Wells Fargo Bank, N.A., et al.; Notice of Application and Temporary Order, 48918-48920 [2013-19409]
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Federal Register / Vol. 78, No. 155 / Monday, August 12, 2013 / Notices
relating to each pilot trading system
operating pursuant to Rule 19b–5, and
to make such records available for
Commission inspection for a period of
not less than five years, the first two
years in an easily accessible place.
The filing of a Form PILOT is
mandatory for any SRO seeking a
temporary exemption under Rule 19b–5
from the rule filing requirements of
Section 19(b) of the Act in connection
with the operation of a pilot trading
system. It is also mandatory that an SRO
operating a pilot trading system file
with the Commission notices of material
systems changes and quarterly
transaction reports on Form PILOT.
Information provided on Form PILOT is
deemed confidential and shall be
available only for examination by the
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federal government, and state securities
authorities.
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The public may view background
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Securities and Exchange Commission,
Office of Information and Regulatory
Affairs, Office of Management and
Budget, Room 10102, New Executive
Office Building, Washington, DC 20503,
or by sending an email to:
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DC 20549 or send an email to:
PRA_Mailbox@sec.gov. Comments must
be submitted to OMB within 30 days of
this notice.
Dated: August 6, 2013.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2013–19407 Filed 8–9–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
mstockstill on DSK4VPTVN1PROD with NOTICES
[Investment Company Act Release No.
30644; 812–14176]
Wells Fargo Bank, N.A., et al.; Notice
of Application and Temporary Order
August 6, 2013.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Temporary order and notice of
application for a permanent order under
AGENCY:
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section 9(c) of the Investment Company
Act of 1940 (‘‘Act’’).
Applicants
have received a temporary order
exempting them from section 9(a) of the
Act, with respect to an injunction
effective July 15, 2013, entered against
Wells Fargo Bank, N.A. (‘‘Wells Fargo
Bank’’) by the United States District
Court for the Northern District of
California, until the Commission takes
final action on an application for a
permanent order. Applicants have
requested a permanent order.
APPLICANTS: Wells Fargo Bank,
Alternative Strategies Brokerage
Services, Inc. (‘‘Alternative Strategies
Brokerage’’), Alternative Strategies
Group, Inc. (‘‘Alternative Strategies’’),
First International Advisors, LLC (‘‘First
International’’), Galliard Capital
Management, Inc. (‘‘Galliard’’), Golden
Capital Management, LLC (‘‘Golden
Capital’’), Metropolitan West Capital
Management, LLC (‘‘Metropolitan
West’’), Peregrine Capital Management,
Inc. (‘‘Peregrine’’), Wells Capital
Management Incorporated (‘‘Wells
Capital Management’’), Wells Fargo
Funds Distributor, LLC (‘‘WF Funds
Distributor’’), and Wells Fargo Funds
Management, LLC (‘‘WF Funds
Management’’) (each an ‘‘Applicant’’
and collectively, the ‘‘Applicants’’).1
DATES: Filing Date: The application was
filed on July 12, 2013.
HEARING OR NOTIFICATION OF HEARING: An
order granting the application will be
issued unless the Commission orders a
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
Applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on September 3, 2013, and
should be accompanied by proof of
service on Applicants, in the form of an
affidavit, or for lawyers, a certificate of
service. Hearing requests should state
the nature of the writer’s interest, the
reason for the request, and the issues
contested. Persons who wish to be
notified of a hearing may request
notification by writing to the
Commission’s Secretary.
ADDRESSES: Elizabeth M. Murphy,
Secretary, U.S. Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
Applicants: Wells Fargo Bank, 101
SUMMARY OF APPLICATION:
1 Applicants request that any relief granted
pursuant to the application also apply to any other
company of which Wells Fargo Bank is or may
become an affiliated person within the meaning of
section 2(a)(3) of the Act (together with the
Applicants, the ‘‘Covered Persons’’).
PO 00000
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North Phillips Avenue, Sioux Falls, SD
57104; Alternative Strategies Brokerage
and Alternative Strategies, 401 South
Tryon Street, TH 3, 5th Floor, Charlotte,
NC 28202; First International, 30
Fenchurch Street, London, England, UK
EC3M 3BD; Galliard, 800 LaSalle
Avenue, Suite 1100, Minneapolis, MN
55402; Golden Capital, 5 Resource
Square, Suite 400, 10715 David Taylor
Drive, Charlotte, NC 28262;
Metropolitan West, 610 Newport Center
Drive, Suite 1000, Newport Beach, CA
92660; Peregrine, 800 LaSalle Avenue,
Suite 1850, Minneapolis, MN 55402;
West Capital Management, 525 Market
Street, 10th Floor, San Francisco, CA
94105; and WF Funds Distributor and
WF Funds Management, 525 Market
Street, 12th Floor, San Francisco, CA
94105.
