PennantPark Investment Corp., et al.; Notice of Application, 16384-16388 [2014-06465]
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Federal Register / Vol. 79, No. 57 / Tuesday, March 25, 2014 / Notices
2014) required by 44 U.S.C. 3506(c)(2).
That request elicited no comments.
Information Collection Request (ICR)
Title: Report of Medicaid State Office
on Beneficiary’s Buy-In Status.
OMB Control Number: 3220–0185.
Forms submitted: RL–380–F.
Type of request: Extension without
change of a currently approved
collection.
Affected public: State, Local, and
Tribal Governments.
Abstract: Under the Railroad
Retirement Act, the Railroad Retirement
Board administers the Medicare
program for persons covered by the
railroad retirement system. The
collection obtains the information
needed to determine if certain railroad
beneficiaries are entitled to receive
Supplemental Medical Insurance
program coverage under a state buy-in
agreement in states in which they
reside.
Changes proposed: The RRB proposes
no changes to Form RL–380–F.
The burden estimate for the ICR is as
follows:
Form No.
Annual
responses
Time
(minutes)
Burden
(hours)
RL–380–F ....................................................................................................................................
600
10
100
Additional Information or Comments:
Copies of the forms and supporting
documents can be obtained from Dana
Hickman at (312) 751–4981 or
Dana.Hickman@RRB.GOV.
Comments regarding the information
collection should be addressed to
Charles Mierzwa, Railroad Retirement
Board, 844 North Rush Street, Chicago,
Illinois 60611–2092 or
Charles.Mierzwa@RRB.GOV and to the
OMB Desk Officer for the RRB, Fax:
202–395–6974, Email address: OIRA_
Submission@omb.eop.gov.
Charles Mierzwa,
Chief of Information Resources Management.
[FR Doc. 2014–06500 Filed 3–24–14; 8:45 am]
BILLING CODE 7905–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–30985; File No. 812–14134]
PennantPark Investment Corp., et al.;
Notice of Application
March 19, 2014.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under sections 17(d) and 57(i) of
the Investment Company Act of 1940
(the ‘‘Act’’) and rule 17d-1 under the
Act to permit certain joint transactions
otherwise prohibited by sections 17(d)
and 57(a)(4) of the Act and rule 17d-1
under the Act.
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AGENCY:
Summary of Application: Applicants
request an order to permit business
development companies (each, a
‘‘BDC’’) and certain closed-end
management investment companies to
co-invest in portfolio companies with
each other and with affiliated
investment funds.
Applicants: PennantPark Investment
Corporation (‘‘PNNT’’), PennantPark
Floating Rate Capital Ltd. (‘‘PFLT’’),
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PennantPark Floating Rate Capital
Funding I, LLC (‘‘Funding I’’),
PennantPark SBIC LP (‘‘SBIC I’’),
PennantPark SBIC II LP (‘‘SBIC II’’),
PennantPark Credit Opportunities Fund,
LP (‘‘PCOF’’) and PennantPark
Investment Advisers, LLC (the
‘‘Adviser’’).
Filing Dates: The application was filed
on March 15, 2013, and amended on
August 7, 2013, December 5, 2013 and
March 5, 2014. Applicants have agreed
to file an amendment during the notice
period, the substance of which is
reflected in this notice.
Hearing or Notification of Hearing: An
order granting the 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 April 14, 2014, 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 St.
NE., Washington, DC 20549–1090.
Applicants: 590 Madison Avenue, 15th
Floor, New York, NY 10022.
FOR FURTHER INFORMATION CONTACT:
Laura L. Solomon, Senior Counsel, at
(202) 551–6915 or Daniele Marchesani,
Branch Chief, at (202) 551–6821 (Chief
Counsel’s Office, Division of Investment
Management).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
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Web site by searching for the file
number, or for an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Applicants’ Representations
1. PNNT and PFLT are Maryland
corporations organized as closed-end
management investment companies that
have elected to be regulated as BDCs
under the Act (together, the
‘‘PennantPark BDCs’’).1 PNNT’s
Objectives and Strategies 2 are to
generate both current income and
capital appreciation through debt and
equity investments. PNNT invests
primarily in U.S. middle-market
companies in the form of senior secured
loans, mezzanine debt and equity
investments. PFLT’s Objectives and
Strategies are to generate current income
and capital appreciation by investing
primarily in floating rate loans and
other investments made to U.S. private
middle-market companies. A majority of
the directors of each of PNNT and PFLT
are not ‘‘interested persons’’ as defined
in section 2(a)(19) of the Act of PNNT
and PFLT, respectively (‘‘Independent
Directors’’).
2. PCOF is a limited partnership
organized under Delaware law and is
excluded from the definition of
investment company under section
3(c)(7) of the Act. PCOF’s investment
objectives are capital preservation,
income generation and capital
1 Section 2(a)(48) defines a BDC to be any closedend investment company that operates for the
purpose of making investments in securities
described in sections 55(a)(1) through 55(a)(3) of the
Act and makes available significant managerial
assistance with respect to the issuers of such
securities.
2 ‘‘Objectives and Strategies’’ means a Regulated
Fund’s (defined below) investment objectives and
strategies as described in the Regulated Fund’s
registration statement on Form N–2, other filings
the Regulated Fund has made with the Commission
under the Securities Act of 1933 (‘‘Securities Act’’),
or under the Securities Exchange Act of 1934, and
the Regulated Fund’s reports to stockholders.
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appreciation primarily through debt
and/or equity investments generally in
midsize companies in North America
and Western Europe.
3. Funding I is a wholly-owned
subsidiary of PFLT formed to enter into
a credit facility. SBIC I and SBIC II,
wholly-owned subsidiaries of PNNT, are
Delaware limited partnerships operating
as small business investment companies
whose investment objectives are to
generate both current income and
capital appreciation through debt and
equity investments. Each of Funding I,
SBIC I and SBIC II is a Wholly-Owned
Investment Subsidiary (as defined
below).
4. PennantPark Investment Advisers,
LLC, a Delaware limited liability
company, is and any other Adviser will
be registered as an investment adviser
under the Investment Advisers Act of
1940 (the ‘‘Advisers Act’’). PennantPark
Investment Advisers, LLC serves as the
investment adviser to PNNT, PFLT,
PCOF and Funding I. PNNT advises
SBIC I and SBIC II.3
5. Applicants seek an order (‘‘Order’’)
to permit one or more Regulated Funds 4
and one or more Private Funds 5 to
participate in the same investment
opportunities through a proposed coinvestment program where such
participation would otherwise be
prohibited under sections 17(d) and
57(a)(4) and rule 17d–1 (the ‘‘CoInvestment Program’’) by (a) coinvesting with each other in certain
securities of issuers (a ‘‘portfolio
company’’) and (b) making additional
investments in securities of issuers,
including through the exercise of
warrants, conversion privileges, and
other rights to purchase securities of the
issuers (‘‘Follow-On Investments’’). ‘‘CoInvestment Transaction’’ means any
transaction in which a Regulated Fund
(or a Wholly-Owned Investment
Subsidiary (as defined below))
participated together with a Co3 Advisory personnel of the Adviser will act on
behalf of PNNT in providing management services
to SBIC I and SBIC II.
