TPG Specialty Lending, Inc., et al.; Notice of Application, 69890-69894 [2014-27696]
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asabaliauskas on DSK5VPTVN1PROD with NOTICES
69890
Federal Register / Vol. 79, No. 226 / Monday, November 24, 2014 / Notices
Notice is hereby given that pursuant
to the Paperwork Reduction Act of 1995
(‘‘PRA’’) (44 U.S.C. 3501 et seq.), the
Securities and Exchange Commission
(‘‘Commission’’) is soliciting comments
on the existing collection of information
provided for in Rule 17Ac2–1 (17 CFR
240.17Ac2–1) under the Securities
Exchange Act of 1934 (15 U.S.C. 78a et
seq.) (‘‘Exchange Act’’). The
Commission plans to submit this
existing collection of information to the
Office of Management and Budget
(‘‘OMB’’) for extension and approval.
Rule 17Ac2–1, pursuant to Section
17A(c) of the Exchange Act, generally
requires transfer agents to register with
their Appropriate Regulatory Agency
(‘‘ARA’’), whether the Commission, the
Comptroller of the Currency, the Board
of Governors of the Federal Reserve
System, the Federal Deposit Insurance
Corporation, or the Office of Thrift
Supervision, and to amend their
registrations if the information becomes
inaccurate, misleading, or incomplete.
Rule 17Ac2–1, pursuant to Section
17A(c) of the Exchange Act, generally
requires transfer agents for whom the
Commission is the transfer agent’s
Appropriate Regulatory Agency
(‘‘ARA’’), to file an application for
registration with the Commission on
Form TA–1 and to amend their
registrations under certain
circumstances.
Specifically, Rule 17Ac2–1 requires
transfer agents to file a Form TA–1
application for registration with the
Commission where the Commission is
their ARA. Such transfer agents must
also amend their Form TA–1 if the
existing information on their Form TA–
1 becomes inaccurate, misleading, or
incomplete within 60 days following the
date the information became inaccurate,
misleading or incomplete. Registration
filings on Form TA–1 and amendments
thereto must be filed with the
Commission electronically, absent an
exemption, on EDGAR pursuant to
Regulation S–T (17 CFR 232).
The Commission annually receives
approximately 174 filings on Form TA–
1 from transfer agents required to
register as such with the Commission.
Included in this figure are
approximately 164 amendments made
annually by transfer agents to their
Form TA–1 as required by Rule 17Ac2–
1(c) to address information that has
become inaccurate, misleading, or
incomplete and approximately 10 new
applications by transfer agents for
registration on Form TA–1 as required
by Rule 17Ac2–1(a). Based on past
submissions, the staff estimates that on
average approximately twelve hours are
required for initial completion of Form
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TA–1 and that on average one and onehalf hours are required for an
amendment to Form TA–1 by each such
firm. Thus, the subtotal burden for new
applications for registration filed on
Form TA–1 each year is 120 hours (12
hours times 10 filers) and the subtotal
burden for amendments to Form TA–1
filed each year is 246 hours (1.5 hours
times 164 filers). The cumulative total is
366 burden hours per year (120 hours
plus 246 hours).
Written comments are invited on: (a)
Whether the proposed collection of
information is necessary for the proper
performance of the functions of the
Commission, including whether the
information shall have practical utility;
(b) the accuracy of the Commission’s
estimates of the burden of the proposed
collection of information; (c) ways to
enhance the quality, utility, and clarity
of the information to be collected; and
(d) ways to minimize the burden of the
collection of information on
respondents, including the use of
automated collection techniques or
other forms of information technology.
Consideration will be given to
comments and suggestions submitted
within 60 days of this publication.
An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information
under the PRA unless it displays a
currently valid OMB control number.
Please direct your written comments
to: Pamela Dyson, Acting Director/Chief
Information Officer, Securities and
Exchange Commission, c/o Remi PavlikSimon, 100 F Street NE., Washington,
DC 20549, or send an email to: PRA_
Mailbox@sec.gov.
Dated: November 18, 2014.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–27695 Filed 11–21–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–31338; File No. 812–13980]
TPG Specialty Lending, Inc., et al.;
Notice of Application
November 18, 2014.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order pursuant to sections 57(a)(4) and
57(i) of the Investment Company Act of
1940 (the ‘‘Act’’) and rule 17d–1 under
the Act permitting certain joint
transactions otherwise prohibited by
section 57(a)(4) of the Act.
AGENCY:
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Summary of Application:
Applicants request an order to permit a
business development company
(‘‘BDC’’) to co-invest in portfolio
companies with affiliated investment
funds.
APPLICANTS: TPG Specialty Lending,
Inc. (the ‘‘Company’’); TSL Advisers,
LLC (‘‘TSL Advisers’’); TPG
Opportunities Partners II (A), L.P., TPG
Opportunities Partners II (B), L.P., TPG
Opportunities Partners II (C), L.P., TPG
Opportunities Partners III (A), L.P., TPG
Opportunities Partners III (B), L.P., TPG
Opportunities Partners III (C), L.P.,
Super TAO MA, L.P., TSSP Adjacent
Opportunities Partners, L.P., TSSP
Adjacent Opportunities Partners (A),
L.P., TPG Partners VI, L.P., TPG FOF
VI–A, L.P., and TPG FOF VI–B, L.P.
(together, the ‘‘Existing Affiliated
Funds’’); and, TPG Opportunities
Advisers, LLC, TPG Opportunities II
Management, LLC, TPG Opportunities
III Management, LLC, TSSP Adjacent
Opportunities Management, LLC, TPG
Capital Advisors, LLC, and TPG VI
Management, LLC (collectively,
‘‘Existing Advisers to Affiliated
Funds’’).
