Steben Alternative Investment Funds and Steben & Company, Inc.; Notice of Application, 44221-44224 [2014-17883]
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Federal Register / Vol. 79, No. 146 / Wednesday, July 30, 2014 / Notices
ACTION:
Notice.
SECURITIES AND EXCHANGE
COMMISSION
The Postal Service gives
notice of filing a request with the Postal
Regulatory Commission to add a
domestic shipping services contract to
the list of Negotiated Service
Agreements in the Mail Classification
Schedule’s Competitive Products List.
SUMMARY:
DATES:
Effective date: July 30, 2014.
Elizabeth A. Reed, 202–268–3179.
The
United States Postal Service® hereby
gives notice that, pursuant to 39 U.S.C.
3642 and 3632(b)(3), on July 23, 2014,
it filed with the Postal Regulatory
Commission a Request of the United
States Postal Service to Add Priority
Mail Contract 88 to Competitive Product
List. Documents are available at
www.prc.gov, Docket Nos. MC2014–37,
CP2014–63.
SUPPLEMENTARY INFORMATION:
Stanley F. Mires,
Attorney, Federal Requirements.
[FR Doc. 2014–17896 Filed 7–29–14; 8:45 am]
BILLING CODE 7710–12–P
POSTAL SERVICE
Product Change—Priority Mail
Negotiated Service Agreement
ACTION:
Postal ServiceTM.
Notice.
The Postal Service gives
notice of filing a request with the Postal
Regulatory Commission to add a
domestic shipping services contract to
the list of Negotiated Service
Agreements in the Mail Classification
Schedule’s Competitive Products List.
SUMMARY:
DATES:
Effective date: July 30, 2014.
FOR FURTHER INFORMATION CONTACT:
Elizabeth A. Reed, 202–268–3179.
The
United States Postal Service® hereby
gives notice that, pursuant to 39 U.S.C.
3642 and 3632(b)(3), on July 23, 2014,
it filed with the Postal Regulatory
Commission a Request of the United
States Postal Service to Add Priority
Mail Contract 86 to Competitive Product
List. Documents are available at
www.prc.gov, Docket Nos. MC2014–35,
CP2014–61.
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SUPPLEMENTARY INFORMATION:
Stanley F. Mires,
Attorney, Federal Requirements.
[FR Doc. 2014–17894 Filed 7–29–14; 8:45 am]
BILLING CODE 7710–12–P
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Steben Alternative Investment Funds
and Steben & Company, Inc.; Notice of
Application
July 24, 2014.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application under
section 6(c) of the Investment Company
Act of 1940 (‘‘Act’’) for an exemption
from section 15(a) of the Act and rule
18f–2 under the Act, as well as from
certain disclosure requirements.
AGENCY:
FOR FURTHER INFORMATION CONTACT:
AGENCY:
[Investment Company Act Release No.
31186; File No. 812–14314]
Applicants
request an order that would permit them
to enter into and materially amend
subadvisory agreements with WhollyOwned Subadvisers (as defined below)
and non-affiliated subadvisers without
shareholder approval and would grant
relief from certain disclosure
requirements.
APPLICANTS: Steben Alternative
Investment Funds (‘‘Trust’’) and Steben
& Company, Inc. (‘‘Adviser’’).
FILING DATES: The application was filed
on May 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 August 18, 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, 9711 Washingtonian
Boulevard, Suite 400, Gaithersburg, MD
20878.
FOR FURTHER INFORMATION CONTACT: KayMario Vobis, Senior Counsel, at (202)
551–6728, or Mary Kay Frech, Branch
Chief, at (202) 551–6821 (Division of
Investment Management, Chief
Counsel’s Office).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
SUMMARY OF APPLICATION:
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44221
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 is organized as a
Delaware statutory trust and is
registered under the Act as an open-end
management investment company. The
Trust currently offers one series of
shares (the ‘‘Series’’), Steben Managed
Futures Strategy Fund. The Series
commenced operations on April 1,
2014. The Adviser, a corporation
organized under the laws of the state of
Maryland, is registered as an investment
adviser under the Investment Advisers
Act of 1940 (‘‘Advisers Act’’).
2. Applicants request an order to
permit the Adviser, subject to the
approval of the board of trustees of the
Trust (‘‘Board’’), including a majority of
the members of the Board who are not
‘‘interested persons,’’ as defined in
section 2(a)(19) of the Act, of the Series
or the Adviser (‘‘Independent Board
Members’’), to, without obtaining
shareholder approval: (i) Select
Subadvisers to manage all or a portion
of the assets of a Series and enter into
Sub-Advisory Agreements (as defined
below) with the Subadvisers,1 and (ii)
materially amend Sub-Advisory
Agreements with the Subadvisers.2
Applicants request that the relief apply
to the named applicants, as well as to
any future Series and any other existing
or future registered open-end
management investment company or
series thereof that is advised by the
1 A ‘‘Subadviser’’ is (1) an indirect or direct
‘‘wholly-owned subsidiary’’ (as such term is
defined in the Act) of the Adviser for the Series, or
(2) a sister company of the Adviser for the Series
that is an indirect or direct ‘‘wholly-owned
subsidiary’’ (as such term is defined in the Act) of
the same company that, indirectly or directly,
wholly owns the Adviser (each of (1) and (2) a
‘‘Wholly-Owned Subadviser’’ and collectively, the
‘‘Wholly-Owned Subadvisers’’), or (3) an
investment subadviser for the Series that is not an
‘‘affiliated person’’ (as such term is defined in
section 2(a)(3) of the Act) of the Series or the
Adviser, except to the extent that an affiliation
arises solely because the subadviser serves as a
subadviser to the Series (each a ‘‘Non-Affiliated
Subadviser’’ and collectively, the ‘‘Non-Affiliated
Subadvisers’’). The Subadvisers will be registered
with the Commission under the Advisers Act or
exempt from such registration.