4 ‘‘Regulated Fund’’ means the PennantPark BDCs
and any management investment company (a) that
is registered under the Act as a closed-end fund or
has elected to be regulated as a BDC; (b) whose
investment adviser is PennantPark Investment
Advisers, LLC or any other adviser that is
controlling, controlled by or under common control
with PennantPark Investment Advisers, LLC
(included in the term ‘‘Adviser’’); and (c) that
intends to participate in the Co-Investment Program
(as defined below).
5 ‘‘Private Fund’’ means PCOF and any other
entity (a) whose investment adviser is an Adviser;
(b) that would be an investment company but for
section 3(c)(1) or 3(c)(7) of the Act; and (c) that
intends to participate in the Co-Investment
Program. The Private Funds, together with the
Regulated Funds are referred to as the ‘‘CoInvestment Affiliates.’’
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Investment Affiliate in reliance on the
Order. ‘‘Potential Co-Investment
Transaction’’ means any investment
opportunity in which a Regulated Fund
(or a Wholly-Owned Investment
Subsidiary) could not participate
together with one or more CoInvestment Affiliates without obtaining
and relying on the Order.6
6. Applicants state that a Regulated
Fund may, from time to time, form a
special purpose subsidiary (a ‘‘WhollyOwned Investment Subsidiary’’).7 A CoInvestment Affiliate would be
prohibited from investing in a CoInvestment Transaction with any
Wholly-Owned Investment Subsidiary
because the Wholly-Owned Investment
Subsidiary would be a company
controlled by a Regulated Fund for
purposes of sections 17(d) and 57(a)(4)
and rule 17d–1. Applicants request that
a Wholly-Owned Investment Subsidiary
be permitted to participate in CoInvestment Transactions in lieu of the
parent Regulated Fund and that the
Wholly-Owned Investment Subsidiary’s
participation in any such transaction be
treated, for purposes of the Order, as
though the applicable Regulated Fund
were participating directly. Applicants
represent that this treatment is justified
because a Wholly-Owned Investment
Subsidiary would have no purpose
other than serving as a holding vehicle
for a Regulated Fund’s investments and,
therefore, no conflicts of interest could
arise between such Regulated Fund and
the Wholly-Owned Investment
Subsidiary. The board of directors of the
applicable Regulated Fund would make
all relevant determinations under the
conditions with regard to a Wholly6 All existing entities that currently intend to rely
on the Order have been named as applicants. Any
other existing or future entity that relies on the
Order in the future will comply with the terms and
conditions of the application.
7 The term ‘‘Wholly-Owned Investment
Subsidiary’’ means an entity (a) whose sole
business purposes are to hold one or more
investments and issue debt on behalf of a Regulated
Fund (and, in the case of an SBIC Subsidiary (as
defined below), maintain a license under the SBA
Act (as defined below) and issue debentures
guaranteed by the SBA (as defined below); (b) that
is wholly-owned by such Regulated Fund (with
such Regulated Fund at all times directly or
indirectly holding, beneficially and of record, 100%
of the voting and economic interests); (c) with
respect to which the board of directors of the
Regulated Fund has the sole authority to make all
determinations with respect to the Wholly-Owned
Investment Subsidiary’s participation under the
conditions of the application; and (d) that is an
entity that would be an investment company but for
section 3(c)(1) or 3(c)(7) of the Act. The term ‘‘SBIC
Subsidiary’’ means a Wholly-Owned Investment
Subsidiary that is licensed by the Small Business
Administration (the ‘‘SBA’’) to operate under the
Small Business Investment Act of 1958, as
amended, (the ‘‘SBA Act’’) as a small business
investment company (an ‘‘SBIC’’).
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Owned Investment Subsidiary’s
participation in a Co-Investment
Transaction, and the board of directors
would be informed of, and take into
consideration, any proposed use of a
Wholly-Owned Investment Subsidiary
in the applicable Regulated Fund’s
place. If a Regulated Fund proposes to
participate in the same Co-Investment
Transaction with any of its WhollyOwned Investment Subsidiaries, the
board of directors will also be informed
of, and take into consideration, the
relative participation of the Regulated
Fund and the Wholly-Owned
Investment Subsidiary.
7. Applicants represent that the
Advisers will refer all Potential CoInvestment Transactions that an
investment adviser considers for a CoInvestment Affiliate, and that are within
a Regulated Fund’s Objectives and
Strategies, to that Regulated Fund’s
Adviser. For each such referral, when
selecting investments for a CoInvestment Affiliate, the applicable
Adviser will consider only the
investment objective, investment
policies, investment position, Available
Capital (as defined below), and other
pertinent factors applicable to the
respective Co-Investment Affiliate. The
Adviser expects that a portfolio
company that is an appropriate
investment for one Co-Investment
Affiliate may be an appropriate
investment for another Co-Investment
Affiliate, with certain exceptions based
on available capital (‘‘Available
Capital’’) 8 or diversification.
8. Other than pro rata dispositions
and Follow-On Investments as provided
in conditions 7 and 8, and after making
the determinations required in
conditions 1 and 2(a), the Adviser will
present each Potential Co-Investment
Transaction and the proposed allocation
to the directors of the board eligible to
vote under section 57(o) of the Act
(‘‘Eligible Directors’’), and the ‘‘required
majority,’’ as defined in section 57(o) of
the Act (‘‘Required Majority’’) 9 of a
Regulated Fund will approve each CoInvestment Transaction prior to any
investment by a Regulated Fund.
9. With respect to the pro rata
dispositions and Follow-On Investments
provided in conditions 7 and 8, a
8 ‘‘Available Capital’’ consists solely of liquid
assets not held for permanent investment, including
cash, amounts that can currently be drawn down
from lines of credit, and marketable securities held
for short-term purposes. In addition, Available
Capital would include bona fide uncalled capital
commitments that can be called by the settlement
date of the Co-Investment Transaction.
9 With respect to Regulated Funds that are not
BDCs, the defined terms Eligible Directors and
Required Majority apply as if each Regulated Fund
were a BDC subject to section 57(o) of the Act.
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Regulated Fund may participate in a pro
rata disposition or Follow-On
Investment without obtaining prior
approval of the Required Majority if,
among other things: (i) the proposed
participation of each Co-Investment
Affiliate in such disposition or FollowOn Investment is proportionate to its
outstanding investments in the issuer
immediately preceding the disposition
or Follow-On Investment, as the case
may be; and (ii) the board of directors
of the Regulated Fund has approved that
Regulated Fund’s participation in pro
rata dispositions and Follow-On
Investments as being in the best
interests of the Regulated Fund. If the
board does not so approve, any such
disposition or Follow-On Investment
will be submitted to the Regulated
Fund’s Eligible Directors. The board of
any Regulated Fund may at any time
rescind, suspend or qualify its approval
of pro rata dispositions and Follow-On
Investments with the result that all
dispositions and/or Follow-On
Investments must be submitted to the
Eligible Directors.
