Elkhorn Investments, LLC and Elkhorn ETF Trust; Notice of Application, 36106-36110 [2014-14798]
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36106
Federal Register / Vol. 79, No. 122 / Wednesday, June 25, 2014 / Notices
ACRS Staff with a CD containing each
presentation at least 30 minutes before
the meeting.
In accordance with Subsection 10(d)
Public Law 92–463, and 5 U.S.C.
552b(c), certain portions of this meeting
may be closed, as specifically noted
above. Use of still, motion picture, and
television cameras during the meeting
may be limited to selected portions of
the meeting as determined by the
Chairman. Electronic recordings will be
permitted only during the open portions
of the meeting.
ACRS meeting agenda, meeting
transcripts, and letter reports are
available through the NRC Public
Document Room at pdr.resource@
nrc.gov, or by calling the PDR at 1–800–
397–4209, or from the Publicly
Available Records System (PARS)
component of NRC’s document system
(ADAMS) which is accessible from the
NRC Web site at https://www.nrc.gov/
reading-rm/adams.html or https://
www.nrc.gov/reading-rm/doccollections/ACRS/.
Video teleconferencing service is
available for observing open sessions of
ACRS meetings. Those wishing to use
this service should contact Mr. Theron
Brown, ACRS Audio Visual Technician
(301–415–8066), between 7:30 a.m. and
3:45 p.m. (ET), at least 10 days before
the meeting to ensure the availability of
this service. Individuals or
organizations requesting this service
will be responsible for telephone line
charges and for providing the
equipment and facilities that they use to
establish the video teleconferencing
link. The availability of video
teleconferencing services is not
guaranteed.
Dated: June 19, 2014.
Andrew L. Bates,
Advisory Committee Management Officer.
[FR Doc. 2014–14866 Filed 6–24–14; 8:45 am]
BILLING CODE 7590–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
31089; 812–14262]
Elkhorn Investments, LLC and Elkhorn
ETF Trust; Notice of Application
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June 19, 2014.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 6(c) of the
Investment Company Act of 1940
(‘‘Act’’) for an exemption from sections
2(a)(32), 5(a)(1), 22(d) and 22(e) of the
Act and rule 22c–1 under the Act, under
AGENCY:
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Applicants’ Representations
1. The Trust, a business trust
organized under the laws of
Massachusetts, is registered with the
APPLICANTS: Elkhorn Investments, LLC
Commission as an open-end
(‘‘Elkhorn Investments’’) and Elkhorn
management investment company. The
ETF Trust (the ‘‘Trust’’).
applicants are requesting relief not only
SUMMARY: Summary of Application:
for the Trust and its current series,
Applicants request an order that
Elkhorn Enhanced Short Term
permits: (a) Series of certain open-end
Government Fund (‘‘Initial Fund’’), but
management investment companies to
also with respect to future series of the
issue shares (‘‘Shares’’) redeemable in
Trust, and to any registered open-end
large aggregations only (‘‘Creation
management investment companies or
Units’’); (b) secondary market
series thereof that may be created in the
transactions in Shares to occur at
future and that utilizes active
negotiated market prices; (c) certain
management investment strategies
series to pay redemption proceeds,
under certain circumstances, more than (‘‘Future Funds’’ and collectively with
1
seven days from the tender of Shares for the Initial Fund, the ‘‘Funds’’). Funds
may invest in equity securities or fixed
redemption; and (d) certain affiliated
income securities traded in the U.S. or
persons of the series to deposit
non-U.S. markets or a combination of
securities into, and receive securities
equity and fixed income securities,
from, the series in connection with the
including ‘‘to-be-announced
purchase and redemption of Creation
transactions’’ (‘‘TBAs’’) 2 and depositary
Units.
receipts (‘‘Depositary Receipts’’).3 The
DATES: Filing Dates: The application was securities, other assets, and other
filed on January 9, 2014, and amended
positions in which a Fund invests are its
on June 4, 2014.
‘‘Portfolio Positions.’’ 4 The Trust
HEARING OR NOTIFICATION OF HEARING:
currently expects that the Initial Fund’s
An order granting the requested relief
1 All entities that currently intend to rely on the
will be issued unless the Commission
orders a hearing. Interested persons may requested order are named as applicants and any
Fund that currently intends to rely on the requested
request a hearing by writing to the
order is identified in the application. Any other
Commission’s Secretary and serving
entity that relies on the requested order in the
future will comply with the terms and conditions
applicants with a copy of the request,
of the application.
personally or by mail. Hearing requests
2 A TBA Transaction is a method of trading
should be received by the Commission
mortgage-backed securities. In a TBA Transaction,
by 5:30 p.m. on July 14, 2014, and
the buyer and seller agree on general trade
should be accompanied by proof of
parameters such as agency, settlement date, par
amount and price. The actual pools delivered
service on applicants, in the form of an
generally are determined two days prior to the
affidavit or, for lawyers, a certificate of
settlement date.
service. Hearing requests should state
3 Depositary Receipts include American
the nature of the writer’s interest, the
Depositary Receipts (‘‘ADRs’’) and Global
Depositary Receipts (‘‘GDRs’’). With respect to
reason for the request, and the issues
ADRs, the depositary is typically a U.S. financial
contested. Persons who wish to be
institution and the underlying securities are issued
notified of a hearing may request
by a foreign issuer. The ADR is registered under the
Securities Act of 1933 (‘‘Securities Act’’) on Form
notification by writing to the
F–6. ADR trades occur either on a national
Commission’s Secretary.
securities exchange as defined in Section 2(a)(26) of
ADDRESSES: Secretary, U.S. Securities
the Act (‘‘Listing Exchange’’) or off-exchange.
and Exchange Commission, 100 F Street Financial Industry Regulatory Authority Rule 6620
requires all off-exchange transactions in ADRs to be
NE., Washington, DC 20549–1090.
reported within 90 seconds and ADR trade reports
Applicants, 207 Reber Street, Suite 201, to be disseminated on a real-time basis. With
Wheaton, IL 60187.
respect to GDRs, the depositary may be a foreign or
a U.S. entity, and the underlying securities may
FOR FURTHER INFORMATION CONTACT:
have a foreign or a U.S. issuer. All GDRs are
Christine Y. Greenlees, Senior Counsel,
sponsored and trade on a foreign exchange. No
at (202) 551–6879, or David P. Bartels,
affiliated persons of applicants, any Adviser, Fund
Sub-Adviser (as defined below), or Fund will serve
Branch Chief, at (202) 551–6821
as the depositary for any Depositary Receipts held
(Division of Investment Management,
by a Fund. A Fund will not invest in any Depositary
Chief Counsel’s Office).
Receipts that the Adviser (or, if applicable, the
Fund Sub-Adviser) deems to be illiquid or for
SUPPLEMENTARY INFORMATION: The
which pricing information is not readily available.
following is a summary of the
4 If a Fund invests in derivatives: (a) The Fund’s
application. The complete application
board of trustees periodically will review and
may be obtained via the Commission’s
approve (i) the Fund’s use of derivatives and (ii)
Web site by searching for the file
how the Fund’s investment adviser assesses and
manages risk with respect to the Fund’s use of
number, or for an applicant using the
derivatives; and (b) the Fund’s disclosure of its use
Company name box, at https://
of derivatives in its offering documents and
www.sec.gov/search/search.htm or by
periodic reports will be consistent with relevant
Commission and staff guidance.
calling (202) 551–8090.
sections 6(c) and 17(b) of the Act for an
exemption from sections 17(a)(1) and
(a)(2) of the Act.
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Federal Register / Vol. 79, No. 122 / Wednesday, June 25, 2014 / Notices
investment objective will be to seek
total return by investing, under normal
market conditions, at least 80% of its
net assets in a portfolio of U.S.
government, corporate and agency debt
securities.
2. Each Fund will (a) be advised by
Elkhorn Investments or an entity
controlling, controlled by or under
common control with Elkhorn
Investments (each such entity and any
successor thereto, an ‘‘Adviser’’) 5 and
(b) comply with the terms and
conditions stated in the application.