FOR FURTHER INFORMATION CONTACT:
Laura J. Riegel, Senior Counsel, at (202)
551–6873 or Mary Kay Frech, Branch
Chief, at (202) 551–6821 (Division of
Investment Management, Office of
Exemptive Applications).
SUPPLEMENTARY INFORMATION: The
following is a temporary order and a
summary of the application. The
complete application may be obtained
via the Commission’s Web site by
searching for the file number, or an
applicant using the Company name box,
at https://www.sec.gov/search/
search.htm or by calling (202) 551–
8090.
Applicants’ Representations
1. Wells Fargo Bank is a national
banking association wholly-owned,
directly and indirectly, by Wells Fargo
& Company (‘‘Wells Fargo’’). Through
its direct and indirect subsidiaries,
Wells Fargo, a registered financial
holding company and bank holding
company under the Bank Holding
Company Act of 1956, as amended,
offers banking, brokerage, advisory and
other financial services to institutional
and individual customers worldwide.
Wells Fargo also is the ultimate parent
of the other Applicants, who, as direct
or indirect, majority-owned or whollyowned, subsidiaries of the same
ultimate parent, are, or may be
considered to be, under common control
with Wells Fargo Bank.
2. Abbot Downing Investment
Advisors and Wells Capital
Management Singapore, each a
separately identifiable department
within Wells Fargo Bank and each
registered as an investment adviser
under the Investment Advisers Act of
1940 (‘‘Advisers Act’’), serve as
investment advisers to one or more
Funds (as defined below). Alternative
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Strategies, First International, Galliard,
Golden Capital, Metropolitan West,
Peregrine, Wells Capital Management,
and WF Funds Management are
registered as investment advisers under
the Advisers Act and serve as
investment advisers or sub-advisers to
various Funds. Alternative Strategies
Brokerage and WF Funds Distributor are
registered as broker-dealers under the
Securities Exchange Act of 1934, and
each serves as principal underwriter to
various Funds. ‘‘Fund’’ means any
registered investment company,
including a registered unit investment
trust (‘‘UIT’’) or registered face amount
certificate company, as well as any
business development company
(‘‘BDC’’) or employees’ securities
company (‘‘ESC’’). ‘‘Fund Servicing
Activities’’ means acting as an adviser,
sub-adviser or depositor to Funds, or
principal underwriter for any registered
open-end investment company, UIT,
registered face amount company or ESC.
3. On May 14, 2013, the United States
District Court for the Northern District
of California issued an order (the ‘‘Court
Order’’) in a certified consumer class
action under Section 17200 of the
California Business and Professions
Code relating to a Wells Fargo Bank
bookkeeping device known as ‘‘high-tolow’’ posting.2 The plaintiffs in the class
action alleged that Wells Fargo Bank,
without adequate disclosure to account
holders, posted debit card transactions
received each day for payment
beginning with the highest amount and
ending with the lowest amount (i.e.,
high-to-low), which could have the
effect of increasing the number of items
posting into overdraft and, therefore,
increased overdraft fees.3 While the
plaintiffs’ challenge to the practice of
high-to-low posting and to the adequacy
of the bank’s disclosures was found to
be preempted by the National Bank Act,
Wells Fargo Bank was found liable
under the California law for making
misleading statements regarding the
practice.4 The Court Order enjoined
Wells Fargo Bank from making or
disseminating, or permitting to be made
or disseminated, any false or misleading
representations relating to the posting
order of debit-card purchases, checks,
and ACH transactions in its customer
bank accounts (the ‘‘Injunction’’). The
Court Order set July 15, 2013, as the
effective date of the Injunction.
2 Gutierrez v. Wells Fargo Bank, N.A., Case No. C
07–05923 WHA (N.D. Cal., May 14, 2013) (granting
in part and denying in part motion for judgment
following remand).
3 Id.
4 Id. at 3 (citing Gutierrez v. Wells Fargo Bank,
N.A., 704 F.3d 712, 725–730 (9th Cir. 2012)).
