imposition of different terms and conditions upon termination of such
Eligible Employee's employment by Citadel, as described in the
Operating Agreement and/or offering documents of the relevant ESC Fund
and/or in other written correspondence issued to such Eligible
Employee. Upon any repurchase of an Eligible Employee's Vested
Membership Interests, the Managing Member will at a minimum pay to the
Eligible Employee the lesser of (a) the amount actually paid by the
Eligible Employee to acquire the Interest plus interest, less prior
distributions and (b) the fair market value of the Interests determined
at the time of repurchase by the Managing Member. The terms of any
repurchase or cancellation of Interests will apply equally to an
Eligible Employee and any Qualified Participant of such Eligible
Employee.
13. The requested order would supersede the Prior Order to reflect
the amendment of certain mandatory redemption terms of the
Participation Points ESC Funds. A Member who remains employed by
Citadel may make a request to defer redemption from the relevant
Participation Points ESC Fund beyond the relevant Determination Date,
subject to approval by Citadel. If a Member does not make such a
request, or Citadel does not approve such request, that Member's
Interest will be mandatorily redeemed as soon as reasonably practicable
following the relevant Determination Date.\3\ Citadel
[[Page 41440]]
will endeavor to treat Members consistently in making the determination
to approve such requests. Such Vested Membership Interest may be
redeemed as of any calendar quarter-end upon not less than seventy
days' prior written notice or according to such other terms as may be
described in such Participation Points ESC Fund's Operating Agreement
and/or Offering Documents or election form, subject to the availability
of liquidity (including suspensions on withdrawals) in respect of the
Citadel Third Party Funds in which the relevant Participation Points
ESC Fund is invested.
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\3\ In the event of such a mandatory redemption, subject to the
availability of liquidity (including suspensions on withdrawals) in
respect of the Citadel Third Party Funds in which the relevant
Participation Points ESC Fund is invested, the balance of such
Member's capital account in such Participation Points ESC Fund
relating to such redeemed Interest, as adjusted through the date of
such redemption, will be distributed to such Member.
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14. Subject to the terms of the applicable Fund Operating Agreement
and/or offering documents, an ESC Fund will be permitted to enter into
transactions involving (i) a Citadel Entity, (ii) any Member or person
or entity affiliated with a Member or (iii) an investment fund or
separate account, organized in part for the benefit of investors who
are not Affiliates of Citadel and over which a Citadel Affiliate
exercises investment discretion (a ``Citadel Third Party Fund''). Prior
to entering into any of these transactions, the Managing Member will
make the findings required in Condition 1 below. A Citadel Entity
(including the Managing Member) also may be compensated for providing
services or financing from entities in which an ESC Fund (directly or
indirectly) makes an investment, from competitors of such entities or
from other unaffiliated persons or entities.
15. The investment objective of each ESC Fund will be set forth in
the ESC Fund's offering documents. Each ESC Fund (directly or
indirectly through its investments in Citadel Third Party Funds) may
engage in various investment strategies implemented by Citadel in
markets around the world.\4\ An ESC Fund may invest directly in
securities and similar investments (including, without limitation,
exchange-traded funds, mutual funds and index funds) and/or may invest
all or substantially all of its assets in Citadel Third Party Funds. An
ESC Fund will not acquire any security issued by a registered
investment company if, immediately after the acquisition, such ESC Fund
will own more than 3% of the outstanding voting stock of the registered
investment company.
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\4\ Applicants are not requesting any exemption from any
provision of the Act or any rule thereunder that may govern the
eligibility of an ESC Fund to invest in an entity relying on section
3(c)(1) or 3(c)(7) of the Act or any such entity's status under the
Act.
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16. If the Managing Manager or a Citadel Entity makes a loan to an
ESC Fund, the loan would bear interest at a rate no less favorable to
the ESC Fund than the rate that could be obtainable in an arm's-length
transaction. An Eligible Employee 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 outstanding securities of the ESC Fund (other than
short-term paper). Any borrowing by an ESC Fund will be non-recourse to
the Members.
