UBS AG, et al.;, 22728-22734 [2014-09212]
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participation of the Funds in the
proposed credit facility and the terms
and other conditions of any extensions
of credit under the credit facility.
14. The Trustees of each Fund,
including a majority of the Independent
Trustees, will:
(a) review, no less frequently than
quarterly, the Fund’s participation in
the proposed credit facility during the
preceding quarter for compliance with
the conditions of any order permitting
such transactions;
(b) establish the Bank Loan Rate
formula used to determine the interest
rate on Interfund Loans and review, no
less frequently than annually, the
continuing appropriateness of the Bank
Loan Rate formula; and
(c) review, no less frequently than
annually, the continuing
appropriateness of the Fund’s
participation in the proposed credit
facility.
15. In the event an Interfund Loan is
not paid according to its terms and such
default is not cured within two business
days from its maturity or from the time
the lending Fund makes a demand for
payment under the provisions of the
Interfund Lending Agreement, Vanguard
will promptly refer such loan for
arbitration to an independent arbitrator
selected by the Trustees of each Fund
involved in the loan who will serve as
arbitrator of disputes concerning
Interfund Loans.3 The arbitrator will
resolve any problem promptly, and the
arbitrator’s decision will be binding on
both Funds. The arbitrator will submit,
at least annually, a written report to the
Trustees setting forth a description of
the nature of any dispute and the
actions taken by the Funds to resolve
the dispute.
16. Each Fund will maintain and
preserve for a period of not less than six
years from the end of the fiscal year in
which any transaction by it under the
proposed credit facility occurred, the
first two years in an easily accessible
place, written records of all such
transactions setting forth a description
of the terms of the transactions,
including the amount, the maturity and
the Interfund Loan Rate, the rate of
interest available at the time each
Interfund Loan is made on overnight
repurchase agreements and commercial
bank borrowings, the yield of any
money market fund in which the
lending Fund could otherwise invest,
and such other information presented to
the Fund’s Trustees in connection with
3 If the dispute involves Funds with different
Trustees, the respective Trustees of each Fund will
select an independent arbitrator that is satisfactory
to each Fund.
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the review required by conditions 13
and 14.
17. The Fund Financial Services
Department will prepare and submit to
the Trustees for review an initial report
describing the operations of the
proposed credit facility and the
procedures to be implemented to ensure
that all Funds are treated fairly. After
the commencement of the proposed
credit facility, the Fund Financial
Services Department will report on the
operations of the proposed credit
facility at the Trustees’ meetings on a
quarterly basis.
Each Fund’s chief compliance officer,
as defined in rule 38a–1(a)(4) under the
Act, shall prepare an annual report for
its Trustees each year that the Fund
participates in the proposed credit
facility, that evaluates the Fund’s
compliance with the terms and
conditions of the application and the
procedures established to achieve such
compliance. Each Fund’s chief
compliance officer will also annually
file a certification pursuant to Item
77Q3 of Form N–SAR as such Form may
be revised, amended or superseded from
time to time, for each year that the Fund
participates in the proposed credit
facility, that certifies that the Fund, and
Vanguard have established procedures
reasonably designed to achieve
compliance with the terms and
conditions of the order. In particular,
such certification will address
procedures designed to achieve the
following objectives:
(a) that the Interfund Loan Rate will
be higher than the Repo Rate, and, if
applicable, the yield of the money
market funds, but lower than the Bank
Loan Rate;
(b) compliance with the collateral
requirements as set forth in the
application;
(c) compliance with the percentage
limitations on interfund borrowing and
lending;
(d) allocation of interfund borrowing
and lending demand in an equitable
manner and in accordance with
procedures established by the Trustees;
and
(e) that the Interfund Loan Rate does
not exceed the interest rate on any third
party borrowings of a borrowing Fund at
the time of the Interfund Loan.
Additionally, each Fund’s
independent public accountants, in
connection with their audit examination
of the Fund, will review the operation
of the proposed credit facility for
compliance with the conditions of the
application and their review will form
the basis, in part, of the auditor’s report
on internal accounting controls in Form
N–SAR.
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18. No Fund will participate in the
proposed credit facility upon receipt of
requisite regulatory approval unless it
has fully disclosed in its prospectus
and/or statement of additional
information all material facts about its
intended participation.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–09236 Filed 4–22–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
31019; File No.813–336]
UBS AG, et al.; Notice of Application
April 17, 2014.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under sections 6(b) and 6(e) of the
Investment Company Act of 1940 (the
‘‘Act’’) exempting the applicants from
all provisions of the Act, except section
9 and sections 36 through 53, and the
rules and regulations under the Act.
With respect to sections 17 and 30 of the
Act, and the rules and regulations
thereunder, and rule 38a–1 under the
Act, the exemption would be limited as
set forth in the application.
AGENCY:
Summary of Application: Applicants
request an order to exempt certain
investment vehicles (‘‘Funds’’) formed
for the benefit of key employees of UBS
AG (‘‘UBS’’) and its affiliates from
certain provisions of the Act. Each Fund
will be an ‘‘employees’ securities
company’’ within the meaning of
section 2(a)(13) of the Act.
Applicants: UBS, UBS IB CoInvestment 2001 Limited Partnership
(‘‘CLP1’’) and UBS IB Co-Investment
2001 (No. 1) Feeder L.P. (‘‘Feeder L.P.’’).
DATES: Filing Dates: The application was
filed on July 6, 2001, and amended on
January 9, 2004, May 8, 2008, November
20, 2012 and January 22, 2014.
Hearing or Notification of Hearing: An
order granting the application will be
issued unless the Commission orders a
hearing. Interested persons may request
a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on May 12, 2014, and
should be accompanied by proof of
service on applicants, in the form of an
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affidavit or, for lawyers, a certificate of
service. Hearing requests should state
the nature of the writer’s interest, the
reason for the request, and the issues
contested. Persons who wish to be
notified of a hearing may request
notification by writing to the
Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
Applicants, 677 Washington Boulevard,
Stamford, CT 06901.
FOR FURTHER INFORMATION CONTACT: Jaea
F. Hahn, Senior Counsel, at (202) 551–
6870, or David P. Bartels, at (202) 551–
6821 (Division of Investment
Management, Chief Counsel’s Office).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or 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. UBS is a bank established under the
laws of Switzerland that offers a range
of financial services including private
banking, asset management and
investment banking services.
2. UBS has organized CLP1, a Cayman
Island limited partnership, and Feeder
L.P., a Delaware limited partnership, as
the Initial Funds. UBS intends to
organize additional Funds from time to
time for the benefit of highly
compensated current and former
employees, officers and directors of UBS
and its affiliates (as defined in rule 12b–
2 under the Securities Exchange Act of
1934 (the ‘‘Exchange Act’’))
(collectively, the ‘‘UBS Group’’) who
have been approved to purchase
interests by UBS (‘‘Eligible
Employees’’). Each Fund will be an
‘‘employees’ securities company’’
within the meaning of section 2(a)(13) of
the Act and will operate as a closed-end,
management investment company,
which may be diversified or
nondiversified. Applicants state that the
Funds are designed primarily to create
capital appreciation opportunities that
are competitive with those at other
financial services firms and to facilitate
the recruitment and retention of high
caliber professionals. Applicants assert
that participation by Eligible Employees
in the Funds may allow them to
diversify their investments or to
participate in investments that might
not otherwise be available to them or
that might be beyond their individual
means. The investment objectives and
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policies for each Fund may vary from
Fund to Fund, and participation in a
Fund will be voluntary.
3. Applicants state that each Fund
will be organized as a limited
partnership, a limited liability company,
a corporation, or another appropriate
entity, in each case organized under the
laws of a state of the United States or
of a jurisdiction outside the United
States. Applicants state that, because a
large portion of Eligible Employees
reside outside of the United States,
applicants expect that most, if not all, of
the Funds will be organized under the
laws of jurisdictions outside of the
United States for various tax, regulatory,
and other reasons.1
4. Each Fund will be managed,
operated and controlled by a general
partner that is controlled, directly or
indirectly, by UBS (a ‘‘General
Partner’’).2 Applicants state that the
General Partner will be responsible for
the overall management of each Fund
and will have the authority to make all
decisions regarding the acquisition,
management and disposition of Fund
investments. The executive officers and
directors of the General Partner or of
any entity controlling the General
Partner will be employees of UBS
Group, a majority of whom will be
eligible to invest in the Fund.
Applicants state that the General Partner
may delegate all management
responsibilities, including responsibility
for investment decisions in respect of
the Fund, to UBS or another entity that
is part of the UBS Group as investment
manager (the ‘‘Investment Manager’’).
The General Partner or Investment
Manager will register as an investment
adviser under the Investment Advisers
Act of 1940 (‘‘Advisers Act’’), if required
under applicable law.3 Whenever UBS,
the General Partner or any other person
1 Applicants state that, for tax, regulatory or other
reasons, a Fund organized for employees residing
in a particular country may have different terms
than other Funds organized for employees residing
in other countries, and Funds that are organized at
different times are likely to have different terms.
However, no organizational document for, or any
other contractual arrangement regarding, a Fund
will contain any provision that protects or purports
to protect UBS AG, the General Partner or their
delegates against any liability with respect to the
Fund or its security holders to which such person
would otherwise be subject by reason of willful
malfeasance, bad faith, or gross negligence in the
performance of such person’s duties, or by reason
of such person’s reckless disregard of such person’s
obligations and duties under such contract or
organizational documents. Moreover, all Funds will
be subject to, and comply with, the terms and
conditions of the application.
2 If a form of organization other than a limited
partnership is used, the functions of the General
Partner will be performed by a corresponding entity
or governing body.
