NGAM Advisors, L.P., et al.; Notice of Application, 46388-46392 [2013-18349]
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46388
Federal Register / Vol. 78, No. 147 / Wednesday, July 31, 2013 / Notices
Fund in excess of the limit in section
12(d)(1)(A)(i), an Investing Fund will
notify the Fund of the investment. At
such time, the Investing Fund will also
transmit to the Fund a list of the names
of each Investing Fund Affiliate and
Underwriting Affiliate. The Investing
Fund will notify the Fund of any
changes to the list as soon as reasonably
practicable after a change occurs. The
Fund and the Investing Fund will
maintain and preserve a copy of the
order, the FOF Participation Agreement,
and the list with any updated
information for the duration of the
investment and for a period of not less
than six years thereafter, the first two
years in an easily accessible place.
10. Before approving any advisory
contract under section 15 of the Act, the
board of directors or trustees of each
Investing Management Company,
including a majority of the independent
directors or trustees, will find that the
advisory fees charged under such
contract are based on services provided
that will be in addition to, rather than
duplicative of, the services provided
under the advisory contract(s) of any
Fund in which the Investing
Management Company may invest.
These findings and their basis will be
recorded fully in the minute books of
the appropriate Investing Management
Company.
11. Any sales charges and/or service
fees charged with respect to shares of an
Investing Fund will not exceed the
limits applicable to a fund of funds as
set forth in NASD Conduct Rule 2830.
12. No Fund relying on the section
12(d)(1) relief will acquire securities of
any investment company or company
relying on section 3(c)(1) or 3(c)(7) of
the Act in excess of the limits contained
in section 12(d)(1)(A) of the Act, except
to the extent permitted by exemptive
relief from the Commission permitting
the Fund to purchase shares of other
investment companies for short-term
cash management purposes.
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For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2013–18348 Filed 7–30–13; 8:45 am]
BILLING CODE 8011–01–P
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SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
30630; File No. 812–13942]
NGAM Advisors, L.P., et al.; Notice of
Application
July 25, 2013.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 6(c) of the
Investment Company Act of 1940 (the
‘‘Act’’) for an exemption from sections
2(a)(32), 5(a)(1), 22(d), and 22(e) of the
Act and rule 22c–1 under the Act, under
sections 6(c) and 17(b) of the Act for an
exemption from sections 17(a)(1) and
(a)(2) of the Act.
AGENCY:
Summary of Application: Applicants
request an order that would permit (a)
series of certain open-end management
investment companies to issue shares
(‘‘Shares’’) redeemable in large
aggregations only (‘‘Creation Unit
Aggregations’’); (b) secondary market
transactions in Shares to occur at
negotiated market prices; (c) certain
series to pay redemption proceeds,
under certain circumstances, more than
seven days after the tender of Shares for
redemption; and (d) certain affiliated
persons of the series to deposit
securities into, and receive securities
from, the series in connection with the
purchase and redemption of Creation
Unit Aggregations.
Applicants: NGAM Advisors, L.P. (the
‘‘Adviser’’), Natixis ETF Trust (the
‘‘Trust’’) and NGAM Distribution, L.P.
Filing Dates: The application was
filed on August 15, 2011, and amended
on February 8, 2012, April 20, 2012,
July 17, 2012 and May 30, 2013.
Hearing or Notification of Hearing: An
order granting the requested relief 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 August 19, 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
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NE., Washington, DC 20549–1090;
Applicants, 399 Boylston Street, Boston,
MA 02116.
FOR FURTHER INFORMATION CONTACT:
Emerson S. Davis, Sr., Senior Counsel at
(202) 551–6868, or Daniele Marchesani,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Exemptive Applications Office).
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.
SUPPLEMENTARY INFORMATION:
Applicants’ Representations
1. The Trust is a Massachusetts
business trust and will be registered
under the Act as an open-end
management investment company. The
Trust will initially offer one series, the
US Minimum Variance ETF (‘‘Initial
Fund’’), whose performance will
correspond generally to the price and
yield performance of a specified
securities index (‘‘Underlying Index’’).1
2. Applicants request that the order
apply to the Initial Fund and any future
series of the Trust or of any other openend management investment companies
that tracks a specified securities index
(‘‘Future Funds’’ and collectively with
the Initial Fund, the ‘‘Funds’’).2 Any
Fund will be (a) advised by the Adviser
or an entity controlling, controlled by,
or under common control with the
Adviser (any such entity is included in
the term ‘‘Adviser’’) and (b) comply
with the terms and conditions of the
application. Future Funds may be based
on indices that only contain global
equity securities or only contain global
fixed income securities (collectively,
‘‘Global Funds’’). Other Future Funds
may be based on (i) indices that only
contain domestic equity securities, (ii)
indices that only contain domestic fixed
income securities (‘‘Domestic Fixed
Income’’), (iii) indices containing a
blend of domestic equity and fixed
income securities (‘‘Blended
Domestic’’), or (iv) indices that only
contain international equity securities,
that only contain international fixed
income securities, or that contain a
blend of international equity and
1 The Underlying Index for the Initial Fund is the
Ossiam US Minimum Variance Net Return Index.
2 All entities that currently intend to rely on the
order have been named as applicants. Any other
existing or future entity that subsequently relies on
the order will comply with the terms and
conditions of the application.
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international fixed income securities
(collectively, ‘‘International Funds’’).
3. An Adviser registered as an
investment adviser under the
Investment Advisers Act of 1940 (the
‘‘Advisers Act’’) will serve as
investment adviser to the Funds, subject
to approval by the Board of Trustees of
the Trust or a Fund (the ‘‘Board’’).
4. The Adviser may enter into subadvisory agreements with one or more
investment advisers each of which will
serve as a sub-adviser to a Fund (each,
a ‘‘Subadviser’’). Each Subadviser will
be registered under the Advisers Act or
not subject to such registration. NGAM
Distribution, L.P. or another brokerdealer registered under the Securities
Exchange Act of 1934 (the ‘‘Exchange
Act’’) will act as the principal
underwriter and distributor for the
Funds (the ‘‘Distributor’’).
5. Each Fund will consist of a
portfolio of securities and other
instruments (‘‘Portfolio Securities’’)
selected to correspond generally to the
price and yield performance of a
specified Underlying Index. No entity
that creates, compiles, sponsors or
maintains an Underlying Index (‘‘Index
Provider’’) is or will be an affiliated
person, as defined in section 2(a)(3) of
the Act, or an affiliated person of an
affiliated person, of the Trust, a Fund,
a promoter, the Adviser, a Subadviser,
or a Distributor.
6. The investment objective of each
Fund will be to provide investment
results that closely correspond to the
price and yield performance of its
Underlying Index.3 Each Fund will
utilize either a replication or
representative sampling strategy to track
its Underlying Index. A Fund using a
replication strategy will invest in
substantially all of the Component
Securities in its Underlying Index in the
same approximate proportions as in the
Underlying Index. A Fund using a
representative sampling strategy will
hold a significant, but not necessarily all
of the Component Securities of its
Underlying Index.4 Applicants state that
if the representative sampling strategy is
used a Fund will not be expected to
track the performance of its Underlying
Index with the same degree of accuracy
as would a Fund employing the
replication strategy. Applicants expect
that each Fund will have a tracking
error relative to the performance of its
Underlying Index of no more than 5
percent.