SUMMARY:
Filing Dates: The application was
filed on November 23, 2011, and
amended on April 23, 2013, September
17, 2013, January 23, 2014, May 6, 2014,
and September 11, 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 December 15, 2014, and
should be accompanied by proof of
service on applicants, in the form of an
affidavit or, for lawyers, a certificate of
service. Pursuant to Rule 0–5 under the
Act, hearing requests should state the
nature of the writer’s interest, any facts
bearing upon the desirability of a
hearing on the matter, 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: The Commission: Secretary,
U.S. Securities and Exchange
Commission, 100 F St. NE., Washington,
DC 20549–1090. Applicants: TPG
Capital Advisors, LLC, 301 Commerce
Street, Suite 3300, Fort Worth, TX
76102.
DATES:
Jaea
F. Hahn, Senior Counsel, at (202) 551–
6870 or David P. Bartels, Branch Chief,
FOR FURTHER INFORMATION CONTACT:
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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 Company is a Delaware
corporation organized as a closed-end
management investment company that
has elected to be regulated as a BDC
under section 54(a) of the Act.1 The
Company’s Objectives and Strategies 2
are to generate current income and
capital appreciation through direct
investments in senior secured loans,
mezzanine loans and, to a lesser extent,
equity securities, of U.S. domiciled
Middle Market Issuers.3 The Company
is managed under the direction of a
board of directors (‘‘Board’’) consisting
of five members, three of whom are not
‘‘interested persons’’ as defined in
section 2(a)(19) of the Act
(‘‘Independent Directors’’).4 TSL
Advisers, a Delaware limited liability
company registered as an investment
adviser under the Investment Advisers
Act of 1940 (the ‘‘Advisers Act’’), serves
as investment adviser to the Company.
2. Each of the Existing Affiliated
Funds is a private investment fund
relying on the exception from the
definition of ‘‘investment company’’
under the Act provided in section
3(c)(1) or 3(c)(7). The Existing Advisers
to Affiliated Funds serve as the
investment advisers to the Existing
Affiliated Funds. Each of the Existing
Advisers to Affiliated Funds is
organized as a Delaware limited liability
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1 Section
2(a)(48) defines a BDC to be any closedend investment company that operates for the
purpose of making investments in securities
described in sections 55(a)(1) through 55(a)(3) of the
Act and makes available significant managerial
assistance with respect to the issuers of such
securities.
2 The Company’s ‘‘Objectives and Strategies’’
means its investment objectives and strategies, as
described in its registration statement on Form N–
2, other filings the Company has made with the
Commission under the Securities Act of 1933 (the
‘‘Securities Act’’), or under the Securities Exchange
Act of 1934, as amended, and the Company’s
reports to shareholders.
3 Applicants define ‘‘Middle Market Issuers’’ as
companies that have annual earnings before
interest, income taxes, depreciation and
amortization of $10 million to $250 million.
4 No Independent Director will have any direct or
indirect financial interest in any Co-Investment
Transaction or any interest in any portfolio
company, other than an interest (if any) in the
securities of the Company.
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company and registered as an
investment adviser under the Advisers
Act.
3. Applicants state that TSL Advisers
and the Existing Advisers to Affiliated
Funds are under common control
because they are each under the indirect
control of David Bonderman and James
Coulter (the ‘‘TPG Founders’’).5
4. Applicants seek an order (‘‘Order’’)
to permit the Company, on the one
hand, and any Affiliated Fund,6 on the
other hand, to participate in the same
Origination Opportunities and FollowOn Investments where such
participation would otherwise be
prohibited under section 57(a)(4) and
the rules under the Act (‘‘Co-Investment
Program’’). ‘‘Co-Investment
Transaction’’ means any transaction in
an Origination Opportunity or any
Follow-On Investment in which the
Company (or any Wholly-Owned
Investment Subsidiary of the Company,
defined below) participated together
with one or more Affiliated Funds in
reliance on the Order. ‘‘Potential CoInvestment Transaction’’ means any
investment opportunity in an
Origination Opportunity or Follow-On
Investment in which the Company (or
any Wholly-Owned Investment
Subsidiary) could not participate
together with an Affiliated Fund
without obtaining and relying on the
Order.7 An ‘‘Origination Opportunity’’
is (a) an investment opportunity
wherein the investing fund would
underwrite and provide the initial
funding for a loan to a Middle Market
Issuer (as opposed to purchasing the
loan from another party) and (b) any
related opportunity to invest in equity,
options, warrants, conversion rights or
other equity-related instruments as part
of the same transaction. A ‘‘Follow-On
Investment’’ is any investment in an
issuer in which the Company and one
or more Affiliated Funds have
completed a Co-Investment Transaction
(defined below) and in which the
5 Applicants represent that the TPG Founders are
the sole shareholders of the ultimate general partner
of entities that indirectly hold all of the voting
power of each Adviser.
6 ‘‘Affiliated Fund’’ means any Existing Affiliated
Fund or any entity (a) whose investment adviser is
an Adviser, (b) that would be an investment
company but for section 3(c)(1) or 3(c)(7) of the Act,
and (c) will have investment objectives and
strategies similar to those of the Company or an
Existing Affiliated Fund. The term ‘‘Adviser’’
means TSL Advisers and the Existing Advisers to
Affiliated Funds, and any future investment adviser
that controls, is controlled by or under common
control with TSL Advisers and is registered under
the Advisers Act.
7 All existing entities that currently intend to rely
upon the requested Order have been named as
applicants. Any other existing or future entity that
subsequently relies on the Order will comply with
the terms and conditions of the application.
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69891
Company remains invested at the time
the investment opportunity arises.
5. Applicants state that, pursuant to
written policies and procedures that
each of the Advisers has adopted, the
Company has the right to determine its
level of participation in an Origination
Opportunity or an opportunity for
Follow-On Investment before the
Advisers allocate any portion of such
opportunity to another client. According
to Applicants, this means that the
Company may choose to participate to
the full extent of an Origination
Opportunity or opportunity for FollowOn Investment, with the Affiliated
Funds receiving no allocation of that
opportunity, or may choose a lower
amount of participation, with the
remainder of the opportunity only then
being offered to the Affiliated Funds.