2 Shareholder approval will continue to be
required for any other subadviser changes and
material amendments to an existing Sub-Advisory
Agreement with any subadviser other than a NonAffiliated Subadviser or a Wholly-Owned
Subadviser, in each case (all such changes requiring
shareholder approval referred to herein as
‘‘Ineligible Subadviser Changes’’) except as
otherwise permitted by applicable law or by rule.
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Adviser or its successors, uses the
multi-manager structure described in
the application, and complies with the
terms and conditions of the application
(‘‘Subadvised Series’’).3
3. The requested relief will not extend
to any subadviser, other than a WhollyOwned Subadviser, who is an affiliated
person, as defined in section 2(a)(3) of
the Act, of the Subadvised Series or of
the Adviser, other than by reason of
serving as a subadviser to one or more
of the Subadvised Series (‘‘Affiliated
Subadviser’’).
4. The Adviser serves as the
investment adviser to the Series
pursuant to an investment advisory
agreement with the Trust (‘‘Investment
Advisory Agreement’). The Investment
Advisory Agreement for the Series has
been approved by the board of trustees
of the Trust (‘‘Board’’),4 including a
majority of the Independent Board
Members, and by the shareholders of the
Series in the manner required by
sections 15(a) and 15(c) of the Act and
rule 18f–2 thereunder. The terms of the
Investment Advisory Agreement comply
with section 15(a) of the Act.
5. Pursuant to the terms of the
Investment Advisory Agreement, the
Adviser, subject to the supervision of
the Board, provides continuous
investment advisory services to the
Series. The Adviser will periodically
review the Series’ investment policies
and strategies, and based on its need
may recommend changes to the
investment policies and strategies of the
Series for consideration by the Board.
For its services to the Series under the
Investment Advisory Agreement, the
Adviser receives an investment
management fee from the Series. The
Investment Advisory Agreement
provides that the Adviser may, subject
to the approval of the Board, including
a majority of the Independent Board
Members and the initial shareholder of
the Subadvised Series, delegate
portfolio management responsibilities of
all or a portion of the assets of a
Subadvised Series to one or more
Subadvisers.
3 For the purposes of the requested order,
‘‘successor’’ is limited to an entity resulting from a
reorganization into another jurisdiction or a change
in the type of business organization. All registered
open-end investment companies that currently
intend to rely on the requested order are named as
applicants. Any entity that relies on the requested
order will do so only in accordance with the terms
and conditions contained in the application. If the
name of any Subadvised Series contains the name
of a Subadviser, the name of the Adviser to the
Subadvised Series, or a trademark or trade name
that is owned by or publicly used to identify the
Adviser, will precede the name of that Subadviser.
4 The term ‘‘Board’’ also includes the board of
trustees or directors of a future Subadvised Series.
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6. Pursuant to the Investment
Advisory Agreement, the Adviser has
overall responsibility for the
management and investment of the
assets of each Subadvised Series. These
responsibilities include, for example,
recommending the removal or
replacement of Subadvisers, and
determining the portion of that
Subadvised Series’ assets to be managed
by any given Subadviser and
reallocating those assets as necessary
from time to time.
7. The Adviser may enter into
investment sub-advisory agreements
with various Subadvisers on behalf of
the Subadvised Series (‘‘Sub-Advisory
Agreements’’) to provide investment
management services to the Subadvised
Series. The terms of each Sub-Advisory
Agreement comply fully with the
requirements of section 15(a) of the Act
and have been approved by the Board,
including a majority of the Independent
Board Members and the initial
shareholder of the Subadvised Series, in
accordance with sections 15(a) and 15(c)
of the Act and rule 18f–2 thereunder.
The Subadvisers, subject to the
supervision of the Adviser and oversight
of the Board, will determine the
securities and other investments to be
purchased, sold or entered into by a
Subadvised Series and will place orders
with brokers or dealers that they select.
The Adviser will compensate each
Subadviser out of the fee paid to the
Adviser under the Investment Advisory
Agreement.
8. If the requested order is granted
and if new Subadvisers are hired, the
Subadvised Series will inform
shareholders of the hiring of a new
Subadviser pursuant to the following
procedures (‘‘Modified Notice and
Access Procedures’’): (a) Within 90 days
after a new Subadviser is hired for any
Subadvised Series, that Subadvised
Series will send its shareholders either
a Multi-manager Notice or a Multimanager Notice and Multi-manager
Information Statement; 5 and (b) the
5 A ‘‘Multi-manager Notice’’ will be modeled on
a Notice of Internet Availability as defined in rule
14a–16 under the Securities Exchange Act of 1934
(‘‘Exchange Act’’), and specifically will, among
other things: (a) Summarize the relevant
information regarding the new Subadviser (except
as modified to permit Aggregate Fee Disclosure (as
defined below); (b) inform shareholders that the
Multi-manager Information Statement is available
on a Web Site; (c) provide the website address; (d)
state the time period during which the Multimanager Information Statement will remain
available on that website; (e) provide instructions
for accessing and printing the Multi-manager
Information Statement; and (f) instruct the
shareholder that a paper or email copy of the Multimanager Information Statement may be obtained,
without charge, by contacting the Subadvised
Series. A ‘‘Multi-manager Information Statement’’
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Subadvised Series will make the Multimanager Information Statement
available on the Web site identified in
the Multi-manager Notice no later than
when the Multi-manager Notice (or
Multi-manager Notice and Multimanager Information Statement) is first
sent to shareholders, and will maintain
it on that Web site for at least 90 days.