7. Each Fund will sell and redeem
Creation Unit Aggregations on a
‘‘Business Day,’’ which is defined as any
day that a Trust is required to be open
under section 22(e) of the Act. The price
of a Fund Share will range from $20 to
$200, and the price of one Creation Unit
Aggregation will range from $1,000,000
to $10,000,000. All orders to purchase
Creation Unit Aggregations must be
placed with the Distributor by or
through an ‘‘Authorized Participant,’’
which is either: (1) A ‘‘participating
party,’’ i.e., a broker or other participant
in the Continuous Net Settlement
(‘‘CNS’’) System of the National
Securities Clearing Corporation
(‘‘NSCC’’), a clearing agency registered
with the Commission and affiliated with
the Depository Trust Company (‘‘DTC’’)
or (2) a DTC Participant, which in any
case, has executed a participant
agreement with the Distributor. The
Distributor will be responsible for
transmitting the orders to the Funds.
8. In order to keep costs low and,
potentially, permit closer tracking of
each Fund’s Underlying Index, Shares
will be purchased and redeemed in
Creation Unit Aggregations and
generally on an in-kind basis.
Accordingly, except where the purchase
or redemption will include cash under
the limited circumstances specified
below, purchasers will be required to
purchase Creation Unit Aggregations by
making an in-kind deposit of specified
instruments (‘‘Deposit Instruments’’),
and shareholders redeeming their
Shares will receive an in-kind transfer
of specified instruments (‘‘Redemption
Instruments’’).5 On any given Business
3 Applicants represent that each Fund will invest
at least 80% of its total assets in the component
securities that comprise its Underlying Index
(‘‘Component Securities’’), or in the case of
Domestic Fixed Income Funds and Blended
Domestic Funds, in Component Securities of its
respective Underlying Index and TBA Transactions
(as defined below) representing Component
Securities, and in the case of Global Funds and
International Funds, in Component Securities and
depositary receipts representing such Component
Securities. Each Fund may also invest up to 20%
of its assets in a broad variety of securities and
other instruments not included in its Underlying
Index, which the Adviser and/or Sub-Adviser
believes will help the Fund in tracking the
performance of the Underlying Index.
4 Securities are selected for inclusion in a Fund
following a representative sampling strategy to have
aggregate investment characteristics, fundamental
characteristics and liquidity measures similar to
those of the Fund’s Underlying Index taken in its
entirety.
5 The Funds must comply with the federal
securities laws in accepting Deposit Instruments
and satisfying redemptions with Redemption
Instruments, including that the Deposit Instruments
and Redemption Instruments are sold in
transactions that would be exempt from registration
under the Securities Act. In accepting Deposit
Instruments and satisfying redemptions with
Redemption Instruments that are restricted
securities eligible for resale pursuant to rule 144A
under the Securities Act, the Funds will comply
with the conditions of Rule 144A.
6 The portfolio used for this purpose will be the
same portfolio used to calculate the Fund’s NAV for
that Business Day.
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Day, the names and quantities of the
instruments that constitute the Deposit
Instruments and the names and
quantities of the instruments that
constitute the Redemption Instruments
will be identical, unless the Fund is
Rebalancing (as defined below). In
addition, the Deposit Instruments and
the Redemption Instruments will each
correspond pro rata to the positions in
the Fund’s portfolio (including cash
positions),6 except: (a) In the case of
bonds, for minor differences when it is
impossible to break up bonds beyond
certain minimum sizes needed for
transfer and settlement; (b) for minor
differences when rounding is necessary
to eliminate fractional shares or lots that
are not tradeable round lots; 7 (c) TBA
Transactions,8 derivatives and other
positions that cannot be transferred in
kind 9 will be excluded from the Deposit
Instruments and the Redemption
Instruments; 10(d) to the extent the Fund
determines, on a given Business Day, to
use a representative sampling of the
Fund’s portfolio; 11 or (e) for temporary
periods, to effect changes in the Fund’s
portfolio as a result of the rebalancing
of its Underlying Index (any such
change, a ‘‘Rebalancing’’).
9. If there is a difference between the
net asset value attributable to a Creation
Unit Aggregation and the aggregate
market value of the Deposit Instruments
or Redemption Instruments exchanged
for the Creation Unit Aggregation, the
party conveying instruments with the
lower value will also pay to the other an
amount in cash equal to that difference
(the ‘‘Cash Amount’’). A difference may
occur where the market value of the
Deposit Instruments or Redemption
Instruments, as applicable, changes
relative to the net asset value of the
Fund for the reasons identified in
clauses (a) through (e) above.
7 A tradeable round lot for a security will be the
standard unit of trading in that particular type of
security in its primary market.
8 A ‘TBA Transaction’ is a method of trading
mortgage-backed securities. In a TBA Transaction,
the buyer and seller agree upon general trade
parameters such as agency, settlement date, par
amount and price. The actual pools delivered
generally are determined two days prior to the
settlement date.
9 This includes instruments that can be
transferred in kind only with the consent of the
original counterparty to the extent the Fund does
not intend to seek such consents.
10 Because these instruments will be excluded
from the Deposit Instruments and the Redemption
Instruments, their value will be reflected in the
determination of the Cash Amount (defined below).
11 A Fund may only use sampling for this purpose
if the sample: (i) Is designed to generate
performance that is highly correlated to the
performance of the Fund’s portfolio; (ii) consists
entirely of instruments that are already included in
the Fund’s portfolio; and (iii) is the same for all
Authorized Participants on a given Business Day.
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10. Purchases and redemptions of
Creation Unit Aggregations may be
made in whole or in part on a cash
basis, rather than in kind, solely under
the following circumstances: (a) To the
extent there is a Cash Amount, as
described above; (b) if, on a given
Business Day, the Fund announces
before the open of trading that all
purchases, all redemptions or all
purchases and redemptions on that day
will be made entirely in cash; (c) if,
upon receiving a purchase or
redemption order from an Authorized
Participant, the Fund determines to
require the purchase or redemption, as
applicable, to be made entirely in
cash; 12 (d) if, on a given Business Day,
the Fund requires all Authorized
Participants purchasing or redeeming
Shares on that day to deposit or receive
(as applicable) cash in lieu of some or
all of the Deposit Instruments or
Redemption Instruments, respectively,
solely because: (i) Such instruments are
not eligible for transfer through either
the NSCC Process or DTC Process; or (ii)
in the case of Global Funds and
International Funds, such instruments
are not eligible for trading due to local
trading restrictions, local restrictions on
securities transfers or other similar
circumstances; or (e) if the Fund permits
an Authorized Participant to deposit or
receive (as applicable) cash in lieu of
some or all of the Deposit Instruments
or Redemption Instruments,
respectively, solely because: (i) Such
instruments are, in the case of the
purchase of a Creation Unit
Aggregations, not available in sufficient
quantity; (ii) such instruments are not
eligible for trading by an Authorized
Participant or the investor on whose
behalf the Authorized Participant is
acting; or (iii) a holder of Shares of a
Global Fund or International Fund
would be subject to unfavorable income
tax treatment if the holder receives
redemption proceeds in kind.13
12 In determining whether a particular Fund will
sell or redeem Creation Unit Aggregations entirely
on a cash or in-kind basis (whether for a given day
or a given order), the key consideration will be the
benefit that would accrue to the Fund and its
investors. For instance, in bond transactions, the
Adviser may be able to obtain better execution than
Share purchasers because of the Adviser’s size,
experience and potentially stronger relationships in
the fixed income markets. Purchases of Creation
Unit Aggregations either on an all cash basis or inkind are expected to be neutral to the Funds from
a tax perspective. In contrast, cash redemptions
typically require selling portfolio holdings, which
may result in adverse tax consequences for the
remaining Fund shareholders that would not occur
with an in-kind redemption. As a result, tax
considerations may warrant in-kind redemptions.