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Applicants’ Legal Analysis
1. Section 9(a)(2) of the Act, in
relevant part, prohibits a person who
has been enjoined from acting as a bank,
or from engaging in or continuing any
conduct or practice in connection with
such activity, from acting, among other
things, as an investment adviser or
depositor of any registered investment
company, or as a principal underwriter
for any registered open-end investment
company, UIT or registered face-amount
certificate company. Section 9(a)(3) of
the Act extends the prohibitions of
section 9(a)(2) to a company any
affiliated person of which has been
disqualified under the provisions of
section 9(a)(2). Section 2(a)(3) of the Act
defines ‘‘affiliated person’’ to include,
among others, any person directly or
indirectly controlling, controlled by, or
under common control with, the other
person. Applicants state that Wells
Fargo Bank is, or may be considered to
be, under common control with and
therefore an affiliated person of each of
the other Applicants. Applicants state
that the Injunction may result in
Applicants being subject to the
disqualification provisions of section
9(a) of the Act because Wells Fargo
Bank is enjoined from engaging in or
continuing certain conduct and/or
practices in connection with its banking
activity.5
2. Section 9(c) of the Act provides that
the Commission shall grant an
application for exemption from the
disqualification provisions of section
9(a) if it is established that these
provisions, as applied to Applicants, are
unduly or disproportionately severe or
that the Applicants’ conduct has been
such as not to make it against the public
interest or the protection of investors to
grant the exemption. Applicants have
filed an application pursuant to section
9(c) seeking temporary and permanent
orders exempting the Applicants and
the other Covered Persons from the
disqualification provisions of section
9(a) of the Act. On July 15, 2013,
Applicants received a temporary
conditional order from the Commission
exempting them from section 9(a) of the
Act with respect to the Injunction from
July 15, 2013 until the Commission
takes final action on an application for
a permanent order or, if earlier,
September 13, 2013.
3. Applicants believe they meet the
standard for exemption specified in
section 9(c). Applicants state that the
prohibitions of section 9(a) as applied to
5 Applicants believe that the conduct and/or
practices covered by the Injunction could be
deemed to be in connection with Wells Fargo
Bank’s banking activity.
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48919
them would be unduly and
disproportionately severe and that the
conduct of Applicants has been such as
not to make it against the public interest
or the protection of investors to grant
the exemption from section 9(a).
4. Applicants state that the conduct
giving rise to the Injunction did not
involve any of the Applicants acting in
their capacity as investment adviser,
sub-adviser, or principal underwriter for
Funds. Applicants also state that the
alleged conduct giving rise to the
Injunction did not involve any Fund or
the assets of any Fund for which they
provided Fund Servicing Activities.
Applicants further state that to the best
of their reasonable knowledge: (i) none
of the Applicants’ (other than certain of
Wells Fargo Bank’s) current or former
directors, officers or employees had any
knowledge of, or had any involvement
in, the conduct alleged in the Court
Order that provided a basis for the
Injunction; (ii) the personnel who were
involved in the violations have had no
involvement in, and will not have any
future involvement in, providing
advisory, sub-advisory, depository or
underwriting services to Funds; and (iii)
because the personnel of the Applicants
involved in Fund Servicing Activities
did not have any involvement in the
alleged misconduct, shareholders of
Funds that received investment
advisory, depository and principal
underwriting services from the
Applicants were not affected any
differently than if those Funds had
received services from any other nonaffiliated investment adviser, depositor
or principal underwriter.
5. Applicants further represent that
the inability of Applicants to continue
providing Fund Servicing Activities
would result in potentially severe
financial hardships for both the Funds
and their shareholders. Applicants state
that they will distribute written
materials, including an offer to meet in
person to discuss the materials, to the
board of directors of each Fund,
including the directors who are not
‘‘interested persons,’’ as defined in
section 2(a)(19) of the Act, of such
Fund, and their independent legal
counsel as defined in rule 0–1(a)(6)
under the Act, if any, regarding the
Injunction, any impact on the Funds,
and the application. The Applicants
will provide the Funds with all
information concerning the Injunction
and the application that is necessary for
the Funds to fulfill their disclosure and
other obligations under the federal
securities laws.
6. Applicants also assert that, if the
Applicants were barred from engaging
in Fund Servicing Activities, the effect
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Federal Register / Vol. 78, No. 155 / Monday, August 12, 2013 / Notices
on their businesses and employees
would be severe. The Applicants state
that they have committed substantial
capital and resources to establishing
expertise in advising and sub-advising
Funds and in support of their principal
underwriting business.