3 Applicants acknowledge that no relief in respect
of such determination is requested.
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acting for or on behalf of a Fund is
required or permitted to make a
decision, take or approve an action, or
omit to do any of the foregoing in such
person’s discretion, such person will act
in the best interest of the Fund and its
security holders and will exercise such
discretion in accordance with
reasonableness and good faith and any
fiduciary duties owed to the Fund and
its security holders.
5. The Investment Manager may, from
time to time, be presented with
investment opportunities by one or
more investment advisers (‘‘Investment
Advisers’’) that are engaged by the
Investment Manager that may be
affiliated or not affiliated with UBS (any
such non-affiliated Investment Adviser
being referred to as an ‘‘Outside
Investment Adviser’’). If the Investment
Manager elects to enter into any side-byside investment with a party that is not
a member of the UBS Group, the
Investment Manager will be permitted
to engage as an Investment Adviser the
Outside Investment Adviser responsible
for the management of such side-by-side
investment. In each of the foregoing
cases, however, all decisions with
respect to the purchase, holding or
disposition of investments by each Fund
will be made by either the General
Partner or the Investment Manager
alone, and not by any Investment
Adviser.
6. Interests in the Funds (‘‘Interests’’)
will be offered without registration in
reliance on section 4(a)(2) of the
Securities Act of 1933 (the ‘‘Securities
Act’’), or Regulation D under the
Securities Act, and will be sold only to
Qualified Participants, as defined
below, and members of the UBS Group.4
The term ‘‘Qualified Participant’’
means: (a) Eligible Employees, (b)
spouses, parents, children, spouses of
children, brothers, sisters and
grandchildren of Eligible Employees
(‘‘Qualified Family Members’’) and (c)
trusts or other investment vehicles
established solely for the benefit of
Eligible Employees or Qualified Family
Members (‘‘Qualified Investment
Vehicles’’).
7. An Eligible Employee must be
either (a) an ‘‘accredited investor’’ as
defined in rule 501(a)(6) or 501(a)(5) of
Regulation D under the Securities Act
(an ‘‘Accredited Investor’’) or (b) one of
not more than 35 employees of the UBS
Group who meets the salary and other
requirements as described below
(‘‘Other Investors’’). Each Other Investor
4 Any member of the UBS Group that acquires
Interests will be an ‘‘accredited investor,’’ as
defined in rule 501(a) of Regulation D under the
1933 Act.
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will, at the time of investment in a
Fund, (x) be a ‘‘knowledgeable
employee,’’ as defined in rule 3c–5
under the Act, of such Fund (with the
Fund treated as though it were a
‘‘Covered Company’’ for purposes of
such rule) or (y) have (i) a graduate
degree in business, law or accounting,
(ii) a minimum of five years of
consulting, investment banking, legal or
similar business experience and (iii) a
reportable income from all sources in
the two calendar years immediately
preceding their participation of at least
$100,000 and a reasonable expectation
of income from all sources of at least
$140,000 per year in each year in which
the person invests in a Fund. An Other
Investor qualifying under (y) above will
not be permitted to invest in any year
more than 10% of such person’s income
from all sources for the immediately
preceding year in the aggregate in a
Fund and in all other Funds in which
that Other Investor has previously
invested. A Qualified Family Member
who purchases an Interest must be an
Accredited Investor.
8. An Eligible Employee or a
Qualified Family Member may purchase
an Interest through a Qualified
Investment Vehicle only if either (a)
such investment vehicle is an
‘‘accredited investor,’’ as defined in rule
501(a) of Regulation D under the
Securities Act or (b) such Eligible
Employee or Qualified Family Member
is a settlor and principal investment
decision-maker with respect to such
investment vehicle. Prior to offering
Interests to an Eligible Employee or
Qualified Family Member, UBS must
reasonably believe that such individual
has such knowledge, sophistication and
experience in business and financial
matters to be capable of evaluating the
merits and risks of participating in the
Fund, is able to bear the economic risk
of such investment and is able to afford
a complete loss of such investment.
9. Applicants represent that the
material terms of investment in a Fund,
including without limitation, the terms
and conditions of any and all transfers
of Interests in any Fund, will be fully
disclosed to each Qualified Participant
and member of the UBS Group when
Interests are offered to that person. The
specific investment objectives and
strategies for a particular Fund will be
set forth in a private placement
memorandum relating to the Interests
offered by a Fund. In connection with
an investment in a Fund, each Qualified
Participant and member of the UBS
Group will receive the private
placement memorandum, form of
application and the limited partnership
agreement (or other constitutive
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document) of the Fund. Each Fund will
send its investors (‘‘Investors’’) annual
reports, which will contain audited
financial statements, as soon as
practicable after the end of each fiscal
year.5 In addition, as soon as practicable
after the end of each tax year of a Fund,
a report will be transmitted to each
Investor setting forth such tax
information as shall be necessary for the
preparation by the Investor of his or her
federal tax returns.
10. Interests in a Fund will not be
transferable by an Investor except with
the prior written consent of UBS or a
Fund’s General Partner and then only to
Qualified Participants or to members of
the UBS Group. Applicants expect that
interests in the Funds will generally not
be redeemable at the option of an
Investor (except on liquidation of a
Fund) but state that it is possible that
one or more Funds may offer Interests
with certain redemption rights. With
respect to certain Funds, UBS may have
the right, but not the obligation, to
repurchase or cancel the Interest of an
Eligible Employee who ceases to be an
employee, officer or director of any
member of the UBS Group for any
reason. Upon repurchase or
cancellation, such Investor’s Interest
will be purchased by the General
Partner for cash in an amount at least
equal to the lesser of (a) the amount of
such Investor’s capital contributions
less prior distributions from the Fund
(plus interest, as determined by UBS) or
(b) the value of the Interest, as
determined by UBS in good faith as of
the date of termination. For other
Funds, UBS AG may be permitted to
exercise this right only under particular
circumstances, such as if an employee
resigns to join a competitor of the UBS
Group, or not at all.
11. UBS may establish one or more
deferred compensation plans in
connection with the Funds. Applicants
state that Eligible Employees may be
able to defer compensation and receive
a return on such deferred compensation
determined by reference to the
performance of a Fund. The deferred
compensation plans and/or an Eligible
Employee’s interest in such plans: (a)
Will be subject to the applicable terms
and conditions of the application; 6 (b)
5 For the purposes of the application, ‘‘audit’’ has
the meaning provided in rule 1–02(d) of Regulation
S–X.
6 For purposes of this application, a Fund will be
deemed to be formed with respect to each deferred
compensation plan and each reference to ‘‘Fund,’’
‘‘capital contribution,’’ ‘‘General Partners,’’
‘‘Investor,’’ ‘‘loans’’ or ‘‘leverage’’ and ‘‘Interest’’ in
this application will be deemed to refer to the
deferred compensation plan, the notional capital
contribution to the deferred compensation plan, the
UBS Group, a participant of the deferred
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will only be offered to Eligible
Employees who are current employees,
officers or directors of the UBS Group;
(c) will have restrictions on
transferability, including prohibitions
on assignment or transfer except in the
event of the Eligible Employee’s death
or as otherwise required by law; and (d)
will provide information to participants
equivalent to that provided to investors
and prospective investors in the
corresponding Fund, including, without
limitation, disclosure documents and
audited financial information.
12. The General Partner or Investment
Manager of a Fund may charge the Fund
an annual management fee, a flat
administrative charge or an expense
reimbursement, but will not charge a
carried interest. Any expense
reimbursement may cover out-of-pocket
expenses of the General Partner or
Investment Manager, including
allocable portions of the salaries of UBS
Group employees who work on the
Funds’ affairs. Directors or officers of
the General Partner or Investment
Manager, or of any entity controlling the
General Partner or Investment Manager,
may also be compensated for their
services to the General Partner or
Investment Manager, including
reimbursement for out-of-pocket
expenses. A Fund will not pay both a
fee to the General Partner of the Fund
and a fee to the Investment Manager of
the Fund for providing the same
services or bearing the same expenses.
An Investment Adviser to the
Investment Manager may charge the
Fund an advisory fee; however, such
advisory fee will not be duplicative of
any fees paid to the General Partner. No
fee of any kind will be charged in
connection with the sale of Interests.
13. If a Fund becomes a limited
partner or otherwise holds an interest in
an investment fund organized or
managed by the UBS Group in which
affiliated third parties also are limited
partners or otherwise hold interests (a
‘‘Client Fund’’), the Fund may be
obligated to pay a pro rata share of any
fees (including carried interest) charged
to the unaffiliated limited partners or
interest holders of such Client Fund. A
Fund may also invest in funds managed
or advised by an Outside Investment
Adviser, which may be entitled to fees
(including carried interest) from the
Fund. In all such cases, the Fund will
enter into commercially reasonable
arm’s length arrangements with respect
to the payment of the fees, and the
potential for payment of any such
compensation plan, notional loans or leverage and
participation rights in the deferred compensation
plan, respectively.
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management fees or carried interest will
be fully described in the applicable
offering documents.
14. Subject to the terms of the
applicable limited partnership
agreement (or other constitutive
documents), a Fund will be permitted to
enter into transactions involving (a) a
UBS Group entity, (b) a Client Fund or
other portfolio company, (c) any
Investor or any person or entity
affiliated with an Investor, or (d) any
partner or other investor in any entity in
which a Fund invests. These
transactions may include a Fund’s
purchase or sale of an investment or an
interest from or to any UBS Group entity
or Client Fund, acting as principal. Prior
to entering into these transactions, the
General Partner (or the Investment
Manager, to whom the General Partner
may delegate this responsibility) must
determine that the terms are fair to
Investors.