This arrangement is referred to in the
application as the Company’s
‘‘Allocation Preference.’’ 8 Applicants
state that the Company disclosed the
Allocation Preference to investors in its
private placement memorandum and
registration statement on Form N–2, and
represent that the Allocation Preference
will not be changed.
6. Applicants represent that each
Adviser has adopted procedures to
ensure that each Origination
Opportunity identified by any Adviser
and each Follow-On investment is first
offered to the Company. Applicants
state that the first step once an
investment opportunity is identified by
any Adviser is for the Legal Department
to be advised of the opportunity and
assess whether the investment
opportunity is within the Company’s
Allocation Preference.9 Applicants
assert that the determinations and
referral process is an objective and
mechanical process with no discretion
involved.10 The Company will not be
8 A Follow-On Investment may not itself fall
within the definition of an Origination Opportunity;
however, applicants intend to treat any additional
investments in an issuer in the same manner as the
Origination Opportunity giving rise to the FollowOn Investment. Applicants believe that once the
Company has an investment in an issuer pursuant
to an Origination Opportunity, it is fair and
appropriate for any additional investments in such
issuer under the Co-Investment Program to be
subject to the Company’s Allocation Preference.
9 The term ‘‘Legal Department’’ refers to the
supervised persons (as defined by the Advisers Act)
of the Advisers who provide legal services and
advice to the Advisers. Applicants state that, as a
group of entities under common control, the
Advisers all share the services of the Legal
Department. As such, the Legal Department acts on
behalf of the Advisers, and actions taken, or not
taken, and determinations made by the Legal
Department for purposes of complying with the
terms and conditions of this application will be
attributed to each of the Advisers.
10 Applicants represent that, as part of the
Advisers’ written policies and procedures, the Legal
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obligated to invest, or co-invest, when
Origination Opportunities or Follow-On
Investments are referred to it.
7. Once the Legal Department has
determined that an opportunity is an
Origination Opportunity or potential
Follow-On Investment, TSL Advisers
will make an independent
determination of the appropriateness of
the investment for the Company, as
required under condition 1. If TSL
Advisers deems the Company’s
participation in such investment to be
appropriate, it will then determine an
appropriate size of the Company’s
investment. In selecting investments for
the Company, TSL Advisers will
consider only the Objectives and
Strategies, investment policies,
investment positions, capital available
for investment, and other pertinent
factors applicable to the Company.
Although the Company has an
Allocation Preference over all
Origination Opportunities and FollowOn Investments, the Affiliated Funds
have investment strategies that could
result in particular Origination
Opportunities being attractive and
appropriate for one or more of them as
well as for the Company. Under the CoInvestment Program, if the amount of
the investment opportunity were to
exceed the amount TSL Advisers
determined was appropriate for the
Company to invest, then the excess
amount would be offered to one or more
Affiliated Funds as a Potential CoInvestment Transaction. When
determining if an Affiliated Fund
should participate in a Potential CoInvestment Transaction offered to it, the
applicable Adviser will review the
Potential Co-Investment Transaction for
each Affiliated Fund that it advises
based only upon the investment
objectives, investment policies,
investment position, capital available
for investment, and other pertinent
factors applicable to that particular
investing entity.
8. Other than pro rata dispositions as
provided in condition 6, and after
making the determinations required in
conditions 1 and 2(a), TSL Advisers will
present each Potential Co-Investment
Transaction and the proposed allocation
to the directors of the Board eligible to
vote under section 57(o) of the Act
(‘‘Eligible Directors’’), and the ‘‘required
majority,’’ as defined in section 57(o) of
the Act (‘‘Required Majority’’), will
approve each Co-Investment
Transaction prior to any investment by
the Company.
Department’s determination with regard to each
investment opportunity will be documented in TSL
Adviser’s allocation log.
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9. With respect to the pro rata
dispositions provided in condition 6,
the Company may participate in a pro
rata disposition without obtaining prior
approval of the Required Majority if,
among other things: (i) The proposed
participation of the Company and the
participating Affiliated Fund in such
disposition is proportionate to its
outstanding investments in the issuer
immediately preceding the disposition,
as the case may be; and (ii) the Board
has approved the Company’s
participation in pro rata dispositions as
being in the best interests of the
Company. If the Board does not so
approve, any such dispositions will be
submitted to the Company’s Eligible
Directors. The Board may at any time
rescind, suspend or qualify its approval
of pro rata dispositions with the result
that all dispositions must be submitted
to the Eligible Directors.
10. Applicants state that the Company
may, from time to time, form one or
more Wholly-Owned Investment
Subsidiaries.11 Such a subsidiary would
be prohibited from investing in a CoInvestment Transaction with an
Affiliated Fund because it would be a
company controlled by the Company for
purposes of section 57(a)(4) and rule
17d-1. Applicants request that each
Wholly-Owned Investment Subsidiary
be permitted to participate in CoInvestment Transactions in lieu of the
Company and that the Wholly-Owned
Investment Subsidiary’s participation in
any such transaction be treated, for
purposes of the requested order, as
though the Company were participating
directly. Applicants represent that this
treatment is justified because a WhollyOwned Investment Subsidiary would
have no purpose other than serving as
a holding vehicle for the Company’s
investments and, therefore, no conflicts
of interest could arise between the
Company and the Wholly-Owned
Investment Subsidiary. The Company’s
Board would make all relevant
determinations under the conditions
with regard to a Wholly-Owned
Investment Subsidiary’s participation in
a Co-Investment Transaction, and the
Company’s Board would be informed of,
11 The term ‘‘Wholly-Owned Investment
Subsidiary’’ means an entity (a) whose sole
business purpose is to hold one or more
investments on behalf of the Company; (b) that is
wholly-owned by the Company (with the Company
at all times holding, beneficially and of record,
100% of the voting and economic interests); (c)
with respect to which the Company’s Board has the
sole authority to make all determinations with
respect to participation under the conditions of the
application; (d) that does not pay a separate
advisory fee, including any performance-based fee,
to any person; and (e) that would be an investment
company but for section 3(c)(1) or 3(c)(7) of the Act.