7. Applicants state that several
Applicants and certain of their affiliates
have previously received orders under
section 9(c), as described in greater
detail in the application.
Applicants’ Condition
Applicants agree that any order
granted by the Commission pursuant to
the application will be subject to the
following condition:
Any temporary exemption granted
pursuant to the application shall be
without prejudice to, and shall not limit
the Commission’s rights in any manner
with respect to, any Commission
investigation of, or administrative
proceedings involving or against,
Covered Persons, including without
limitation, the consideration by the
Commission of a permanent exemption
from section 9(a) of the Act requested
pursuant to the application, or the
revocation or removal of any temporary
exemptions granted under the Act in
connection with the application.
Temporary Order
The Commission has considered the
matter and finds that Applicants have
made the necessary showing to justify
granting a temporary exemption.
Accordingly,
It is hereby ordered, pursuant to
section 9(c) of the Act, that the
Applicants and the other Covered
Persons are granted a temporary
exemption from the provisions of
section 9(a), effective forthwith, solely
with respect to the Injunction, subject to
the condition in the application, until
the date the Commission takes final
action on their application for a
permanent order.
By the Commission.
Kevin M. O’Neill,
Deputy Secretary.
mstockstill on DSK4VPTVN1PROD with NOTICES
[FR Doc. 2013–19409 Filed 8–9–13; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
of the most significant parts of such
statements.
[Release No. 34–70124; File No. SR–
NYSEARCA–2013–78]
A. Self-Regulatory Organization’s
Statement of the Purpose of, and the
Statutory Basis for, the Proposed Rule
Change
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Amending NYSE Arca
Equities Rule 5.3(i)(1)(i) To Specify the
Procedures To Be Followed if a Listed
Derivative Securities Product or a
Listed Structured Product Is Based on
an Index or Portfolio of Securities and
Such Index or Portfolio Is Modified or
Replaced
August 6, 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 25,
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, II, and
III below, which Items have been
prepared by the self-regulatory
organization. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend
NYSE Arca Equities Rule 5.3(i)(1)(i) to
specify the procedures to be followed if
a listed Derivative Securities Product or
a listed Structured Product is based on
an index or portfolio of securities and
such index or portfolio is modified or
replaced. 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,
1 15
U.S.C.78s(b)(1).
U.S.C. 78a.
3 17 CFR 240.19b–4.
2 15
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1. Purpose
The Exchange proposes to amend its
rules to clarify Exchange policies with
respect to changes in the index or
portfolio on which a listed security is
based. The proposed rule change is
consistent with the policies currently
applied under existing Exchange rules.
In particular, the Exchange proposes to
adopt specific procedures to be followed
when a Derivative Securities Product 4
or a Structured Product 5 based on an
index or portfolio of securities is listed
on the Exchange and: (1) The value of
such index or portfolio is no longer
calculated or available and a new index
or portfolio is substituted; or (2) such
index or portfolio is replaced with a
new index or portfolio from the same or
a different index provider; or (3) the
index or portfolio is significantly
modified (including, but not limited to,
a significant modification to the index
methodology, a change in the index
provider or a change in control of the
index provider) (each of (1), (2) and (3),
a ‘‘Material Index or Portfolio Change’’).
It is the Exchange’s long-standing
policy to require the issuer of any
Derivative Securities Product or
Structured Product to submit an
executed Supplemental Listing
Application and to obtain authorization
from NYSE Regulation prior to the
effective date of any change in the index
or portfolio on which such security is
based. Generally, NYSE Regulation
requires at least two weeks to review
and to approve a Supplemental Listing
Application. The Exchange reminds
issuers of this policy in an annual
reminder letter sent to all listed issuers
which summarizes important Exchange
corporate governance and notice
requirements. This current policy is
appropriate in light of NYSE Arca
Equities Rule 5.3(i)(1)(i)(N), which
requires listed issuers to ‘‘provide
4 ‘‘Derivative Securities Products’’ are (i)
investment company units listed under NYSE Arca
Equities Rule 5.2(j)(3) Commentary .01(a)(A)(1) and
(ii) securities defined in Section 2 of NYSE Arca
Equities Rule 8.