13 A ‘‘custom order’’ is any purchase or
redemption of Shares made in whole or in part on
a cash basis in reliance on clause (e)(i) or (e)(ii).
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11. Each Business Day, before the
open of trading on a national securities
exchange as defined in Section 2(a)(26)
of the Act (‘‘Exchange’’), the Fund will
cause to be published through the NSCC
the names and quantities of the
instruments comprising the Deposit
Instruments and the Redemption
Instruments, as well as the estimated
Cash Amount (if any), for that day.14
The list of Deposit Instruments and
Redemption Instruments will apply
until a new list is announced on the
following Business Day, and there will
be no intra-day changes to the list
except to correct errors in the published
list.
12. An investor acquiring or
redeeming a Creation Unit Aggregation
from a Fund will be charged a fee
(‘‘Transaction Fee’’) to prevent the
dilution of the interests of the remaining
shareholders resulting from costs in
connection with the purchase or
redemption of Creation Unit
Aggregations.15 The Distributor will
furnish the Fund’s prospectus and
confirmation to those persons
purchasing Shares in Creation Units
Aggregations and will maintain a record
of the instructions given to the
applicable Fund to implement the
delivery of its Shares.
13. Shares will be listed and traded on
an Exchange. One or more Exchange
market makers (‘‘Market Makers’’) will
be assigned to the Shares and maintain
a market for Shares trading on the
Exchange.16 Prices of Shares trading on
an Exchange will be based on the
current bid/offer market. Shares sold in
the secondary market will be subject to
customary brokerage commissions and
charges.
14. Applicants expect that purchasers
of Creation Unit Aggregations will
include institutional investors and
arbitrageurs. Authorized Participants
also may purchase Creation Unit
Aggregations for use in market-making
activities. Applicants expect that
secondary market purchasers of Shares
will include both institutional investors
and retail investors.17 Applicants expect
14 If the Fund is Rebalancing, it may need to
announce two estimated Cash Amounts for that
day, one for deposits and one for redemptions.
15 Where a Fund permits an in-kind purchaser to
deposit cash in lieu of depositing one or more
Deposit Instruments, the purchaser may be assessed
a higher Transaction Fee to offset the transaction
cost to the Fund of buying those particular Deposit
Instruments.
16 If Shares are listed on NASDAQ Stock Market
LLC or a similar electronic Exchange (including
NYSE Arca), one or more member firms of that
Exchange will act as Market Maker and maintain a
market for Shares trading on the Exchange
17 Shares will be registered in book-entry form
only. DTC or its nominee will be the registered
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that the price at which Shares trade will
be disciplined by arbitrage
opportunities created by the ability to
purchase or redeem Creation Unit
Aggregations at their NAV, which
should ensure that Shares will not trade
at a material discount or premium in
relation to their NAV.
15. Shares will not be individually
redeemable, and owners of Shares may
acquire those Shares from the Fund, or
tender such Shares for redemption to
the Fund, in Creation Unit Aggregations
only. To redeem, an investor will have
to accumulate enough Shares to
constitute a Creation Unit Aggregation.
Redemption orders must be placed by or
through an Authorized Participant.
16. Neither the Trust nor any Fund
will be advertised, marketed or
otherwise held out as a traditional openend investment company or a mutual
fund. Instead, each Fund will be
advertised or marketed as an
‘‘exchange–traded fund.’’ All marketing
materials that describe the features or
method of obtaining, buying or selling
Creation Unit Aggregations or Shares
traded on an Exchange, or refer to
redeemability, will prominently
disclose that Shares are not individually
redeemable and that the owners of
Shares may purchase or redeem Shares
from the Fund in Creation Unit
Aggregations only. The same approach
will be followed in the shareholder
reports and investor educational
materials issued or circulated in
connection with the Shares. The Trust
will provide copies of their annual and
semi-annual shareholder reports to DTC
Participants for distribution to
shareholders.
Applicants’ Legal Analysis
1. Applicants request an order under
section 6(c) of the Act for an exemption
from sections 2(a)(32), 5(a)(1), 22(d), and
22(e) of the Act and rule 22c–1 under
the Act, under sections 6(c) and 17(b) of
the Act for an exemption from sections
17(a)(1) and 17(a)(2) of the Act.
2. Section 6(c) of the Act provides that
the Commission may exempt any
person, security or transaction, or any
class of persons, securities or
transactions, from any provision of the
Act, if and to the extent that 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. Section 17(b)
of the Act authorizes the Commission to
exempt a proposed transaction from
owner of all outstanding Shares. DTC or DTC
Participants will maintain records reflecting
beneficial owners of Shares.
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section 17(a) of the Act if evidence
establishes that the terms of the
transaction, including the consideration
to be paid or received, are reasonable
and fair and do not involve
overreaching on the part of any person
concerned, and the proposed
transaction is consistent with the
policies of the registered investment
company and the general provisions of
the Act.
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Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an
‘‘open-end company’’ as a management
investment company that is offering for
sale or has outstanding any redeemable
security of which it is the issuer.
Section 2(a)(32) of the Act defines a
redeemable security as any security,
other than short-term paper, under the
terms of which the holder, upon its
presentation to the issuer, is entitled to
receive approximately his proportionate
share of the issuer’s current net assets,
or the cash equivalent. Because Shares
will not be individually redeemable,
applicants request an order that would
permit the Funds to register as open-end
management investment companies and
issue Shares that are redeemable in
Creation Unit Aggregations only.
Applicants state that investors may
purchase Shares in Creation Unit
Aggregations and redeem Creation Unit
Aggregations from each Fund.
Applicants state that because the market
price of Shares will be disciplined by
arbitrage opportunities investors should
be able to sell Shares in the secondary
market at prices that do not vary
materially from their NAV.
Section 22(d) of the Act and Rule 22c–
1 Under the Act
4. Section 22(d) of the Act, among
other things, prohibits a dealer from
selling a redeemable security that is
currently being offered to the public by
or through an underwriter, except at a
current public offering price described
in the prospectus. Rule 22c–1 under the
Act generally requires that a dealer
selling, redeeming or repurchasing a
redeemable security do so only at a
price based on its NAV. Applicants state
that secondary market trading in Shares
will take place at negotiated prices, not
at a current offering price described in
a Fund’s prospectus, and not at a price
based on NAV. Thus, purchases and
sales of Shares in the secondary market
will not comply with section 22(d) of
the Act and rule 22c–1 under the Act.
Applicants request an exemption under
section 6(c) from these provisions.