Elkhorn Investments is a Delaware
limited liability company and is
registered as an investment adviser
under section 203 of the Investment
Advisers Act of 1940 (the ‘‘Advisers
Act’’). Any other Adviser to a Fund will
be registered under the Advisers Act.
The Adviser may retain sub-advisers
(each, a ‘‘Fund Sub-Adviser’’) in
connection with the Funds; each Fund
Sub-Adviser will be registered under the
Advisers Act or not subject to such
registration.
3. The Trust will enter into a
distribution agreement with one or more
distributors (‘‘Distributor’’). Each
Distributor will be registered under the
Securities Exchange Act of 1934, as
amended (the ‘‘Exchange Act’’), and will
act as Distributor and principal
underwriter of the Funds. No
Distributor will be affiliated with the
Listing Exchange. The Distributor of any
Fund may be an ‘‘affiliated person’’ or
an affiliated person of an affiliated
person of the Fund’s Adviser or Fund
Sub-Adviser.
4. Shares of each Fund will be
purchased from the Trust only in large
aggregations of a specified number
referred to as ‘‘Creation Units.’’ Creation
Units may be purchased through orders
placed with the Distributor by or
through an ‘‘Authorized Participant’’
which is either (1) a broker-dealer or
other participant in the Continuous Net
Settlement (‘‘CNS’’) System of the
National Securities Clearing Corporation
(‘‘NSCC’’), a clearing agency that is
registered with the Commission, or (2)
a participant (‘‘DTC Participant’’) in the
Depository Trust Company (‘‘DTC’’),
and which in either case has executed
a participant agreement with the
Distributor with respect to the creation
and redemption of Creation Units.
Purchases and redemptions of the
Funds’ Creation Units will be processed
either through an enhanced clearing
process available to DTC Participants
5 For the purposes of the requested order, a
‘‘successor’’ is limited to an entity or entities that
result from a reorganization into another
jurisdiction or a change in the type of business
organization.
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that are also participants in the CNS
system of the NSCC (the ‘‘NSCC
Process’’) or through a manual clearing
process that is available to all DTC
Participants (the ‘‘DTC Process’’).
5. In order to keep costs low and
permit each Fund to be as fully invested
as possible, Shares will be purchased
and redeemed in Creation Units and
generally on an in-kind basis.
Accordingly, except where the purchase
or redemption will include cash under
the limited circumstances specified
below, purchasers will be required to
purchase Creation Units by making an
in-kind deposit of specified instruments
(‘‘Deposit Instruments’’), and
shareholders redeeming their Shares
will receive an in-kind transfer of
specified instruments (‘‘Redemption
Instruments’’).6 On any given Business
Day 7 the names and quantities of the
instruments that constitute the Deposit
Instruments and the names and
quantities of the instruments that
constitute the Redemption Instruments
will be identical, and these instruments
may be referred to, in the case of either
a purchase or redemption, as the
‘‘Creation Basket.’’ In addition, the
Creation Basket will correspond pro rata
to the positions in a Fund’s portfolio
(including cash positions),8 except: (a)
In the case of bonds, for minor
differences when it is impossible to
break up bonds beyond certain
minimum sizes needed for transfer and
settlement; (b) for minor differences
when rounding is necessary to eliminate
fractional shares or lots that are not
tradeable round lots; 9 or (c) TBA
Transactions, short positions, and other
positions that cannot be transferred inkind 10 will be excluded from the
Creation Basket.11 If there is a difference
6 The Funds must comply with the federal
securities laws in accepting Deposit Instruments
and satisfying redemptions with Redemption
Instruments, including that the Deposit Instruments
and Redemption Instruments are sold in
transactions that would be exempt from registration
under the Securities Act. In accepting Deposit
Instruments and satisfying redemptions with
Redemption Instruments that are restricted
securities eligible for resale pursuant to Rule 144A
under the Securities Act, the Funds will comply
with the conditions of Rule 144A.
7 Each Fund will sell and redeem Creation Units
on any day the Fund is open, including as required
by section 22(e) of the Act (each, a ‘‘Business Day’’).
8 The portfolio used for this purpose will be the
same portfolio used to calculate the Fund’s NAV for
that Business Day.
9 A tradeable round lot for a security will be the
standard unit of trading in that particular type of
security in its primary market.
10 This includes instruments that can be
transferred in-kind only with the consent of the
original counterparty to the extent the Fund does
not intend to seek such consents.
11 Because these instruments will be excluded
from the Creation Basket, their value will be
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36107
between the net asset value (‘‘NAV’’)
attributable to a Creation Unit and the
aggregate market value of the Creation
Basket exchanged for the Creation Unit,
the party conveying instruments with
the lower value will also pay to the
other an amount in cash equal to that
difference (the ‘‘Balancing Amount’’).
6. Purchases and redemptions of
Creation Units may be made in whole or
in part on a cash basis, rather than inkind, solely under the following
circumstances: (a) To the extent there is
a Balancing Amount, as described
above; (b) if, on a given Business Day,
a Fund announces before the open of
trading that all purchases, all
redemptions or all purchases and
redemptions on that day will be made
entirely in cash; (c) if, upon receiving a
purchase or redemption order from an
Authorized Participant, a Fund
determines to require the purchase or
redemption, as applicable, to be made
entirely in cash; 12 (d) if, on a given
Business Day, a Fund requires all
Authorized Participants purchasing or
redeeming Shares on that day to deposit
or receive (as applicable) cash in lieu of
some or all of the Deposit Instruments
or Redemption Instruments,
respectively, solely because: (i) Such
instruments are not eligible for transfer
through either the NSCC Process or DTC
Process; or (ii) in the case of Funds
holding non-U.S. investments (‘‘Global
Funds’’), such instruments are not
eligible for trading due to local trading
restrictions, local restrictions on
securities transfers or other similar
circumstances; or (e) if a Fund permits
an Authorized Participant to deposit or
receive (as applicable) cash in lieu of
some or all of the Deposit Instruments
or Redemption Instruments,
respectively, solely because: (i) Such
instruments are, in the case of the
purchase of a Creation Unit, not
available in sufficient quantity; (ii) such
instruments are not eligible for trading
by an Authorized Participant or the
reflected in the determination of the Balancing
Amount (defined below).
12 In determining whether a particular Fund will
sell or redeem Creation Units entirely on a cash or
in-kind basis (whether for a given day or a given
order), the key consideration will be the benefit that
would accrue to the Fund and its investors. For
instance, in bond transactions, the Adviser may be
able to obtain better execution than Share
purchasers because of the Adviser’s size, experience
and potentially stronger relationships in the fixed
income markets. Purchases of Creation Units either
on an all cash basis or in-kind are expected to be
neutral to the Funds from a tax perspective. In
contrast, cash redemptions typically require selling
portfolio holdings, which may result in adverse tax
consequences for the remaining Fund shareholders
that would not occur with an in-kind redemption.
As a result, tax considerations may warrant in-kind
redemptions.
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investor on whose behalf the
Authorized Participant is acting; or (iii)
a holder of Shares of a Fund holding
non-U.S. investments would be subject
to unfavorable income tax treatment if
the holder receives redemption
proceeds in-kind.13
7. Each Business Day, before the open
of trading on the Listing Exchange, each
Fund will cause to be published through
the NSCC the names and quantities of
the instruments comprising the Creation
Basket, as well as the estimated
Balancing Amount (if any), for that day.
The published Creation Basket will
apply until a new Creation Basket is
announced on the following Business
Day, and there will be no intra-day
changes to the Creation Basket except to
correct errors in the published Creation
Basket. The Listing Exchange or a major
market data vendor will disseminate
every 15 seconds throughout the trading
day an amount representing the Fund’s
estimated NAV, which will be the value
of the Fund’s Portfolio Positions, on a
per Share basis.