5 Pursuant to NYSE Arca Equities Rule 5.1(b)(17),
the term ‘‘Structured Products’’ means products
that are derived from and/or based on a single
security or securities, a basket of stocks, an index,
a commodity, debt issuance and/or a foreign
currency, among other things. Structured Products
include index and equity linked notes, term notes
and units generally consisting of a contract to
purchase equity and/or debt securities at a specified
time.
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Agencies
[Federal Register Volume 78, Number 155 (Monday, August 12, 2013)]
[Notices]
[Pages 48918-48920]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-19409]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 30644; 812-14176]
Wells Fargo Bank, N.A., et al.; Notice of Application and
Temporary Order
August 6, 2013.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Temporary order and notice of application for a permanent order
under section 9(c) of the Investment Company Act of 1940 (``Act'').
-----------------------------------------------------------------------
Summary of Application: Applicants have received a temporary order
exempting them from section 9(a) of the Act, with respect to an
injunction effective July 15, 2013, entered against Wells Fargo Bank,
N.A. (``Wells Fargo Bank'') by the United States District Court for the
Northern District of California, until the Commission takes final
action on an application for a permanent order. Applicants have
requested a permanent order.
Applicants: Wells Fargo Bank, Alternative Strategies Brokerage
Services, Inc. (``Alternative Strategies Brokerage''), Alternative
Strategies Group, Inc. (``Alternative Strategies''), First
International Advisors, LLC (``First International''), Galliard Capital
Management, Inc. (``Galliard''), Golden Capital Management, LLC
(``Golden Capital''), Metropolitan West Capital Management, LLC
(``Metropolitan West''), Peregrine Capital Management, Inc.
(``Peregrine''), Wells Capital Management Incorporated (``Wells Capital
Management''), Wells Fargo Funds Distributor, LLC (``WF Funds
Distributor''), and Wells Fargo Funds Management, LLC (``WF Funds
Management'') (each an ``Applicant'' and collectively, the
``Applicants'').\1\
---------------------------------------------------------------------------
\1\ Applicants request that any relief granted pursuant to the
application also apply to any other company of which Wells Fargo
Bank is or may become an affiliated person within the meaning of
section 2(a)(3) of the Act (together with the Applicants, the
``Covered Persons'').
---------------------------------------------------------------------------
DATES: Filing Date: The application was filed on July 12, 2013.
Hearing or Notification of Hearing: An order granting the application
will be issued unless the Commission orders a hearing. Interested
persons may request a hearing by writing to the Commission's Secretary
and serving Applicants with a copy of the request, personally or by
mail. Hearing requests should be received by the Commission by 5:30
p.m. on September 3, 2013, and should be accompanied by proof of
service on Applicants, in the form of an affidavit, or for lawyers, a
certificate of service. Hearing requests should state the nature of the
writer's interest, the reason for the request, and the issues
contested. Persons who wish to be notified of a hearing may request
notification by writing to the Commission's Secretary.
ADDRESSES: Elizabeth M. Murphy, Secretary, U.S. Securities and Exchange
Commission, 100 F Street NE., Washington, DC 20549-1090. Applicants:
Wells Fargo Bank, 101 North Phillips Avenue, Sioux Falls, SD 57104;
Alternative Strategies Brokerage and Alternative Strategies, 401 South
Tryon Street, TH 3, 5th Floor, Charlotte, NC 28202; First
International, 30 Fenchurch Street, London, England, UK EC3M 3BD;
Galliard, 800 LaSalle Avenue, Suite 1100, Minneapolis, MN 55402; Golden
Capital, 5 Resource Square, Suite 400, 10715 David Taylor Drive,
Charlotte, NC 28262; Metropolitan West, 610 Newport Center Drive, Suite
1000, Newport Beach, CA 92660; Peregrine, 800 LaSalle Avenue, Suite
1850, Minneapolis, MN 55402; West Capital Management, 525 Market
Street, 10th Floor, San Francisco, CA 94105; and WF Funds Distributor
and WF Funds Management, 525 Market Street, 12th Floor, San Francisco,
CA 94105.
FOR FURTHER INFORMATION CONTACT: Laura J. Riegel, Senior Counsel, at
(202) 551-6873 or Mary Kay Frech, Branch Chief, at (202) 551-6821
(Division of Investment Management, Office of Exemptive Applications).
SUPPLEMENTARY INFORMATION: The following is a temporary order and a
summary of the application. The complete application may be obtained
via the Commission's Web site by searching for the file number, or an
applicant using the Company name box, at https://www.sec.gov/search/search.htm or by calling (202) 551-8090.