15. A Fund will not invest more than
15% of its assets in securities issued by
registered investment companies except
for temporary investments in money
market funds. A Fund will not acquire
any security issued by a registered
investment company if, immediately
after the acquisition, the Fund will own
more than 3% of the outstanding voting
stock of the registered investment
company. Applicants state that a Fund
may also invest in Client Funds that are
not registered under the Act by virtue of
section 3(c)(1) or section 3(c)(7) of the
Act.7
16. Members of the UBS Group and/
or unaffiliated third parties may make
loans to Funds and/or to Investors in
connection with their purchase of
Interests, provided that a Fund will not
borrow from any person if the
borrowing would cause any person not
named in section 2(a)(13) of the Act to
own outstanding securities of the Fund
(other than short-term paper). Members
of the UBS Group may also make
preferred capital contributions to the
Funds. In connection with any leverage
of the Fund or preferred capital
contributions, Eligible Employees will
not have any personal liability in excess
of the amounts payable under their
respective subscription agreements for
the repayment of the loan or preferred
capital contribution, including in the
event that, upon liquidation of the
Fund, the assets of the Fund are
insufficient to permit the Fund to repay
such loan preferred capital contribution
7 Applicants are not requesting any exemption
from any provision of the Act or any rule
thereunder that may govern a Fund’s eligibility to
invest in a Client Fund relying on section 3(c)(1) or
3(c)(7) of the Act or a Client Fund’s status under
the Act.
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in full. Any leverage or preferred capital
contributions will bear interest at a rate
no less favorable to a Fund or its
Investors than that could be obtained on
an arm’s length basis. The terms of any
leverage or preferred capital
contribution provided by any member of
the UBS Group (or third party lender)
will be described in the applicable
private placement memorandum and
partnership agreement (or other
constitutive documents) as appropriate.
Applicants’ Legal Analysis
1. Section 6(b) of the Act provides, in
part, that the Commission will exempt
employees’ securities companies from
the provisions of the Act to the extent
that the exemption is consistent with
the protection of investors. Section 6(b)
provides that the Commission will
consider, in determining the provisions
of the Act from which the company
should be exempt, the company’s form
of organization and capital structure, the
persons who will own and control the
company’s voting securities, evidences
of indebtedness and other securities, the
prices at which securities issued by the
company will be sold and any
applicable sales load, the disposition of
the proceeds of the securities issued by
the company, the character of securities
in which those proceeds will be
invested, and any relationship between
the company and the issuers of the
securities. Section 2(a)(13) defines an
employees’ securities company, in
relevant part, as any investment
company all of whose securities are
beneficially owned (a) by current or
former employees, or persons on
retainer, of one or more affiliated
employers, (b) by immediate family
members of such persons, or (c) by such
employer or employers, together with
any of the persons in (a) or (b).
2. Section 7 of the Act generally
prohibits investment companies that are
not registered under section 8 of the Act
from selling or redeeming their
securities. Section 6(e) provides that, in
connection with any order exempting an
investment company from any provision
of section 7, certain provisions of the
Act, as specified by the Commission,
will be applicable to the company and
other persons dealing with the company
as though the company were registered
under the Act. Applicants request an
order under sections 6(b) and 6(e) of the
Act exempting the Funds from all
provisions of the Act, except section 9
and sections 36 through 53 of the Act,
and the rules and regulations
thereunder. With respect to sections 17
and 30 of the Act, and the rules and
regulations thereunder, and rule 38a–1
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22731
under the Act, the exception is limited
as set forth in the application.
3. Section 17(a) generally prohibits
any affiliated person of a registered
investment company, or any affiliated
person of that person, acting as
principal, from knowingly selling or
purchasing any security or other
property to or from the company.
Applicants request an exemption from
section 17(a) to permit: (a) A member of
the UBS Group or a Client Fund, acting
as principal, to engage in any
transaction directly or indirectly with
any Fund or entity controlled by such
Fund; (b) a Fund to invest in or engage
in any transaction with any entity,
acting as principal (i) in which such
Fund, any company controlled by such
Fund, or any entity within the UBS
Group or a Client Fund has invested or
will invest or (ii) with which such
Fund, any company controlled by such
Fund or any entity within the UBS
Group or a Client Fund is or will
otherwise become affiliated; and (c) a
partner or other investor in any entity in
which a Fund invests, acting as
principal, to engage in transactions
directly or indirectly with the related
Fund or any company controlled by
such Fund.
4. Applicants state that an exemption
from section 17(a) is consistent with the
protection of investors and the purposes
of the Funds. Applicants state that the
Investors in each Fund will be informed
of the possible extent of the Fund’s
dealings with the UBS Group and of the
potential conflicts of interest that may
exist. Applicants also assert that the
community of interest among the
Investors and UBS Group will serve to
reduce any risk of abuse in transactions
involving a Fund and the UBS Group.
Applicants represent that the requested
relief will not extend to any transaction
between a Fund and an Outside
Investment Adviser or an affiliated
person of the Outside Investment
Adviser, or between a Fund and who is
not a member of the UBS Group or an
employee, officer or director of a
member of the UBS Group and is an
affiliated person of the Fund as defined
in section 2(a)(3)(E) of the Act
(‘‘Advisory Person’’) or any affiliated
person of such person.
5. Section 17(d) of the Act and rule
17d–1 under the Act prohibit any
affiliated person of a registered
investment company, or any affiliated
person of an affiliated person, acting as
principal, from participating in any joint
enterprise, or other joint arrangement,
unless approved by the Commission.
Applicants request relief to permit
affiliated persons of each Fund, or
affiliated persons of such persons, to
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participate in any joint arrangement in
which the Fund or an entity controlled
by the Fund is a participant. Applicants
acknowledge that the requested relief
will not extend to any transaction in
which an Outside Investment Adviser or
an Advisory Person, or an affiliated
person of either, has an interest.
6. Applicants assert that compliance
with section 17(d) could cause a Fund
to forego investment simply because an
affiliate of the Fund has made, or is
contemplating making, the same
investment. Applicants also submit that
the types of investment opportunities
considered by a Fund often require each
investor to make funds available in an
amount that may be substantially greater
than what a Fund may make available
on its own. Applicants state that the
possibility that permitting coinvestments by an affiliated person or
an affiliated person of an affiliated
person might lead to less advantageous
treatment of the Fund is minimal in
light of (a) the UBS Group’s intention in
establishing a Fund so as to reward
Eligible Employees and to attract and
retain highly qualified personnel, (b) the
UBS Group’s capital contributions to the
Funds, and (c) the fact that a majority
of the directors of the General Partner or
Investment Manager or of the entity
controlling the General Partner or
Investment Manager may themselves
invest in the Fund.
7. Applicants believe that the interests
of the Eligible Employees participating
in a Fund will be adequately protected
in situations where condition 3 in the
application does not apply. Applicants
state that a Fund may co-invest with an
investment fund or separate account,
organized for the benefit of investors
who are not affiliated with the UBS
Group, over which a member of the UBS
Group exercises investment discretion
(a ‘‘Third-Party Fund’’). Applicants
assert that, in structuring a Third-Party
Fund, it is common for unaffiliated
investors of such fund to require that
the UBS Group invest its own capital in
fund investments, either through the
fund or on a side-by-side basis, and that
such UBS Group investment be subject
to substantially the same terms as those
applicable to the fund’s investment.
Applicants state that it is important to
the UBS Group that the interests of the
Third-Party Fund take priority over the
interests of the Funds, and that the
activities of the Third-Party Fund not be
burdened or otherwise affected by the
activities of the Funds. In addition,
applicants contend that the relationship
of a Fund to a Third-Party Fund, in the
context of this application, is
fundamentally different from such
Fund’s relationship to the UBS Group.
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Applicants assert that the focus of, and
the rationale for, the protections
contained in condition 3 are to protect
the Funds from any overreaching by the
UBS Group in the employer/employee
context, whereas the same concerns are
not present with respect to the Funds
`
vis-a-vis the investors of a Third-Party
Fund.
8. Section 17(e) of the Act and rule
17e–1 under the Act limit the
compensation an affiliated person may
receive when acting as agent or broker
for a registered investment company.
Applicants request an exemption from
section 17(e) to permit a UBS Group
member (including the General Partner)
acting as agent or broker, to receive
placement fees, financial advisory fees
or other compensation in connection
with the purchase or sale by a Fund of
securities, subject to the requirement
that placement fees, financial advisory
fees or other compensation is deemed
‘‘usual and customary.’’ Applicants state
that for the purposes of the application,
fees and other compensation that is
being charged or received by the UBS
Group entity will be deemed ‘‘usual and
customary’’ only if (a) the Fund is
purchasing or selling securities with
other unaffiliated third parties, (b) the
fees or compensation being charged to
the Fund are also being charged to the
unaffiliated third parties, and (c) the
amount of securities being purchased or
sold by the Fund does not exceed 50%
of the total amount of securities being
purchased or sold by the Fund and
unaffiliated third parties.
9. Applicants assert that compliance
with section 17(e) would prevent a
Fund from participating in a transaction
in which a member of the UBS Group
does not, for other business reasons,
wish a Fund to be treated in a more
favorable manner (in terms of lower
fees) than unaffiliated third parties also
participating in the transaction.
Applicants assert that the concerns of
overreaching and abuse that section
17(e) and rule 17e–1 were designed to
prevent are alleviated by the conditions
that ensure that fees or other
compensation paid to members of the
UBS Group are the same as those
negotiated at arm’s length with
unaffiliated third parties, and the
unaffiliated third parties have as great or
greater interest as the Fund in the
transaction as a whole.