In the circumstances described in the
application, a proxy solicitation to
approve the appointment of new
Subadvisers provides no more
meaningful information to shareholders
than the proposed Multi-manager
Information Statement. Applicants state
that each Board would comply with the
requirements of sections 15(a) and 15(c)
of the Act before entering into or
amending Sub-Advisory Agreements.
9. Applicants also request an order
exempting the Subadvised Series from
certain disclosure obligations that may
require each Subadvised Series to
disclose fees paid by the Adviser to each
Subadviser. Applicants seek relief to
permit each Subadvised Series to
disclose (as a dollar amount and a
percentage of the Subadvised Series’ net
assets): (a) The aggregate fees paid to the
Adviser and any Wholly-Owned
Subadvisers; (b) the aggregate fees paid
to Non-Affiliated Subadvisers; and (c)
the fee paid to each Affiliated
Subadviser (collectively, the ‘‘Aggregate
Fee Disclosure’’). An exemption is
requested to permit the Series to include
only the Aggregate Fee Disclosure. All
other items required by Sections 6–
07(2)(a), (b), and (c) of Regulation S–X
will be disclosed.
Applicants’ Legal Analysis
1. Section 15(a) of the Act states, in
part, that it is unlawful for any person
to act as an investment adviser to a
registered investment company ‘‘except
pursuant to a written contract, which
contract, whether with such registered
company or with an investment adviser
of such registered company, has been
approved by the vote of a majority of the
outstanding voting securities of such
registered company.’’ Rule 18f–2 under
the Act provides that each series or class
of stock in a series investment company
affected by a matter must approve that
matter if the Act requires shareholder
approval.
2. Form N–1A is the registration
statement used by open-end investment
companies. Item 19(a)(3) of Form N–1A
will meet the requirements of Regulation 14C,
Schedule 14C and Item 22 of Schedule 14A under
the Exchange Act for an information statement,
except as modified by the order to permit Aggregate
Fee Disclosure. Multi-manager Information
Statements will be filed with the Commission via
the EDGAR system.
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Federal Register / Vol. 79, No. 146 / Wednesday, July 30, 2014 / Notices
requires a registered investment
company to disclose in its statement of
additional information the method of
computing the ‘‘advisory fee payable’’
by the investment company, including
the total dollar amounts that the
investment company ‘‘paid to the
adviser (aggregated with amounts paid
to affiliated advisers, if any), and any
advisers who are not affiliated persons
of the adviser, under the investment
advisory contract for the last three fiscal
years.’’
3. Rule 20a–1 under the Act requires
proxies solicited with respect to a
registered investment company to
comply with Schedule 14A under the
Exchange Act. Items 22(c)(1)(ii),
22(c)(1)(iii), 22(c)(8) and 22(c)(9) of
Schedule 14A, taken together, require a
proxy statement for a shareholder
meeting at which the advisory contract
will be voted upon to include the ‘‘rate
of compensation of the investment
adviser,’’ the ‘‘aggregate amount of the
investment adviser’s fee,’’ a description
of the ‘‘terms of the contract to be acted
upon,’’ and, if a change in the advisory
fee is proposed, the existing and
proposed fees and the difference
between the two fees.
4. Regulation S–X sets forth the
requirements for financial statements
required to be included as part of a
registered investment company’s
registration statement and shareholder
reports filed with the Commission.
Sections 6–07(2)(a), (b), and (c) of
Regulation S–X require a registered
investment company to include in its
financial statement information about
the investment advisory fees.
5. Section 6(c) of the Act provides that
the Commission by order upon
application may conditionally or
unconditionally exempt any person,
security, or transaction or any class or
classes of persons, securities, or
transactions from any provisions of the
Act, or from any rule thereunder, if 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. Applicants
state that their requested relief meets
this standard for the reasons discussed
below.
6. Applicants assert that the
shareholders expect the Adviser, subject
to the review and approval of the Board,
to select the Subadvisers who are in the
best position to achieve the Subadvised
Series’ investment objective. Applicants
assert that, from the perspective of the
shareholder, the role of the Subadvisers
is substantially equivalent to the role of
the individual portfolio managers
employed by an investment adviser to a
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traditional investment company.
Applicants believe that permitting the
Adviser to perform the duties for which
the shareholders of the Subadvised
Series are paying the Adviser—the
selection, supervision and evaluation of
the Subadvisers—without incurring
unnecessary delays or expenses is
appropriate in the interest of the
Subadvised Series’ shareholders and
will allow such Subadvised Series to
operate more efficiently. Applicants
state that the Investment Advisory
Agreement will continue to be fully
subject to section 15(a) of, and rule 18f–
2 under, the Act and approved by the
Board, including a majority of the
Independent Board Members, in the
manner required by sections 15(a) and
15(c) of the Act. Applicants are not
seeking an exemption with respect to
the Investment Advisory Agreement.
7. Applicants assert that disclosure of
the individual fees that the Adviser
would pay to the Subadvisers of
Subadvised Series that operate under
the multi-manager structure described
in the application would not serve any
meaningful purpose. Applicants
contend that the primary reasons for
requiring disclosure of individual fees
paid to Subadvisers are to inform
shareholders of expenses to be charged
by a particular Subadvised Series and to
enable shareholders to compare the fees
to those of other comparable investment
companies. Applicants believe that the
requested relief satisfies these objectives
because the advisory fee paid to the
Adviser will be fully disclosed and
therefore, shareholders will know what
the Subadvised Series’ fees and
expenses are and will be able to
compare the advisory fees a Subadvised
Series is charged to those of other
investment companies. Applicants
assert that the requested disclosure
relief would benefit shareholders of the
Subadvised Series because it would
improve the Adviser’s ability to
negotiate the fees paid to Subadvisers.