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 employees'
securities companies 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 investment company and other
persons dealing with the investment company as though the investment
company were registered under the Act. Applicants request an order
under sections 6(b) and 6(e) of the Act exempting the Applicants and
any ESC Funds from all provisions of the Act, except section 9 and
sections 36 through 53 and the rules and regulations under those
sections. 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 investment
company. Applicants request an exemption from section 17(a) to permit:
(a) A Citadel Entity or a Citadel Third Party Fund (or any affiliated
person of such Third Party Fund), acting as principal, to engage in any
transaction directly or indirectly with any ESC Fund or any company
controlled by such ESC Fund; (b) any ESC Fund to invest in or engage in
any transaction with any Citadel Entity, or Citadel Third Party Fund,
acting as principal, (i) in which such ESC Fund, any company controlled
by such ESC Fund or any Citadel Entity or Citadel Third Party Fund has
invested or will invest; or (ii) with which such ESC Fund, any company
controlled by such ESC Fund or any Citadel Entity or Citadel Third
Party Fund is or will otherwise become affiliated.
4. Applicants submit that an exemption from section 17(a) is
consistent with the purposes of each ESC Fund and the protection of
investors and is necessary to promote the basic purpose of such ESC
Fund. Applicants state that the Members of each ESC Fund will be fully
informed of the possible extent of such ESC Fund's dealings with
Citadel and, as professionals with experience in financial services
businesses, Members will be able to understand and evaluate the
attendant risks. Applicants assert that the community of interest among
the Members in each ESC Fund and Citadel is the best insurance against
any risk of abuse.
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 enterprise or joint arrangement with the
company unless authorized by the Commission. Applicants request relief
to permit affiliated persons of each ESC Fund or affiliated persons of
such persons to participate in, or effect any transaction in connection
with, any joint enterprise or joint arrangement or profit-sharing plan
in which an ESC Fund or a company controlled by such ESC Fund is a
participant.
[[Page 41441]]
6. Applicants assert that compliance with section 17(d) would cause
an ESC Fund to forego investment opportunities simply because a Member
or any other affiliated person of the ESC Fund (or any affiliate of
such a person) also had, or contemplated making, a similar investment.
Applicants also submit that co-investment opportunities with Citadel
are advantageous to Eligible Employees because (a) the resources of
Citadel enable it to analyze investment opportunities to an extent that
Eligible Employees would have neither the time nor resources to
duplicate, (b) investments made by Citadel will not be generally
available to investors even if the financial status of the Eligible
Employees would enable them to otherwise participate in such
opportunities and (c) Eligible Employees will be able to pool their
resources in co-investments, thus achieving greater diversification of
their individual portfolios. Applicants note that each ESC Fund will be
primarily organized for the benefit of Eligible Employees as an
incentive for them to remain with Citadel and for the generation and
maintenance of goodwill through an investment in Citadel Third Party
Funds. 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. Side-by-side investments held by a Citadel Third Party Fund, or
by a Citadel Entity in a transaction in which the Citadel investment
was made pursuant to a contractual obligation to a Citadel Third Party
Fund will not be subject to condition 3 below. Applicants note that
Citadel is likely to invest its own capital in Citadel Third Party Fund
investments and that such investments will be subject to substantially
the same terms as those applicable to such Citadel Third Party Fund,
except as otherwise disclosed in the offering documents and/or
Operating Agreement of the relevant ESC Fund. In addition, applicants
assert that the relationship of an ESC Fund to a Citadel Third Party
Fund is fundamentally different from such ESC Fund's relationship to
Citadel. Applicants contend that the focus of, and the rationale for,
the protections contained in the requested relief are to protect the
ESC Funds from any overreaching by Citadel in the employer/employee
context, whereas the same concerns are not present with respect to the
ESC Funds vis-[agrave]-vis the investors in a Citadel Third Party Fund.