10. Rule 17e–1(b) requires that a
majority of directors who are not
‘‘interested persons’’ (as defined by
section 2(a)(19) of the Act) take actions
and make approvals regarding
commissions, fees, or other
remuneration. Applicants request an
exemption from rule 17e–1 to the extent
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Fmt 4703
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necessary to permit each Fund to
comply with the rule without having a
majority of the directors of the General
Partner who are not interested persons
take actions and make determinations as
set forth in paragraph (b) of the rule.
Applicants state that because all of the
directors of a General Partner will be
affiliated persons, without the relief
requested, a Fund could not comply
with rule 17e–1. Applicants state that
each Fund will comply with rule 17e–
1(b) by having a majority of the directors
of the General Partner take actions and
make approvals as set forth in rule 17e–
1. Applicants state that each Fund will
otherwise comply with the requirements
of rule 17e–1.
11. Section 17(f) designates the
entities that may act as investment
company custodians, and rule 17f–1
imposes certain requirements when the
custodian is a member of a national
securities exchange. Applicants request
an exemption from section 17(f) and
rule 17f–1(a) to the extent necessary to
permit a member of the UBS Group to
act as custodian for a Fund without a
written contract. Applicants also request
an exemption from the rule 17f–1(b)(4)
requirement that an independent
accountant periodically verify the assets
held by the custodian . Applicants
further request an exemption from rule
17f–1(c)’s requirement of transmitting to
the Commission a copy of any contract
executed pursuant to rule 17f–1.
Applicants believe that, because of the
community of interest of all of the
parties involved and the requirement to
provide annual audited financial
reports, compliance with these
requirements would be unnecessary.
Applicants state that they will comply
with rule 17f–1(d), provided that
ratification by the General Partner of
any Fund will be deemed to be
ratification by a majority of a board of
directors. Applicants state that they will
comply with all other requirements of
rule 17f–1.
12. Section 17(g) and rule 17g–1
generally require the bonding of officers
and employees of a registered
investment company who have access to
its securities or funds. Rule 17g–1
requires that a majority of directors who
are not interested persons take certain
actions and give certain approvals
relating to fidelity bonding. Applicants
request relief to the extent necessary to
permit the General Partner’s officers and
directors, who may be deemed to be
interested persons, to take the actions
and make the determinations set forth in
the rule. Applicants also request an
exemption from the requirements of
paragraph (g) of rule 17g–1 relating to
the filing of copies of fidelity bonds and
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related information with the
Commission and the provision of
notices to the board of directors, and
paragraph (h) of rule 17g–1 relating to
the appointment of a person to make the
filings and provide the notices required
by paragraph (g). Applicants state that,
because all the directors of the General
Partner will be affiliated persons, a
Fund could not comply with rule 17g–
1 without the requested relief. Each
Fund will comply with rule 17g–1 by
having a majority of the General
Partner’s directors take actions and
make determinations as set forth in rule
17g–1. Applicants also state that the
Funds will comply with all other
requirements of rule 17g–1.
13. Section 17(j) and paragraph (b) of
rule 17j–1 make it unlawful for certain
enumerated persons to engage in
fraudulent or deceptive practices in
connection with the purchase or sale of
a security held or to be acquired by a
registered investment company. Rule
17j–1 also requires that every registered
investment company adopt a written
code of ethics and that every access
person of a registered investment
company report personal securities
transactions. Applicants request an
exemption from the provisions of rule
17j–1, except for the antifraud
provisions of paragraph (b), asserting
that these provisions are unnecessarily
burdensome because of the community
of interest among the Investors. The
relief requested will only extend to
members of the UBS Group and is not
requested with respect to any Outside
Investment Adviser or Advisory Person.
14. Applicants request an exemption
from the requirements in sections 30(a),
30(b) and 30(e), and the rules under
those sections, that registered
investment companies prepare and file
with the Commission and mail to their
shareholders certain periodic reports
and financial statements. Applicants
contend that the forms prescribed by the
Commission for periodic reports have
little relevance to the Funds and would
entail administrative and legal costs that
outweigh any benefit to the Investors.
Applicants request exemptive relief to
the extent necessary to permit each
Fund to report annually to its Investors.
Applicants also request an exemption
from section 30(h) to the extent
necessary to exempt the General Partner
of each Fund and any other person who
may be deemed to be a member of an
advisory board of a Fund from filing
Forms 3, 4, and 5 under section 16(a) of
the Exchange Act with respect to their
ownership of Interests in a Fund.
Applicants assert that, because there
will be no trading market and the
transfers of Interests will be severely
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15:37 Apr 22, 2014
Jkt 232001
restricted, these filings are unnecessary
for the protection of investors and
burdensome to those required to make
them.
15. Rule 38a–1 requires investment
companies to adopt, implement and
periodically review written policies and
procedures reasonably designed to
prevent violation of the federal
securities laws, appoint a chief
compliance officer and maintain certain
records. Applicants state that the Funds
will comply with rule 38a–1(a), (c) and
(d), except that (a) the board of directors
of the General Partner of each Fund will
fulfill the responsibilities assigned to
the Fund’s board of directors under the
rule, (b) because all members of the
board of directors of the General Partner
would be considered interested persons
of the Funds, approval by a majority of
the disinterested directors required by
rule 38a–1 would not be obtained, and
(c) because the board of directors of the
General Partner do not have any
disinterested members, the Funds will
comply with the requirement in rule
38a–1(a)(4)(iv) that the chief compliance
officer meet with the independent
directors by having the chief
compliance officer meet with the board
of directors of the General Partner as
constituted. Applicants assert that, in
view of the community of interest
between the Funds and the General
Partners and Investment Managers,
there is no significant benefits to be
gained from imposing the costs of
compliance with the other aspects of the
rule on the Funds.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
1. Each proposed transaction to which
a Fund is a party otherwise prohibited
by section 17(a) or section 17(d) of the
Act and rule 17d–1 thereunder (the
‘‘Section 17 Transactions’’) will be
effected only if the General Partner
determines that: (a) The terms of the
Section 17 Transaction, including the
consideration to be paid or received, are
fair and reasonable to the Investors and
do not involve overreaching of the Fund
or its Investors on the part of any person
concerned; and (b) the Section 17
Transaction is consistent with the
interests of the Investors, the Fund’s
organizational documents, and the
Fund’s reports to its Investors. In
addition, the General Partner will record
and preserve a description of the
Section 17 Transactions, the General
Partner’s findings, the information or
materials upon which the General
Partner’s findings are based, and the
basis therefore. All such records will be
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Fmt 4703
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22733
maintained for the life of the Fund and
at least six years thereafter, and will be
subject to examination by the
Commission and its staff. Each Fund
will preserve the accounts, books and
other documents required to be
maintained in an easily accessible place
for the first two years.
2. In connection with the Section 17
Transactions, the General Partner of
each Fund will adopt, and periodically
review and update, procedures designed
to ensure that reasonable inquiry is
made, before the consummation of any
such transaction, with respect to the
possible involvement in the transaction
of any affiliated person or promoter of
or principal underwriter for the Funds,
or any affiliated person of such a
person, promoter, or principal
underwriter.
3. The General Partner of each Fund
will not invest the funds of the Funds
in any investment in which an
‘‘Affiliated Co-Investor’’ (as defined
below) has acquired or proposes to
acquire the same class of securities of
the same issuer, where the investment
involves a joint enterprise or other joint
arrangement within the meaning of rule
17d–1 in which the Fund and an
Affiliated Co-Investor are participants,
unless any such Affiliated Co-Investor,
prior to disposing of all or part of its
investment, (a) gives the General Partner
sufficient, but not less than one day’s
notice, of its intent to dispose of its
investment, and (b) refrains from
disposing of its investment unless the
Fund has the opportunity to dispose of
the Fund’s investment prior to or
concurrently with, on the same terms as,
and pro rata with the Affiliated CoInvestor. The term ‘‘Affiliated CoInvestor’’ with respect to a Fund means
(a) an ‘‘affiliated person,’’ as such term
is defined in section 2(a)(3) of the Act,
of the Fund (other than a Third-Party
Fund or a person that is an affiliated
person of the Fund solely because of
section 2(a)(3)(B) of the Act); (b) the
UBS Group; (c) an officer or director of
a member of the UBS Group; or (d) an
entity (other than a Third-Party Fund) in
which a member of the UBS Group acts
as a general partner or has a similar
capacity to control the sale or other
disposition of an entity’s securities. The
restrictions contained in this condition,
however, shall not be deemed to limit
or prevent the disposition of an
investment by an Affiliated Co-Investor:
(a) to its direct or indirect whollyowned subsidiary, to any company (a
‘‘Parent’’) of which the Affiliated CoInvestor is a direct or indirect whollyowned subsidiary, or to a direct or
indirect wholly-owned subsidiary of its
Parent; (b) to immediate family
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members of the Affiliated Co-Investor or
a trust established for any Affiliated CoInvestor or any such family member; or
(c) when the investment is comprised of
securities that are (i) listed on any
exchange registered as a national
securities exchange under section 6 of
the Exchange Act; (ii) national market
system securities pursuant to section
11A(a)(2) of the Exchange Act and rule
11Aa2–1 thereunder; (iii) government
securities as defined in section 2(a)(16)
of the Act; or (iv) when the investment
is comprised of securities that are listed
on, or traded on, any foreign securities
exchange or board of trade that satisfies
regulatory requirements under the law
of the jurisdiction in which such foreign
securities exchange or board of trade is
organized similar to those that apply to
a national securities exchange or a
national market system.
4. Each Fund and its General Partner
will maintain and preserve, for the life
of each such Fund and at least six years
thereafter, such accounts, books, and
other documents as constitute the
record forming the basis for the audited
financial statements that are to be
provided to the Investors, and each
annual report of the Fund required to be
sent to the Investors, and agree that all
such records will be subject to
examination by the Commission and its
staff. Each Fund will preserve the
accounts, books and other documents
required to be maintained in an easily
accessible place for the first two years.