8. An investor purchasing or
redeeming a Creation Unit will be
charged a fee (‘‘Transaction Fee’’) to
protect existing shareholders of the
Funds from the dilutive costs associated
with the purchase and redemption of
Creation Units.14 The Distributor will
deliver a confirmation and Fund
prospectus (‘‘Prospectus’’) to the
purchaser. In addition, the Distributor
will maintain records of both the orders
placed with it and the confirmations of
acceptance furnished by it.
9. Beneficial owners of Shares may
sell their Shares in the secondary
market. Shares will be listed on a
Listing Exchange and traded in the
secondary market in the same manner as
other equity securities. Applicants state
that one or more specialists or market
makers will be assigned to the Shares.
The price of Shares trading on the
Listing Exchange will be based on a
current bid/offer market. Transactions
involving the sale of Shares on the
Listing Exchange will be subject to
customary brokerage commissions and
charges.
10. Applicants expect that purchasers
of Creation Units will include
13 A ‘‘custom order’’ is any purchase or
redemption of Shares made in whole or in part on
a cash basis in reliance on clause (e)(i) or (e)(ii).
14 Where a Fund permits an in-kind purchaser to
deposit cash in lieu of depositing one or more
Deposit Instruments, the purchaser may be assessed
a higher Transaction Fee to offset the cost to the
Fund of buying those particular Deposit
Instruments. In all cases, such Transaction Fees will
be limited in accordance with requirements of the
Commission applicable to open-end management
investment companies offering redeemable
securities.
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arbitrageurs and that Listing Exchange
specialists or market makers, acting in
their unique role to provide a fair and
orderly secondary market for Shares,
also may purchase Creation Units for
use in their own market making
activities.15 Applicants expect that
secondary market purchasers of Shares
will include both institutional investors
and retail investors.16 Applicants state
that because the market price of
Creation Units will be disciplined by
arbitrage opportunities, investors should
be able to sell Shares in the secondary
market at prices that do not vary
materially from their NAV.
11. Neither the Trust nor any Fund
will be advertised or marketed as a
conventional open-end investment
company or mutual fund. Instead, each
Fund will be marketed as an ‘‘activelymanaged exchange-traded fund.’’ Any
advertising material that describes the
features of obtaining, buying or selling
Creation Units, or buying or selling
Shares on the Listing Exchange, or
where there is reference to
redeemability, will prominently
disclose that Shares are not individually
redeemable and that owners of Shares
may acquire Shares from a Fund and
tender those Shares for redemption to a
Fund in Creation Units only.
12. The Funds’ Web site, which will
be publicly available prior to the public
offering of Shares, will include, or will
include links to, each Fund’s current
Prospectus and Summary Prospectus (if
any), which may be downloaded. That
Web site, which will be publicly
available at no charge, will also contain,
on a per Share basis for each Fund, the
prior Business Day’s NAV and the
market closing price or the mid-point of
the bid/ask spread at the time of
calculation of such NAV (the ‘‘Bid/Ask
Price’’), and a calculation of the
premium or discount of the market
15 If Shares are listed on The NASDAQ Stock
Market LLC (‘‘Nasdaq’’) or a similar electronic Stock
Exchange (including NYSE Arca), one or more
member firms of that Stock Exchange will act as
Market Maker and maintain a market for Shares
trading on that Stock Exchange. On Nasdaq, no
particular Market Maker would be contractually
obligated to make a market in Shares. However, the
listing requirements on Nasdaq, for example,
stipulate that at least two Market Makers must be
registered in Shares to maintain a listing. In
addition, on Nasdaq and NYSE Arca, registered
Market Makers are required to make a continuous
two-sided market or subject themselves to
regulatory sanctions. No Market Maker will be an
affiliated person or an affiliated person of an
affiliated person, of the Funds, except within the
meaning of section 2(a)(3)(A) or (C) of the Act due
solely to ownership of Shares as discussed below.
16 Shares will be registered in book-entry form
only. DTC or its nominee will be the record or
registered owner of all outstanding Shares. DTC or
DTC Participants will maintain records of beneficial
ownership of Shares.
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closing price or Bid/Ask Price against
such NAV. On each Business Day,
before commencement of trading in
Shares on the Listing Exchange, each
Fund will also disclose on the Web site
the identities and quantities of its
Portfolio Positions held by the Fund
that will form the basis for the Fund’s
calculation of NAV at the end of the
Business Day.17
Applicants’ Legal Analysis
1. Applicants request an order under
section 6(c) of the Act for an exemption
from sections 2(a)(32), 5(a)(1), 22(d) and
22(e) of the Act and rule 22c–1 under
the Act, and under sections 6(c) and
17(b) of the Act for an exemption from
sections 17(a)(1) and (a)(2) of the Act.
2. Section 6(c) of the Act provides that
the Commission may exempt any
person, security or transaction, or any
class of persons, securities or
transactions, from any provision of the
Act, if and to the extent that such
exemption is necessary or appropriate
in the public interest and consistent
with the protection of investors and the
purposes fairly intended by the policy
and provisions of the Act. Section 17(b)
of the Act authorizes the Commission to
exempt a proposed transaction from
section 17(a) of the Act if evidence
establishes that the terms of the
proposed transaction, including the
consideration to be paid or received, are
reasonable and fair and do not involve
overreaching on the part of any person
concerned, and the proposed
transaction is consistent with the
policies of the registered investment
company and the general provisions of
the Act.
Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an
‘‘open-end company’’ as a management
investment company that is offering for
sale or has outstanding any redeemable
security of which it is the issuer.
Section 2(a)(32) of the Act defines a
redeemable security as any security,
other than short-term paper, under the
terms of which the holder, upon its
presentation to the issuer, is entitled to
receive approximately a proportionate
share of the issuer’s current net assets,
or the cash equivalent. Applicants
request an order to permit the Trust to
register as an open-end management
investment company and redeem Shares
in Creation Units only. Applicants state
17 Under accounting procedures followed by the
Funds, trades made on the prior Business Day (‘‘T’’)
will be booked and reflected in NAV on the current
Business Day (‘‘T+1’’). Accordingly, the Funds will
be able to disclose at the beginning of the Business
Day the portfolio that will form the basis for the
NAV calculation at the end of the Business Day.
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that each investor is entitled to purchase
or redeem Creation Units rather than
trade the individual Shares in the
secondary market. Applicants further
state that because of the arbitrage
possibilities created by the
redeemability of Creation Units, it is
expected that the market price of an
individual Share will not vary
materially from its NAV.
Section 22(d) of the Act and Rule 22c–
1 Under the Act
4. Section 22(d) of the Act, among
other things, prohibits a dealer from
selling a redeemable security, which is
currently being offered to the public by
or through a principal underwriter,
except at a current public offering price
described in the prospectus. Rule 22c–
1 under the Act generally requires that
a dealer selling, redeeming, or
repurchasing a redeemable security do
so only at a price based on its NAV.
Applicants state that secondary market
trading in Shares will take place at
negotiated prices, rather than at the
current offering price described in the
Fund’s Prospectus. Thus, purchases and
sales of Shares in the secondary market
will not comply with section 22(d) of
the Act and rule 22c–1 under the Act.
Applicants request an exemption under
section 6(c) from these provisions.
5. Applicants assert that the concerns
sought to be addressed by section 22(d)
of the Act and rule 22c–1 under the Act
with respect to pricing are equally
satisfied by the proposed method of
pricing Shares. Applicants maintain that
while there is little legislative history
regarding section 22(d), its provisions,
as well as those of rule 22c–1, appear to
have been intended (a) to prevent
dilution caused by certain risklesstrading schemes by principal
underwriters and contract dealers, (b) to
prevent unjust discrimination or
preferential treatment among buyers,
and (c) to ensure an orderly distribution
of shares by eliminating price
competition from brokers offering shares
at less than the published sales price
and repurchasing shares at more than
the published redemption price.