8. 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 member of a national
securities exchange. Applicants request an exemption from section 17(f)
and rule 17f-1 to permit a Citadel 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 ESC Fund will otherwise comply
with all the provisions of rule 17f-1.
9. Applicants also request an exemption from rule 17f-2 to permit
the following exceptions from the requirements of rule 17f-2: (a) An
ESC Fund's investments may be kept in the locked files of the Managing
Member (or a Citadel Entity) for purposes of paragraph (b) of the rule;
(b) for purposes of paragraph (d) of the rule, (i) employees of the
Managing Member (or a Citadel Entity) will be deemed to be employees of
the ESC Funds, (ii) officers or managers of the Managing Member of an
ESC Fund (or a Citadel Entity) will be deemed to be officers of the ESC
Fund, and (iii) the Managing Member will be deemed to be the board of
directors of the ESC Fund; and (c) in place of the verification
procedure under paragraph (f) of the rule, verification will be
effected quarterly by two high level employees of the Managing Member
(or another Citadel Entity). Applicants expect that most of their
investments may be evidenced only by partnership agreements,
participation agreements or similar documents, rather than by
negotiable certificates that could be misappropriated. Applicants
believe that these instruments are most suitably kept in the files of
the Managing Member (or a Citadel Entity), where they can be referred
to as necessary.
10. 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. Applicants request exemptive relief to permit the
Managing Member, regardless of whether it is deemed an interested
person of the ESC Funds, to take actions and make determinations set
forth in the rule. Applicants state that the ESC Funds are unable to
comply with Rule 17g-1 because the ESC Funds will not have a board of
directors and the Managing Member of the ESC Fund will be an interested
person of the ESC Funds. Applicants also state that the ESC Funds will
comply with all other requirements of rule 17g-1, except that the
Applicants request an exemption from the requirements of paragraphs (g)
and (h) of rule 17g-1 (relating to the filing of copies of fidelity
bonds and related information with the Commission and relating to the
provision of notices to the board of directors), and an exemption from
the requirements of paragraph (j)(3) of rule 17g-1 that the ESCs comply
with the fund governance standards defined in rule 0-1(a)(7).
11. 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 unnecessary and burdensome as applied to the ESC
Funds.
12. 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 an ESC
Fund and would entail administrative and legal costs that outweigh any
benefit to the Members of such ESC Fund. Applicants request exemptive
relief to the extent necessary to permit each ESC Fund to report
annually to its Members. Applicants also request an exemption from
section 30(h) of the Act to the extent necessary to exempt the Managing
Member of each ESC Fund, directors and officers of the Managing Member
and any other persons who may be deemed to be members of an advisory
board or an investment adviser (and affiliated persons thereof) of such
ESC Fund from filing Forms 3, 4, and 5 under section 16 of the Exchange
Act with respect to such ESC Fund. Applicants assert that, because
there will be no trading market and the transfers of Interests will be
severely
[[Page 41442]]
restricted, these filings are unnecessary for the protection of
investors and burdensome to those required to make them.
13. Rule 38a-1 requires investment companies to adopt, implement
and periodically review written policies and procedures reasonably
designed to prevent violation of the federal securities laws and to
appoint a chief compliance officer. Each ESC Fund will comply will rule
38a-1(a), (c) and (d), except that (a) because the ESC Funds do not
have a board of directors, the Managing Member will fulfill the
responsibilities assigned to a board of directors under the rule, (b)
because the Managing Member 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) because the ESC Funds do not
have any independent directors, the ESC Funds 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 Managing Member.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
1. Each proposed transaction to which an ESC Fund is a party
otherwise prohibited by section 17(a) or section 17(d) of the Act and
rule 17d-1 under the Act (the ``Section 17 Transactions'') will be
effected only if the Managing Member determines that: (a) The terms of
the Section 17 Transaction, including the consideration to be paid or
received, are fair and reasonable to the Members of the ESC Fund and do
not involve overreaching of the ESC Fund or its Members on the part of
any person concerned and (b) the Section 17 Transaction is consistent
with the interests of the Members of the ESC Fund, the ESC Fund's
organizational documents and the ESC Fund's reports to its Members.