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and take into consideration, any
proposed use of a Wholly-Owned
Investment Subsidiary in the Company’s
place. If the Company proposes to
participate in the same Co-Investment
Transaction with any of its WhollyOwned Investment Subsidiaries, the
Board will also be informed of, and take
into consideration, the relative
participation of the Company and the
Wholly-Owned Investment Subsidiary.
Applicants’ Legal Analysis
1. Section 57(a)(4) of the Act prohibits
certain affiliated persons of a BDC from
participating in joint transactions with
the BDC (or a company controlled by
such BDC) in contravention of rules as
prescribed by the Commission. Under
section 57(b)(2) of the Act, any person
who is directly or indirectly controlling,
controlled by, or under common control
with a BDC is subject to section 57(a)(4).
Section 57(i) of the Act provides that,
until the Commission prescribes rules
under section 57(a)(4), the
Commission’s rules under section 17(d)
of the Act applicable to registered
closed-end investment companies will
be deemed to apply to transactions
subject to section 57(a)(4). Because the
Commission has not adopted any rules
under section 57(a)(4), rule 17d–1
applies to joint transactions with the
Company because it is a BDC.
2. Rule 17d–1 under the Act prohibits
affiliated persons of a registered
investment company from participating
in joint transactions with the company
unless the Commission has granted an
order permitting such transactions. In
passing upon applications under rule
17d–1, the Commission considers
whether the company’s participation in
the joint transaction is consistent with
the provisions, policies, and purposes of
the Act and the extent to which such
participation is on a basis different from
or less advantageous than that of other
participants.
3. Co-Investment Transactions would
be prohibited by section 57(a)(4) and
rule 17d–1 without a prior exemptive
order of the Commission to the extent
that the Affiliated Funds fall within the
category of persons described by section
`
57(b) vis-a-vis the Company. Applicants
state that Company’s ability to complete
Co-Investment Transactions in portfolio
companies will increase favorable
investment opportunities for the
Company.
4. Applicants believe that CoInvestment Transactions would
necessarily be fair to the Company
because they would only occur if TSL
Advisers determined that the
investment opportunity exceeded the
Company’s desired investment in the
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opportunity. Applicants believe that the
proposed terms and conditions will
ensure that the terms on which CoInvestment Transactions may be made
are consistent with the participation of
the Company being on a basis that is
neither different from nor less
advantageous than other participants,
thus protecting the shareholders of the
Company from being disadvantaged,
and are consistent with the purposes
intended by the policies and provisions
of the Act.
Applicants’ Conditions
Applicants agree that the Order
granting the requested relief will be
subject to the following conditions:
1. The Company will receive an
Allocation Preference with respect to all
Origination Opportunities and potential
Follow-On Investments. The Advisers
will ensure that TSL Advisers and the
Company are notified of all Origination
Opportunities. Each time TSL Advisers
considers a Potential Co-Investment for
the Company, it will make an
independent determination of the
appropriateness of the investment for
the Company in light of the Company’s
then-current circumstances.
2. (a) If TSL Advisers deems the
Company’s participation in any
Potential Co-Investment Transaction to
be appropriate for the Company, it will
then determine an appropriate level of
investment for the Company.
(b) The Company has the right to
participate in the Potential CoInvestment Transaction to the full
extent TSL Advisers deems appropriate,
and the participating Affiliated Funds
will be allocated the remaining excess
amount.
(c) After making the determinations
required in conditions 1 and 2(a) above,
TSL Advisers will distribute written
information concerning the Potential
Co-Investment Transaction, including
the amounts proposed to be invested by
the Affiliated Funds, to the Eligible
Directors for their consideration. The
Company will co-invest with one or
more Affiliated Funds only if, prior to
the Company’s and any Affiliated
Fund’s participation in the CoInvestment Transaction, a Required
Majority concludes that:
(i) The terms of the transaction,
including the consideration to be paid,
are reasonable and fair and do not
involve overreaching in respect of the
Company or its shareholders on the part
of any person concerned;
(ii) the transaction is consistent with:
(A) The interests of the shareholders
of the Company; and
(B) the Company’s then-current
Objectives and Strategies;
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(iii) the investment by the Affiliated
Fund(s) would not disadvantage the
Company, and participation by the
Company is not on a basis different from
or less advantageous than that of an
Affiliated Fund; provided that, if an
Affiliated Fund, but not the Company,
gains the right to nominate a director for
election to a portfolio company’s board
of directors or the right to have a board
observer or any similar right to
participate in the governance or
management of the portfolio company,
such event will not be interpreted to
prohibit the Required Majority from
reaching the conclusions required by
this condition (2)(c)(iii), if:
(A) The Eligible Directors will have
the right to ratify the selection of such
director or board observer, if any;
(B) the applicable Adviser agrees to,
and does, provide periodic reports to
the Company’s Board with respect to the
actions of the director or the
information received by the board
observer or obtained through the
exercise of any similar right to
participate in the governance or
management of the portfolio company;
and
(C) any fees or other compensation
that the Affiliated Fund or any affiliated
person of an Affiliated Fund receives in
connection with the right of the
Affiliated Fund to nominate a director
or appoint a board observer or otherwise
to participate in the governance or
management of the portfolio company
will be shared proportionately among
the Affiliated Fund (which may, in turn,
share its portion with its affiliated
persons) and the Company in
accordance with the amount of each
party’s investment; and
(iv) the proposed investment by the
Company will not benefit any Adviser,
Affiliated Fund or any affiliated person
thereof (other than the participating
Affiliated Funds), except (A) to the
extent permitted by condition 12, (B) to
the extent permitted by section 17(e) or
57(k) of the Act, as applicable, (C) in the
case of fees or other compensation
described in condition 2(c)(iii)(C), or (D)
indirectly, as a result of an interest in
the securities issued by one of the
parties to the Co-Investment
Transaction.