Applicants state that the Adviser may be
able to negotiate rates that are below a
Subadviser’s ‘‘posted’’ amounts if the
Adviser is not required to disclose the
Subadvisers’ fees to the public.
Applicants submit that the relief
requested to use Aggregate Fee
Disclosure will also encourage
Subadvisers to negotiate lower subadvisory fees with the Adviser if the
lower fees are not required to be made
public.
8. For the reasons discussed above,
applicants submit that the requested
relief meets the standards for relief
under section 6(c) of the Act. Applicants
state that the operation of the
Subadvised Series in the manner
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44223
described in the application must be
approved by shareholders of a
Subadvised Series before that
Subadvised Series may rely on the
requested relief. In addition, applicants
state that the proposed conditions to the
requested relief are designed to address
any potential conflicts of interest,
including any posed by the use of
Wholly-Owned Subadvisers, and
provide that shareholders are informed
when new Subadvisers are hired.
Applicants assert that conditions 6, 7,
10 and 11 are designed to provide the
Board with sufficient independence and
the resources and information it needs
to monitor and address any conflicts of
interest with affiliated persons of the
Adviser, including Wholly-Owned
Subadvisers. Applicants state that,
accordingly, they believe the requested
relief 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.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
1. Before a Subadvised Series may
rely on the order requested in the
application, the operation of the
Subadvised Series in the manner
described in the application, including
the hiring of Wholly-Owned
Subadvisers, will be, or has been,
approved by a majority of the
Subadvised Series’ outstanding voting
securities as defined in the Act, or, in
the case of a new Subadvised Series
whose public shareholders purchase
shares on the basis of a prospectus
containing the disclosure contemplated
by condition 2 below, by the sole initial
shareholder before offering the
Subadvised Series’ shares to the public.
2. The prospectus for each
Subadvised Series will disclose the
existence, substance, and effect of any
order granted pursuant to the
application. Each Subadvised Series
will hold itself out to the public as
employing the multi-manager structure
described in the application. Each
prospectus will prominently disclose
that the Adviser has the ultimate
responsibility, subject to oversight by
the Board, to oversee the Subadvisers
and recommend their hiring,
termination and replacement.
3. The Adviser will provide general
management services to a Subadvised
Series, including overall supervisory
responsibility for the general
management and investment of the
Subadvised Series’ assets. Subject to
review and approval of the Board, the
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Adviser will (a) set a Subadvised Series’
overall investment strategies, (b)
evaluate, select, and recommend
Subadvisers to manage all or a portion
of a Subadvised Series’ assets, and (c)
implement procedures reasonably
designed to ensure that Subadvisers
comply with a Subadvised Series’
investment objective, policies and
restrictions. Subject to review by the
Board, the Adviser will (a) when
appropriate, allocate and reallocate a
Subadvised Series’ assets among
multiple Subadvisers; and (b) monitor
and evaluate the performance of
Subadvisers.
4. A Subadvised Series will not make
any Ineligible Subadviser Changes
without such agreement, including the
compensation to be paid thereunder,
being approved by the shareholders of
the applicable Subadvised Series.
5. Subadvised Series will inform
shareholders of the hiring of a new
Subadviser within 90 days after the
hiring of the new Subadviser pursuant
to the Modified Notice and Access
Procedures.
6. At all times, at least a majority of
the Board will be Independent Board
Members, and the selection and
nomination of new or additional
Independent Board Members will be
placed within the discretion of the thenexisting Independent Board Members.
7. Independent Legal Counsel, as
defined in rule 0–1(a)(6) under the Act,
will be engaged to represent the
Independent Board Members. The
selection of such counsel will be within
the discretion of the then-existing
Independent Board Members.
8. The Adviser will provide the
Board, no less frequently than quarterly,
with information about the profitability
of the Adviser on a per Subadvised
Series basis. The information will reflect
the impact on profitability of the hiring
or termination of any Subadviser during
the applicable quarter.
9. Whenever a Subadviser is hired or
terminated, the Adviser will provide the
Board with information showing the
expected impact on the profitability of
the Adviser.
10. Whenever a Subadviser change is
proposed for a Subadvised Series with
an Affiliated Subadviser or a WhollyOwned Subadviser, the Board,
including a majority of the Independent
Board Members, will make a separate
finding, reflected in the Board minutes,
that such change is in the best interests
of the Subadvised Series and its
shareholders, and does not involve a
conflict of interest from which the
Adviser or the Affiliated Subadviser or
Wholly-Owned Subadviser derives an
inappropriate advantage.
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11. No Board member or officer of a
Subadvised Series, or partner, director,
manager, or officer of the Adviser, will
own directly or indirectly (other than
through a pooled investment vehicle
that is not controlled by such person),
any interest in a Subadviser, except for
(i) ownership of interests in the Adviser
or any entity, other than a WhollyOwned Subadviser, that controls, is
controlled by, or is under common
control with the Adviser, or (ii)
ownership of less than 1% of the
outstanding securities of any class of
equity or debt of a publicly traded
company that is either a Subadviser or
an entity that controls, is controlled by,
or is under common control with a
Subadviser.
12. Each Subadvised Series will
disclose the Aggregate Fee Disclosure in
its registration statement.
13. In the event the Commission
adopts a rule under the Act providing
substantially similar relief to that
requested in the application, the
requested order will expire on the
effective date of that rule.