5. Applicants assert that the concerns
sought to be addressed by section 22(d)
of the Act and rule 22c–1 under the Act
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with respect to pricing are equally
satisfied by the proposed method of
pricing Shares. Applicants maintain that
while there is little legislative history
regarding section 22(d), its provisions,
as well as those of rule 22c–1, appear to
have been designed to (a) prevent
dilution caused by certain riskless
trading schemes by principal
underwriters and contract dealers, (b)
prevent unjust discrimination or
preferential treatment among buyers,
and (c) ensure an orderly distribution of
investment company shares by
eliminating price competition from noncontract dealers offering shares at less
than the published sales price and
repurchasing shares at more than the
published redemption price.
6. Applicants believe that none of
these purposes will be thwarted by
permitting Shares to trade in the
secondary market at negotiated prices.
Applicants state that (a) secondary
market trading in Shares does not
involve a Fund as a party and will not
result in dilution of an investment in
Shares, and (b) to the extent different
prices exist during a given trading day,
or from day to day, such variances occur
as a result of third party market forces,
such as supply and demand. Therefore,
applicants assert that secondary market
transactions in Shares will not lead to
discrimination or preferential treatment
among purchasers. Finally, applicants
contend that the proposed distribution
system will be orderly because
competitive forces will ensure that the
difference between the market price of
Shares and their NAV remains narrow.
Section 22(e)
7. Section 22(e) of the Act generally
prohibits a registered investment
company from suspending the right of
redemption or postponing the date of
payment of redemption proceeds for
more than seven days after the tender of
a security for redemption. Applicants
observe that the settlement of
redemptions of Creation Unit
Aggregations of the Global and
International Funds is contingent not
only on the settlement cycle of the U.S.
securities markets, but also on the
delivery cycles present in international
markets in which those Funds invest.
Applicants state that, under certain
circumstances, the delivery cycles for
transferring Portfolio Securities to
redeeming investors, coupled with local
market holiday schedules, will require a
delivery process of up to 14 calendar
days. Applicants therefore request relief
from section 22(e) in order to provide
for payment or satisfaction of
redemptions within a longer number of
calendar days required for such
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payment or satisfaction in the principal
local markets where transactions in the
Portfolio Securities of each Global Fund
and International Fund customarily
clear and settle, but in all cases no later
than 14 calendar days following the
tender of a Creation Unit Aggregation.18
With respect to Future Funds that are
Global Funds or International Funds,
applicants seek the same relief from
section 22(e) only to the extent that
circumstances exist similar to those
described in the application.
8. Applicants submit that section
22(e) was designed to prevent
unreasonable, undisclosed and
unforeseen delays in the actual payment
of redemption proceeds. Applicants
state that allowing redemption
payments for Creation Unit
Aggregations of a Fund to be made
within the number of days indicated
above would not be inconsistent with
the spirit and intent of section 22(e).
Applicants state that the SAI will
disclose those local holidays (over the
period of at least one year following the
date of the SAI), if any, that are
expected to prevent the delivery of
redemption proceeds in seven calendar
days, and the maximum number of days
needed to deliver the proceeds for each
affected Global and International Fund.
Applicants are not seeking relief from
section 22(e) with respect to Global
Funds and International Funds that do
not effect redemptions of Creation Unit
Aggregations in-kind.
Sections 17(a)(1) and (2) of the Act
9. Section 17(a) of the Act generally
prohibits an affiliated person of a
registered investment company, or an
affiliated person of such a person
(‘‘second-tier affiliate’’), from selling any
security to or acquiring any security
from the company. Section 2(a)(3) of the
Act defines ‘‘affiliated person’’ to
include (a) any person directly or
indirectly owning, controlling or
holding with power to vote 5% or more
of the outstanding voting securities of
the other person, (b) any person 5% or
more of whose outstanding voting
securities are directly or indirectly
owned, controlled or held with the
power to vote by the other person, and
(c) any person directly or indirectly
controlling, controlled by or under
common control with the other person.
Section 2(a)(9) of the Act defines
‘‘control’’ as the power to exercise a
controlling influence over the
18 Applicants acknowledge that no relief obtained
from the requirements of section 22(e) will affect
any obligations applicants may have under rule
15c6–1 under the Exchange Act. Rule 15c6–1
requires that most securities transactions be settled
within three business days of the trade.
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Federal Register / Vol. 78, No. 147 / Wednesday, July 31, 2013 / Notices
mstockstill on DSK4VPTVN1PROD with NOTICES
management or policies of a company
and provides that a control relationship
will be presumed where one person
owns more than 25% of another
person’s voting securities. Each Fund
may be deemed to be controlled by an
Adviser and hence affiliated persons of
each other. In addition, the Funds may
be deemed to be under common control
with any other registered investment
company (or series thereof) advised by
the Adviser or an entity controlling,
controlled by or under common control
with the Adviser (an ‘‘Affiliated Fund’’).
10. Applicants request an exemption
from section 17(a) of the Act pursuant
to sections 17(b) and 6(c) of the Act to
permit persons to effectuate in-kind
purchases and redemptions with a Fund
when they are affiliated persons of the
Fund or second-tier affiliates solely by
virtue of one or more of the following:
(a) Holding 5% or more, or in excess of
25%, of the outstanding Shares of one
or more Funds; (b) having an affiliation
with a person with an ownership
interest described in (a); or (c) holding
5% or more, or more than 25%, of the
shares of one or more Affiliated Funds.
11. Applicants assert that no useful
purpose would be served by prohibiting
these types of affiliated persons from
acquiring or redeeming Creation Unit
Aggregations through ‘‘in-kind’’
transactions. The deposit procedures for
both in kind purchases and in-kind
redemptions of Creation Unit
Aggregations will be the same for all
purchases and redemptions. Deposit
Instruments, Redemption Instruments,
and the balancing cash amounts (except
for any permitted cash-in-lieu amounts)
will be the same regardless of the
identity of the purchaser or redeemer
and the Deposit Instruments and
Redemption Instruments will be valued
in the same manner as Portfolio
Securities. Therefore, applicants state
that in-kind purchases and redemptions
will afford no opportunity for the
specified affiliated persons, or secondtier affiliates, of a Fund to effect a
transaction detrimental to other holders
of Shares. Applicants also believe that
in-kind purchases and redemptions will
not result in self-dealing or overreaching
of the Fund.
Applicants’ Conditions
Applicants agree that any order of the
Commission granting the requested
relief will be subject to the following
conditions:
ETF Relief
1. As long as the Trust operates in
reliance on the requested order, the
Shares of the Funds will be listed on an
Exchange.
VerDate Mar<15>2010
16:14 Jul 30, 2013
Jkt 229001
2. Neither the Trust nor any Fund will
be advertised or marketed as an openend investment company or a mutual
fund. Any advertising material that
describes the purchase or sale of
Creation Unit Aggregations or refers to
redeemability will prominently disclose
that Fund Shares are not individually
redeemable and that owners of Fund
Shares may acquire those Fund Shares
from a Fund and tender those Fund
Shares for redemption to a Fund in
Creation Unit Aggregations only.
3. The Web site for the Funds, which
is and will be publicly accessible at no
charge, will contain the following
information, on a per Share basis, for
each Fund, the prior Business Day’s
NAV and the market closing price or the
midpoint of the bid/ask spread at the
time of the calculation of such NAV
(‘‘Bid/Ask Price’’), and a calculation of
the premium or discount of the market
closing price or Bid/Ask Price against
such NAV.