3. The Company has the right to
decline to participate in any Potential
Co-Investment Transaction or to invest
less than the amount proposed.
4. Except for Follow-On Investments
made in accordance with condition 7,
the Company will not invest in reliance
on the Order in any issuer in which any
Affiliated Fund or any affiliated person
of an Affiliated Fund is an existing
investor.
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69893
5. The Company will not participate
in any Potential Co-Investment
Transaction unless the terms,
conditions, price, class of securities to
be purchased, settlement date, and
registration rights will be the same for
the Company as for the participating
Affiliated Funds. The grant to an
Affiliated Fund, but not the Company,
of the right to nominate a director for
election to a portfolio company’s board
of directors, the right to have an
observer on the board of directors or
similar rights to participate in the
governance or management of the
portfolio company will not be
interpreted so as to violate this
condition 5, if conditions 2(c)(iii)(A), (B)
and (C) are met.
6. (a) If any of the Affiliated Funds
elects to sell, exchange or otherwise
dispose of an interest in a security that
was acquired by the Company and such
Affiliated Fund in a Co-Investment
Transaction, then:
(i) The relevant Adviser will notify
the Company of the proposed
disposition at the earliest practical time;
and
(ii) TSL Advisers will formulate a
recommendation as to participation by
the Company in the disposition.
(b) The Company will have the right
to participate in such disposition on a
proportionate basis, at the same price
and on the same terms and conditions
as those applicable to the participating
Affiliated Fund(s).
(c) The Company may participate in
such disposition without obtaining prior
approval of the Required Majority if: (i)
The proposed participation of the
Company and each participating
Affiliated Fund in such disposition is
proportionate to its outstanding
investment in the issuer immediately
preceding the disposition; (ii) the Board
has approved as being in the best
interests of the Company the ability to
participate in such dispositions on a pro
rata basis (as described in greater detail
in the application); and (iii) the Board
is provided on a quarterly basis with a
list of all dispositions made in
accordance with this condition. In all
other cases, TSL Advisers will provide
its written recommendation as to the
Company’s participation to the Eligible
Directors, and the Company will
participate in such disposition solely to
the extent that a Required Majority
determines that it is in the Company’s
best interests.
(d) The Company and each
participating Affiliated Fund will bear
its own expenses in connection with
any such disposition.
7. (a) If any Affiliated Fund desires to
make a Follow-On Investment then:
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69894
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(i) The relevant Adviser will notify
the Company of the proposed
transaction at the earliest practical time;
and
(ii) TSL Advisers will formulate a
recommendation as to the proposed
participation, including the amount of
the proposed Follow-On Investment, by
the Company.
(b) The Company has the right to
participate in the Follow-On Investment
to the full extent TSL Advisers deems
appropriate, and the participating
Affiliated Funds will be allocated the
remaining excess amount.
(c) TSL Advisers will provide its
written recommendation as to the
Company’s participation to the Eligible
Directors, and the Company will
participate in such Follow-On
Investment solely to the extent that a
Required Majority determines that it is
in the Company’s best interest.
(d) The acquisition of Follow-On
Investments as permitted by this
condition will be considered a CoInvestment Transaction for all purposes
and subject to the other conditions set
forth in the application.
8. The Independent Directors will be
provided quarterly for review all
information concerning Potential CoInvestment Transactions and CoInvestment Transactions, including
investments made by an Affiliated Fund
that the Company participated in and
investments made by an Affiliated Fund
that the Company considered but
declined to co-invest in, so that the
Independent Directors may determine
whether all investments made during
the preceding quarter, including those
investments that the Company
considered but declined to participate
in, comply with the conditions of the
Order. In addition, the Independent
Directors will consider at least annually
the continued appropriateness for the
Company of participating in new and
existing Co-Investment Transactions.
9. The Company will maintain the
records required by section 57(f)(3) of
the Act as if each of the investments
permitted under these conditions were
approved by the Required Majority
under section 57(f).
10. No Independent Director will also
be a director, general partner, managing
member or principal, or otherwise an
‘‘affiliated person’’ (as defined in the
Act) of any of the Affiliated Funds.
11. The expenses, if any, associated
with acquiring, holding or disposing of
any securities acquired in a CoInvestment Transaction (including,
without limitation, the expenses of the
distribution of any such securities
registered for sale under the Securities
Act) will, to the extent not payable by
VerDate Sep<11>2014
20:32 Nov 21, 2014
Jkt 235001
the Advisers to Affiliated Funds under
their respective investment advisory
agreements with the Affiliated Funds,
be shared by the Company and the
Affiliated Funds in proportion to the
relative amounts of the securities to be
acquired, held or disposed of, as the
case may be.
12. Any transaction fee (including any
break-up fees or commitment fees but
excluding broker’s fees contemplated
section 17(e) or 57(k) of the Act, as
applicable), received in connection with
a Co-Investment Transaction will be
distributed to the Company and the
Affiliated Funds on a pro rata basis
based on the amount they invested or
committed, as the case may be, in such
Co-Investment Transaction. If any
transaction fee is to be held by an
Adviser pending consummation of the
transaction, the fee will be deposited
into an account maintained by such
investment adviser at a bank or banks
having the qualifications prescribed in
section 26(a)(1) of the Act, and the
account will earn a competitive rate of
interest that will also be divided pro
rata among the Company and the
Affiliated Funds based on the amount
they invest in such Co-Investment
Transaction. None of the Affiliated
Funds, Advisers, nor any affiliated
person of the Company will receive
additional compensation or
remuneration of any kind as a result of
or in connection with a Co-Investment
Transaction (other than (a) in the case
of the Company and the Affiliated
Funds, the pro rata transaction fees
described above and fees or other
compensation described in condition
2(c)(iii)(C); and (b) in the case of the
Advisers, investment advisory fees paid
in accordance with the Company’s and
the Affiliated Funds’ respective
investment advisory agreements).