6. Applicants state that (a) secondary
market transactions in Shares would not
cause dilution for owners of such Shares
because such transactions do not
involve the Trust or Funds as parties,
and (b) to the extent different prices
exist during a given trading day, or from
day to day, such variances occur as a
result of third-party market forces, such
as supply and demand. Therefore,
applicants assert that secondary market
transactions in Shares will not lead to
discrimination or preferential treatment
among purchasers. Finally, applicants
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contend that the proposed distribution
system will be orderly because arbitrage
activity will ensure that the difference
between the market price of Shares and
their NAV remains immaterial.
Section 22(e)
7. Section 22(e) of the Act generally
prohibits a registered investment
company from suspending the right of
redemption or postponing the date of
payment of redemption proceeds for
more than seven days after the tender of
a security for redemption. Applicants
observe that the settlement of
redemptions of Creation Units of Global
Funds will be contingent not only on
the settlement cycle of the U.S.
securities markets but also on the
delivery cycles in foreign markets in
which those Funds invest. Applicants
assert that, under certain circumstances,
the delivery cycles for transferring
Portfolio Positions to redeeming
investors, coupled with local market
holiday schedules, may require a
delivery process of up to 15 calendar
days. Applicants therefore request relief
from section 22(e) in order for each
Global Fund to provide payment or
satisfaction of redemptions within the
maximum number of calendar days
required for such payment or
satisfaction in the principal local
market(s) where transactions in its
Portfolio Positions customarily clear
and settle, but in any event, within a
period not to exceed fifteen calendar
days.18
8. Applicants submit that Congress
adopted section 22(e) to prevent
unreasonable, undisclosed or
unforeseen delays in the actual payment
of redemption proceeds. Applicants
state that allowing redemption
payments for Creation Units of a Global
Fund to be made within 15 calendar
days would not be inconsistent with the
spirit and intent of section 22(e).19
Applicants state that each Global Fund’s
statement of additional information
(‘‘SAI’’) will disclose those local
holidays (over the period of at least one
year following the date of the SAI), if
any, that are expected to prevent the
delivery of redemption proceeds in
seven calendar days and the maximum
number of days, up to 15 calendar days,
needed to deliver the proceeds for that
Global Fund. Applicants are not seeking
18 Applicants acknowledge that no relief obtained
from the requirements of section 22(e) will affect
any obligations that they may otherwise have under
rule 15c6–1 under the Exchange Act, which
requires that most securities transactions be settled
within three business days of the trade date.
19 Certain countries in which a Global Fund may
invest have historically had settlement periods of
up to 15 calendar days.
PO 00000
Frm 00122
Fmt 4703
Sfmt 4703
36109
relief from section 22(e) with respect to
Global Funds that do not effect
redemptions of Creation Units in-kind.
Sections 17(a)(1) and (2) of the Act
9. Section 17(a)(1) and (2) of the Act
generally prohibit an affiliated person of
a registered investment company, or an
affiliated person of such a person
(‘‘second tier affiliate’’), from selling any
security to or purchasing any security
from the company. Section 2(a)(3) of the
Act defines ‘‘affiliated person’’ to
include any person directly or indirectly
owning, controlling, or holding with
power to vote 5% or more of the
outstanding voting securities of the
other person and any person directly or
indirectly controlling, controlled by, or
under common control with, the other
person. Section 2(a)(9) of the Act
defines ‘‘control’’ of a fund as ‘‘the
power to exercise a controlling
influence over the management or
policies’’ of the fund and provides that
a control relationship will be presumed
where one person owns more than 25%
of another person’s voting securities.
The Funds may be deemed to be
controlled by an Adviser and hence
affiliated persons of each other. In
addition, the Funds may be deemed to
be under common control with any
other registered investment company (or
series thereof) advised by an Adviser (an
‘‘Affiliated Fund’’).
10. Applicants request an exemption
from section 17(a) under sections 6(c)
and 17(b) to permit in-kind purchases
and redemptions of Creation Units from
the Funds by persons that are affiliated
persons or second tier affiliates of the
Funds solely by virtue of one or more
of the following: (1) Holding 5% or
more, or more than 25%, of the
outstanding Shares of one or more
Funds; (2) an affiliation with a person
with an ownership interest described in
(1); or (3) holding 5% or more, or more
than 25%, of the shares of one or more
Affiliated Funds.
11. Applicants assert that no useful
purpose would be served by prohibiting
the affiliated persons described above
from making in-kind purchases or inkind redemptions of Shares of a Fund in
Creation Units. Both the deposit
procedures for in-kind purchases of
Creation Units and the redemption
procedures for in-kind redemptions will
be effected in exactly the same manner
for all purchases and redemptions. The
valuation of the Deposit Instruments
and Redemption Instruments will be
made in the same manner, and in the
same manner as the Fund’s Portfolio
Positions, regardless of the identity of
the purchaser or redeemer. Except with
respect to cash determined in
E:\FR\FM\25JNN1.SGM
25JNN1
36110
Federal Register / Vol. 79, No. 122 / Wednesday, June 25, 2014 / Notices
accordance with the procedures
described in section I.G.1. of the
application, Deposit Instruments and
Redemption Instruments will be the
same for all purchasers and redeemers.
Therefore, applicants state that the inkind purchases and redemptions will
afford no opportunity for the specified
affiliated persons of a Fund to effect a
transaction detrimental to other holders
of Shares of that Fund. Applicants do
not believe that in-kind purchases and
redemptions will result in abusive selfdealing or overreaching of the Fund.
mstockstill on DSK4VPTVN1PROD with NOTICES
Applicant’s Conditions
Applicants agree that any order of the
Commission granting the requested
relief will be subject to the following
conditions:
1. As long as the Funds operate in
reliance on the requested order, the
Shares of the Funds will be listed on a
Listing Exchange.
2. Neither the Trust nor any Fund will
be advertised or marketed as an openend investment company or a mutual
fund. Any advertising material that
describes the purchase or sale of
Creation Units or refers to redeemability
will prominently disclose that the
Shares are not individually redeemable
and that owners of the Shares may
acquire those Shares from the Fund and
tender those Shares for redemption to
the Fund in Creation Units only.
3. The Web site for the Funds, which
is and will be publicly accessible at no
charge, will contain on a per Share
basis, for each Fund, the prior Business
Day’s NAV and the market closing price
or Bid/Ask Price, and a calculation of
the premium or discount of the market
closing price or Bid/Ask Price against
such NAV.
4. On each Business Day, before
commencement of trading in Shares on
the Listing Exchange, the Fund will
disclose on its Web site the identities
and quantities of the Portfolio Positions
held by the Fund that will form the
basis for the Fund’s calculation of NAV
at the end of the Business Day.
5. The Adviser or any Fund SubAdviser, directly or indirectly, will not
cause any Authorized Participant (or
any investor on whose behalf an
Authorized Participant may transact
with the Fund) to acquire any Deposit
Instrument for the Fund through a
transaction in which the Fund could not
engage directly.
6. The requested relief to permit ETF
operations will expire on the effective
date of any Commission rule under the
Act that provides relief permitting the
operation of actively managed
exchange-traded funds.
VerDate Mar<15>2010
18:01 Jun 24, 2014
Jkt 232001
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–14798 Filed 6–24–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–72434; File No. SR–BATS–
2014–014; SR–BX–2014–021; SR–BYX–
2014–007; SR–CHX–2014–06; SR–EDGA–
2014–11; SR–EDGX–2014–12; SR–FINRA–
2014–021; SR–ISE–2014–25; SR–NASDAQ–
2014–044; SR–NSX–2014–08; SR–NYSE–
2014–22; SR–NYSEArca–2014–48; SR–
NYSEMKT–2014–37; SR–Phlx–2014–27]
Self-Regulatory Organizations; BATS
Exchange, Inc.; BATS–Y Exchange,
Inc.; NASDAQ OMX BX, Inc.; Chicago
Stock Exchange, Inc.; EDGA
Exchange, Inc.; EDGX Exchange, Inc.;
Financial Industry Regulatory
Authority, Inc.; International Securities
Exchange LLC; The NASDAQ Stock
Market LLC; National Stock Exchange,
Inc.; New York Stock Exchange LLC;
NYSE Arca, Inc.; NYSE MKT LLC;
NASDAQ OMX PHLX LLC; Order
Granting Approval of Proposed Rule
Changes Relating to Clearly Erroneous
Executions
June 19, 2014.