14. Any new Sub-Advisory
Agreement or any amendment to a
Subadvised Series’ existing Investment
Advisory Agreement or Sub-Advisory
Agreement that directly or indirectly
results in an increase in the aggregate
advisory fee rate payable by the
Subadvised Series will be submitted to
the Subadvised Series’ shareholders for
approval.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–17883 Filed 7–29–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–72666; File No. SR–
NYSEArca–2013–122]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Order Granting Approval of
Proposed Rule Change as Modified by
Amendment No. 2 Thereto Relating to
the Use of Derivative Instruments by
PIMCO Total Return Exchange Traded
Fund
July 24, 2014.
I. Introduction
On November 6, 2013, NYSE Arca,
Inc. (‘‘Exchange’’ or ‘‘NYSE Arca’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
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Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to amend the description of the
means of achieving the investment
objective applicable to the PIMCO Total
Return Exchange Traded Fund (‘‘Fund’’)
relating to its use of derivative
instruments. The proposed rule change
was published for comment in the
Federal Register on November 26,
2013.3 On January 9, 2014, the
Commission designated a longer period
within which to approve the proposed
rule change, disapprove the proposed
rule change, or institute proceedings to
determine whether to disapprove the
proposed rule change.4 On February 24,
2014, the Commission instituted
proceedings to determine whether to
approve or disapprove the proposed
rule change.5 On April 15, 2014, the
Exchange submitted Amendments No. 1
and 2 to the proposed rule change.6 On
May 21, 2014, pursuant to Section
19(b)(2) of the Act,7 the Commission
designated a longer period within which
to issue an order approving or
disapproving the proposed rule change.8
The Commission received no comments
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 70905
(November 20, 2013), 78 FR 70610 (‘‘Notice’’).
4 See Securities Exchange Act Release No. 71271
(January 9, 2014), 79 FR 2736 (January 15, 2014).
The Commission determined that it was appropriate
to designate a longer period within which to take
action on the proposed rule change so that it has
sufficient time to consider the proposed rule
change. Accordingly, the Commission designated
February 24, 2014 as the date by which it should
approve, disapprove, or institute proceedings to
determine whether to disapprove the proposed rule
change.
5 See Securities Exchange Act Release No. 71606,
79 FR 11486 (February 28, 2014).
6 The Exchange submitted and subsequently
withdrew Amendment No. 1 to the proposed rule
change. In Amendment No. 2, the Exchange
provided additional details describing how the
contents of the portfolio composition of the Fund
would be disclosed on a daily basis. Specifically,
the Fund will disclose on the Fund’s Web site the
following information regarding each portfolio
holding, as applicable to the type of holding: ticker
symbol, CUSIP number or other identifier, if any;
a description of the holding (including the type of
holding, such as the type of swap); the identity of
the security, commodity, index or other asset or
instrument underlying the holding, if any; for
options, the option strike price; quantity held (as
measured by, for example, par value, notional value
or number of shares, contracts or units); maturity
date, if any; coupon rate, if any; effective date, if
any; market value of the holding; and the
percentage weighting of the holding in the Fund’s
portfolio. It also confirms that all other facts and
representations made in the Prior Release remain
unchanged. See infra, note 9. Amendment No. 2
provides clarification to the proposed rule change,
and because it does not materially affect the
substance of the proposed rule change, Amendment
No. 2 does not require notice and comment.
7 15 U.S.C. 78s(b)(1).
8 See Securities Exchange Act Release No. 72216,
79 FR 30680 (May 28, 2014).
2 17
E:\FR\FM\30JYN1.SGM
30JYN1
Agencies
[Federal Register Volume 79, Number 146 (Wednesday, July 30, 2014)]
[Notices]
[Pages 44221-44224]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-17883]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 31186; File No. 812-14314]
Steben Alternative Investment Funds and Steben & Company, Inc.;
Notice of Application
July 24, 2014.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application under section 6(c) of the Investment
Company Act of 1940 (``Act'') for an exemption from section 15(a) of
the Act and rule 18f-2 under the Act, as well as from certain
disclosure requirements.
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Summary of Application: Applicants request an order that would permit
them to enter into and materially amend subadvisory agreements with
Wholly-Owned Subadvisers (as defined below) and non-affiliated
subadvisers without shareholder approval and would grant relief from
certain disclosure requirements.
Applicants: Steben Alternative Investment Funds (``Trust'') and Steben
& Company, Inc. (``Adviser'').
Filing Dates: The application was filed on May 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 August 18, 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, 9711 Washingtonian
Boulevard, Suite 400, Gaithersburg, MD 20878.
FOR FURTHER INFORMATION CONTACT: Kay-Mario Vobis, Senior Counsel, at
(202) 551-6728, or Mary Kay Frech, 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 is organized as a Delaware statutory trust and is
registered under the Act as an open-end management investment company.
The Trust currently offers one series of shares (the ``Series''),
Steben Managed Futures Strategy Fund. The Series commenced operations
on April 1, 2014. The Adviser, a corporation organized under the laws
of the state of Maryland, is registered as an investment adviser under
the Investment Advisers Act of 1940 (``Advisers Act'').
2. Applicants request an order to permit the Adviser, subject to
the approval of the board of trustees of the Trust (``Board''),
including a majority of the members of the Board who are not
``interested persons,'' as defined in section 2(a)(19) of the Act, of
the Series or the Adviser (``Independent Board Members''), to, without
obtaining shareholder approval: (i) Select Subadvisers to manage all or
a portion of the assets of a Series and enter into Sub-Advisory
Agreements (as defined below) with the Subadvisers,\1\ and (ii)
materially amend Sub-Advisory Agreements with the Subadvisers.\2\
Applicants request that the relief apply to the named applicants, as
well as to any future Series and any other existing or future
registered open-end management investment company or series thereof
that is advised by the
[[Page 44222]]
Adviser or its successors, uses the multi-manager structure described
in the application, and complies with the terms and conditions of the
application (``Subadvised Series'').\3\
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\1\ A ``Subadviser'' is (1) an indirect or direct ``wholly-owned
subsidiary'' (as such term is defined in the Act) of the Adviser for
the Series, or (2) a sister company of the Adviser for the Series
that is an indirect or direct ``wholly-owned subsidiary'' (as such
term is defined in the Act) of the same company that, indirectly or
directly, wholly owns the Adviser (each of (1) and (2) a ``Wholly-
Owned Subadviser'' and collectively, the ``Wholly-Owned
Subadvisers''), or (3) an investment subadviser for the Series that
is not an ``affiliated person'' (as such term is defined in section
2(a)(3) of the Act) of the Series or the Adviser, except to the
extent that an affiliation arises solely because the subadviser
serves as a subadviser to the Series (each a ``Non-Affiliated
Subadviser'' and collectively, the ``Non-Affiliated Subadvisers'').