4. The requested relief to permit ETF
operations will expire on the effective
date of any Commission rule under the
Act that provides relief permitting the
operation of index-based exchangetraded funds.
solicit comments on the proposed rule
change from interested persons.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and the
Statutory Basis for, the Proposed Rule
Change
[FR Doc. 2013–18349 Filed 7–30–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–70038; File No. SR–
NYSEArca–2013–72]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Adding a New Rule To
Codify Existing Price Protection
Mechanisms
July 25, 2013.
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that, on July 17,
2013, NYSE Arca, Inc. (the ‘‘Exchange’’
or ‘‘NYSE Arca’’) filed with the
Securities and Exchange Commission
(the ‘‘Commission’’) the proposed rule
change as described in Items I and II
below, which Items have been prepared
by the self-regulatory organization. The
Commission is publishing this notice to
PO 00000
1 15
U.S.C.78s(b)(1).
U.S.C. 78a.
3 17 CFR 240.19b–4.
2 15
Frm 00081
Fmt 4703
Sfmt 4703
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to add a new
rule to codify existing price protection
mechanisms. The text of the proposed
rule change is available on the
Exchange’s Web site at www.nyse.com,
at the principal office of the Exchange,
and at the Commission’s Public
Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
of those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
1. Purpose
The Exchange is proposing to add
Rule 6.60 to codify and clarify price
protection mechanisms already in use
on the Exchange. The Exchange has in
place various price check parameter
features that are designed to help
maintain a fair and orderly market by
preventing incoming options orders
from automatically executing at
potentially erroneous prices. The
Exchange believes that the features
assist with the maintenance of fair and
orderly markets by helping to mitigate
the potential risks associated with
orders sweeping through multiple price
points, thereby resulting in executions
at prices that are away from the last sale
price or best bid or offer and that are
potentially erroneous. The Exchange is
proposing to add a new rule to codify
existing price check protection and
order handling features to provide
clarity on the operation of the
functionality.
Trading Collars
The Exchange applies a ‘‘Trade Collar
Protection’’ mechanism that prevents
the immediate execution of incoming
market orders or marketable limit orders
(‘‘marketable orders’’) outside of a
specified parameter (referred to as a
E:\FR\FM\31JYN1.SGM
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Agencies
[Federal Register Volume 78, Number 147 (Wednesday, July 31, 2013)]
[Notices]
[Pages 46388-46392]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-18349]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 30630; File No. 812-13942]
NGAM Advisors, L.P., et al.; Notice of Application
July 25, 2013.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under section 6(c) of the
Investment Company Act of 1940 (the ``Act'') for an exemption from
sections 2(a)(32), 5(a)(1), 22(d), and 22(e) of the Act and rule 22c-1
under the Act, under sections 6(c) and 17(b) of the Act for an
exemption from sections 17(a)(1) and (a)(2) of the Act.
-----------------------------------------------------------------------
Summary of Application: Applicants request an order that would
permit (a) series of certain open-end management investment companies
to issue shares (``Shares'') redeemable in large aggregations only
(``Creation Unit Aggregations''); (b) secondary market transactions in
Shares to occur at negotiated market prices; (c) certain series to pay
redemption proceeds, under certain circumstances, more than seven days
after the tender of Shares for redemption; and (d) certain affiliated
persons of the series to deposit securities into, and receive
securities from, the series in connection with the purchase and
redemption of Creation Unit Aggregations.
Applicants: NGAM Advisors, L.P. (the ``Adviser''), Natixis ETF
Trust (the ``Trust'') and NGAM Distribution, L.P.
Filing Dates: The application was filed on August 15, 2011, and
amended on February 8, 2012, April 20, 2012, July 17, 2012 and May 30,
2013.
Hearing or Notification of Hearing: An order granting the requested
relief 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 August 19, 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, 399 Boylston Street,
Boston, MA 02116.
FOR FURTHER INFORMATION CONTACT: Emerson S. Davis, Sr., 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 name box, at https://www.sec.gov/search/search.htm or
by calling (202) 551-8090.
Applicants' Representations
1. The Trust is a Massachusetts business trust and will be
registered under the Act as an open-end management investment company.
The Trust will initially offer one series, the US Minimum Variance ETF
(``Initial Fund''), whose performance will correspond generally to the
price and yield performance of a specified securities index
(``Underlying Index'').\1\
---------------------------------------------------------------------------
\1\ The Underlying Index for the Initial Fund is the Ossiam US
Minimum Variance Net Return Index.
---------------------------------------------------------------------------
2. Applicants request that the order apply to the Initial Fund and
any future series of the Trust or of any other open-end management
investment companies that tracks a specified securities index (``Future
Funds'' and collectively with the Initial Fund, the ``Funds'').\2\ Any
Fund will be (a) advised by the Adviser or an entity controlling,
controlled by, or under common control with the Adviser (any such
entity is included in the term ``Adviser'') and (b) comply with the
terms and conditions of the application. Future Funds may be based on
indices that only contain global equity securities or only contain
global fixed income securities (collectively, ``Global Funds''). Other
Future Funds may be based on (i) indices that only contain domestic
equity securities, (ii) indices that only contain domestic fixed income
securities (``Domestic Fixed Income''), (iii) indices containing a
blend of domestic equity and fixed income securities (``Blended
Domestic''), or (iv) indices that only contain international equity
securities, that only contain international fixed income securities, or
that contain a blend of international equity and
[[Page 46389]]
international fixed income securities (collectively, ``International
Funds'').
---------------------------------------------------------------------------
\2\ All entities that currently intend to rely on the order have
been named as applicants. Any other existing or future entity that
subsequently relies on the order will comply with the terms and
conditions of the application.
---------------------------------------------------------------------------
3. An Adviser registered as an investment adviser under the
Investment Advisers Act of 1940 (the ``Advisers Act'') will serve as
investment adviser to the Funds, subject to approval by the Board of
Trustees of the Trust or a Fund (the ``Board'').
4. The Adviser may enter into sub-advisory agreements with one or
more investment advisers each of which will serve as a sub-adviser to a
Fund (each, a ``Subadviser''). Each Subadviser will be registered under
the Advisers Act or not subject to such registration. NGAM
Distribution, L.P. or another broker-dealer registered under the
Securities Exchange Act of 1934 (the ``Exchange Act'') will act as the
principal underwriter and distributor for the Funds (the
``Distributor'').
5. Each Fund will consist of a portfolio of securities and other
instruments (``Portfolio Securities'') selected to correspond generally
to the price and yield performance of a specified Underlying Index. No
entity that creates, compiles, sponsors or maintains an Underlying
Index (``Index Provider'') is or will be an affiliated person, as
defined in section 2(a)(3) of the Act, or an affiliated person of an
affiliated person, of the Trust, a Fund, a promoter, the Adviser, a
Subadviser, or a Distributor.
6. The investment objective of each Fund will be to provide
investment results that closely correspond to the price and yield
performance of its Underlying Index.\3\ Each Fund will utilize either a
replication or representative sampling strategy to track its Underlying
Index. A Fund using a replication strategy will invest in substantially
all of the Component Securities in its Underlying Index in the same
approximate proportions as in the Underlying Index. A Fund using a
representative sampling strategy will hold a significant, but not
necessarily all of the Component Securities of its Underlying Index.\4\
Applicants state that if the representative sampling strategy is used a
Fund will not be expected to track the performance of its Underlying
Index with the same degree of accuracy as would a Fund employing the
replication strategy. Applicants expect that each Fund will have a
tracking error relative to the performance of its Underlying Index of
no more than 5 percent.