10. No Independent Director of a
Regulated Fund will have a direct or
indirect financial interest in any CoInvestment Transaction or any interest
in a portfolio company other than
through an interest (if any) in the
securities of a Regulated Fund and none
will participate individually in any CoInvestment Transaction.
Applicants’ Legal Analysis
1. Section 17(d) of the Act and rule
17d-1 under the Act prohibit affiliated
persons of a registered investment
company from participating in joint
transactions with the company or a
company controlled by such registered
investment company unless the
Commission has granted an order
permitting such transactions. Section
57(a)(4) of the Act prohibits certain
affiliated persons of a BDC from
participating in joint transactions with
the BDC (or a company controlled by
such BDC) in contravention of rules as
prescribed by the Commission. Section
57(i) of the Act provides that, until the
Commission prescribes rules under
section 57(a)(4), the Commission’s rules
under section 17(d) of the Act
applicable to registered closed-end
investment companies will be deemed
to apply to BDCs. Because the
Commission has not adopted any rules
under section 57(a)(4), rule 17d–1
applies.
2. Applicants submit that the Adviser
and the Co-Investment Affiliates would
be deemed to be persons related to a
Regulated Fund in a manner described
by sections 17(d) or 57(b) and therefore
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prohibited by sections 17(d) or 57(a)(4)
and rule 17d–1 from participating in the
Co-Investment Transactions without the
Order.
3. Rule 17d–1 under the Act generally
prohibits participation by a registered
investment company, or a company
controlled by such registered
investment company, and an affiliated
person (as defined in section 2(a)(3) of
the Act) or principal underwriter for
that investment company, or an
affiliated person of such affiliated
person or principal underwriter, in any
joint enterprise or other joint
arrangement or profit sharing plan, as
defined in the rule, absent an order by
the Commission. Similarly, rule 17d–1,
as made applicable to BDCs by section
57(i), prohibits any person who is
related to a BDC in a manner described
in section 57(b), acting as principal,
from participating in, or effecting any
transaction in connection with, any
joint enterprise or other joint
arrangement or profit-sharing plan in
which the BDC (or a company
controlled by such BDC) is a participant,
absent an order from the Commission.
In passing upon applications under rule
17d–1, the Commission considers
whether the company’s participation in
the joint transaction is consistent with
the provisions, policies, and purposes of
the Act and the extent to which such
participation is on a basis different from
or less advantageous than that of other
participants.
4. Applicants state that co-investment
in portfolio companies by the CoInvestment Affiliates will increase
favorable investment opportunities for
the PennantPark BDCs and any other
Regulated Fund. Applicants submit that
the Required Majority’s approval of each
Co-Investment Transaction before
investment, and other protective
conditions set forth in the application,
will ensure that the Regulated Funds
will be treated fairly. Applicants state
that the Regulated Funds’ participation
in the Co-Investment Transactions will
be consistent with the provisions,
policies and purposes of the Act and on
a basis that is not different from or less
advantageous than that of other CoInvestment Affiliates.
Applicants’ Conditions
Applicants agree that any Order
granting the requested relief will be
subject to the following conditions:
1. Each time an investment adviser of
a Co-Investment Affiliate considers a
Potential Co-Investment Transaction for
any Co-Investment Affiliate that falls
within a Regulated Fund’s Objectives
and Strategies, the Regulated Fund’s
Adviser will make an independent
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determination of the appropriateness of
the investment for the Regulated Fund
in light of the Regulated Fund’s thencurrent circumstances.
2. (a) If the Adviser deems a Regulated
Fund’s participation in any Potential
Co-Investment Transaction to be
appropriate for the Regulated Fund, it
will then determine an appropriate level
of investment for the Regulated Fund;
(b) If the aggregate amount
recommended by the Adviser to be
invested by the Regulated Fund in the
Potential Co-Investment Transaction,
together with the amount proposed to be
invested by each other Co-Investment
Affiliate, collectively in the same
transaction, exceeds the amount of the
investment opportunity, the investment
opportunity will be allocated among
them pro rata based on each
participating party’s Available Capital
in the asset class being allocated, up to
the amount proposed to be invested by
each. The Adviser will provide the
respective Eligible Directors with
information concerning each party’s
Available Capital to assist the Eligible
Directors with their review of such
Regulated Fund’s investments for
compliance with these allocation
procedures; and
(c) After making the determinations
required in conditions 1 and 2(a), the
Adviser will distribute written
information concerning the Potential
Co-Investment Transaction, (including
the amount proposed to be invested by
each Co-Investment Affiliate), to the
Eligible Directors for their
consideration. The Regulated Fund will
co-invest with one or more CoInvestment Affiliates only if, prior to
participating in the Potential CoInvestment Transaction, a Required
Majority concludes that:
(i) the terms of the transaction,
including the consideration to be paid,
are reasonable and fair to the Regulated
Fund and its stockholders and do not
involve overreaching in respect of the
Regulated Fund or its stockholders on
the part of any person concerned;
(ii) the transaction is consistent with:
(A) the interests of the stockholders of
the Regulated Fund; and
(B) the Regulated Fund’s then-current
Objectives and Strategies;
(iii) the investment by the CoInvestment Affiliates would not
disadvantage the Regulated Fund, and
participation by the Regulated Fund
would not be on a basis different from
or less advantageous than that of the CoInvestment Affiliates; provided, that, if
any Co-Investment Affiliate, but not the
Regulated Fund itself, gains the right to
nominate a director for election to a
portfolio company’s board of directors
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or the right to have a board observer or
any similar right to participate in the
governance or management of the
portfolio company, such event shall not
be interpreted to prohibit the Required
Majority from reaching the conclusions
required by this condition (2)(c)(iii), if:
(A) the Eligible Directors will have the
right to ratify the selection of such
director or board observer, if any;
(B) the Adviser agrees to, and does,
provide periodic reports to the
Regulated Fund’s board of directors
with respect to the actions of the
director or the information received by
the board observer or obtained through
the exercise of any similar right to
participate in the governance or
management of the portfolio company;
and
(C) any fees or other compensation
that any Co-Investment Affiliate or any
affiliated person of any Co-Investment
Affiliate receives in connection with the
right of the Co-Investment Affiliate to
nominate a director or appoint a board
observer or otherwise to participate in
the governance or management of the
portfolio company will be shared
proportionately among the participating
Co-Investment Affiliates (the Private
Funds may, in turn, share their portion
with their affiliated persons) and the
Regulated Fund in accordance with the
amount of each party’s investment; and
(iv) the proposed investment by the
Regulated Fund will not benefit the
Adviser or the Co-Investment Affiliates
or any affiliated person of any of them
(other than the parties to the CoInvestment Transaction), except (A) to
the extent permitted by condition 13,
(B) to the extent permitted by section
17(e) or 57(k) of the Act, as applicable;
(C) indirectly, as a result of an interest
in securities issued by one of the parties
to the Co-Investment Transaction, or (D)
in the case of fees or other
compensation described in condition
2(c)(iii)(C).
3. Each Regulated Fund has the right
to decline to participate in any Potential
Co-Investment Transaction or to invest
less than the amount proposed.