The Subadvisers will be registered with the Commission under the
Advisers Act or exempt from such registration.
\2\ Shareholder approval will continue to be required for any
other subadviser changes and material amendments to an existing Sub-
Advisory Agreement with any subadviser other than a Non-Affiliated
Subadviser or a Wholly-Owned Subadviser, in each case (all such
changes requiring shareholder approval referred to herein as
``Ineligible Subadviser Changes'') except as otherwise permitted by
applicable law or by rule.
\3\ For the purposes of the requested order, ``successor'' is
limited to an entity resulting from a reorganization into another
jurisdiction or a change in the type of business organization. All
registered open-end investment companies that currently intend to
rely on the requested order are named as applicants. Any entity that
relies on the requested order will do so only in accordance with the
terms and conditions contained in the application. If the name of
any Subadvised Series contains the name of a Subadviser, the name of
the Adviser to the Subadvised Series, or a trademark or trade name
that is owned by or publicly used to identify the Adviser, will
precede the name of that Subadviser.
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3. The requested relief will not extend to any subadviser, other
than a Wholly-Owned Subadviser, who is an affiliated person, as defined
in section 2(a)(3) of the Act, of the Subadvised Series or of the
Adviser, other than by reason of serving as a subadviser to one or more
of the Subadvised Series (``Affiliated Subadviser'').
4. The Adviser serves as the investment adviser to the Series
pursuant to an investment advisory agreement with the Trust
(``Investment Advisory Agreement'). The Investment Advisory Agreement
for the Series has been approved by the board of trustees of the Trust
(``Board''),\4\ including a majority of the Independent Board Members,
and by the shareholders of the Series in the manner required by
sections 15(a) and 15(c) of the Act and rule 18f-2 thereunder. The
terms of the Investment Advisory Agreement comply with section 15(a) of
the Act.
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\4\ The term ``Board'' also includes the board of trustees or
directors of a future Subadvised Series.
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5. Pursuant to the terms of the Investment Advisory Agreement, the
Adviser, subject to the supervision of the Board, provides continuous
investment advisory services to the Series. The Adviser will
periodically review the Series' investment policies and strategies, and
based on its need may recommend changes to the investment policies and
strategies of the Series for consideration by the Board. For its
services to the Series under the Investment Advisory Agreement, the
Adviser receives an investment management fee from the Series. The
Investment Advisory Agreement provides that the Adviser may, subject to
the approval of the Board, including a majority of the Independent
Board Members and the initial shareholder of the Subadvised Series,
delegate portfolio management responsibilities of all or a portion of
the assets of a Subadvised Series to one or more Subadvisers.
6. Pursuant to the Investment Advisory Agreement, the Adviser has
overall responsibility for the management and investment of the assets
of each Subadvised Series. These responsibilities include, for example,
recommending the removal or replacement of Subadvisers, and determining
the portion of that Subadvised Series' assets to be managed by any
given Subadviser and reallocating those assets as necessary from time
to time.
7. The Adviser may enter into investment sub-advisory agreements
with various Subadvisers on behalf of the Subadvised Series (``Sub-
Advisory Agreements'') to provide investment management services to the
Subadvised Series. The terms of each Sub-Advisory Agreement comply
fully with the requirements of section 15(a) of the Act and have been
approved by the Board, including a majority of the Independent Board
Members and the initial shareholder of the Subadvised Series, in
accordance with sections 15(a) and 15(c) of the Act and rule 18f-2
thereunder. The Subadvisers, subject to the supervision of the Adviser
and oversight of the Board, will determine the securities and other
investments to be purchased, sold or entered into by a Subadvised
Series and will place orders with brokers or dealers that they select.
The Adviser will compensate each Subadviser out of the fee paid to the
Adviser under the Investment Advisory Agreement.
8. If the requested order is granted and if new Subadvisers are
hired, the Subadvised Series will inform shareholders of the hiring of
a new Subadviser pursuant to the following procedures (``Modified
Notice and Access Procedures''): (a) Within 90 days after a new
Subadviser is hired for any Subadvised Series, that Subadvised Series
will send its shareholders either a Multi-manager Notice or a Multi-
manager Notice and Multi-manager Information Statement; \5\ and (b) the
Subadvised Series will make the Multi-manager Information Statement
available on the Web site identified in the Multi-manager Notice no
later than when the Multi-manager Notice (or Multi-manager Notice and
Multi-manager Information Statement) is first sent to shareholders, and
will maintain it on that Web site for at least 90 days. In the
circumstances described in the application, a proxy solicitation to
approve the appointment of new Subadvisers provides no more meaningful
information to shareholders than the proposed Multi-manager Information
Statement. Applicants state that each Board would comply with the
requirements of sections 15(a) and 15(c) of the Act before entering
into or amending Sub-Advisory Agreements.