---------------------------------------------------------------------------
\3\ Applicants represent that each Fund will invest at least 80%
of its total assets in the component securities that comprise its
Underlying Index (``Component Securities''), or in the case of
Domestic Fixed Income Funds and Blended Domestic Funds, in Component
Securities of its respective Underlying Index and TBA Transactions
(as defined below) representing Component Securities, and in the
case of Global Funds and International Funds, in Component
Securities and depositary receipts representing such Component
Securities. Each Fund may also invest up to 20% of its assets in a
broad variety of securities and other instruments not included in
its Underlying Index, which the Adviser and/or Sub-Adviser believes
will help the Fund in tracking the performance of the Underlying
Index.
\4\ Securities are selected for inclusion in a Fund following a
representative sampling strategy to have aggregate investment
characteristics, fundamental characteristics and liquidity measures
similar to those of the Fund's Underlying Index taken in its
entirety.
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7. Each Fund will sell and redeem Creation Unit Aggregations on a
``Business Day,'' which is defined as any day that a Trust is required
to be open under section 22(e) of the Act. The price of a Fund Share
will range from $20 to $200, and the price of one Creation Unit
Aggregation will range from $1,000,000 to $10,000,000. All orders to
purchase Creation Unit Aggregations must be placed with the Distributor
by or through an ``Authorized Participant,'' which is either: (1) A
``participating party,'' i.e., a broker or other participant in the
Continuous Net Settlement (``CNS'') System of the National Securities
Clearing Corporation (``NSCC''), a clearing agency registered with the
Commission and affiliated with the Depository Trust Company (``DTC'')
or (2) a DTC Participant, which in any case, has executed a participant
agreement with the Distributor. The Distributor will be responsible for
transmitting the orders to the Funds.
8. In order to keep costs low and, potentially, permit closer
tracking of each Fund's Underlying Index, Shares will be purchased and
redeemed in Creation Unit Aggregations and generally on an in-kind
basis. Accordingly, except where the purchase or redemption will
include cash under the limited circumstances specified below,
purchasers will be required to purchase Creation Unit Aggregations by
making an in-kind deposit of specified instruments (``Deposit
Instruments''), and shareholders redeeming their Shares will receive an
in-kind transfer of specified instruments (``Redemption
Instruments'').\5\ On any given Business Day, the names and quantities
of the instruments that constitute the Deposit Instruments and the
names and quantities of the instruments that constitute the Redemption
Instruments will be identical, unless the Fund is Rebalancing (as
defined below). In addition, the Deposit Instruments and the Redemption
Instruments will each correspond pro rata to the positions in the
Fund's portfolio (including cash positions),\6\ except: (a) In the case
of bonds, for minor differences when it is impossible to break up bonds
beyond certain minimum sizes needed for transfer and settlement; (b)
for minor differences when rounding is necessary to eliminate
fractional shares or lots that are not tradeable round lots; \7\ (c)
TBA Transactions,\8\ derivatives and other positions that cannot be
transferred in kind \9\ will be excluded from the Deposit Instruments
and the Redemption Instruments; \10\(d) to the extent the Fund
determines, on a given Business Day, to use a representative sampling
of the Fund's portfolio; \11\ or (e) for temporary periods, to effect
changes in the Fund's portfolio as a result of the rebalancing of its
Underlying Index (any such change, a ``Rebalancing'').
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\5\ The Funds must comply with the federal securities laws in
accepting Deposit Instruments and satisfying redemptions with
Redemption Instruments, including that the Deposit Instruments and
Redemption Instruments are sold in transactions that would be exempt
from registration under the Securities Act. In accepting Deposit
Instruments and satisfying redemptions with Redemption Instruments
that are restricted securities eligible for resale pursuant to rule
144A under the Securities Act, the Funds will comply with the
conditions of Rule 144A.
\6\ The portfolio used for this purpose will be the same
portfolio used to calculate the Fund's NAV for that Business Day.
\7\ A tradeable round lot for a security will be the standard
unit of trading in that particular type of security in its primary
market.
\8\ A `TBA Transaction' is a method of trading mortgage-backed
securities. In a TBA Transaction, the buyer and seller agree upon
general trade parameters such as agency, settlement date, par amount
and price. The actual pools delivered generally are determined two
days prior to the settlement date.
\9\ This includes instruments that can be transferred in kind
only with the consent of the original counterparty to the extent the
Fund does not intend to seek such consents.
\10\ Because these instruments will be excluded from the Deposit
Instruments and the Redemption Instruments, their value will be
reflected in the determination of the Cash Amount (defined below).
\11\ A Fund may only use sampling for this purpose if the
sample: (i) Is designed to generate performance that is highly
correlated to the performance of the Fund's portfolio; (ii) consists
entirely of instruments that are already included in the Fund's
portfolio; and (iii) is the same for all Authorized Participants on
a given Business Day.
---------------------------------------------------------------------------
9. If there is a difference between the net asset value
attributable to a Creation Unit Aggregation and the aggregate market
value of the Deposit Instruments or Redemption Instruments exchanged
for the Creation Unit Aggregation, the party conveying instruments with
the lower value will also pay to the other an amount in cash equal to
that difference (the ``Cash Amount''). A difference may occur where the
market value of the Deposit Instruments or Redemption Instruments, as
applicable, changes relative to the net asset value of the Fund for the
reasons identified in clauses (a) through (e) above.
[[Page 46390]]
10. Purchases and redemptions of Creation Unit Aggregations may be
made in whole or in part on a cash basis, rather than in kind, solely
under the following circumstances: (a) To the extent there is a Cash
Amount, as described above; (b) if, on a given Business Day, the Fund
announces before the open of trading that all purchases, all
redemptions or all purchases and redemptions on that day will be made
entirely in cash; (c) if, upon receiving a purchase or redemption order
from an Authorized Participant, the Fund determines to require the
purchase or redemption, as applicable, to be made entirely in cash;
\12\ (d) if, on a given Business Day, the Fund requires all Authorized
Participants purchasing or redeeming Shares on that day to deposit or
receive (as applicable) cash in lieu of some or all of the Deposit
Instruments or Redemption Instruments, respectively, solely because:
(i) Such instruments are not eligible for transfer through either the
NSCC Process or DTC Process; or (ii) in the case of Global Funds and
International Funds, such instruments are not eligible for trading due
to local trading restrictions, local restrictions on securities
transfers or other similar circumstances; or (e) if the Fund permits an
Authorized Participant to deposit or receive (as applicable) cash in
lieu of some or all of the Deposit Instruments or Redemption
Instruments, respectively, solely because: (i) Such instruments are, in
the case of the purchase of a Creation Unit Aggregations, not available
in sufficient quantity; (ii) such instruments are not eligible for
trading by an Authorized Participant or the investor on whose behalf
the Authorized Participant is acting; or (iii) a holder of Shares of a
Global Fund or International Fund would be subject to unfavorable
income tax treatment if the holder receives redemption proceeds in
kind.\13\
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\12\ In determining whether a particular Fund will sell or
redeem Creation Unit Aggregations entirely on a cash or in-kind
basis (whether for a given day or a given order), the key
consideration will be the benefit that would accrue to the Fund and
its investors. For instance, in bond transactions, the Adviser may
be able to obtain better execution than Share purchasers because of
the Adviser's size, experience and potentially stronger
relationships in the fixed income markets. Purchases of Creation
Unit Aggregations either on an all cash basis or in-kind are
expected to be neutral to the Funds from a tax perspective. In
contrast, cash redemptions typically require selling portfolio
holdings, which may result in adverse tax consequences for the
remaining Fund shareholders that would not occur with an in-kind
redemption. As a result, tax considerations may warrant in-kind
redemptions.