In addition, the Managing Member will record and will preserve a
description of all Section 17 Transactions, the Managing Member's
findings, the information or materials upon which the findings are
based and the basis for the findings. All such records will be
maintained for the life of the ESC Fund and at least six years
thereafter, and will be subject to examination by the Commission and
its staff. Each ESC Fund will preserve the accounts, books and other
documents required to be maintained in an easily accessible place for
at least the first two years.
2. The Managing Member 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 any ESC Fund, or any
affiliated person of such affiliated person, promoter or principal
underwriter.
3. The Managing Member of each ESC Fund will not invest the funds
of the ESC Fund in 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 and where the investment involves a joint
enterprise or other joint arrangement within the meaning of rule 17d-1
in which the ESC Fund and the Co-Investor are participants, unless any
such Co-Investor, prior to disposing of all or part of its investment:
Agrees to (a) give the Managing Member sufficient, but not less than
one day's notice of its intent to dispose of its investment; and (b)
refrain from disposing of its investment unless the ESC Fund has the
opportunity to dispose of its investment prior to or concurrently with,
and on the same terms as, and pro rata with, the Co-Investor. The term
``Co-Investor'' with respect to any ESC Fund means any person who is:
(a) An ``affiliated person'' (as defined in section 2(a)(3) of the Act)
of the ESC Fund (other than a Citadel Third Party Fund); (b) a Citadel
Entity; (c) an officer, director or employee of a Citadel Entity; or
(d) an entity (other than a Citadel Third Party Fund) in which a
Managing Member or an Affiliate of Citadel acts as a managing member or
in a similar capacity so as to control the sale or other disposition of
the entity's investments. 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 the Co-Investor is a
direct or indirect wholly-owned subsidiary or to a direct or indirect
wholly-owned subsidiary of such Parent; (b) to immediate family members
of the Co-Investor or a trust or other investment vehicle established
for any such family member; or (c) when the investment is comprised of
securities that are (i) listed on any exchange registered as a national
exchange under section 6 of the Exchange Act; (ii) NMS stocks, pursuant
to section 11A(a)(2) of the Exchange Act and rule 600(a) of Regulation
NMS thereunder; (iii) government securities as defined in section
2(a)(16) of the Act, or (iv) listed 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 ESC Fund and its Managing Member will maintain and
preserve, for the life of such ESC Fund and at least six years
thereafter, such accounts, books, and other documents constituting the
record forming the basis for the audited financial statements that are
to be provided to the Members of such ESC Fund, and each annual report
of such ESC Fund required to be sent to such Members, and agree that
all such records will be subject to examination by the Commission and
its staff. Each ESC Fund will preserve the accounts, books and other
documents required to be maintained in an easily accessible place for
the first two years after the life of such ESC Fund.
5. The Managing Member of each ESC Fund will send to each person
who was a Member having an Interest in the ESC Fund at any time during
the fiscal year then ended (except for the first fiscal year of
operations of an ESC Fund if no investment activities took place in
such fiscal year), audited financial statements with respect to those
ESC Funds in which the Member held Interests. At the end of each fiscal
year, the Managing Member will make a valuation or have a valuation
made of all of the assets of the ESC Fund 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 ESC Fund. In addition,
within 180 days after the end of each fiscal year of each ESC Fund or
as soon as practicable thereafter, the Managing Member will send a
report to each person who was a Member at any time during the fiscal
year then ended, setting forth such tax information as shall be
necessary for the preparation by the Member of his, her or its U.S.
federal and state income tax returns and a report of the investment
activities of the ESC Fund during that fiscal year.
6. If an ESC Fund makes purchases from, or sales to, an entity
affiliated with the ESC Fund by reason of an officer, director or
employee of Citadel (a) serving as an officer, director, managing
member, 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 ESC Fund's
[[Page 41443]]
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. 2013-16537 Filed 7-9-13; 8:45 am]
BILLING CODE 8011-01-P