4. The Adviser will present to the
board of directors of each Regulated
Fund, on a quarterly basis, a record of
all investments in Potential CoInvestment Transactions made by the
Co-Investment Affiliates during the
preceding quarter that fell within the
Regulated Fund’s then-current
Objectives and Strategies that were not
made available to the Regulated Fund,
and an explanation of why such
investment opportunities were not
offered to the Regulated Fund. All
information presented to the board of
directors pursuant to this condition will
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be kept for the life of the Regulated
Fund and at least two years thereafter
and will be subject to examination by
the Commission and its staff.
5. Except for Follow-On Investments
made in accordance with condition 8,
the Regulated Fund will not invest in
reliance on the Order in any issuer in
which any Co-Investment Affiliate or
any affiliated person of the CoInvestment Affiliates is an existing
investor.
6. The Regulated Fund will not
participate in any Potential CoInvestment Transaction unless the
terms, conditions, price, class of
securities to be purchased, settlement
date, and registration rights will be the
same for the Regulated Fund as for each
participating Co-Investment Affiliate.
The grant to a Co-Investment Affiliate,
but not the Regulated Fund, of the right
to nominate a director for election to a
portfolio company’s board of directors,
the right to have an observer on the
board of directors or similar rights to
participate in the governance or
management of the portfolio company
will not be interpreted so as to violate
this condition 6, if conditions
2(c)(iii)(A), (B) and (C) are met.
7. (a) If any Co-Investment Affiliate
elects to sell, exchange or otherwise
dispose of an interest in a security that
was acquired in a Co-Investment
Transaction, the Adviser will:
(i) notify each Regulated Fund that
participated in the Co-Investment
Transaction of the proposed disposition
at the earliest practical time; and
(ii) formulate a recommendation as to
participation by each Regulated Fund in
the disposition.
(b) Each Regulated Fund will have the
right to participate in such disposition
on a proportionate basis, at the same
price and on the same terms and
conditions as those applicable to the
participating Co-Investment Affiliates.
(c) A Regulated Fund may participate
in such disposition without obtaining
prior approval of the Required Majority
if: (i) The proposed participation of each
Co-Investment Affiliate in such
disposition is proportionate to its
outstanding investment in the issuer
immediately preceding the disposition;
(ii) the board of directors of the
Regulated Fund has approved as being
in the best interests of the Regulated
Fund the ability to participate in such
dispositions on a pro rata basis (as
described in greater detail in the
application); and (iii) the board of
directors of the Regulated Fund is
provided on a quarterly basis with a list
of all dispositions made in accordance
with this condition. In all other cases,
the Adviser will provide its written
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16387
recommendation as to the Regulated
Fund’s participation to the Eligible
Directors, and the Regulated Fund will
participate in such disposition solely to
the extent that a Required Majority
determines that it is in the Regulated
Fund’s best interests.
(d) Each participating Co-Investment
Affiliate will bear its own expenses in
connection with any such disposition.
8. (a) If any Co-Investment Affiliate
desires to make a Follow-On Investment
in a portfolio company whose securities
were acquired in a Co-Investment
Transaction, the Adviser will:
(i) notify each Regulated Fund that
participated in the Co-Investment
Transaction of the proposed transaction
at the earliest practical time; and
(ii) formulate a recommendation as to
the proposed participation, including
the amount of the proposed Follow-On
Investment, by each Regulated Fund.
(b) A Regulated Fund may participate
in such Follow-On Investment without
obtaining prior approval of the Required
Majority if: (i) the proposed
participation of each Co-Investment
Affiliate in such investment is
proportionate to its outstanding
investments in the issuer immediately
preceding the Follow-On Investment;
and (ii) the board of directors of the
Regulated Fund has approved as being
in the best interests of the Regulated
Fund the ability to participate in
Follow-On Investments on a pro rata
basis (as described in greater detail in
the application). In all other cases, the
Adviser will provide its written
recommendation as to the Regulated
Fund’s participation to the Eligible
Directors, and the Regulated Fund will
participate in such Follow-On
Investment solely to the extent that a
Required Majority determines that it is
in the Regulated Fund’s best interests.
(c) If, with respect to any Follow-On
Investment:
(i) the amount of the opportunity is
not based on the Co-Investment
Affiliates’ outstanding investments
immediately preceding the Follow-On
Investment; and
(ii) the aggregate amount
recommended by the Adviser to be
invested by the Regulated Fund in the
Follow-On Investment, together with
the amount proposed to be invested by
the participating Co-Investment
Affiliates in the same transaction,
exceeds the amount of the opportunity;
then the amount invested by each such
party will be allocated among them pro
rata based on each party’s Available
Capital in the asset class being
allocated, up to the amount proposed to
be invested by each.
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(d) The acquisition of Follow-On
Investments as permitted by this
condition will be considered a CoInvestment Transaction for all purposes
and subject to the other conditions set
forth in the application.
9. The Independent Directors of each
Regulated Fund will be provided
quarterly for review all information
concerning Potential Co-Investment
Transactions and Co-Investment
Transactions, including investments
made by other Co-Investment Affiliates
that the Regulated Fund considered but
declined to participate in, so that the
Independent Directors may determine
whether all investments made during
the preceding quarter, including those
investments that the Regulated Fund
considered but declined to participate
in, comply with the conditions of the
Order. In addition, the Independent
Directors will consider at least annually
the continued appropriateness for the
Regulated Fund of participating in new
and existing Co-Investment
Transactions.
10. Each Regulated Fund will
maintain the records required by section
57(f)(3) of the Act as if each of the
Regulated Funds were a BDC and each
of the investments permitted under
these conditions were approved by the
Required Majority under section 57(f).
11. No Independent Director will also
be a director, general partner, managing
member or principal, or otherwise an
‘‘affiliated person’’ (as defined in the
Act), of any of the Private Funds.
12. The expenses, if any, associated
with acquiring, holding or disposing of
any securities acquired in a CoInvestment Transaction (including,
without limitation, the expenses of the
distribution of any such securities
registered for sale under the Securities
Act) will, to the extent not payable by
the Adviser under its respective
investment advisory agreements with
the Co-Investment Affiliates, be shared
by the Co-Investment Affiliates in
proportion to the relative amounts of the
securities held or being acquired or
disposed of, as the case may be.
13. Any transaction fee (including
break-up or commitment fees but
excluding broker’s fees contemplated by
section 17(e) or 57(k), as applicable)
received in connection with a CoInvestment Transaction will be
distributed to the participating CoInvestment Affiliates on a pro rata basis
based on the amounts they invested or
committed, as the case may be, in such
Co-Investment Transaction. If any
transaction fee is to be held by the
Adviser pending consummation of the
transaction, the fee will be deposited
into an account maintained by the
VerDate Mar<15>2010
18:16 Mar 24, 2014
Jkt 232001
Adviser at a bank or banks having the
qualifications prescribed in section
26(a)(1), and the account will earn a
competitive rate of interest that will also
be divided pro rata among the
participating Co-Investment Affiliates
based on the amounts they invest in
such Co-Investment Transaction. None
of the Adviser, the Co-Investment
Affiliates nor any affiliated person of the
Co-Investment Affiliates will receive
additional compensation or
remuneration of any kind as a result of
or in connection with a Co-Investment
Transaction (other than (a) in the case
of the participating Co-Investment
Affiliates, the pro rata transaction fees
described above and fees or other
compensation described in condition
2(c)(iii)(C), and (b) in the case of the
Adviser, investment advisory fees paid
in accordance with the respective
agreements between the Adviser and the
Co-Investment Affiliates).