Applicants' Representations
1. Wells Fargo Bank is a national banking association wholly-owned,
directly and indirectly, by Wells Fargo & Company (``Wells Fargo'').
Through its direct and indirect subsidiaries, Wells Fargo, a registered
financial holding company and bank holding company under the Bank
Holding Company Act of 1956, as amended, offers banking, brokerage,
advisory and other financial services to institutional and individual
customers worldwide. Wells Fargo also is the ultimate parent of the
other Applicants, who, as direct or indirect, majority-owned or wholly-
owned, subsidiaries of the same ultimate parent, are, or may be
considered to be, under common control with Wells Fargo Bank.
2. Abbot Downing Investment Advisors and Wells Capital Management
Singapore, each a separately identifiable department within Wells Fargo
Bank and each registered as an investment adviser under the Investment
Advisers Act of 1940 (``Advisers Act''), serve as investment advisers
to one or more Funds (as defined below). Alternative
[[Page 48919]]
Strategies, First International, Galliard, Golden Capital, Metropolitan
West, Peregrine, Wells Capital Management, and WF Funds Management are
registered as investment advisers under the Advisers Act and serve as
investment advisers or sub-advisers to various Funds. Alternative
Strategies Brokerage and WF Funds Distributor are registered as broker-
dealers under the Securities Exchange Act of 1934, and each serves as
principal underwriter to various Funds. ``Fund'' means any registered
investment company, including a registered unit investment trust
(``UIT'') or registered face amount certificate company, as well as any
business development company (``BDC'') or employees' securities company
(``ESC''). ``Fund Servicing Activities'' means acting as an adviser,
sub-adviser or depositor to Funds, or principal underwriter for any
registered open-end investment company, UIT, registered face amount
company or ESC.
3. On May 14, 2013, the United States District Court for the
Northern District of California issued an order (the ``Court Order'')
in a certified consumer class action under Section 17200 of the
California Business and Professions Code relating to a Wells Fargo Bank
bookkeeping device known as ``high-to-low'' posting.\2\ The plaintiffs
in the class action alleged that Wells Fargo Bank, without adequate
disclosure to account holders, posted debit card transactions received
each day for payment beginning with the highest amount and ending with
the lowest amount (i.e., high-to-low), which could have the effect of
increasing the number of items posting into overdraft and, therefore,
increased overdraft fees.\3\ While the plaintiffs' challenge to the
practice of high-to-low posting and to the adequacy of the bank's
disclosures was found to be preempted by the National Bank Act, Wells
Fargo Bank was found liable under the California law for making
misleading statements regarding the practice.\4\ The Court Order
enjoined Wells Fargo Bank from making or disseminating, or permitting
to be made or disseminated, any false or misleading representations
relating to the posting order of debit-card purchases, checks, and ACH
transactions in its customer bank accounts (the ``Injunction''). The
Court Order set July 15, 2013, as the effective date of the Injunction.
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\2\ Gutierrez v. Wells Fargo Bank, N.A., Case No. C 07-05923 WHA
(N.D. Cal., May 14, 2013) (granting in part and denying in part
motion for judgment following remand).
\3\ Id.
\4\ Id. at 3 (citing Gutierrez v. Wells Fargo Bank, N.A., 704
F.3d 712, 725-730 (9th Cir. 2012)).
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Applicants' Legal Analysis
1. Section 9(a)(2) of the Act, in relevant part, prohibits a person
who has been enjoined from acting as a bank, or from engaging in or
continuing any conduct or practice in connection with such activity,
from acting, among other things, as an investment adviser or depositor
of any registered investment company, or as a principal underwriter for
any registered open-end investment company, UIT or registered face-
amount certificate company. Section 9(a)(3) of the Act extends the
prohibitions of section 9(a)(2) to a company any affiliated person of
which has been disqualified under the provisions of section 9(a)(2).
Section 2(a)(3) of the Act defines ``affiliated person'' to include,
among others, any person directly or indirectly controlling, controlled
by, or under common control with, the other person. Applicants state
that Wells Fargo Bank is, or may be considered to be, under common
control with and therefore an affiliated person of each of the other
Applicants. Applicants state that the Injunction may result in
Applicants being subject to the disqualification provisions of section
9(a) of the Act because Wells Fargo Bank is enjoined from engaging in
or continuing certain conduct and/or practices in connection with its
banking activity.\5\
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\5\ Applicants believe that the conduct and/or practices covered
by the Injunction could be deemed to be in connection with Wells
Fargo Bank's banking activity.