I. Introduction
On April 17, 2014, BATS Exchange,
Inc. (‘‘BATS’’), BATS–Y Exchange, Inc.
(‘‘BATS–Y’’), NASDAQ OMX BX, Inc.
(‘‘BX’’), EDGA Exchange, Inc. (‘‘EDGA’’),
EDGX Exchange, Inc. (‘‘EDGX’’),
Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’), International
Securities Exchange LLC (‘‘ISE’’), The
NASDAQ Stock Market LLC (‘‘Nasdaq’’),
National Stock Exchange, Inc. (‘‘NSX’’),
and NASDAQ OMX PHLX LLC (‘‘Phlx’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’) pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 proposed rule
changes to amend certain of their
respective rules relating to clearly
erroneous transactions. On April 21,
2014, New York Stock Exchange LLC
(‘‘NYSE’’), NYSE Arca, Inc. (‘‘NYSE
Arca’’) and NYSE MKT LLC (‘‘NYSE
MKT’’) filed with the Commission
pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 3 and Rule 19b–4 thereunder,4
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 15 U.S.C. 78s(b)(1).
4 17 CFR 240.19b–4.
2 17
PO 00000
Frm 00123
Fmt 4703
Sfmt 4703
proposed rule changes to amend certain
of their respective rules relating to
clearly erroneous transactions. On April
22, 2014, Chicago Stock Exchange, Inc.
(‘‘CHX’’) filed with the Commission
pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 5 and Rule 19b–4 thereunder,6
proposed rule changes to amend certain
of its respective rules relating to clearly
erroneous transactions. The proposed
rule changes were published for
comment in the Federal Register on
May 6, 2014.7 The Commission received
no comments on the proposed changes.
This order approves the proposed rule
changes.
II. Description of the Proposal
A. Background
The U.S. equity markets experienced
a severe disruption on May 6, 2010.8
Severe price volatility led to a large
number of trades being executed at
temporarily depressed prices, including
many that occurred at prices
dramatically away from pre-decline
levels. BATS, BX, CHX, EDGA, EDGX,
ISE, Nasdaq, NSX, NYSE, NYSE Arca,
NYSE MKT (collectively, and, together
with BATS–Y and Phlx, the
‘‘Exchanges’’) and FINRA (collectively,
the ‘‘self-regulatory organizations’’ or
the ‘‘SROs’’) exercised their authority
under their clearly erroneous executions
rules to break trades that were effected
at prices 60% or more away from predecline prices, using a process that was
not sufficiently clear or transparent to
market participants. To clarify the
clearly erroneous execution review
process across all SROs, and reduce the
discretion of the Exchanges and FINRA
to deviate from the objective standards
in their respective rules when dealing
with clearly erroneous transactions, the
Exchanges and FINRA filed proposed
rule changes to, among other things,
establish clear thresholds for when
5 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
7 See Securities Exchange Act Release Nos. 72044
(April 30, 2014), 79 FR 25919; 72045 (April 30,
2014), 79 FR 25943; 72046 (April 30, 2014), 79 FR
25972; 72047 (April 30, 2014), 79 FR 25940; 72048
(April 30, 2014), 79 FR 25976; 72049 (April 30,
2014), 79 FR 25951; 72050 (April 30, 2014), 79 FR
25933; 72051 (April 30, 2014), 79 FR 25954; 72052
(April 30, 2014), 79 FR 25958; 72053 (April 30,
2014), 79 FR 25965; 72054 (April 30, 2014), 79 FR
25947; 72055 (April 30, 2014), 79 FR 25961; 72056
(April 30, 2014), 79 FR 25968; and 72057 (April 30,
2014), 79 FR 25937 (collectively, the ‘‘Notices’’).
8 The events of May 6, 2010 are described more
fully in the report of the staffs of the Commodity
Futures Trading Commission (‘‘CFTC’’) and the
Commission, titled Report of the CFTC and SEC to
the Joint Advisory Committee on Emerging
Regulatory Issues, ‘‘Preliminary Findings Regarding
the Market Events of May 6, 2010,’’ dated May 18,
2010.
6 17
E:\FR\FM\25JNN1.SGM
25JNN1
Agencies
[Federal Register Volume 79, Number 122 (Wednesday, June 25, 2014)]
[Notices]
[Pages 36106-36110]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-14798]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 31089; 812-14262]
Elkhorn Investments, LLC and Elkhorn ETF Trust; Notice of
Application
June 19, 2014.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under section 6(c) of the
Investment Company Act of 1940 (``Act'') for an exemption from sections
2(a)(32), 5(a)(1), 22(d) and 22(e) of the Act and rule 22c-1 under the
Act, under sections 6(c) and 17(b) of the Act for an exemption from
sections 17(a)(1) and (a)(2) of the Act.
-----------------------------------------------------------------------
Applicants: Elkhorn Investments, LLC (``Elkhorn Investments'') and
Elkhorn ETF Trust (the ``Trust'').
SUMMARY: Summary of Application: Applicants request an order that
permits: (a) Series of certain open-end management investment companies
to issue shares (``Shares'') redeemable in large aggregations only
(``Creation Units''); (b) secondary market transactions in Shares to
occur at negotiated market prices; (c) certain series to pay redemption
proceeds, under certain circumstances, more than seven days from the
tender of Shares for redemption; and (d) certain affiliated persons of
the series to deposit securities into, and receive securities from, the
series in connection with the purchase and redemption of Creation
Units.
DATES: Filing Dates: The application was filed on January 9, 2014, and
amended on June 4, 2014.
Hearing or Notification of Hearing: An order granting the requested
relief will be issued unless the Commission orders a hearing.
Interested persons may request a hearing by writing to the Commission's
Secretary and serving applicants with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 p.m. on July 14, 2014, and should be accompanied by proof of
service on applicants, in the form of an affidavit or, for lawyers, a
certificate of service. Hearing requests should state the nature of the
writer's interest, the reason for the request, and the issues
contested. Persons who wish to be notified of a hearing may request
notification by writing to the Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street NE., Washington, DC 20549-1090. Applicants, 207 Reber Street,
Suite 201, Wheaton, IL 60187.
FOR FURTHER INFORMATION CONTACT: Christine Y. Greenlees, Senior
Counsel, at (202) 551-6879, or David P. Bartels, Branch Chief, 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. The Trust, a business trust organized under the laws of
Massachusetts, is registered with the Commission as an open-end
management investment company. The applicants are requesting relief not
only for the Trust and its current series, Elkhorn Enhanced Short Term
Government Fund (``Initial Fund''), but also with respect to future
series of the Trust, and to any registered open-end management
investment companies or series thereof that may be created in the
future and that utilizes active management investment strategies
(``Future Funds'' and collectively with the Initial Fund, the
``Funds'').\1\ Funds may invest in equity securities or fixed income
securities traded in the U.S. or non-U.S. markets or a combination of
equity and fixed income securities, including ``to-be-announced
transactions'' (``TBAs'') \2\ and depositary receipts (``Depositary
Receipts'').\3\ The securities, other assets, and other positions in
which a Fund invests are its ``Portfolio Positions.'' \4\ The Trust
currently expects that the Initial Fund's
[[Page 36107]]
investment objective will be to seek total return by investing, under
normal market conditions, at least 80% of its net assets in a portfolio
of U.S. government, corporate and agency debt securities.
---------------------------------------------------------------------------
\1\ All entities that currently intend to rely on the requested
order are named as applicants and any Fund that currently intends to
rely on the requested order is identified in the application. Any
other entity that relies on the requested order in the future will
comply with the terms and conditions of the application.
\2\ A TBA Transaction is a method of trading mortgage-backed
securities. In a TBA Transaction, the buyer and seller agree on
general trade parameters such as agency, settlement date, par amount
and price. The actual pools delivered generally are determined two
days prior to the settlement date.