5. The General Partner of each Fund
will send to each Investor who had an
Interest in the Fund, at any time during
the fiscal year then ended, Fund
financial statements that have been
audited by independent accountants. At
the end of each fiscal year, the General
Partner will make a valuation or have a
valuation made of all of the assets of the
Fund as of such fiscal year end in a
manner consistent with customary
practice with respect to the valuation of
assets of the kind held by the Fund. In
addition, within 90 days after the end of
each fiscal year of each of the Funds or
as soon as practicable thereafter, the
General Partner of each Fund shall send
a report to each person who was a
Investor at any time during the fiscal
year then ended, setting forth such tax
information as shall be necessary for the
preparation by the Investor of his or her
federal and state income tax returns and
a report of the investment activities of
the Fund during that year.
6. If purchases or sales are made by
a Fund from or to an entity affiliated
with the Fund solely by reason of a
partner or employee of the UBS Group
(a) serving as officer, director, general
partner or investment adviser of the
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15:37 Apr 22, 2014
Jkt 232001
entity, or (b) having a 5% or more
investment in such entity, such
individual will not participate in the
Fund’s determination of whether or not
to effect the purchase or sale.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–09212 Filed 4–22–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–71959; File No. SR–FINRA–
2014–020]
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
FINRA 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 these statements
may be examined at the places specified
in Item IV below. FINRA has prepared
summaries, set forth in sections A, B,
and C below, of the most significant
aspects of such statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of a
Proposed Rule Change To Adopt
FINRA Rule 2081 (Prohibited
Conditions Relating to Expungement
of Customer Dispute Information)
April 17, 2014.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on April 14,
2014, Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’) filed with the
Securities and Exchange Commission
(‘‘SEC’’ or ‘‘Commission’’) the proposed
rule change as described in Items I, II,
and III below, which Items have been
prepared by FINRA. 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
FINRA is proposing to adopt FINRA
Rule 2081 to prohibit member firms and
associated persons from conditioning or
seeking to condition settlement of a
dispute with a customer on, or to
otherwise compensate the customer for,
the customer’s agreement to consent to,
or not to oppose, the firm’s or associated
person’s request to expunge such
customer dispute information from the
Central Registration Depository (CRD®).
The text of the proposed rule change
is available on FINRA’s Web site at
https://www.finra.org, at the principal
office of FINRA and at the
Commission’s Public Reference Room.
1 15
2 17
PO 00000
U.S.C. 78s(b)(1).
CFR 240.19b–4.
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Background
The CRD system is the central
licensing and registration system for the
U.S. securities industry and its
regulators. In general, the information in
the CRD system is submitted by
registered securities firms and
regulatory authorities in response to
questions on the uniform registration
forms. These forms collect
administrative and disciplinary
information about registered personnel,
including customer complaints,
arbitration claims, and court filings
made by customers, and the arbitration
awards or court judgments that may
result from those claims or filings (i.e.,
‘‘customer dispute information’’).3
FINRA, state and other regulators use
this information in connection with
their licensing and regulatory activities.
Firms also use the information when
making hiring decisions. In addition,
the information that FINRA releases to
the public through BrokerCheck® is
derived from the CRD system.
Brokers who wish to have customer
dispute information removed from the
CRD system (and thereby, from
BrokerCheck) because, for example, they
believe that the allegations made against
them are unfounded or that they have
been incorrectly identified, must seek
expungement pursuant to FINRA Rule
2080 (formerly NASD Rule 2130).4
FINRA Rule 2080 provides that firms
and associated persons seeking
expungement of customer dispute
information from the CRD system must
3 See Notice to Members (‘‘NTM’’) 04–16 (March
2004).
4 See Securities Exchange Act Release No. 48933
(December 16, 2003), 68 FR 74667 (December 24,
2003) (Order Approving File No. SR–NASD–2002–
168). See also Securities Exchange Act Release No.
59987 (May 27, 2009), 74 FR 26902 (June 4, 2009)
(Order Approving File No. SR–FINRA–2009–016).
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Agencies
[Federal Register Volume 79, Number 78 (Wednesday, April 23, 2014)]
[Notices]
[Pages 22728-22734]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-09212]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 31019; File No.813-336]
UBS AG, et al.; Notice of Application
April 17, 2014.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application for an order under sections 6(b) and 6(e)
of the Investment Company Act of 1940 (the ``Act'') exempting the
applicants from all provisions of the Act, except section 9 and
sections 36 through 53, and the rules and regulations under the Act.
With respect to sections 17 and 30 of the Act, and the rules and
regulations thereunder, and rule 38a-1 under the Act, the exemption
would be limited as set forth in the application.
-----------------------------------------------------------------------
Summary of Application: Applicants request an order to exempt
certain investment vehicles (``Funds'') formed for the benefit of key
employees of UBS AG (``UBS'') and its affiliates from certain
provisions of the Act. Each Fund will be an ``employees' securities
company'' within the meaning of section 2(a)(13) of the Act.
Applicants: UBS, UBS IB Co-Investment 2001 Limited Partnership
(``CLP1'') and UBS IB Co-Investment 2001 (No. 1) Feeder L.P. (``Feeder
L.P.'').
DATES: Filing Dates: The application was filed on July 6, 2001, and
amended on January 9, 2004, May 8, 2008, November 20, 2012 and January
22, 2014.
Hearing or Notification of Hearing: An order granting the
application will be issued unless the Commission orders a hearing.
Interested persons may request a hearing by writing to the Commission's
Secretary and serving applicants with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 p.m. on May 12, 2014, and should be accompanied by proof of
service on applicants, in the form of an
[[Page 22729]]
affidavit or, for lawyers, a certificate of service. Hearing requests
should state the nature of the writer's interest, the reason for the
request, and the issues contested. Persons who wish to be notified of a
hearing may request notification by writing to the Commission's
Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street NE., Washington, DC 20549-1090. Applicants, 677 Washington
Boulevard, Stamford, CT 06901.
FOR FURTHER INFORMATION CONTACT: Jaea F. Hahn, Senior Counsel, at (202)
551-6870, or David P. Bartels, at (202) 551-6821 (Division of
Investment Management, Chief Counsel's Office).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or 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. UBS is a bank established under the laws of Switzerland that
offers a range of financial services including private banking, asset
management and investment banking services.
2. UBS has organized CLP1, a Cayman Island limited partnership, and
Feeder L.P., a Delaware limited partnership, as the Initial Funds. UBS
intends to organize additional Funds from time to time for the benefit
of highly compensated current and former employees, officers and
directors of UBS and its affiliates (as defined in rule 12b-2 under the
Securities Exchange Act of 1934 (the ``Exchange Act'')) (collectively,
the ``UBS Group'') who have been approved to purchase interests by UBS
(``Eligible Employees''). Each Fund will be an ``employees' securities
company'' within the meaning of section 2(a)(13) of the Act and will
operate as a closed-end, management investment company, which may be
diversified or nondiversified. Applicants state that the Funds are
designed primarily to create capital appreciation opportunities that
are competitive with those at other financial services firms and to
facilitate the recruitment and retention of high caliber professionals.
Applicants assert that participation by Eligible Employees in the Funds
may allow them to diversify their investments or to participate in
investments that might not otherwise be available to them or that might
be beyond their individual means. The investment objectives and
policies for each Fund may vary from Fund to Fund, and participation in
a Fund will be voluntary.
3. Applicants state that each Fund will be organized as a limited
partnership, a limited liability company, a corporation, or another
appropriate entity, in each case organized under the laws of a state of
the United States or of a jurisdiction outside the United States.
Applicants state that, because a large portion of Eligible Employees
reside outside of the United States, applicants expect that most, if
not all, of the Funds will be organized under the laws of jurisdictions
outside of the United States for various tax, regulatory, and other
reasons.\1\
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\1\ Applicants state that, for tax, regulatory or other reasons,
a Fund organized for employees residing in a particular country may
have different terms than other Funds organized for employees
residing in other countries, and Funds that are organized at
different times are likely to have different terms. However, no
organizational document for, or any other contractual arrangement
regarding, a Fund will contain any provision that protects or
purports to protect UBS AG, the General Partner or their delegates
against any liability with respect to the Fund or its security
holders to which such person would otherwise be subject by reason of
willful malfeasance, bad faith, or gross negligence in the
performance of such person's duties, or by reason of such person's
reckless disregard of such person's obligations and duties under
such contract or organizational documents. Moreover, all Funds will
be subject to, and comply with, the terms and conditions of the
application.
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4. Each Fund will be managed, operated and controlled by a general
partner that is controlled, directly or indirectly, by UBS (a ``General
Partner'').\2\ Applicants state that the General Partner will be
responsible for the overall management of each Fund and will have the
authority to make all decisions regarding the acquisition, management
and disposition of Fund investments. The executive officers and
directors of the General Partner or of any entity controlling the
General Partner will be employees of UBS Group, a majority of whom will
be eligible to invest in the Fund. Applicants state that the General
Partner may delegate all management responsibilities, including
responsibility for investment decisions in respect of the Fund, to UBS
or another entity that is part of the UBS Group as investment manager
(the ``Investment Manager''). The General Partner or Investment Manager
will register as an investment adviser under the Investment Advisers
Act of 1940 (``Advisers Act''), if required under applicable law.\3\
Whenever UBS, the General Partner or any other person acting for or on
behalf of a Fund is required or permitted to make a decision, take or
approve an action, or omit to do any of the foregoing in such person's
discretion, such person will act in the best interest of the Fund and
its security holders and will exercise such discretion in accordance
with reasonableness and good faith and any fiduciary duties owed to the
Fund and its security holders.