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2. Section 9(c) of the Act provides that the Commission shall grant
an application for exemption from the disqualification provisions of
section 9(a) if it is established that these provisions, as applied to
Applicants, are unduly or disproportionately severe or that the
Applicants' conduct has been such as not to make it against the public
interest or the protection of investors to grant the exemption.
Applicants have filed an application pursuant to section 9(c) seeking
temporary and permanent orders exempting the Applicants and the other
Covered Persons from the disqualification provisions of section 9(a) of
the Act. On July 15, 2013, Applicants received a temporary conditional
order from the Commission exempting them from section 9(a) of the Act
with respect to the Injunction from July 15, 2013 until the Commission
takes final action on an application for a permanent order or, if
earlier, September 13, 2013.
3. Applicants believe they meet the standard for exemption
specified in section 9(c). Applicants state that the prohibitions of
section 9(a) as applied to them would be unduly and disproportionately
severe and that the conduct of Applicants has been such as not to make
it against the public interest or the protection of investors to grant
the exemption from section 9(a).
4. Applicants state that the conduct giving rise to the Injunction
did not involve any of the Applicants acting in their capacity as
investment adviser, sub-adviser, or principal underwriter for Funds.
Applicants also state that the alleged conduct giving rise to the
Injunction did not involve any Fund or the assets of any Fund for which
they provided Fund Servicing Activities. Applicants further state that
to the best of their reasonable knowledge: (i) none of the Applicants'
(other than certain of Wells Fargo Bank's) current or former directors,
officers or employees had any knowledge of, or had any involvement in,
the conduct alleged in the Court Order that provided a basis for the
Injunction; (ii) the personnel who were involved in the violations have
had no involvement in, and will not have any future involvement in,
providing advisory, sub-advisory, depository or underwriting services
to Funds; and (iii) because the personnel of the Applicants involved in
Fund Servicing Activities did not have any involvement in the alleged
misconduct, shareholders of Funds that received investment advisory,
depository and principal underwriting services from the Applicants were
not affected any differently than if those Funds had received services
from any other non-affiliated investment adviser, depositor or
principal underwriter.
5. Applicants further represent that the inability of Applicants to
continue providing Fund Servicing Activities would result in
potentially severe financial hardships for both the Funds and their
shareholders. Applicants state that they will distribute written
materials, including an offer to meet in person to discuss the
materials, to the board of directors of each Fund, including the
directors who are not ``interested persons,'' as defined in section
2(a)(19) of the Act, of such Fund, and their independent legal counsel
as defined in rule 0-1(a)(6) under the Act, if any, regarding the
Injunction, any impact on the Funds, and the application. The
Applicants will provide the Funds with all information concerning the
Injunction and the application that is necessary for the Funds to
fulfill their disclosure and other obligations under the federal
securities laws.
6. Applicants also assert that, if the Applicants were barred from
engaging in Fund Servicing Activities, the effect
[[Page 48920]]
on their businesses and employees would be severe. The Applicants state
that they have committed substantial capital and resources to
establishing expertise in advising and sub-advising Funds and in
support of their principal underwriting business.
7. Applicants state that several Applicants and certain of their
affiliates have previously received orders under section 9(c), as
described in greater detail in the application.
Applicants' Condition
Applicants agree that any order granted by the Commission pursuant
to the application will be subject to the following condition:
Any temporary exemption granted pursuant to the application shall
be without prejudice to, and shall not limit the Commission's rights in
any manner with respect to, any Commission investigation of, or
administrative proceedings involving or against, Covered Persons,
including without limitation, the consideration by the Commission of a
permanent exemption from section 9(a) of the Act requested pursuant to
the application, or the revocation or removal of any temporary
exemptions granted under the Act in connection with the application.
Temporary Order
The Commission has considered the matter and finds that Applicants
have made the necessary showing to justify granting a temporary
exemption.
Accordingly,
It is hereby ordered, pursuant to section 9(c) of the Act, that the
Applicants and the other Covered Persons are granted a temporary
exemption from the provisions of section 9(a), effective forthwith,
solely with respect to the Injunction, subject to the condition in the
application, until the date the Commission takes final action on their
application for a permanent order.
By the Commission.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2013-19409 Filed 8-9-13; 8:45 am]
BILLING CODE 8011-01-P