\13\ A ``custom order'' is any purchase or redemption of Shares
made in whole or in part on a cash basis in reliance on clause
(e)(i) or (e)(ii).
---------------------------------------------------------------------------
11. Each Business Day, before the open of trading on a national
securities exchange as defined in Section 2(a)(26) of the Act
(``Exchange''), the Fund will cause to be published through the NSCC
the names and quantities of the instruments comprising the Deposit
Instruments and the Redemption Instruments, as well as the estimated
Cash Amount (if any), for that day.\14\ The list of Deposit Instruments
and Redemption Instruments will apply until a new list is announced on
the following Business Day, and there will be no intra-day changes to
the list except to correct errors in the published list.
---------------------------------------------------------------------------
\14\ If the Fund is Rebalancing, it may need to announce two
estimated Cash Amounts for that day, one for deposits and one for
redemptions.
---------------------------------------------------------------------------
12. An investor acquiring or redeeming a Creation Unit Aggregation
from a Fund will be charged a fee (``Transaction Fee'') to prevent the
dilution of the interests of the remaining shareholders resulting from
costs in connection with the purchase or redemption of Creation Unit
Aggregations.\15\ The Distributor will furnish the Fund's prospectus
and confirmation to those persons purchasing Shares in Creation Units
Aggregations and will maintain a record of the instructions given to
the applicable Fund to implement the delivery of its Shares.
---------------------------------------------------------------------------
\15\ Where a Fund permits an in-kind purchaser to deposit cash
in lieu of depositing one or more Deposit Instruments, the purchaser
may be assessed a higher Transaction Fee to offset the transaction
cost to the Fund of buying those particular Deposit Instruments.
---------------------------------------------------------------------------
13. Shares will be listed and traded on an Exchange. One or more
Exchange market makers (``Market Makers'') will be assigned to the
Shares and maintain a market for Shares trading on the Exchange.\16\
Prices of Shares trading on an Exchange will be based on the current
bid/offer market. Shares sold in the secondary market will be subject
to customary brokerage commissions and charges.
---------------------------------------------------------------------------
\16\ If Shares are listed on NASDAQ Stock Market LLC or a
similar electronic Exchange (including NYSE Arca), one or more
member firms of that Exchange will act as Market Maker and maintain
a market for Shares trading on the Exchange
---------------------------------------------------------------------------
14. Applicants expect that purchasers of Creation Unit Aggregations
will include institutional investors and arbitrageurs. Authorized
Participants also may purchase Creation Unit Aggregations for use in
market-making activities. Applicants expect that secondary market
purchasers of Shares will include both institutional investors and
retail investors.\17\ Applicants expect that the price at which Shares
trade will be disciplined by arbitrage opportunities created by the
ability to purchase or redeem Creation Unit Aggregations at their NAV,
which should ensure that Shares will not trade at a material discount
or premium in relation to their NAV.
---------------------------------------------------------------------------
\17\ Shares will be registered in book-entry form only. DTC or
its nominee will be the registered owner of all outstanding Shares.
DTC or DTC Participants will maintain records reflecting beneficial
owners of Shares.
---------------------------------------------------------------------------
15. Shares will not be individually redeemable, and owners of
Shares may acquire those Shares from the Fund, or tender such Shares
for redemption to the Fund, in Creation Unit Aggregations only. To
redeem, an investor will have to accumulate enough Shares to constitute
a Creation Unit Aggregation. Redemption orders must be placed by or
through an Authorized Participant.
16. Neither the Trust nor any Fund will be advertised, marketed or
otherwise held out as a traditional open-end investment company or a
mutual fund. Instead, each Fund will be advertised or marketed as an
``exchange-traded fund.'' All marketing materials that describe the
features or method of obtaining, buying or selling Creation Unit
Aggregations or Shares traded on an Exchange, or refer to
redeemability, will prominently disclose that Shares are not
individually redeemable and that the owners of Shares may purchase or
redeem Shares from the Fund in Creation Unit Aggregations only. The
same approach will be followed in the shareholder reports and investor
educational materials issued or circulated in connection with the
Shares. The Trust will provide copies of their annual and semi-annual
shareholder reports to DTC Participants for distribution to
shareholders.
Applicants' Legal Analysis
1. Applicants request an order under section 6(c) of the Act for an
exemption from sections 2(a)(32), 5(a)(1), 22(d), and 22(e) of the Act
and rule 22c-1 under the Act, under sections 6(c) and 17(b) of the Act
for an exemption from sections 17(a)(1) and 17(a)(2) of the Act.
2. Section 6(c) of the Act provides that the Commission may exempt
any person, security or transaction, or any class of persons,
securities or transactions, from any provision of the Act, if and to
the extent that 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.
Section 17(b) of the Act authorizes the Commission to exempt a proposed
transaction from
[[Page 46391]]
section 17(a) of the Act if evidence establishes that the terms of the
transaction, including the consideration to be paid or received, are
reasonable and fair and do not involve overreaching on the part of any
person concerned, and the proposed transaction is consistent with the
policies of the registered investment company and the general
provisions of the Act.
Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an ``open-end company'' as a
management investment company that is offering for sale or has
outstanding any redeemable security of which it is the issuer. Section
2(a)(32) of the Act defines a redeemable security as any security,
other than short-term paper, under the terms of which the holder, upon
its presentation to the issuer, is entitled to receive approximately
his proportionate share of the issuer's current net assets, or the cash
equivalent. Because Shares will not be individually redeemable,
applicants request an order that would permit the Funds to register as
open-end management investment companies and issue Shares that are
redeemable in Creation Unit Aggregations only. Applicants state that
investors may purchase Shares in Creation Unit Aggregations and redeem
Creation Unit Aggregations from each Fund. Applicants state that
because the market price of Shares will be disciplined by arbitrage
opportunities investors should be able to sell Shares in the secondary
market at prices that do not vary materially from their NAV.
Section 22(d) of the Act and Rule 22c-1 Under the Act
4. Section 22(d) of the Act, among other things, prohibits a dealer
from selling a redeemable security that is currently being offered to
the public by or through an underwriter, except at a current public
offering price described in the prospectus. Rule 22c-1 under the Act
generally requires that a dealer selling, redeeming or repurchasing a
redeemable security do so only at a price based on its NAV. Applicants
state that secondary market trading in Shares will take place at
negotiated prices, not at a current offering price described in a
Fund's prospectus, and not at a price based on NAV. Thus, purchases and
sales of Shares in the secondary market will not comply with section
22(d) of the Act and rule 22c-1 under the Act. Applicants request an
exemption under section 6(c) from these provisions.