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–06465 Filed 3–24–14; 8:45 am]
BILLING CODE 8011–01–P
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes several
amendments to expand the short-term
option series (‘‘STOS’’) program. 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.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–71749; File No. SR–
NYSEMKT–2014–20]
Self-Regulatory Organizations; NYSE
MKT LLC; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Expanding the ShortTerm Option Series Program
March 19, 2014.
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 March
13, 2014 NYSE MKT LLC (the
‘‘Exchange’’ or ‘‘NYSE MKT’’) 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 solicit
comments on the proposed rule change
from interested persons.
1 15
U.S.C. 78s(b)(1).
U.S.C. 78a.
3 17 CFR 240.19b–4.
2 15
PO 00000
Frm 00113
Fmt 4703
Sfmt 4703
The Exchange proposes several
amendments to expand the STOS
Program (the ‘‘Proposal’’) to harmonize
the Exchange’s rules with recently
approved changes to the rules governing
short-term options series programs of
other options exchanges. The proposed
changes are discussed separately below
in order to align them with the recently
approved filings by the other exchanges.
The Exchange believes that this
Proposal would enable the Exchange to
compete equally and fairly with other
options exchanges in satisfying high
market demand for weekly options and
continuing strong customer demand to
use STOS to execute hedging and
trading strategies, particularly in the
current fast and volatile investing
environment.
Part I of the Proposal
Under Part I of the Proposal, the
Exchange proposes to make two changes
to the STOS Program for non-index
options, including equity, currency, and
exchange-traded funds (‘‘ETFs’’), as
follows: (i) to allow the Exchange to list
options in the STOS Program on each of
the next five Fridays that are business
days and are not Fridays in which
monthly options series or quarterly
options series expire (‘‘Short Term
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[Federal Register Volume 79, Number 57 (Tuesday, March 25, 2014)]
[Notices]
[Pages 16384-16388]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-06465]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-30985; File No. 812-14134]
PennantPark Investment Corp., et al.; Notice of Application
March 19, 2014.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application for an order under sections 17(d) and
57(i) of the Investment Company Act of 1940 (the ``Act'') and rule 17d-
1 under the Act to permit certain joint transactions otherwise
prohibited by sections 17(d) and 57(a)(4) of the Act and rule 17d-1
under the Act.
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Summary of Application: Applicants request an order to permit business
development companies (each, a ``BDC'') and certain closed-end
management investment companies to co-invest in portfolio companies
with each other and with affiliated investment funds.
Applicants: PennantPark Investment Corporation (``PNNT''), PennantPark
Floating Rate Capital Ltd. (``PFLT''), PennantPark Floating Rate
Capital Funding I, LLC (``Funding I''), PennantPark SBIC LP (``SBIC
I''), PennantPark SBIC II LP (``SBIC II''), PennantPark Credit
Opportunities Fund, LP (``PCOF'') and PennantPark Investment Advisers,
LLC (the ``Adviser'').
Filing Dates: The application was filed on March 15, 2013, and amended
on August 7, 2013, December 5, 2013 and March 5, 2014. Applicants have
agreed to file an amendment during the notice period, the substance of
which is reflected in this notice.
Hearing or Notification of Hearing: An order granting the 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 April 14, 2014, 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
St. NE., Washington, DC 20549-1090. Applicants: 590 Madison Avenue,
15th Floor, New York, NY 10022.
FOR FURTHER INFORMATION CONTACT: Laura L. Solomon, Senior Counsel, at
(202) 551-6915 or Daniele Marchesani, Branch Chief, at (202) 551-6821
(Chief Counsel's Office, Division of Investment Management).
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 for an
applicant using the Company name box, at https://www.sec.gov/search/search.htm or by calling (202) 551-8090.
Applicants' Representations
1. PNNT and PFLT are Maryland corporations organized as closed-end
management investment companies that have elected to be regulated as
BDCs under the Act (together, the ``PennantPark BDCs'').\1\ PNNT's
Objectives and Strategies \2\ are to generate both current income and
capital appreciation through debt and equity investments. PNNT invests
primarily in U.S. middle-market companies in the form of senior secured
loans, mezzanine debt and equity investments. PFLT's Objectives and
Strategies are to generate current income and capital appreciation by
investing primarily in floating rate loans and other investments made
to U.S. private middle-market companies. A majority of the directors of
each of PNNT and PFLT are not ``interested persons'' as defined in
section 2(a)(19) of the Act of PNNT and PFLT, respectively
(``Independent Directors'').
---------------------------------------------------------------------------
\1\ Section 2(a)(48) defines a BDC to be any closed-end
investment company that operates for the purpose of making
investments in securities described in sections 55(a)(1) through
55(a)(3) of the Act and makes available significant managerial
assistance with respect to the issuers of such securities.
\2\ ``Objectives and Strategies'' means a Regulated Fund's
(defined below) investment objectives and strategies as described in
the Regulated Fund's registration statement on Form N-2, other
filings the Regulated Fund has made with the Commission under the
Securities Act of 1933 (``Securities Act''), or under the Securities
Exchange Act of 1934, and the Regulated Fund's reports to
stockholders.
---------------------------------------------------------------------------
2. PCOF is a limited partnership organized under Delaware law and
is excluded from the definition of investment company under section
3(c)(7) of the Act. PCOF's investment objectives are capital
preservation, income generation and capital
[[Page 16385]]
appreciation primarily through debt and/or equity investments generally
in midsize companies in North America and Western Europe.
3. Funding I is a wholly-owned subsidiary of PFLT formed to enter
into a credit facility. SBIC I and SBIC II, wholly-owned subsidiaries
of PNNT, are Delaware limited partnerships operating as small business
investment companies whose investment objectives are to generate both
current income and capital appreciation through debt and equity
investments. Each of Funding I, SBIC I and SBIC II is a Wholly-Owned
Investment Subsidiary (as defined below).
4. PennantPark Investment Advisers, LLC, a Delaware limited
liability company, is and any other Adviser will be registered as an
investment adviser under the Investment Advisers Act of 1940 (the
``Advisers Act''). PennantPark Investment Advisers, LLC serves as the
investment adviser to PNNT, PFLT, PCOF and Funding I. PNNT advises SBIC
I and SBIC II.\3\
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\3\ Advisory personnel of the Adviser will act on behalf of PNNT
in providing management services to SBIC I and SBIC II.