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–27696 Filed 11–21–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. PA–52; File No. S7–11–14]
Privacy Act of 1974: Systems of
Records
Securities and Exchange
Commission.
ACTION: Notice to revise two existing
systems of records.
AGENCY:
PO 00000
Frm 00073
Fmt 4703
Sfmt 4703
In accordance with the
requirements of the Privacy Act of 1974,
as amended, 5 U.S.C. 552a, the
Securities and Exchange Commission
(‘‘Commission’’ or ‘‘SEC’’) proposes to
revise two existing systems of records,
‘‘Administrative Proceeding Files (SEC–
36)’’, last published in the Federal
Register Volume 62 FR 47884
(September 11, 1997) and ‘‘Information
Pertaining or Relevant to SEC Regulated
Entities and Their Activities’’ (SEC–55),
last published in the Federal Register
Volume 75 FR 35853 (June 23, 2010).
DATES: The proposed system will
become effective January 5, 2015 unless
further notice is given. The Commission
will publish a new notice if the effective
date is delayed to review comments or
if changes are made based on comments
received. To be assured of
consideration, comments should be
received on or before December 24,
2014.
SUMMARY:
Comments may be
submitted by any of the following
methods:
ADDRESSES:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/other.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number S7–
11–14 on the subject line.
Paper Comments
Send paper comments in triplicate to
Brent J. Fields, Secretary, U.S. Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090. All
submissions should refer to File
Number S7–11–14. This file number
should be included on the subject line
if email is used. To help process and
review your comments more efficiently,
please use only one method. The
Commission will post all comments on
the Commission’s Internet Web site
(https://www.sec.gov/rules/other.shtml).
Comments are also available for Web
site viewing and printing in the
Commission’s Public Reference Room,
100 F Street NE., Washington, DC
20549, on official business days
between the hours of 10:00 a.m. and
3:00 p.m. All comments received will be
posted without change; we do not edit
personal identifying information from
submissions. You should submit only
information that you wish to make
available publicly.
FOR FURTHER INFORMATION CONTACT:
Todd Scharf, Acting Chief Privacy
Officer, Office of Information
Technology, 202–551–8800.
SUPPLEMENTARY INFORMATION:
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Agencies
[Federal Register Volume 79, Number 226 (Monday, November 24, 2014)]
[Notices]
[Pages 69890-69894]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-27696]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-31338; File No. 812-13980]
TPG Specialty Lending, Inc., et al.; Notice of Application
November 18, 2014.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application for an order pursuant to sections
57(a)(4) and 57(i) of the Investment Company Act of 1940 (the ``Act'')
and rule 17d-1 under the Act permitting certain joint transactions
otherwise prohibited by section 57(a)(4) of the Act.
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SUMMARY: Summary of Application: Applicants request an order to permit
a business development company (``BDC'') to co-invest in portfolio
companies with affiliated investment funds.
Applicants: TPG Specialty Lending, Inc. (the ``Company''); TSL
Advisers, LLC (``TSL Advisers''); TPG Opportunities Partners II (A),
L.P., TPG Opportunities Partners II (B), L.P., TPG Opportunities
Partners II (C), L.P., TPG Opportunities Partners III (A), L.P., TPG
Opportunities Partners III (B), L.P., TPG Opportunities Partners III
(C), L.P., Super TAO MA, L.P., TSSP Adjacent Opportunities Partners,
L.P., TSSP Adjacent Opportunities Partners (A), L.P., TPG Partners VI,
L.P., TPG FOF VI-A, L.P., and TPG FOF VI-B, L.P. (together, the
``Existing Affiliated Funds''); and, TPG Opportunities Advisers, LLC,
TPG Opportunities II Management, LLC, TPG Opportunities III Management,
LLC, TSSP Adjacent Opportunities Management, LLC, TPG Capital Advisors,
LLC, and TPG VI Management, LLC (collectively, ``Existing Advisers to
Affiliated Funds'').
DATES: Filing Dates: The application was filed on November 23, 2011,
and amended on April 23, 2013, September 17, 2013, January 23, 2014,
May 6, 2014, and September 11, 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 December 15, 2014, and should be accompanied by proof of
service on applicants, in the form of an affidavit or, for lawyers, a
certificate of service. Pursuant to Rule 0-5 under the Act, hearing
requests should state the nature of the writer's interest, any facts
bearing upon the desirability of a hearing on the matter, 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: The Commission: Secretary, U.S. Securities and Exchange
Commission, 100 F St. NE., Washington, DC 20549-1090. Applicants: TPG
Capital Advisors, LLC, 301 Commerce Street, Suite 3300, Fort Worth, TX
76102.
FOR FURTHER INFORMATION CONTACT: Jaea F. Hahn, Senior Counsel, at (202)
551-6870 or David P. Bartels, Branch Chief,
[[Page 69891]]
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 Company is a Delaware corporation organized as a closed-end
management investment company that has elected to be regulated as a BDC
under section 54(a) of the Act.\1\ The Company's Objectives and
Strategies \2\ are to generate current income and capital appreciation
through direct investments in senior secured loans, mezzanine loans
and, to a lesser extent, equity securities, of U.S. domiciled Middle
Market Issuers.\3\ The Company is managed under the direction of a
board of directors (``Board'') consisting of five members, three of
whom are not ``interested persons'' as defined in section 2(a)(19) of
the Act (``Independent Directors'').\4\ TSL Advisers, a Delaware
limited liability company registered as an investment adviser under the
Investment Advisers Act of 1940 (the ``Advisers Act''), serves as
investment adviser to the Company.