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\2\ If a form of organization other than a limited partnership
is used, the functions of the General Partner will be performed by a
corresponding entity or governing body.
\3\ Applicants acknowledge that no relief in respect of such
determination is requested.
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5. The Investment Manager may, from time to time, be presented with
investment opportunities by one or more investment advisers
(``Investment Advisers'') that are engaged by the Investment Manager
that may be affiliated or not affiliated with UBS (any such non-
affiliated Investment Adviser being referred to as an ``Outside
Investment Adviser''). If the Investment Manager elects to enter into
any side-by-side investment with a party that is not a member of the
UBS Group, the Investment Manager will be permitted to engage as an
Investment Adviser the Outside Investment Adviser responsible for the
management of such side-by-side investment. In each of the foregoing
cases, however, all decisions with respect to the purchase, holding or
disposition of investments by each Fund will be made by either the
General Partner or the Investment Manager alone, and not by any
Investment Adviser.
6. Interests in the Funds (``Interests'') will be offered without
registration in reliance on section 4(a)(2) of the Securities Act of
1933 (the ``Securities Act''), or Regulation D under the Securities
Act, and will be sold only to Qualified Participants, as defined below,
and members of the UBS Group.\4\ The term ``Qualified Participant''
means: (a) Eligible Employees, (b) spouses, parents, children, spouses
of children, brothers, sisters and grandchildren of Eligible Employees
(``Qualified Family Members'') and (c) trusts or other investment
vehicles established solely for the benefit of Eligible Employees or
Qualified Family Members (``Qualified Investment Vehicles'').
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\4\ Any member of the UBS Group that acquires Interests will be
an ``accredited investor,'' as defined in rule 501(a) of Regulation
D under the 1933 Act.
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7. An Eligible Employee must be either (a) an ``accredited
investor'' as defined in rule 501(a)(6) or 501(a)(5) of Regulation D
under the Securities Act (an ``Accredited Investor'') or (b) one of not
more than 35 employees of the UBS Group who meets the salary and other
requirements as described below (``Other Investors''). Each Other
Investor
[[Page 22730]]
will, at the time of investment in a Fund, (x) be a ``knowledgeable
employee,'' as defined in rule 3c-5 under the Act, of such Fund (with
the Fund treated as though it were a ``Covered Company'' for purposes
of such rule) or (y) have (i) a graduate degree in business, law or
accounting, (ii) a minimum of five years of consulting, investment
banking, legal or similar business experience and (iii) a reportable
income from all sources in the two calendar years immediately preceding
their participation of at least $100,000 and a reasonable expectation
of income from all sources of at least $140,000 per year in each year
in which the person invests in a Fund. An Other Investor qualifying
under (y) above will not be permitted to invest in any year more than
10% of such person's income from all sources for the immediately
preceding year in the aggregate in a Fund and in all other Funds in
which that Other Investor has previously invested. A Qualified Family
Member who purchases an Interest must be an Accredited Investor.
8. An Eligible Employee or a Qualified Family Member may purchase
an Interest through a Qualified Investment Vehicle only if either (a)
such investment vehicle is an ``accredited investor,'' as defined in
rule 501(a) of Regulation D under the Securities Act or (b) such
Eligible Employee or Qualified Family Member is a settlor and principal
investment decision-maker with respect to such investment vehicle.
Prior to offering Interests to an Eligible Employee or Qualified Family
Member, UBS must reasonably believe that such individual has such
knowledge, sophistication and experience in business and financial
matters to be capable of evaluating the merits and risks of
participating in the Fund, is able to bear the economic risk of such
investment and is able to afford a complete loss of such investment.
9. Applicants represent that the material terms of investment in a
Fund, including without limitation, the terms and conditions of any and
all transfers of Interests in any Fund, will be fully disclosed to each
Qualified Participant and member of the UBS Group when Interests are
offered to that person. The specific investment objectives and
strategies for a particular Fund will be set forth in a private
placement memorandum relating to the Interests offered by a Fund. In
connection with an investment in a Fund, each Qualified Participant and
member of the UBS Group will receive the private placement memorandum,
form of application and the limited partnership agreement (or other
constitutive document) of the Fund. Each Fund will send its investors
(``Investors'') annual reports, which will contain audited financial
statements, as soon as practicable after the end of each fiscal
year.\5\ In addition, as soon as practicable after the end of each tax
year of a Fund, a report will be transmitted to each Investor setting
forth such tax information as shall be necessary for the preparation by
the Investor of his or her federal tax returns.
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\5\ For the purposes of the application, ``audit'' has the
meaning provided in rule 1-02(d) of Regulation S-X.
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10. Interests in a Fund will not be transferable by an Investor
except with the prior written consent of UBS or a Fund's General
Partner and then only to Qualified Participants or to members of the
UBS Group. Applicants expect that interests in the Funds will generally
not be redeemable at the option of an Investor (except on liquidation
of a Fund) but state that it is possible that one or more Funds may
offer Interests with certain redemption rights. With respect to certain
Funds, UBS may have the right, but not the obligation, to repurchase or
cancel the Interest of an Eligible Employee who ceases to be an
employee, officer or director of any member of the UBS Group for any
reason. Upon repurchase or cancellation, such Investor's Interest will
be purchased by the General Partner for cash in an amount at least
equal to the lesser of (a) the amount of such Investor's capital
contributions less prior distributions from the Fund (plus interest, as
determined by UBS) or (b) the value of the Interest, as determined by
UBS in good faith as of the date of termination. For other Funds, UBS
AG may be permitted to exercise this right only under particular
circumstances, such as if an employee resigns to join a competitor of
the UBS Group, or not at all.
11. UBS may establish one or more deferred compensation plans in
connection with the Funds. Applicants state that Eligible Employees may
be able to defer compensation and receive a return on such deferred
compensation determined by reference to the performance of a Fund. The
deferred compensation plans and/or an Eligible Employee's interest in
such plans: (a) Will be subject to the applicable terms and conditions
of the application; \6\ (b) will only be offered to Eligible Employees
who are current employees, officers or directors of the UBS Group; (c)
will have restrictions on transferability, including prohibitions on
assignment or transfer except in the event of the Eligible Employee's
death or as otherwise required by law; and (d) will provide information
to participants equivalent to that provided to investors and
prospective investors in the corresponding Fund, including, without
limitation, disclosure documents and audited financial information.
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\6\ For purposes of this application, a Fund will be deemed to
be formed with respect to each deferred compensation plan and each
reference to ``Fund,'' ``capital contribution,'' ``General
Partners,'' ``Investor,'' ``loans'' or ``leverage'' and ``Interest''
in this application will be deemed to refer to the deferred
compensation plan, the notional capital contribution to the deferred
compensation plan, the UBS Group, a participant of the deferred
compensation plan, notional loans or leverage and participation
rights in the deferred compensation plan, respectively.
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12. The General Partner or Investment Manager of a Fund may charge
the Fund an annual management fee, a flat administrative charge or an
expense reimbursement, but will not charge a carried interest. Any
expense reimbursement may cover out-of-pocket expenses of the General
Partner or Investment Manager, including allocable portions of the
salaries of UBS Group employees who work on the Funds' affairs.
Directors or officers of the General Partner or Investment Manager, or
of any entity controlling the General Partner or Investment Manager,
may also be compensated for their services to the General Partner or
Investment Manager, including reimbursement for out-of-pocket expenses.
A Fund will not pay both a fee to the General Partner of the Fund and a
fee to the Investment Manager of the Fund for providing the same
services or bearing the same expenses. An Investment Adviser to the
Investment Manager may charge the Fund an advisory fee; however, such
advisory fee will not be duplicative of any fees paid to the General
Partner. No fee of any kind will be charged in connection with the sale
of Interests.
13. If a Fund becomes a limited partner or otherwise holds an
interest in an investment fund organized or managed by the UBS Group in
which affiliated third parties also are limited partners or otherwise
hold interests (a ``Client Fund''), the Fund may be obligated to pay a
pro rata share of any fees (including carried interest) charged to the
unaffiliated limited partners or interest holders of such Client Fund.
A Fund may also invest in funds managed or advised by an Outside
Investment Adviser, which may be entitled to fees (including carried
interest) from the Fund. In all such cases, the Fund will enter into
commercially reasonable arm's length arrangements with respect to the
payment of the fees, and the potential for payment of any such
[[Page 22731]]
management fees or carried interest will be fully described in the
applicable offering documents.
14. Subject to the terms of the applicable limited partnership
agreement (or other constitutive documents), a Fund will be permitted
to enter into transactions involving (a) a UBS Group entity, (b) a
Client Fund or other portfolio company, (c) any Investor or any person
or entity affiliated with an Investor, or (d) any partner or other
investor in any entity in which a Fund invests. These transactions may
include a Fund's purchase or sale of an investment or an interest from
or to any UBS Group entity or Client Fund, acting as principal. Prior
to entering into these transactions, the General Partner (or the
Investment Manager, to whom the General Partner may delegate this
responsibility) must determine that the terms are fair to Investors.
15. A Fund will not invest more than 15% of its assets in
securities issued by registered investment companies except for
temporary investments in money market funds. A Fund will not acquire
any security issued by a registered investment company if, immediately
after the acquisition, the Fund will own more than 3% of the
outstanding voting stock of the registered investment company.
Applicants state that a Fund may also invest in Client Funds that are
not registered under the Act by virtue of section 3(c)(1) or section
3(c)(7) of the Act.\7\
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\7\ Applicants are not requesting any exemption from any
provision of the Act or any rule thereunder that may govern a Fund's
eligibility to invest in a Client Fund relying on section 3(c)(1) or
3(c)(7) of the Act or a Client Fund's status under the Act.