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\5\ A ``Multi-manager Notice'' will be modeled on a Notice of
Internet Availability as defined in rule 14a-16 under the Securities
Exchange Act of 1934 (``Exchange Act''), and specifically will,
among other things: (a) Summarize the relevant information regarding
the new Subadviser (except as modified to permit Aggregate Fee
Disclosure (as defined below); (b) inform shareholders that the
Multi-manager Information Statement is available on a Web Site; (c)
provide the website address; (d) state the time period during which
the Multi-manager Information Statement will remain available on
that website; (e) provide instructions for accessing and printing
the Multi-manager Information Statement; and (f) instruct the
shareholder that a paper or email copy of the Multi-manager
Information Statement may be obtained, without charge, by contacting
the Subadvised Series. A ``Multi-manager Information Statement''
will meet the requirements of Regulation 14C, Schedule 14C and Item
22 of Schedule 14A under the Exchange Act for an information
statement, except as modified by the order to permit Aggregate Fee
Disclosure. Multi-manager Information Statements will be filed with
the Commission via the EDGAR system.
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9. Applicants also request an order exempting the Subadvised Series
from certain disclosure obligations that may require each Subadvised
Series to disclose fees paid by the Adviser to each Subadviser.
Applicants seek relief to permit each Subadvised Series to disclose (as
a dollar amount and a percentage of the Subadvised Series' net assets):
(a) The aggregate fees paid to the Adviser and any Wholly-Owned
Subadvisers; (b) the aggregate fees paid to Non-Affiliated Subadvisers;
and (c) the fee paid to each Affiliated Subadviser (collectively, the
``Aggregate Fee Disclosure''). An exemption is requested to permit the
Series to include only the Aggregate Fee Disclosure. All other items
required by Sections 6-07(2)(a), (b), and (c) of Regulation S-X will be
disclosed.
Applicants' Legal Analysis
1. Section 15(a) of the Act states, in part, that it is unlawful
for any person to act as an investment adviser to a registered
investment company ``except pursuant to a written contract, which
contract, whether with such registered company or with an investment
adviser of such registered company, has been approved by the vote of a
majority of the outstanding voting securities of such registered
company.'' Rule 18f-2 under the Act provides that each series or class
of stock in a series investment company affected by a matter must
approve that matter if the Act requires shareholder approval.
2. Form N-1A is the registration statement used by open-end
investment companies. Item 19(a)(3) of Form N-1A
[[Page 44223]]
requires a registered investment company to disclose in its statement
of additional information the method of computing the ``advisory fee
payable'' by the investment company, including the total dollar amounts
that the investment company ``paid to the adviser (aggregated with
amounts paid to affiliated advisers, if any), and any advisers who are
not affiliated persons of the adviser, under the investment advisory
contract for the last three fiscal years.''
3. Rule 20a-1 under the Act requires proxies solicited with respect
to a registered investment company to comply with Schedule 14A under
the Exchange Act. Items 22(c)(1)(ii), 22(c)(1)(iii), 22(c)(8) and
22(c)(9) of Schedule 14A, taken together, require a proxy statement for
a shareholder meeting at which the advisory contract will be voted upon
to include the ``rate of compensation of the investment adviser,'' the
``aggregate amount of the investment adviser's fee,'' a description of
the ``terms of the contract to be acted upon,'' and, if a change in the
advisory fee is proposed, the existing and proposed fees and the
difference between the two fees.
4. Regulation S-X sets forth the requirements for financial
statements required to be included as part of a registered investment
company's registration statement and shareholder reports filed with the
Commission. Sections 6-07(2)(a), (b), and (c) of Regulation S-X require
a registered investment company to include in its financial statement
information about the investment advisory fees.
5. Section 6(c) of the Act provides that the Commission by order
upon application may conditionally or unconditionally exempt any
person, security, or transaction or any class or classes of persons,
securities, or transactions from any provisions of the Act, or from any
rule thereunder, if 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.
Applicants state that their requested relief meets this standard for
the reasons discussed below.
6. Applicants assert that the shareholders expect the Adviser,
subject to the review and approval of the Board, to select the
Subadvisers who are in the best position to achieve the Subadvised
Series' investment objective. Applicants assert that, from the
perspective of the shareholder, the role of the Subadvisers is
substantially equivalent to the role of the individual portfolio
managers employed by an investment adviser to a traditional investment
company. Applicants believe that permitting the Adviser to perform the
duties for which the shareholders of the Subadvised Series are paying
the Adviser--the selection, supervision and evaluation of the
Subadvisers--without incurring unnecessary delays or expenses is
appropriate in the interest of the Subadvised Series' shareholders and
will allow such Subadvised Series to operate more efficiently.
Applicants state that the Investment Advisory Agreement will continue
to be fully subject to section 15(a) of, and rule 18f-2 under, the Act
and approved by the Board, including a majority of the Independent
Board Members, in the manner required by sections 15(a) and 15(c) of
the Act. Applicants are not seeking an exemption with respect to the
Investment Advisory Agreement.
7. Applicants assert that disclosure of the individual fees that
the Adviser would pay to the Subadvisers of Subadvised Series that
operate under the multi-manager structure described in the application
would not serve any meaningful purpose. Applicants contend that the
primary reasons for requiring disclosure of individual fees paid to
Subadvisers are to inform shareholders of expenses to be charged by a
particular Subadvised Series and to enable shareholders to compare the
fees to those of other comparable investment companies. Applicants
believe that the requested relief satisfies these objectives because
the advisory fee paid to the Adviser will be fully disclosed and
therefore, shareholders will know what the Subadvised Series' fees and
expenses are and will be able to compare the advisory fees a Subadvised
Series is charged to those of other investment companies. Applicants
assert that the requested disclosure relief would benefit shareholders
of the Subadvised Series because it would improve the Adviser's ability
to negotiate the fees paid to Subadvisers. Applicants state that the
Adviser may be able to negotiate rates that are below a Subadviser's
``posted'' amounts if the Adviser is not required to disclose the
Subadvisers' fees to the public. Applicants submit that the relief
requested to use Aggregate Fee Disclosure will also encourage
Subadvisers to negotiate lower sub-advisory fees with the Adviser if
the lower fees are not required to be made public.