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\1\ Section 2(a)(48) defines a BDC to be any closed-end
investment company that operates for the purpose of making
investments in securities described in sections 55(a)(1) through
55(a)(3) of the Act and makes available significant managerial
assistance with respect to the issuers of such securities.
\2\ The Company's ``Objectives and Strategies'' means its
investment objectives and strategies, as described in its
registration statement on Form N-2, other filings the Company has
made with the Commission under the Securities Act of 1933 (the
``Securities Act''), or under the Securities Exchange Act of 1934,
as amended, and the Company's reports to shareholders.
\3\ Applicants define ``Middle Market Issuers'' as companies
that have annual earnings before interest, income taxes,
depreciation and amortization of $10 million to $250 million.
\4\ No Independent Director will have any direct or indirect
financial interest in any Co-Investment Transaction or any interest
in any portfolio company, other than an interest (if any) in the
securities of the Company.
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2. Each of the Existing Affiliated Funds is a private investment
fund relying on the exception from the definition of ``investment
company'' under the Act provided in section 3(c)(1) or 3(c)(7). The
Existing Advisers to Affiliated Funds serve as the investment advisers
to the Existing Affiliated Funds. Each of the Existing Advisers to
Affiliated Funds is organized as a Delaware limited liability company
and registered as an investment adviser under the Advisers Act.
3. Applicants state that TSL Advisers and the Existing Advisers to
Affiliated Funds are under common control because they are each under
the indirect control of David Bonderman and James Coulter (the ``TPG
Founders'').\5\
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\5\ Applicants represent that the TPG Founders are the sole
shareholders of the ultimate general partner of entities that
indirectly hold all of the voting power of each Adviser.
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4. Applicants seek an order (``Order'') to permit the Company, on
the one hand, and any Affiliated Fund,\6\ on the other hand, to
participate in the same Origination Opportunities and Follow-On
Investments where such participation would otherwise be prohibited
under section 57(a)(4) and the rules under the Act (``Co-Investment
Program''). ``Co-Investment Transaction'' means any transaction in an
Origination Opportunity or any Follow-On Investment in which the
Company (or any Wholly-Owned Investment Subsidiary of the Company,
defined below) participated together with one or more Affiliated Funds
in reliance on the Order. ``Potential Co-Investment Transaction'' means
any investment opportunity in an Origination Opportunity or Follow-On
Investment in which the Company (or any Wholly-Owned Investment
Subsidiary) could not participate together with an Affiliated Fund
without obtaining and relying on the Order.\7\ An ``Origination
Opportunity'' is (a) an investment opportunity wherein the investing
fund would underwrite and provide the initial funding for a loan to a
Middle Market Issuer (as opposed to purchasing the loan from another
party) and (b) any related opportunity to invest in equity, options,
warrants, conversion rights or other equity-related instruments as part
of the same transaction. A ``Follow-On Investment'' is any investment
in an issuer in which the Company and one or more Affiliated Funds have
completed a Co-Investment Transaction (defined below) and in which the
Company remains invested at the time the investment opportunity arises.
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\6\ ``Affiliated Fund'' means any Existing Affiliated Fund or
any entity (a) whose investment adviser is an Adviser, (b) that
would be an investment company but for section 3(c)(1) or 3(c)(7) of
the Act, and (c) will have investment objectives and strategies
similar to those of the Company or an Existing Affiliated Fund. The
term ``Adviser'' means TSL Advisers and the Existing Advisers to
Affiliated Funds, and any future investment adviser that controls,
is controlled by or under common control with TSL Advisers and is
registered under the Advisers Act.
\7\ All existing entities that currently intend to rely upon the
requested Order have been named as applicants. Any other existing or
future entity that subsequently relies on the Order will comply with
the terms and conditions of the application.
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5. Applicants state that, pursuant to written policies and
procedures that each of the Advisers has adopted, the Company has the
right to determine its level of participation in an Origination
Opportunity or an opportunity for Follow-On Investment before the
Advisers allocate any portion of such opportunity to another client.
According to Applicants, this means that the Company may choose to
participate to the full extent of an Origination Opportunity or
opportunity for Follow-On Investment, with the Affiliated Funds
receiving no allocation of that opportunity, or may choose a lower
amount of participation, with the remainder of the opportunity only
then being offered to the Affiliated Funds. This arrangement is
referred to in the application as the Company's ``Allocation
Preference.'' \8\ Applicants state that the Company disclosed the
Allocation Preference to investors in its private placement memorandum
and registration statement on Form N-2, and represent that the
Allocation Preference will not be changed.
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\8\ A Follow-On Investment may not itself fall within the
definition of an Origination Opportunity; however, applicants intend
to treat any additional investments in an issuer in the same manner
as the Origination Opportunity giving rise to the Follow-On
Investment. Applicants believe that once the Company has an
investment in an issuer pursuant to an Origination Opportunity, it
is fair and appropriate for any additional investments in such
issuer under the Co-Investment Program to be subject to the
Company's Allocation Preference.
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6. Applicants represent that each Adviser has adopted procedures to
ensure that each Origination Opportunity identified by any Adviser and
each Follow-On investment is first offered to the Company. Applicants
state that the first step once an investment opportunity is identified
by any Adviser is for the Legal Department to be advised of the
opportunity and assess whether the investment opportunity is within the
Company's Allocation Preference.\9\ Applicants assert that the
determinations and referral process is an objective and mechanical
process with no discretion involved.\10\ The Company will not be
[[Page 69892]]
obligated to invest, or co-invest, when Origination Opportunities or
Follow-On Investments are referred to it.
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\9\ The term ``Legal Department'' refers to the supervised
persons (as defined by the Advisers Act) of the Advisers who provide
legal services and advice to the Advisers. Applicants state that, as
a group of entities under common control, the Advisers all share the
services of the Legal Department. As such, the Legal Department acts
on behalf of the Advisers, and actions taken, or not taken, and
determinations made by the Legal Department for purposes of
complying with the terms and conditions of this application will be
attributed to each of the Advisers.