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16. Members of the UBS Group and/or unaffiliated third parties may
make loans to Funds and/or to Investors in connection with their
purchase of Interests, provided that a Fund will not borrow from any
person if the borrowing would cause any person not named in section
2(a)(13) of the Act to own outstanding securities of the Fund (other
than short-term paper). Members of the UBS Group may also make
preferred capital contributions to the Funds. In connection with any
leverage of the Fund or preferred capital contributions, Eligible
Employees will not have any personal liability in excess of the amounts
payable under their respective subscription agreements for the
repayment of the loan or preferred capital contribution, including in
the event that, upon liquidation of the Fund, the assets of the Fund
are insufficient to permit the Fund to repay such loan preferred
capital contribution in full. Any leverage or preferred capital
contributions will bear interest at a rate no less favorable to a Fund
or its Investors than that could be obtained on an arm's length basis.
The terms of any leverage or preferred capital contribution provided by
any member of the UBS Group (or third party lender) will be described
in the applicable private placement memorandum and partnership
agreement (or other constitutive documents) as appropriate.
Applicants' Legal Analysis
1. Section 6(b) of the Act provides, in part, that the Commission
will exempt employees' securities companies from the provisions of the
Act to the extent that the exemption is consistent with the protection
of investors. Section 6(b) provides that the Commission will consider,
in determining the provisions of the Act from which the company should
be exempt, the company's form of organization and capital structure,
the persons who will own and control the company's voting securities,
evidences of indebtedness and other securities, the prices at which
securities issued by the company will be sold and any applicable sales
load, the disposition of the proceeds of the securities issued by the
company, the character of securities in which those proceeds will be
invested, and any relationship between the company and the issuers of
the securities. Section 2(a)(13) defines an employees' securities
company, in relevant part, as any investment company all of whose
securities are beneficially owned (a) by current or former employees,
or persons on retainer, of one or more affiliated employers, (b) by
immediate family members of such persons, or (c) by such employer or
employers, together with any of the persons in (a) or (b).
2. Section 7 of the Act generally prohibits investment companies
that are not registered under section 8 of the Act from selling or
redeeming their securities. Section 6(e) provides that, in connection
with any order exempting an investment company from any provision of
section 7, certain provisions of the Act, as specified by the
Commission, will be applicable to the company and other persons dealing
with the company as though the company were registered under the Act.
Applicants request an order under sections 6(b) and 6(e) of the Act
exempting the Funds from all provisions of the Act, except section 9
and sections 36 through 53 of the Act, and the rules and regulations
thereunder. With respect to sections 17 and 30 of the Act, and the
rules and regulations thereunder, and rule 38a-1 under the Act, the
exception is limited as set forth in the application.
3. Section 17(a) generally prohibits any affiliated person of a
registered investment company, or any affiliated person of that person,
acting as principal, from knowingly selling or purchasing any security
or other property to or from the company. Applicants request an
exemption from section 17(a) to permit: (a) A member of the UBS Group
or a Client Fund, acting as principal, to engage in any transaction
directly or indirectly with any Fund or entity controlled by such Fund;
(b) a Fund to invest in or engage in any transaction with any entity,
acting as principal (i) in which such Fund, any company controlled by
such Fund, or any entity within the UBS Group or a Client Fund has
invested or will invest or (ii) with which such Fund, any company
controlled by such Fund or any entity within the UBS Group or a Client
Fund is or will otherwise become affiliated; and (c) a partner or other
investor in any entity in which a Fund invests, acting as principal, to
engage in transactions directly or indirectly with the related Fund or
any company controlled by such Fund.
4. Applicants state that an exemption from section 17(a) is
consistent with the protection of investors and the purposes of the
Funds. Applicants state that the Investors in each Fund will be
informed of the possible extent of the Fund's dealings with the UBS
Group and of the potential conflicts of interest that may exist.
Applicants also assert that the community of interest among the
Investors and UBS Group will serve to reduce any risk of abuse in
transactions involving a Fund and the UBS Group. Applicants represent
that the requested relief will not extend to any transaction between a
Fund and an Outside Investment Adviser or an affiliated person of the
Outside Investment Adviser, or between a Fund and who is not a member
of the UBS Group or an employee, officer or director of a member of the
UBS Group and is an affiliated person of the Fund as defined in section
2(a)(3)(E) of the Act (``Advisory Person'') or any affiliated person of
such person.
5. Section 17(d) of the Act and rule 17d-1 under the Act prohibit
any affiliated person of a registered investment company, or any
affiliated person of an affiliated person, acting as principal, from
participating in any joint enterprise, or other joint arrangement,
unless approved by the Commission. Applicants request relief to permit
affiliated persons of each Fund, or affiliated persons of such persons,
to
[[Page 22732]]
participate in any joint arrangement in which the Fund or an entity
controlled by the Fund is a participant. Applicants acknowledge that
the requested relief will not extend to any transaction in which an
Outside Investment Adviser or an Advisory Person, or an affiliated
person of either, has an interest.
6. Applicants assert that compliance with section 17(d) could cause
a Fund to forego investment simply because an affiliate of the Fund has
made, or is contemplating making, the same investment. Applicants also
submit that the types of investment opportunities considered by a Fund
often require each investor to make funds available in an amount that
may be substantially greater than what a Fund may make available on its
own. Applicants state that the possibility that permitting co-
investments by an affiliated person or an affiliated person of an
affiliated person might lead to less advantageous treatment of the Fund
is minimal in light of (a) the UBS Group's intention in establishing a
Fund so as to reward Eligible Employees and to attract and retain
highly qualified personnel, (b) the UBS Group's capital contributions
to the Funds, and (c) the fact that a majority of the directors of the
General Partner or Investment Manager or of the entity controlling the
General Partner or Investment Manager may themselves invest in the
Fund.
7. Applicants believe that the interests of the Eligible Employees
participating in a Fund will be adequately protected in situations
where condition 3 in the application does not apply. Applicants state
that a Fund may co-invest with an investment fund or separate account,
organized for the benefit of investors who are not affiliated with the
UBS Group, over which a member of the UBS Group exercises investment
discretion (a ``Third-Party Fund''). Applicants assert that, in
structuring a Third-Party Fund, it is common for unaffiliated investors
of such fund to require that the UBS Group invest its own capital in
fund investments, either through the fund or on a side-by-side basis,
and that such UBS Group investment be subject to substantially the same
terms as those applicable to the fund's investment. Applicants state
that it is important to the UBS Group that the interests of the Third-
Party Fund take priority over the interests of the Funds, and that the
activities of the Third-Party Fund not be burdened or otherwise
affected by the activities of the Funds. In addition, applicants
contend that the relationship of a Fund to a Third-Party Fund, in the
context of this application, is fundamentally different from such
Fund's relationship to the UBS Group. Applicants assert that the focus
of, and the rationale for, the protections contained in condition 3 are
to protect the Funds from any overreaching by the UBS Group in the
employer/employee context, whereas the same concerns are not present
with respect to the Funds vis-[agrave]-vis the investors of a Third-
Party Fund.
8. Section 17(e) of the Act and rule 17e-1 under the Act limit the
compensation an affiliated person may receive when acting as agent or
broker for a registered investment company. Applicants request an
exemption from section 17(e) to permit a UBS Group member (including
the General Partner) acting as agent or broker, to receive placement
fees, financial advisory fees or other compensation in connection with
the purchase or sale by a Fund of securities, subject to the
requirement that placement fees, financial advisory fees or other
compensation is deemed ``usual and customary.'' Applicants state that
for the purposes of the application, fees and other compensation that
is being charged or received by the UBS Group entity will be deemed
``usual and customary'' only if (a) the Fund is purchasing or selling
securities with other unaffiliated third parties, (b) the fees or
compensation being charged to the Fund are also being charged to the
unaffiliated third parties, and (c) the amount of securities being
purchased or sold by the Fund does not exceed 50% of the total amount
of securities being purchased or sold by the Fund and unaffiliated
third parties.
9. Applicants assert that compliance with section 17(e) would
prevent a Fund from participating in a transaction in which a member of
the UBS Group does not, for other business reasons, wish a Fund to be
treated in a more favorable manner (in terms of lower fees) than
unaffiliated third parties also participating in the transaction.
Applicants assert that the concerns of overreaching and abuse that
section 17(e) and rule 17e-1 were designed to prevent are alleviated by
the conditions that ensure that fees or other compensation paid to
members of the UBS Group are the same as those negotiated at arm's
length with unaffiliated third parties, and the unaffiliated third
parties have as great or greater interest as the Fund in the
transaction as a whole.
10. Rule 17e-1(b) requires that a majority of directors who are not
``interested persons'' (as defined by section 2(a)(19) of the Act) take
actions and make approvals regarding commissions, fees, or other
remuneration. Applicants request an exemption from rule 17e-1 to the
extent necessary to permit each Fund to comply with the rule without
having a majority of the directors of the General Partner who are not
interested persons take actions and make determinations as set forth in
paragraph (b) of the rule. Applicants state that because all of the
directors of a General Partner will be affiliated persons, without the
relief requested, a Fund could not comply with rule 17e-1. Applicants
state that each Fund will comply with rule 17e-1(b) by having a
majority of the directors of the General Partner take actions and make
approvals as set forth in rule 17e-1. Applicants state that each Fund
will otherwise comply with the requirements of rule 17e-1.