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5. Applicants seek an order (``Order'') to permit one or more
Regulated Funds \4\ and one or more Private Funds \5\ to participate in
the same investment opportunities through a proposed co-investment
program where such participation would otherwise be prohibited under
sections 17(d) and 57(a)(4) and rule 17d-1 (the ``Co-Investment
Program'') by (a) co-investing with each other in certain securities of
issuers (a ``portfolio company'') and (b) making additional investments
in securities of issuers, including through the exercise of warrants,
conversion privileges, and other rights to purchase securities of the
issuers (``Follow-On Investments''). ``Co-Investment Transaction''
means any transaction in which a Regulated Fund (or a Wholly-Owned
Investment Subsidiary (as defined below)) participated together with a
Co-Investment Affiliate in reliance on the Order. ``Potential Co-
Investment Transaction'' means any investment opportunity in which a
Regulated Fund (or a Wholly-Owned Investment Subsidiary) could not
participate together with one or more Co-Investment Affiliates without
obtaining and relying on the Order.\6\
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\4\ ``Regulated Fund'' means the PennantPark BDCs and any
management investment company (a) that is registered under the Act
as a closed-end fund or has elected to be regulated as a BDC; (b)
whose investment adviser is PennantPark Investment Advisers, LLC or
any other adviser that is controlling, controlled by or under common
control with PennantPark Investment Advisers, LLC (included in the
term ``Adviser''); and (c) that intends to participate in the Co-
Investment Program (as defined below).
\5\ ``Private Fund'' means PCOF and any other entity (a) whose
investment adviser is an Adviser; (b) that would be an investment
company but for section 3(c)(1) or 3(c)(7) of the Act; and (c) that
intends to participate in the Co-Investment Program. The Private
Funds, together with the Regulated Funds are referred to as the
``Co-Investment Affiliates.''
\6\ All existing entities that currently intend to rely on the
Order have been named as applicants. Any other existing or future
entity that relies on the Order in the future will comply with the
terms and conditions of the application.
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6. Applicants state that a Regulated Fund may, from time to time,
form a special purpose subsidiary (a ``Wholly-Owned Investment
Subsidiary'').\7\ A Co-Investment Affiliate would be prohibited from
investing in a Co-Investment Transaction with any Wholly-Owned
Investment Subsidiary because the Wholly-Owned Investment Subsidiary
would be a company controlled by a Regulated Fund for purposes of
sections 17(d) and 57(a)(4) and rule 17d-1. Applicants request that a
Wholly-Owned Investment Subsidiary be permitted to participate in Co-
Investment Transactions in lieu of the parent Regulated Fund and that
the Wholly-Owned Investment Subsidiary's participation in any such
transaction be treated, for purposes of the Order, as though the
applicable Regulated Fund were participating directly. Applicants
represent that this treatment is justified because a Wholly-Owned
Investment Subsidiary would have no purpose other than serving as a
holding vehicle for a Regulated Fund's investments and, therefore, no
conflicts of interest could arise between such Regulated Fund and the
Wholly-Owned Investment Subsidiary. The board of directors of the
applicable Regulated Fund would make all relevant determinations under
the conditions with regard to a Wholly-Owned Investment Subsidiary's
participation in a Co-Investment Transaction, and the board of
directors would be informed of, and take into consideration, any
proposed use of a Wholly-Owned Investment Subsidiary in the applicable
Regulated Fund's place. If a Regulated Fund proposes to participate in
the same Co-Investment Transaction with any of its Wholly-Owned
Investment Subsidiaries, the board of directors will also be informed
of, and take into consideration, the relative participation of the
Regulated Fund and the Wholly-Owned Investment Subsidiary.
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\7\ The term ``Wholly-Owned Investment Subsidiary'' means an
entity (a) whose sole business purposes are to hold one or more
investments and issue debt on behalf of a Regulated Fund (and, in
the case of an SBIC Subsidiary (as defined below), maintain a
license under the SBA Act (as defined below) and issue debentures
guaranteed by the SBA (as defined below); (b) that is wholly-owned
by such Regulated Fund (with such Regulated Fund at all times
directly or indirectly holding, beneficially and of record, 100% of
the voting and economic interests); (c) with respect to which the
board of directors of the Regulated Fund has the sole authority to
make all determinations with respect to the Wholly-Owned Investment
Subsidiary's participation under the conditions of the application;
and (d) that is an entity that would be an investment company but
for section 3(c)(1) or 3(c)(7) of the Act. The term ``SBIC
Subsidiary'' means a Wholly-Owned Investment Subsidiary that is
licensed by the Small Business Administration (the ``SBA'') to
operate under the Small Business Investment Act of 1958, as amended,
(the ``SBA Act'') as a small business investment company (an
``SBIC'').
---------------------------------------------------------------------------
7. Applicants represent that the Advisers will refer all Potential
Co-Investment Transactions that an investment adviser considers for a
Co-Investment Affiliate, and that are within a Regulated Fund's
Objectives and Strategies, to that Regulated Fund's Adviser. For each
such referral, when selecting investments for a Co-Investment
Affiliate, the applicable Adviser will consider only the investment
objective, investment policies, investment position, Available Capital
(as defined below), and other pertinent factors applicable to the
respective Co-Investment Affiliate. The Adviser expects that a
portfolio company that is an appropriate investment for one Co-
Investment Affiliate may be an appropriate investment for another Co-
Investment Affiliate, with certain exceptions based on available
capital (``Available Capital'') \8\ or diversification.
---------------------------------------------------------------------------
\8\ ``Available Capital'' consists solely of liquid assets not
held for permanent investment, including cash, amounts that can
currently be drawn down from lines of credit, and marketable
securities held for short-term purposes. In addition, Available
Capital would include bona fide uncalled capital commitments that
can be called by the settlement date of the Co-Investment
Transaction.
---------------------------------------------------------------------------
8. Other than pro rata dispositions and Follow-On Investments as
provided in conditions 7 and 8, and after making the determinations
required in conditions 1 and 2(a), the Adviser will present each
Potential Co-Investment Transaction and the proposed allocation to the
directors of the board eligible to vote under section 57(o) of the Act
(``Eligible Directors''), and the ``required majority,'' as defined in
section 57(o) of the Act (``Required Majority'') \9\ of a Regulated
Fund will approve each Co-Investment Transaction prior to any
investment by a Regulated Fund.
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\9\ With respect to Regulated Funds that are not BDCs, the
defined terms Eligible Directors and Required Majority apply as if
each Regulated Fund were a BDC subject to section 57(o) of the Act.
---------------------------------------------------------------------------
9. With respect to the pro rata dispositions and Follow-On
Investments provided in conditions 7 and 8, a
[[Page 16386]]
Regulated Fund may participate in a pro rata disposition or Follow-On
Investment without obtaining prior approval of the Required Majority
if, among other things: (i) the proposed participation of each Co-
Investment Affiliate in such disposition or Follow-On Investment is
proportionate to its outstanding investments in the issuer immediately
preceding the disposition or Follow-On Investment, as the case may be;
and (ii) the board of directors of the Regulated Fund has approved that
Regulated Fund's participation in pro rata dispositions and Follow-On
Investments as being in the best interests of the Regulated Fund. If
the board does not so approve, any such disposition or Follow-On
Investment will be submitted to the Regulated Fund's Eligible
Directors. The board of any Regulated Fund may at any time rescind,
suspend or qualify its approval of pro rata dispositions and Follow-On
Investments with the result that all dispositions and/or Follow-On
Investments must be submitted to the Eligible Directors.