\3\ Depositary Receipts include American Depositary Receipts
(``ADRs'') and Global Depositary Receipts (``GDRs''). With respect
to ADRs, the depositary is typically a U.S. financial institution
and the underlying securities are issued by a foreign issuer. The
ADR is registered under the Securities Act of 1933 (``Securities
Act'') on Form F-6. ADR trades occur either on a national securities
exchange as defined in Section 2(a)(26) of the Act (``Listing
Exchange'') or off-exchange. Financial Industry Regulatory Authority
Rule 6620 requires all off-exchange transactions in ADRs to be
reported within 90 seconds and ADR trade reports to be disseminated
on a real-time basis. With respect to GDRs, the depositary may be a
foreign or a U.S. entity, and the underlying securities may have a
foreign or a U.S. issuer. All GDRs are sponsored and trade on a
foreign exchange. No affiliated persons of applicants, any Adviser,
Fund Sub-Adviser (as defined below), or Fund will serve as the
depositary for any Depositary Receipts held by a Fund. A Fund will
not invest in any Depositary Receipts that the Adviser (or, if
applicable, the Fund Sub-Adviser) deems to be illiquid or for which
pricing information is not readily available.
\4\ If a Fund invests in derivatives: (a) The Fund's board of
trustees periodically will review and approve (i) the Fund's use of
derivatives and (ii) how the Fund's investment adviser assesses and
manages risk with respect to the Fund's use of derivatives; and (b)
the Fund's disclosure of its use of derivatives in its offering
documents and periodic reports will be consistent with relevant
Commission and staff guidance.
---------------------------------------------------------------------------
2. Each Fund will (a) be advised by Elkhorn Investments or an
entity controlling, controlled by or under common control with Elkhorn
Investments (each such entity and any successor thereto, an
``Adviser'') \5\ and (b) comply with the terms and conditions stated in
the application. Elkhorn Investments is a Delaware limited liability
company and is registered as an investment adviser under section 203 of
the Investment Advisers Act of 1940 (the ``Advisers Act''). Any other
Adviser to a Fund will be registered under the Advisers Act. The
Adviser may retain sub-advisers (each, a ``Fund Sub-Adviser'') in
connection with the Funds; each Fund Sub-Adviser will be registered
under the Advisers Act or not subject to such registration.
---------------------------------------------------------------------------
\5\ For the purposes of the requested order, a ``successor'' is
limited to an entity or entities that result from a reorganization
into another jurisdiction or a change in the type of business
organization.
---------------------------------------------------------------------------
3. The Trust will enter into a distribution agreement with one or
more distributors (``Distributor''). Each Distributor will be
registered under the Securities Exchange Act of 1934, as amended (the
``Exchange Act''), and will act as Distributor and principal
underwriter of the Funds. No Distributor will be affiliated with the
Listing Exchange. The Distributor of any Fund may be an ``affiliated
person'' or an affiliated person of an affiliated person of the Fund's
Adviser or Fund Sub-Adviser.
4. Shares of each Fund will be purchased from the Trust only in
large aggregations of a specified number referred to as ``Creation
Units.'' Creation Units may be purchased through orders placed with the
Distributor by or through an ``Authorized Participant'' which is either
(1) a broker-dealer or other participant in the Continuous Net
Settlement (``CNS'') System of the National Securities Clearing
Corporation (``NSCC''), a clearing agency that is registered with the
Commission, or (2) a participant (``DTC Participant'') in the
Depository Trust Company (``DTC''), and which in either case has
executed a participant agreement with the Distributor with respect to
the creation and redemption of Creation Units. Purchases and
redemptions of the Funds' Creation Units will be processed either
through an enhanced clearing process available to DTC Participants that
are also participants in the CNS system of the NSCC (the ``NSCC
Process'') or through a manual clearing process that is available to
all DTC Participants (the ``DTC Process'').
5. In order to keep costs low and permit each Fund to be as fully
invested as possible, Shares will be purchased and redeemed in Creation
Units and generally on an in-kind basis. Accordingly, except where the
purchase or redemption will include cash under the limited
circumstances specified below, purchasers will be required to purchase
Creation Units by making an in-kind deposit of specified instruments
(``Deposit Instruments''), and shareholders redeeming their Shares will
receive an in-kind transfer of specified instruments (``Redemption
Instruments'').\6\ On any given Business Day \7\ the names and
quantities of the instruments that constitute the Deposit Instruments
and the names and quantities of the instruments that constitute the
Redemption Instruments will be identical, and these instruments may be
referred to, in the case of either a purchase or redemption, as the
``Creation Basket.'' In addition, the Creation Basket will correspond
pro rata to the positions in a Fund's portfolio (including cash
positions),\8\ except: (a) In the case of bonds, for minor differences
when it is impossible to break up bonds beyond certain minimum sizes
needed for transfer and settlement; (b) for minor differences when
rounding is necessary to eliminate fractional shares or lots that are
not tradeable round lots; \9\ or (c) TBA Transactions, short positions,
and other positions that cannot be transferred in-kind \10\ will be
excluded from the Creation Basket.\11\ If there is a difference between
the net asset value (``NAV'') attributable to a Creation Unit and the
aggregate market value of the Creation Basket exchanged for the
Creation Unit, the party conveying instruments with the lower value
will also pay to the other an amount in cash equal to that difference
(the ``Balancing Amount'').
---------------------------------------------------------------------------
\6\ The Funds must comply with the federal securities laws in
accepting Deposit Instruments and satisfying redemptions with
Redemption Instruments, including that the Deposit Instruments and
Redemption Instruments are sold in transactions that would be exempt
from registration under the Securities Act. In accepting Deposit
Instruments and satisfying redemptions with Redemption Instruments
that are restricted securities eligible for resale pursuant to Rule
144A under the Securities Act, the Funds will comply with the
conditions of Rule 144A.
\7\ Each Fund will sell and redeem Creation Units on any day the
Fund is open, including as required by section 22(e) of the Act
(each, a ``Business Day'').
\8\ The portfolio used for this purpose will be the same
portfolio used to calculate the Fund's NAV for that Business Day.
\9\ A tradeable round lot for a security will be the standard
unit of trading in that particular type of security in its primary
market.
\10\ This includes instruments that can be transferred in-kind
only with the consent of the original counterparty to the extent the
Fund does not intend to seek such consents.
\11\ Because these instruments will be excluded from the
Creation Basket, their value will be reflected in the determination
of the Balancing Amount (defined below).
---------------------------------------------------------------------------
6. Purchases and redemptions of Creation Units may be made in whole
or in part on a cash basis, rather than in-kind, solely under the
following circumstances: (a) To the extent there is a Balancing Amount,
as described above; (b) if, on a given Business Day, a Fund announces
before the open of trading that all purchases, all redemptions or all
purchases and redemptions on that day will be made entirely in cash;
(c) if, upon receiving a purchase or redemption order from an
Authorized Participant, a Fund determines to require the purchase or
redemption, as applicable, to be made entirely in cash; \12\ (d) if, on
a given Business Day, a Fund requires all Authorized Participants
purchasing or redeeming Shares on that day to deposit or receive (as
applicable) cash in lieu of some or all of the Deposit Instruments or
Redemption Instruments, respectively, solely because: (i) Such
instruments are not eligible for transfer through either the NSCC
Process or DTC Process; or (ii) in the case of Funds holding non-U.S.
investments (``Global Funds''), such instruments are not eligible for
trading due to local trading restrictions, local restrictions on
securities transfers or other similar circumstances; or (e) if a Fund
permits an Authorized Participant to deposit or receive (as applicable)
cash in lieu of some or all of the Deposit Instruments or Redemption
Instruments, respectively, solely because: (i) Such instruments are, in
the case of the purchase of a Creation Unit, not available in
sufficient quantity; (ii) such instruments are not eligible for trading
by an Authorized Participant or the
[[Page 36108]]
investor on whose behalf the Authorized Participant is acting; or (iii)
a holder of Shares of a Fund holding non-U.S. investments would be
subject to unfavorable income tax treatment if the holder receives
redemption proceeds in-kind.\13\
---------------------------------------------------------------------------
\12\ In determining whether a particular Fund will sell or
redeem Creation Units entirely on a cash or in-kind basis (whether
for a given day or a given order), the key consideration will be the
benefit that would accrue to the Fund and its investors. For
instance, in bond transactions, the Adviser may be able to obtain
better execution than Share purchasers because of the Adviser's
size, experience and potentially stronger relationships in the fixed
income markets. Purchases of Creation Units either on an all cash
basis or in-kind are expected to be neutral to the Funds from a tax
perspective. In contrast, cash redemptions typically require selling
portfolio holdings, which may result in adverse tax consequences for
the remaining Fund shareholders that would not occur with an in-kind
redemption. As a result, tax considerations may warrant in-kind
redemptions.