5. Applicants assert that the concerns sought to be addressed by
section 22(d) of the Act and rule 22c-1 under the Act with respect to
pricing are equally satisfied by the proposed method of pricing Shares.
Applicants maintain that while there is little legislative history
regarding section 22(d), its provisions, as well as those of rule 22c-
1, appear to have been designed to (a) prevent dilution caused by
certain riskless trading schemes by principal underwriters and contract
dealers, (b) prevent unjust discrimination or preferential treatment
among buyers, and (c) ensure an orderly distribution of investment
company shares by eliminating price competition from non-contract
dealers offering shares at less than the published sales price and
repurchasing shares at more than the published redemption price.
6. Applicants believe that none of these purposes will be thwarted
by permitting Shares to trade in the secondary market at negotiated
prices. Applicants state that (a) secondary market trading in Shares
does not involve a Fund as a party and will not result in dilution of
an investment in Shares, and (b) to the extent different prices exist
during a given trading day, or from day to day, such variances occur as
a result of third party market forces, such as supply and demand.
Therefore, applicants assert that secondary market transactions in
Shares will not lead to discrimination or preferential treatment among
purchasers. Finally, applicants contend that the proposed distribution
system will be orderly because competitive forces will ensure that the
difference between the market price of Shares and their NAV remains
narrow.
Section 22(e)
7. Section 22(e) of the Act generally prohibits a registered
investment company from suspending the right of redemption or
postponing the date of payment of redemption proceeds for more than
seven days after the tender of a security for redemption. Applicants
observe that the settlement of redemptions of Creation Unit
Aggregations of the Global and International Funds is contingent not
only on the settlement cycle of the U.S. securities markets, but also
on the delivery cycles present in international markets in which those
Funds invest. Applicants state that, under certain circumstances, the
delivery cycles for transferring Portfolio Securities to redeeming
investors, coupled with local market holiday schedules, will require a
delivery process of up to 14 calendar days. Applicants therefore
request relief from section 22(e) in order to provide for payment or
satisfaction of redemptions within a longer number of calendar days
required for such payment or satisfaction in the principal local
markets where transactions in the Portfolio Securities of each Global
Fund and International Fund customarily clear and settle, but in all
cases no later than 14 calendar days following the tender of a Creation
Unit Aggregation.\18\ With respect to Future Funds that are Global
Funds or International Funds, applicants seek the same relief from
section 22(e) only to the extent that circumstances exist similar to
those described in the application.
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\18\ Applicants acknowledge that no relief obtained from the
requirements of section 22(e) will affect any obligations applicants
may have under rule 15c6-1 under the Exchange Act. Rule 15c6-1
requires that most securities transactions be settled within three
business days of the trade.
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8. Applicants submit that section 22(e) was designed to prevent
unreasonable, undisclosed and unforeseen delays in the actual payment
of redemption proceeds. Applicants state that allowing redemption
payments for Creation Unit Aggregations of a Fund to be made within the
number of days indicated above would not be inconsistent with the
spirit and intent of section 22(e). Applicants state that the SAI will
disclose those local holidays (over the period of at least one year
following the date of the SAI), if any, that are expected to prevent
the delivery of redemption proceeds in seven calendar days, and the
maximum number of days needed to deliver the proceeds for each affected
Global and International Fund. Applicants are not seeking relief from
section 22(e) with respect to Global Funds and International Funds that
do not effect redemptions of Creation Unit Aggregations in-kind.
Sections 17(a)(1) and (2) of the Act
9. Section 17(a) of the Act generally prohibits an affiliated
person of a registered investment company, or an affiliated person of
such a person (``second-tier affiliate''), from selling any security to
or acquiring any security from the company. Section 2(a)(3) of the Act
defines ``affiliated person'' to include (a) any person directly or
indirectly owning, controlling or holding with power to vote 5% or more
of the outstanding voting securities of the other person, (b) any
person 5% or more of whose outstanding voting securities are directly
or indirectly owned, controlled or held with the power to vote by the
other person, and (c) any person directly or indirectly controlling,
controlled by or under common control with the other person. Section
2(a)(9) of the Act defines ``control'' as the power to exercise a
controlling influence over the
[[Page 46392]]
management or policies of a company and provides that a control
relationship will be presumed where one person owns more than 25% of
another person's voting securities. Each Fund may be deemed to be
controlled by an Adviser and hence affiliated persons of each other. In
addition, the Funds may be deemed to be under common control with any
other registered investment company (or series thereof) advised by the
Adviser or an entity controlling, controlled by or under common control
with the Adviser (an ``Affiliated Fund'').
10. Applicants request an exemption from section 17(a) of the Act
pursuant to sections 17(b) and 6(c) of the Act to permit persons to
effectuate in-kind purchases and redemptions with a Fund when they are
affiliated persons of the Fund or second-tier affiliates solely by
virtue of one or more of the following: (a) Holding 5% or more, or in
excess of 25%, of the outstanding Shares of one or more Funds; (b)
having an affiliation with a person with an ownership interest
described in (a); or (c) holding 5% or more, or more than 25%, of the
shares of one or more Affiliated Funds.
11. Applicants assert that no useful purpose would be served by
prohibiting these types of affiliated persons from acquiring or
redeeming Creation Unit Aggregations through ``in-kind'' transactions.
The deposit procedures for both in kind purchases and in-kind
redemptions of Creation Unit Aggregations will be the same for all
purchases and redemptions. Deposit Instruments, Redemption Instruments,
and the balancing cash amounts (except for any permitted cash-in-lieu
amounts) will be the same regardless of the identity of the purchaser
or redeemer and the Deposit Instruments and Redemption Instruments will
be valued in the same manner as Portfolio Securities. Therefore,
applicants state that in-kind purchases and redemptions will afford no
opportunity for the specified affiliated persons, or second-tier
affiliates, of a Fund to effect a transaction detrimental to other
holders of Shares. Applicants also believe that in-kind purchases and
redemptions will not result in self-dealing or overreaching of the
Fund.
Applicants' Conditions
Applicants agree that any order of the Commission granting the
requested relief will be subject to the following conditions:
ETF Relief
1. As long as the Trust operates in reliance on the requested
order, the Shares of the Funds will be listed on an Exchange.
2. Neither the Trust nor any Fund will be advertised or marketed as
an open-end investment company or a mutual fund. Any advertising
material that describes the purchase or sale of Creation Unit
Aggregations or refers to redeemability will prominently disclose that
Fund Shares are not individually redeemable and that owners of Fund
Shares may acquire those Fund Shares from a Fund and tender those Fund
Shares for redemption to a Fund in Creation Unit Aggregations only.
3. The Web site for the Funds, which is and will be publicly
accessible at no charge, will contain the following information, on a
per Share basis, for each Fund, the prior Business Day's NAV and the
market closing price or the midpoint of the bid/ask spread at the time
of the calculation of such NAV (``Bid/Ask Price''), and a calculation
of the premium or discount of the market closing price or Bid/Ask Price
against such NAV.
4. The requested relief to permit ETF operations will expire on the
effective date of any Commission rule under the Act that provides
relief permitting the operation of index-based exchange-traded funds.
For the Commission, by the Division of Investment Management,
under delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2013-18349 Filed 7-30-13; 8:45 am]
BILLING CODE 8011-01-P