10. No Independent Director of a Regulated Fund will have a direct
or indirect financial interest in any Co-Investment Transaction or any
interest in a portfolio company other than through an interest (if any)
in the securities of a Regulated Fund and none will participate
individually in any Co-Investment Transaction.
Applicants' Legal Analysis
1. Section 17(d) of the Act and rule 17d-1 under the Act prohibit
affiliated persons of a registered investment company from
participating in joint transactions with the company or a company
controlled by such registered investment company unless the Commission
has granted an order permitting such transactions. Section 57(a)(4) of
the Act prohibits certain affiliated persons of a BDC from
participating in joint transactions with the BDC (or a company
controlled by such BDC) in contravention of rules as prescribed by the
Commission. Section 57(i) of the Act provides that, until the
Commission prescribes rules under section 57(a)(4), the Commission's
rules under section 17(d) of the Act applicable to registered closed-
end investment companies will be deemed to apply to BDCs. Because the
Commission has not adopted any rules under section 57(a)(4), rule 17d-1
applies.
2. Applicants submit that the Adviser and the Co-Investment
Affiliates would be deemed to be persons related to a Regulated Fund in
a manner described by sections 17(d) or 57(b) and therefore prohibited
by sections 17(d) or 57(a)(4) and rule 17d-1 from participating in the
Co-Investment Transactions without the Order.
3. Rule 17d-1 under the Act generally prohibits participation by a
registered investment company, or a company controlled by such
registered investment company, and an affiliated person (as defined in
section 2(a)(3) of the Act) or principal underwriter for that
investment company, or an affiliated person of such affiliated person
or principal underwriter, in any joint enterprise or other joint
arrangement or profit sharing plan, as defined in the rule, absent an
order by the Commission. Similarly, rule 17d-1, as made applicable to
BDCs by section 57(i), prohibits any person who is related to a BDC in
a manner described in section 57(b), acting as principal, from
participating in, or effecting any transaction in connection with, any
joint enterprise or other joint arrangement or profit-sharing plan in
which the BDC (or a company controlled by such BDC) is a participant,
absent an order from the Commission. In passing upon applications under
rule 17d-1, the Commission considers whether the company's
participation in the joint transaction is consistent with the
provisions, policies, and purposes of the Act and the extent to which
such participation is on a basis different from or less advantageous
than that of other participants.
4. Applicants state that co-investment in portfolio companies by
the Co-Investment Affiliates will increase favorable investment
opportunities for the PennantPark BDCs and any other Regulated Fund.
Applicants submit that the Required Majority's approval of each Co-
Investment Transaction before investment, and other protective
conditions set forth in the application, will ensure that the Regulated
Funds will be treated fairly. Applicants state that the Regulated
Funds' participation in the Co-Investment Transactions will be
consistent with the provisions, policies and purposes of the Act and on
a basis that is not different from or less advantageous than that of
other Co-Investment Affiliates.
Applicants' Conditions
Applicants agree that any Order granting the requested relief will
be subject to the following conditions:
1. Each time an investment adviser of a Co-Investment Affiliate
considers a Potential Co-Investment Transaction for any Co-Investment
Affiliate that falls within a Regulated Fund's Objectives and
Strategies, the Regulated Fund's Adviser will make an independent
determination of the appropriateness of the investment for the
Regulated Fund in light of the Regulated Fund's then-current
circumstances.
2. (a) If the Adviser deems a Regulated Fund's participation in any
Potential Co-Investment Transaction to be appropriate for the Regulated
Fund, it will then determine an appropriate level of investment for the
Regulated Fund;
(b) If the aggregate amount recommended by the Adviser to be
invested by the Regulated Fund in the Potential Co-Investment
Transaction, together with the amount proposed to be invested by each
other Co-Investment Affiliate, collectively in the same transaction,
exceeds the amount of the investment opportunity, the investment
opportunity will be allocated among them pro rata based on each
participating party's Available Capital in the asset class being
allocated, up to the amount proposed to be invested by each. The
Adviser will provide the respective Eligible Directors with information
concerning each party's Available Capital to assist the Eligible
Directors with their review of such Regulated Fund's investments for
compliance with these allocation procedures; and
(c) After making the determinations required in conditions 1 and
2(a), the Adviser will distribute written information concerning the
Potential Co-Investment Transaction, (including the amount proposed to
be invested by each Co-Investment Affiliate), to the Eligible Directors
for their consideration. The Regulated Fund will co-invest with one or
more Co-Investment Affiliates only if, prior to participating in the
Potential Co-Investment Transaction, a Required Majority concludes
that:
(i) the terms of the transaction, including the consideration to be
paid, are reasonable and fair to the Regulated Fund and its
stockholders and do not involve overreaching in respect of the
Regulated Fund or its stockholders on the part of any person concerned;
(ii) the transaction is consistent with:
(A) the interests of the stockholders of the Regulated Fund; and
(B) the Regulated Fund's then-current Objectives and Strategies;
(iii) the investment by the Co-Investment Affiliates would not
disadvantage the Regulated Fund, and participation by the Regulated
Fund would not be on a basis different from or less advantageous than
that of the Co-Investment Affiliates; provided, that, if any Co-
Investment Affiliate, but not the Regulated Fund itself, gains the
right to nominate a director for election to a portfolio company's
board of directors
[[Page 16387]]
or the right to have a board observer or any similar right to
participate in the governance or management of the portfolio company,
such event shall not be interpreted to prohibit the Required Majority
from reaching the conclusions required by this condition (2)(c)(iii),
if:
(A) the Eligible Directors will have the right to ratify the
selection of such director or board observer, if any;
(B) the Adviser agrees to, and does, provide periodic reports to
the Regulated Fund's board of directors with respect to the actions of
the director or the information received by the board observer or
obtained through the exercise of any similar right to participate in
the governance or management of the portfolio company; and
(C) any fees or other compensation that any Co-Investment Affiliate
or any affiliated person of any Co-Investment Affiliate receives in
connection with the right of the Co-Investment Affiliate to nominate a
director or appoint a board observer or otherwise to participate in the
governance or management of the portfolio company will be shared
proportionately among the participating Co-Investment Affiliates (the
Private Funds may, in turn, share their portion with their affiliated
persons) and the Regulated Fund in accordance with the amount of each
party's investment; and
(iv) the proposed investment by the Regulated Fund will not benefit
the Adviser or the Co-Investment Affiliates or any affiliated person of
any of them (other than the parties to the Co-Investment Transaction),
except (A) to the extent permitted by condition 13, (B) to the extent
permitted by section 17(e) or 57(k) of the Act, as applicable; (C)
indirectly, as a result of an interest in securities issued by one of
the parties to the Co-Investment Transaction, or (D) in the case of
fees or other compensation described in condition 2(c)(iii)(C).
3. Each Regulated Fund has the right to decline to participate in
any Potential Co-Investment Transaction or to invest less than the
amount proposed.