\13\ A ``custom order'' is any purchase or redemption of Shares
made in whole or in part on a cash basis in reliance on clause
(e)(i) or (e)(ii).
---------------------------------------------------------------------------
7. Each Business Day, before the open of trading on the Listing
Exchange, each Fund will cause to be published through the NSCC the
names and quantities of the instruments comprising the Creation Basket,
as well as the estimated Balancing Amount (if any), for that day. The
published Creation Basket will apply until a new Creation Basket is
announced on the following Business Day, and there will be no intra-day
changes to the Creation Basket except to correct errors in the
published Creation Basket. The Listing Exchange or a major market data
vendor will disseminate every 15 seconds throughout the trading day an
amount representing the Fund's estimated NAV, which will be the value
of the Fund's Portfolio Positions, on a per Share basis.
8. An investor purchasing or redeeming a Creation Unit will be
charged a fee (``Transaction Fee'') to protect existing shareholders of
the Funds from the dilutive costs associated with the purchase and
redemption of Creation Units.\14\ The Distributor will deliver a
confirmation and Fund prospectus (``Prospectus'') to the purchaser. In
addition, the Distributor will maintain records of both the orders
placed with it and the confirmations of acceptance furnished by it.
---------------------------------------------------------------------------
\14\ Where a Fund permits an in-kind purchaser to deposit cash
in lieu of depositing one or more Deposit Instruments, the purchaser
may be assessed a higher Transaction Fee to offset the cost to the
Fund of buying those particular Deposit Instruments. In all cases,
such Transaction Fees will be limited in accordance with
requirements of the Commission applicable to open-end management
investment companies offering redeemable securities.
---------------------------------------------------------------------------
9. Beneficial owners of Shares may sell their Shares in the
secondary market. Shares will be listed on a Listing Exchange and
traded in the secondary market in the same manner as other equity
securities. Applicants state that one or more specialists or market
makers will be assigned to the Shares. The price of Shares trading on
the Listing Exchange will be based on a current bid/offer market.
Transactions involving the sale of Shares on the Listing Exchange will
be subject to customary brokerage commissions and charges.
10. Applicants expect that purchasers of Creation Units will
include arbitrageurs and that Listing Exchange specialists or market
makers, acting in their unique role to provide a fair and orderly
secondary market for Shares, also may purchase Creation Units for use
in their own market making activities.\15\ Applicants expect that
secondary market purchasers of Shares will include both institutional
investors and retail investors.\16\ Applicants state that because the
market price of Creation Units will be disciplined by arbitrage
opportunities, investors should be able to sell Shares in the secondary
market at prices that do not vary materially from their NAV.
---------------------------------------------------------------------------
\15\ If Shares are listed on The NASDAQ Stock Market LLC
(``Nasdaq'') or a similar electronic Stock Exchange (including NYSE
Arca), one or more member firms of that Stock Exchange will act as
Market Maker and maintain a market for Shares trading on that Stock
Exchange. On Nasdaq, no particular Market Maker would be
contractually obligated to make a market in Shares. However, the
listing requirements on Nasdaq, for example, stipulate that at least
two Market Makers must be registered in Shares to maintain a
listing. In addition, on Nasdaq and NYSE Arca, registered Market
Makers are required to make a continuous two-sided market or subject
themselves to regulatory sanctions. No Market Maker will be an
affiliated person or an affiliated person of an affiliated person,
of the Funds, except within the meaning of section 2(a)(3)(A) or (C)
of the Act due solely to ownership of Shares as discussed below.
\16\ Shares will be registered in book-entry form only. DTC or
its nominee will be the record or registered owner of all
outstanding Shares. DTC or DTC Participants will maintain records of
beneficial ownership of Shares.
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11. Neither the Trust nor any Fund will be advertised or marketed
as a conventional open-end investment company or mutual fund. Instead,
each Fund will be marketed as an ``actively-managed exchange-traded
fund.'' Any advertising material that describes the features of
obtaining, buying or selling Creation Units, or buying or selling
Shares on the Listing Exchange, or where there is reference to
redeemability, will prominently disclose that Shares are not
individually redeemable and that owners of Shares may acquire Shares
from a Fund and tender those Shares for redemption to a Fund in
Creation Units only.
12. The Funds' Web site, which will be publicly available prior to
the public offering of Shares, will include, or will include links to,
each Fund's current Prospectus and Summary Prospectus (if any), which
may be downloaded. That Web site, which will be publicly available at
no charge, will also contain, on a per Share basis for each Fund, the
prior Business Day's NAV and the market closing price or the mid-point
of the bid/ask spread at the time of calculation of such NAV (the
``Bid/Ask Price''), and a calculation of the premium or discount of the
market closing price or Bid/Ask Price against such NAV. On each
Business Day, before commencement of trading in Shares on the Listing
Exchange, each Fund will also disclose on the Web site the identities
and quantities of its Portfolio Positions held by the Fund that will
form the basis for the Fund's calculation of NAV at the end of the
Business Day.\17\
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\17\ Under accounting procedures followed by the Funds, trades
made on the prior Business Day (``T'') will be booked and reflected
in NAV on the current Business Day (``T+1''). Accordingly, the Funds
will be able to disclose at the beginning of the Business Day the
portfolio that will form the basis for the NAV calculation at the
end of the Business Day.
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Applicants' Legal Analysis
1. Applicants request an order under section 6(c) of the Act for an
exemption from sections 2(a)(32), 5(a)(1), 22(d) and 22(e) of the Act
and rule 22c-1 under the Act, and under sections 6(c) and 17(b) of the
Act for an exemption from sections 17(a)(1) and (a)(2) of the Act.
2. Section 6(c) of the Act provides that the Commission may exempt
any person, security or transaction, or any class of persons,
securities or transactions, from any provision of the Act, if and to
the extent that such exemption is necessary or appropriate in the
public interest and consistent with the protection of investors and the
purposes fairly intended by the policy and provisions of the Act.
Section 17(b) of the Act authorizes the Commission to exempt a proposed
transaction from section 17(a) of the Act if evidence establishes that
the terms of the proposed transaction, including the consideration to
be paid or received, are reasonable and fair and do not involve
overreaching on the part of any person concerned, and the proposed
transaction is consistent with the policies of the registered
investment company and the general provisions of the Act.
Sections 5(a)(1) and 2(a)(32) of the Act
3. Section 5(a)(1) of the Act defines an ``open-end company'' as a
management investment company that is offering for sale or has
outstanding any redeemable security of which it is the issuer. Section
2(a)(32) of the Act defines a redeemable security as any security,
other than short-term paper, under the terms of which the holder, upon
its presentation to the issuer, is entitled to receive approximately a
proportionate share of the issuer's current net assets, or the cash
equivalent. Applicants request an order to permit the Trust to register
as an open-end management investment company and redeem Shares in
Creation Units only. Applicants state
[[Page 36109]]
that each investor is entitled to purchase or redeem Creation Units
rather than trade the individual Shares in the secondary market.
Applicants further state that because of the arbitrage possibilities
created by the redeemability of Creation Units, it is expected that the
market price of an individual Share will not vary materially from its
NAV.