11. Section 17(f) designates the entities that may act as
investment company custodians, and rule 17f-1 imposes certain
requirements when the custodian is a member of a national securities
exchange. Applicants request an exemption from section 17(f) and rule
17f-1(a) to the extent necessary to permit a member of the UBS Group to
act as custodian for a Fund without a written contract. Applicants also
request an exemption from the rule 17f-1(b)(4) requirement that an
independent accountant periodically verify the assets held by the
custodian . Applicants further request an exemption from rule 17f-
1(c)'s requirement of transmitting to the Commission a copy of any
contract executed pursuant to rule 17f-1. Applicants believe that,
because of the community of interest of all of the parties involved and
the requirement to provide annual audited financial reports, compliance
with these requirements would be unnecessary. Applicants state that
they will comply with rule 17f-1(d), provided that ratification by the
General Partner of any Fund will be deemed to be ratification by a
majority of a board of directors. Applicants state that they will
comply with all other requirements of rule 17f-1.
12. Section 17(g) and rule 17g-1 generally require the bonding of
officers and employees of a registered investment company who have
access to its securities or funds. Rule 17g-1 requires that a majority
of directors who are not interested persons take certain actions and
give certain approvals relating to fidelity bonding. Applicants request
relief to the extent necessary to permit the General Partner's officers
and directors, who may be deemed to be interested persons, to take the
actions and make the determinations set forth in the rule. Applicants
also request an exemption from the requirements of paragraph (g) of
rule 17g-1 relating to the filing of copies of fidelity bonds and
[[Page 22733]]
related information with the Commission and the provision of notices to
the board of directors, and paragraph (h) of rule 17g-1 relating to the
appointment of a person to make the filings and provide the notices
required by paragraph (g). Applicants state that, because all the
directors of the General Partner will be affiliated persons, a Fund
could not comply with rule 17g-1 without the requested relief. Each
Fund will comply with rule 17g-1 by having a majority of the General
Partner's directors take actions and make determinations as set forth
in rule 17g-1. Applicants also state that the Funds will comply with
all other requirements of rule 17g-1.
13. Section 17(j) and paragraph (b) of rule 17j-1 make it unlawful
for certain enumerated persons to engage in fraudulent or deceptive
practices in connection with the purchase or sale of a security held or
to be acquired by a registered investment company. Rule 17j-1 also
requires that every registered investment company adopt a written code
of ethics and that every access person of a registered investment
company report personal securities transactions. Applicants request an
exemption from the provisions of rule 17j-1, except for the antifraud
provisions of paragraph (b), asserting that these provisions are
unnecessarily burdensome because of the community of interest among the
Investors. The relief requested will only extend to members of the UBS
Group and is not requested with respect to any Outside Investment
Adviser or Advisory Person.
14. Applicants request an exemption from the requirements in
sections 30(a), 30(b) and 30(e), and the rules under those sections,
that registered investment companies prepare and file with the
Commission and mail to their shareholders certain periodic reports and
financial statements. Applicants contend that the forms prescribed by
the Commission for periodic reports have little relevance to the Funds
and would entail administrative and legal costs that outweigh any
benefit to the Investors. Applicants request exemptive relief to the
extent necessary to permit each Fund to report annually to its
Investors. Applicants also request an exemption from section 30(h) to
the extent necessary to exempt the General Partner of each Fund and any
other person who may be deemed to be a member of an advisory board of a
Fund from filing Forms 3, 4, and 5 under section 16(a) of the Exchange
Act with respect to their ownership of Interests in a Fund. Applicants
assert that, because there will be no trading market and the transfers
of Interests will be severely restricted, these filings are unnecessary
for the protection of investors and burdensome to those required to
make them.
15. Rule 38a-1 requires investment companies to adopt, implement
and periodically review written policies and procedures reasonably
designed to prevent violation of the federal securities laws, appoint a
chief compliance officer and maintain certain records. Applicants state
that the Funds will comply with rule 38a-1(a), (c) and (d), except that
(a) the board of directors of the General Partner of each Fund will
fulfill the responsibilities assigned to the Fund's board of directors
under the rule, (b) because all members of the board of directors of
the General Partner would be considered interested persons of the
Funds, approval by a majority of the disinterested directors required
by rule 38a-1 would not be obtained, and (c) because the board of
directors of the General Partner do not have any disinterested members,
the Funds will comply with the requirement in rule 38a-1(a)(4)(iv) that
the chief compliance officer meet with the independent directors by
having the chief compliance officer meet with the board of directors of
the General Partner as constituted. Applicants assert that, in view of
the community of interest between the Funds and the General Partners
and Investment Managers, there is no significant benefits to be gained
from imposing the costs of compliance with the other aspects of the
rule on the Funds.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
1. Each proposed transaction to which a Fund is a party otherwise
prohibited by section 17(a) or section 17(d) of the Act and rule 17d-1
thereunder (the ``Section 17 Transactions'') will be effected only if
the General Partner determines that: (a) The terms of the Section 17
Transaction, including the consideration to be paid or received, are
fair and reasonable to the Investors and do not involve overreaching of
the Fund or its Investors on the part of any person concerned; and (b)
the Section 17 Transaction is consistent with the interests of the
Investors, the Fund's organizational documents, and the Fund's reports
to its Investors. In addition, the General Partner will record and
preserve a description of the Section 17 Transactions, the General
Partner's findings, the information or materials upon which the General
Partner's findings are based, and the basis therefore. All such records
will be maintained for the life of the Fund and at least six years
thereafter, and will be subject to examination by the Commission and
its staff. Each Fund will preserve the accounts, books and other
documents required to be maintained in an easily accessible place for
the first two years.
2. In connection with the Section 17 Transactions, the General
Partner of each Fund will adopt, and periodically review and update,
procedures designed to ensure that reasonable inquiry is made, before
the consummation of any such transaction, with respect to the possible
involvement in the transaction of any affiliated person or promoter of
or principal underwriter for the Funds, or any affiliated person of
such a person, promoter, or principal underwriter.
3. The General Partner of each Fund will not invest the funds of
the Funds in any investment in which an ``Affiliated Co-Investor'' (as
defined below) has acquired or proposes to acquire the same class of
securities of the same issuer, where the investment involves a joint
enterprise or other joint arrangement within the meaning of rule 17d-1
in which the Fund and an Affiliated Co-Investor are participants,
unless any such Affiliated Co-Investor, prior to disposing of all or
part of its investment, (a) gives the General Partner sufficient, but
not less than one day's notice, of its intent to dispose of its
investment, and (b) refrains from disposing of its investment unless
the Fund has the opportunity to dispose of the Fund's investment prior
to or concurrently with, on the same terms as, and pro rata with the
Affiliated Co-Investor. The term ``Affiliated Co-Investor'' with
respect to a Fund means (a) an ``affiliated person,'' as such term is
defined in section 2(a)(3) of the Act, of the Fund (other than a Third-
Party Fund or a person that is an affiliated person of the Fund solely
because of section 2(a)(3)(B) of the Act); (b) the UBS Group; (c) an
officer or director of a member of the UBS Group; or (d) an entity
(other than a Third-Party Fund) in which a member of the UBS Group acts
as a general partner or has a similar capacity to control the sale or
other disposition of an entity's securities. The restrictions contained
in this condition, however, shall not be deemed to limit or prevent the
disposition of an investment by an Affiliated Co-Investor: (a) to its
direct or indirect wholly-owned subsidiary, to any company (a
``Parent'') of which the Affiliated Co-Investor is a direct or indirect
wholly-owned subsidiary, or to a direct or indirect wholly-owned
subsidiary of its Parent; (b) to immediate family
[[Page 22734]]
members of the Affiliated Co-Investor or a trust established for any
Affiliated Co-Investor or any such family member; or (c) when the
investment is comprised of securities that are (i) listed on any
exchange registered as a national securities exchange under section 6
of the Exchange Act; (ii) national market system securities pursuant to
section 11A(a)(2) of the Exchange Act and rule 11Aa2-1 thereunder;
(iii) government securities as defined in section 2(a)(16) of the Act;
or (iv) when the investment is comprised of securities that are listed
on, or traded on, any foreign securities exchange or board of trade
that satisfies regulatory requirements under the law of the
jurisdiction in which such foreign securities exchange or board of
trade is organized similar to those that apply to a national securities
exchange or a national market system.
4. Each Fund and its General Partner will maintain and preserve,
for the life of each such Fund and at least six years thereafter, such
accounts, books, and other documents as constitute the record forming
the basis for the audited financial statements that are to be provided
to the Investors, and each annual report of the Fund required to be
sent to the Investors, and agree that all such records will be subject
to examination by the Commission and its staff. Each Fund will preserve
the accounts, books and other documents required to be maintained in an
easily accessible place for the first two years.
5. The General Partner of each Fund will send to each Investor who
had an Interest in the Fund, at any time during the fiscal year then
ended, Fund financial statements that have been audited by independent
accountants. At the end of each fiscal year, the General Partner will
make a valuation or have a valuation made of all of the assets of the
Fund as of such fiscal year end in a manner consistent with customary
practice with respect to the valuation of assets of the kind held by
the Fund. In addition, within 90 days after the end of each fiscal year
of each of the Funds or as soon as practicable thereafter, the General
Partner of each Fund shall send a report to each person who was a
Investor at any time during the fiscal year then ended, setting forth
such tax information as shall be necessary for the preparation by the
Investor of his or her federal and state income tax returns and a
report of the investment activities of the Fund during that year.
6. If purchases or sales are made by a Fund from or to an entity
affiliated with the Fund solely by reason of a partner or employee of
the UBS Group (a) serving as officer, director, general partner or
investment adviser of the entity, or (b) having a 5% or more investment
in such entity, such individual will not participate in the Fund's
determination of whether or not to effect the purchase or sale.
For the Commission, by the Division of Investment Management,
under delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-09212 Filed 4-22-14; 8:45 am]
BILLING CODE 8011-01-P