4. The Adviser will present to the board of directors of each
Regulated Fund, on a quarterly basis, a record of all investments in
Potential Co-Investment Transactions made by the Co-Investment
Affiliates during the preceding quarter that fell within the Regulated
Fund's then-current Objectives and Strategies that were not made
available to the Regulated Fund, and an explanation of why such
investment opportunities were not offered to the Regulated Fund. All
information presented to the board of directors pursuant to this
condition will be kept for the life of the Regulated Fund and at least
two years thereafter and will be subject to examination by the
Commission and its staff.
5. Except for Follow-On Investments made in accordance with
condition 8, the Regulated Fund will not invest in reliance on the
Order in any issuer in which any Co-Investment Affiliate or any
affiliated person of the Co-Investment Affiliates is an existing
investor.
6. The Regulated Fund will not participate in any Potential Co-
Investment Transaction unless the terms, conditions, price, class of
securities to be purchased, settlement date, and registration rights
will be the same for the Regulated Fund as for each participating Co-
Investment Affiliate. The grant to a Co-Investment Affiliate, but not
the Regulated Fund, of the right to nominate a director for election to
a portfolio company's board of directors, the right to have an observer
on the board of directors or similar rights to participate in the
governance or management of the portfolio company will not be
interpreted so as to violate this condition 6, if conditions
2(c)(iii)(A), (B) and (C) are met.
7. (a) If any Co-Investment Affiliate elects to sell, exchange or
otherwise dispose of an interest in a security that was acquired in a
Co-Investment Transaction, the Adviser will:
(i) notify each Regulated Fund that participated in the Co-
Investment Transaction of the proposed disposition at the earliest
practical time; and
(ii) formulate a recommendation as to participation by each
Regulated Fund in the disposition.
(b) Each Regulated Fund will have the right to participate in such
disposition on a proportionate basis, at the same price and on the same
terms and conditions as those applicable to the participating Co-
Investment Affiliates.
(c) A Regulated Fund may participate in such disposition without
obtaining prior approval of the Required Majority if: (i) The proposed
participation of each Co-Investment Affiliate in such disposition is
proportionate to its outstanding investment in the issuer immediately
preceding the disposition; (ii) the board of directors of the Regulated
Fund has approved as being in the best interests of the Regulated Fund
the ability to participate in such dispositions on a pro rata basis (as
described in greater detail in the application); and (iii) the board of
directors of the Regulated Fund is provided on a quarterly basis with a
list of all dispositions made in accordance with this condition. In all
other cases, the Adviser will provide its written recommendation as to
the Regulated Fund's participation to the Eligible Directors, and the
Regulated Fund will participate in such disposition solely to the
extent that a Required Majority determines that it is in the Regulated
Fund's best interests.
(d) Each participating Co-Investment Affiliate will bear its own
expenses in connection with any such disposition.
8. (a) If any Co-Investment Affiliate desires to make a Follow-On
Investment in a portfolio company whose securities were acquired in a
Co-Investment Transaction, the Adviser will:
(i) notify each Regulated Fund that participated in the Co-
Investment Transaction of the proposed transaction at the earliest
practical time; and
(ii) formulate a recommendation as to the proposed participation,
including the amount of the proposed Follow-On Investment, by each
Regulated Fund.
(b) A Regulated Fund may participate in such Follow-On Investment
without obtaining prior approval of the Required Majority if: (i) the
proposed participation of each Co-Investment Affiliate in such
investment is proportionate to its outstanding investments in the
issuer immediately preceding the Follow-On Investment; and (ii) the
board of directors of the Regulated Fund has approved as being in the
best interests of the Regulated Fund the ability to participate in
Follow-On Investments on a pro rata basis (as described in greater
detail in the application). In all other cases, the Adviser will
provide its written recommendation as to the Regulated Fund's
participation to the Eligible Directors, and the Regulated Fund will
participate in such Follow-On Investment solely to the extent that a
Required Majority determines that it is in the Regulated Fund's best
interests.
(c) If, with respect to any Follow-On Investment:
(i) the amount of the opportunity is not based on the Co-Investment
Affiliates' outstanding investments immediately preceding the Follow-On
Investment; and
(ii) the aggregate amount recommended by the Adviser to be invested
by the Regulated Fund in the Follow-On Investment, together with the
amount proposed to be invested by the participating Co-Investment
Affiliates in the same transaction, exceeds the amount of the
opportunity;
then the amount invested by each such party will be allocated among
them pro rata based on each party's Available Capital in the asset
class being allocated, up to the amount proposed to be invested by
each.
[[Page 16388]]
(d) The acquisition of Follow-On Investments as permitted by this
condition will be considered a Co-Investment Transaction for all
purposes and subject to the other conditions set forth in the
application.
9. The Independent Directors of each Regulated Fund will be
provided quarterly for review all information concerning Potential Co-
Investment Transactions and Co-Investment Transactions, including
investments made by other Co-Investment Affiliates that the Regulated
Fund considered but declined to participate in, so that the Independent
Directors may determine whether all investments made during the
preceding quarter, including those investments that the Regulated Fund
considered but declined to participate in, comply with the conditions
of the Order. In addition, the Independent Directors will consider at
least annually the continued appropriateness for the Regulated Fund of
participating in new and existing Co-Investment Transactions.
10. Each Regulated Fund will maintain the records required by
section 57(f)(3) of the Act as if each of the Regulated Funds were a
BDC and each of the investments permitted under these conditions were
approved by the Required Majority under section 57(f).
11. No Independent Director will also be a director, general
partner, managing member or principal, or otherwise an ``affiliated
person'' (as defined in the Act), of any of the Private Funds.
12. The expenses, if any, associated with acquiring, holding or
disposing of any securities acquired in a Co-Investment Transaction
(including, without limitation, the expenses of the distribution of any
such securities registered for sale under the Securities Act) will, to
the extent not payable by the Adviser under its respective investment
advisory agreements with the Co-Investment Affiliates, be shared by the
Co-Investment Affiliates in proportion to the relative amounts of the
securities held or being acquired or disposed of, as the case may be.
13. Any transaction fee (including break-up or commitment fees but
excluding broker's fees contemplated by section 17(e) or 57(k), as
applicable) received in connection with a Co-Investment Transaction
will be distributed to the participating Co-Investment Affiliates on a
pro rata basis based on the amounts they invested or committed, as the
case may be, in such Co-Investment Transaction. If any transaction fee
is to be held by the Adviser pending consummation of the transaction,
the fee will be deposited into an account maintained by the Adviser at
a bank or banks having the qualifications prescribed in section
26(a)(1), and the account will earn a competitive rate of interest that
will also be divided pro rata among the participating Co-Investment
Affiliates based on the amounts they invest in such Co-Investment
Transaction. None of the Adviser, the Co-Investment Affiliates nor any
affiliated person of the Co-Investment Affiliates will receive
additional compensation or remuneration of any kind as a result of or
in connection with a Co-Investment Transaction (other than (a) in the
case of the participating Co-Investment Affiliates, the pro rata
transaction fees described above and fees or other compensation
described in condition 2(c)(iii)(C), and (b) in the case of the
Adviser, investment advisory fees paid in accordance with the
respective agreements between the Adviser and the Co-Investment
Affiliates).
For the Commission, by the Division of Investment Management,
under delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-06465 Filed 3-24-14; 8:45 am]
BILLING CODE 8011-01-P