8. For the reasons discussed above, applicants submit that the
requested relief meets the standards for relief under section 6(c) of
the Act. Applicants state that the operation of the Subadvised Series
in the manner described in the application must be approved by
shareholders of a Subadvised Series before that Subadvised Series may
rely on the requested relief. In addition, applicants state that the
proposed conditions to the requested relief are designed to address any
potential conflicts of interest, including any posed by the use of
Wholly-Owned Subadvisers, and provide that shareholders are informed
when new Subadvisers are hired. Applicants assert that conditions 6, 7,
10 and 11 are designed to provide the Board with sufficient
independence and the resources and information it needs to monitor and
address any conflicts of interest with affiliated persons of the
Adviser, including Wholly-Owned Subadvisers. Applicants state that,
accordingly, they believe the requested relief 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.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
1. Before a Subadvised Series may rely on the order requested in
the application, the operation of the Subadvised Series in the manner
described in the application, including the hiring of Wholly-Owned
Subadvisers, will be, or has been, approved by a majority of the
Subadvised Series' outstanding voting securities as defined in the Act,
or, in the case of a new Subadvised Series whose public shareholders
purchase shares on the basis of a prospectus containing the disclosure
contemplated by condition 2 below, by the sole initial shareholder
before offering the Subadvised Series' shares to the public.
2. The prospectus for each Subadvised Series will disclose the
existence, substance, and effect of any order granted pursuant to the
application. Each Subadvised Series will hold itself out to the public
as employing the multi-manager structure described in the application.
Each prospectus will prominently disclose that the Adviser has the
ultimate responsibility, subject to oversight by the Board, to oversee
the Subadvisers and recommend their hiring, termination and
replacement.
3. The Adviser will provide general management services to a
Subadvised Series, including overall supervisory responsibility for the
general management and investment of the Subadvised Series' assets.
Subject to review and approval of the Board, the
[[Page 44224]]
Adviser will (a) set a Subadvised Series' overall investment
strategies, (b) evaluate, select, and recommend Subadvisers to manage
all or a portion of a Subadvised Series' assets, and (c) implement
procedures reasonably designed to ensure that Subadvisers comply with a
Subadvised Series' investment objective, policies and restrictions.
Subject to review by the Board, the Adviser will (a) when appropriate,
allocate and reallocate a Subadvised Series' assets among multiple
Subadvisers; and (b) monitor and evaluate the performance of
Subadvisers.
4. A Subadvised Series will not make any Ineligible Subadviser
Changes without such agreement, including the compensation to be paid
thereunder, being approved by the shareholders of the applicable
Subadvised Series.
5. Subadvised Series will inform shareholders of the hiring of a
new Subadviser within 90 days after the hiring of the new Subadviser
pursuant to the Modified Notice and Access Procedures.
6. At all times, at least a majority of the Board will be
Independent Board Members, and the selection and nomination of new or
additional Independent Board Members will be placed within the
discretion of the then-existing Independent Board Members.
7. Independent Legal Counsel, as defined in rule 0-1(a)(6) under
the Act, will be engaged to represent the Independent Board Members.
The selection of such counsel will be within the discretion of the
then-existing Independent Board Members.
8. The Adviser will provide the Board, no less frequently than
quarterly, with information about the profitability of the Adviser on a
per Subadvised Series basis. The information will reflect the impact on
profitability of the hiring or termination of any Subadviser during the
applicable quarter.
9. Whenever a Subadviser is hired or terminated, the Adviser will
provide the Board with information showing the expected impact on the
profitability of the Adviser.
10. Whenever a Subadviser change is proposed for a Subadvised
Series with an Affiliated Subadviser or a Wholly-Owned Subadviser, the
Board, including a majority of the Independent Board Members, will make
a separate finding, reflected in the Board minutes, that such change is
in the best interests of the Subadvised Series and its shareholders,
and does not involve a conflict of interest from which the Adviser or
the Affiliated Subadviser or Wholly-Owned Subadviser derives an
inappropriate advantage.
11. No Board member or officer of a Subadvised Series, or partner,
director, manager, or officer of the Adviser, will own directly or
indirectly (other than through a pooled investment vehicle that is not
controlled by such person), any interest in a Subadviser, except for
(i) ownership of interests in the Adviser or any entity, other than a
Wholly-Owned Subadviser, that controls, is controlled by, or is under
common control with the Adviser, or (ii) ownership of less than 1% of
the outstanding securities of any class of equity or debt of a publicly
traded company that is either a Subadviser or an entity that controls,
is controlled by, or is under common control with a Subadviser.
12. Each Subadvised Series will disclose the Aggregate Fee
Disclosure in its registration statement.
13. In the event the Commission adopts a rule under the Act
providing substantially similar relief to that requested in the
application, the requested order will expire on the effective date of
that rule.
14. Any new Sub-Advisory Agreement or any amendment to a Subadvised
Series' existing Investment Advisory Agreement or Sub-Advisory
Agreement that directly or indirectly results in an increase in the
aggregate advisory fee rate payable by the Subadvised Series will be
submitted to the Subadvised Series' shareholders for approval.
For the Commission, by the Division of Investment Management,
under delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-17883 Filed 7-29-14; 8:45 am]
BILLING CODE 8011-01-P