Section 22(d) of the Act and Rule 22c-1 Under the Act
4. Section 22(d) of the Act, among other things, prohibits a dealer
from selling a redeemable security, which is currently being offered to
the public by or through a principal underwriter, except at a current
public offering price described in the prospectus. Rule 22c-1 under the
Act generally requires that a dealer selling, redeeming, or
repurchasing a redeemable security do so only at a price based on its
NAV. Applicants state that secondary market trading in Shares will take
place at negotiated prices, rather than at the current offering price
described in the Fund's Prospectus. Thus, purchases and sales of Shares
in the secondary market will not comply with section 22(d) of the Act
and rule 22c-1 under the Act. Applicants request an exemption under
section 6(c) from these provisions.
5. Applicants assert that the concerns sought to be addressed by
section 22(d) of the Act and rule 22c-1 under the Act with respect to
pricing are equally satisfied by the proposed method of pricing Shares.
Applicants maintain that while there is little legislative history
regarding section 22(d), its provisions, as well as those of rule 22c-
1, appear to have been intended (a) to prevent dilution caused by
certain riskless-trading schemes by principal underwriters and contract
dealers, (b) to prevent unjust discrimination or preferential treatment
among buyers, and (c) to ensure an orderly distribution of shares by
eliminating price competition from brokers offering shares at less than
the published sales price and repurchasing shares at more than the
published redemption price.
6. Applicants state that (a) secondary market transactions in
Shares would not cause dilution for owners of such Shares because such
transactions do not involve the Trust or Funds as parties, and (b) to
the extent different prices exist during a given trading day, or from
day to day, such variances occur as a result of third-party market
forces, such as supply and demand. Therefore, applicants assert that
secondary market transactions in Shares will not lead to discrimination
or preferential treatment among purchasers. Finally, applicants contend
that the proposed distribution system will be orderly because arbitrage
activity will ensure that the difference between the market price of
Shares and their NAV remains immaterial.
Section 22(e)
7. Section 22(e) of the Act generally prohibits a registered
investment company from suspending the right of redemption or
postponing the date of payment of redemption proceeds for more than
seven days after the tender of a security for redemption. Applicants
observe that the settlement of redemptions of Creation Units of Global
Funds will be contingent not only on the settlement cycle of the U.S.
securities markets but also on the delivery cycles in foreign markets
in which those Funds invest. Applicants assert that, under certain
circumstances, the delivery cycles for transferring Portfolio Positions
to redeeming investors, coupled with local market holiday schedules,
may require a delivery process of up to 15 calendar days. Applicants
therefore request relief from section 22(e) in order for each Global
Fund to provide payment or satisfaction of redemptions within the
maximum number of calendar days required for such payment or
satisfaction in the principal local market(s) where transactions in its
Portfolio Positions customarily clear and settle, but in any event,
within a period not to exceed fifteen calendar days.\18\
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\18\ Applicants acknowledge that no relief obtained from the
requirements of section 22(e) will affect any obligations that they
may otherwise have under rule 15c6-1 under the Exchange Act, which
requires that most securities transactions be settled within three
business days of the trade date.
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8. Applicants submit that Congress adopted section 22(e) to prevent
unreasonable, undisclosed or unforeseen delays in the actual payment of
redemption proceeds. Applicants state that allowing redemption payments
for Creation Units of a Global Fund to be made within 15 calendar days
would not be inconsistent with the spirit and intent of section
22(e).\19\ Applicants state that each Global Fund's statement of
additional information (``SAI'') will disclose those local holidays
(over the period of at least one year following the date of the SAI),
if any, that are expected to prevent the delivery of redemption
proceeds in seven calendar days and the maximum number of days, up to
15 calendar days, needed to deliver the proceeds for that Global Fund.
Applicants are not seeking relief from section 22(e) with respect to
Global Funds that do not effect redemptions of Creation Units in-kind.
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\19\ Certain countries in which a Global Fund may invest have
historically had settlement periods of up to 15 calendar days.
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Sections 17(a)(1) and (2) of the Act
9. Section 17(a)(1) and (2) of the Act generally prohibit an
affiliated person of a registered investment company, or an affiliated
person of such a person (``second tier affiliate''), from selling any
security to or purchasing any security from the company. Section
2(a)(3) of the Act defines ``affiliated person'' to include any person
directly or indirectly owning, controlling, or holding with power to
vote 5% or more of the outstanding voting securities of the other
person and any person directly or indirectly controlling, controlled
by, or under common control with, the other person. Section 2(a)(9) of
the Act defines ``control'' of a fund as ``the power to exercise a
controlling influence over the management or policies'' of the fund and
provides that a control relationship will be presumed where one person
owns more than 25% of another person's voting securities. The Funds may
be deemed to be controlled by an Adviser and hence affiliated persons
of each other. In addition, the Funds may be deemed to be under common
control with any other registered investment company (or series
thereof) advised by an Adviser (an ``Affiliated Fund'').
10. Applicants request an exemption from section 17(a) under
sections 6(c) and 17(b) to permit in-kind purchases and redemptions of
Creation Units from the Funds by persons that are affiliated persons or
second tier affiliates of the Funds solely by virtue of one or more of
the following: (1) Holding 5% or more, or more than 25%, of the
outstanding Shares of one or more Funds; (2) an affiliation with a
person with an ownership interest described in (1); or (3) holding 5%
or more, or more than 25%, of the shares of one or more Affiliated
Funds.
11. Applicants assert that no useful purpose would be served by
prohibiting the affiliated persons described above from making in-kind
purchases or in-kind redemptions of Shares of a Fund in Creation Units.
Both the deposit procedures for in-kind purchases of Creation Units and
the redemption procedures for in-kind redemptions will be effected in
exactly the same manner for all purchases and redemptions. The
valuation of the Deposit Instruments and Redemption Instruments will be
made in the same manner, and in the same manner as the Fund's Portfolio
Positions, regardless of the identity of the purchaser or redeemer.
Except with respect to cash determined in
[[Page 36110]]
accordance with the procedures described in section I.G.1. of the
application, Deposit Instruments and Redemption Instruments will be the
same for all purchasers and redeemers. Therefore, applicants state that
the in-kind purchases and redemptions will afford no opportunity for
the specified affiliated persons of a Fund to effect a transaction
detrimental to other holders of Shares of that Fund. Applicants do not
believe that in-kind purchases and redemptions will result in abusive
self-dealing or overreaching of the Fund.
Applicant's Conditions
Applicants agree that any order of the Commission granting the
requested relief will be subject to the following conditions:
1. As long as the Funds operate in reliance on the requested order,
the Shares of the Funds will be listed on a Listing Exchange.
2. Neither the Trust nor any Fund will be advertised or marketed as
an open-end investment company or a mutual fund. Any advertising
material that describes the purchase or sale of Creation Units or
refers to redeemability will prominently disclose that the Shares are
not individually redeemable and that owners of the Shares may acquire
those Shares from the Fund and tender those Shares for redemption to
the Fund in Creation Units only.
3. The Web site for the Funds, which is and will be publicly
accessible at no charge, will contain on a per Share basis, for each
Fund, the prior Business Day's NAV and the market closing price or Bid/
Ask Price, and a calculation of the premium or discount of the market
closing price or Bid/Ask Price against such NAV.
4. On each Business Day, before commencement of trading in Shares
on the Listing Exchange, the Fund will disclose on its Web site the
identities and quantities of the Portfolio Positions held by the Fund
that will form the basis for the Fund's calculation of NAV at the end
of the Business Day.
5. The Adviser or any Fund Sub-Adviser, directly or indirectly,
will not cause any Authorized Participant (or any investor on whose
behalf an Authorized Participant may transact with the Fund) to acquire
any Deposit Instrument for the Fund through a transaction in which the
Fund could not engage directly.
6. The requested relief to permit ETF operations will expire on the
effective date of any Commission rule under the Act that provides
relief permitting the operation of actively managed exchange-traded
funds.
For the Commission, by the Division of Investment Management,
under delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-14798 Filed 6-24-14; 8:45 am]
BILLING CODE 8011-01-P