\10\ Applicants represent that, as part of the Advisers' written
policies and procedures, the Legal Department's determination with
regard to each investment opportunity will be documented in TSL
Adviser's allocation log.
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7. Once the Legal Department has determined that an opportunity is
an Origination Opportunity or potential Follow-On Investment, TSL
Advisers will make an independent determination of the appropriateness
of the investment for the Company, as required under condition 1. If
TSL Advisers deems the Company's participation in such investment to be
appropriate, it will then determine an appropriate size of the
Company's investment. In selecting investments for the Company, TSL
Advisers will consider only the Objectives and Strategies, investment
policies, investment positions, capital available for investment, and
other pertinent factors applicable to the Company. Although the Company
has an Allocation Preference over all Origination Opportunities and
Follow-On Investments, the Affiliated Funds have investment strategies
that could result in particular Origination Opportunities being
attractive and appropriate for one or more of them as well as for the
Company. Under the Co-Investment Program, if the amount of the
investment opportunity were to exceed the amount TSL Advisers
determined was appropriate for the Company to invest, then the excess
amount would be offered to one or more Affiliated Funds as a Potential
Co-Investment Transaction. When determining if an Affiliated Fund
should participate in a Potential Co-Investment Transaction offered to
it, the applicable Adviser will review the Potential Co-Investment
Transaction for each Affiliated Fund that it advises based only upon
the investment objectives, investment policies, investment position,
capital available for investment, and other pertinent factors
applicable to that particular investing entity.
8. Other than pro rata dispositions as provided in condition 6, and
after making the determinations required in conditions 1 and 2(a), TSL
Advisers will present each Potential Co-Investment Transaction and the
proposed allocation to the directors of the Board eligible to vote
under section 57(o) of the Act (``Eligible Directors''), and the
``required majority,'' as defined in section 57(o) of the Act
(``Required Majority''), will approve each Co-Investment Transaction
prior to any investment by the Company.
9. With respect to the pro rata dispositions provided in condition
6, the Company may participate in a pro rata disposition without
obtaining prior approval of the Required Majority if, among other
things: (i) The proposed participation of the Company and the
participating Affiliated Fund in such disposition is proportionate to
its outstanding investments in the issuer immediately preceding the
disposition, as the case may be; and (ii) the Board has approved the
Company's participation in pro rata dispositions as being in the best
interests of the Company. If the Board does not so approve, any such
dispositions will be submitted to the Company's Eligible Directors. The
Board may at any time rescind, suspend or qualify its approval of pro
rata dispositions with the result that all dispositions must be
submitted to the Eligible Directors.
10. Applicants state that the Company may, from time to time, form
one or more Wholly-Owned Investment Subsidiaries.\11\ Such a subsidiary
would be prohibited from investing in a Co-Investment Transaction with
an Affiliated Fund because it would be a company controlled by the
Company for purposes of section 57(a)(4) and rule 17d-1. Applicants
request that each Wholly-Owned Investment Subsidiary be permitted to
participate in Co-Investment Transactions in lieu of the Company and
that the Wholly-Owned Investment Subsidiary's participation in any such
transaction be treated, for purposes of the requested order, as though
the Company were participating directly. Applicants represent that this
treatment is justified because a Wholly-Owned Investment Subsidiary
would have no purpose other than serving as a holding vehicle for the
Company's investments and, therefore, no conflicts of interest could
arise between the Company and the Wholly-Owned Investment Subsidiary.
The Company's Board would make all relevant determinations under the
conditions with regard to a Wholly-Owned Investment Subsidiary's
participation in a Co-Investment Transaction, and the Company's Board
would be informed of, and take into consideration, any proposed use of
a Wholly-Owned Investment Subsidiary in the Company's place. If the
Company proposes to participate in the same Co-Investment Transaction
with any of its Wholly-Owned Investment Subsidiaries, the Board will
also be informed of, and take into consideration, the relative
participation of the Company and the Wholly-Owned Investment
Subsidiary.
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\11\ The term ``Wholly-Owned Investment Subsidiary'' means an
entity (a) whose sole business purpose is to hold one or more
investments on behalf of the Company; (b) that is wholly-owned by
the Company (with the Company at all times holding, beneficially and
of record, 100% of the voting and economic interests); (c) with
respect to which the Company's Board has the sole authority to make
all determinations with respect to participation under the
conditions of the application; (d) that does not pay a separate
advisory fee, including any performance-based fee, to any person;
and (e) that would be an investment company but for section 3(c)(1)
or 3(c)(7) of the Act.
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Applicants' Legal Analysis
1. Section 57(a)(4) of the Act prohibits certain affiliated persons
of a BDC from participating in joint transactions with the BDC (or a
company controlled by such BDC) in contravention of rules as prescribed
by the Commission. Under section 57(b)(2) of the Act, any person who is
directly or indirectly controlling, controlled by, or under common
control with a BDC is subject to section 57(a)(4). Section 57(i) of the
Act provides that, until the Commission prescribes rules under section
57(a)(4), the Commission's rules under section 17(d) of the Act
applicable to registered closed-end investment companies will be deemed
to apply to transactions subject to section 57(a)(4). Because the
Commission has not adopted any rules under section 57(a)(4), rule 17d-1
applies to joint transactions with the Company because it is a BDC.
2. Rule 17d-1 under the Act prohibits affiliated persons of a
registered investment company from participating in joint transactions
with the company unless the Commission has granted an order permitting
such transactions. In passing upon applications under rule 17d-1, the
Commission considers whether the company's participation in the joint
transaction is consistent with the provisions, policies, and purposes
of the Act and the extent to which such participation is on a basis
different from or less advantageous than that of other participants.
3. Co-Investment Transactions would be prohibited by section
57(a)(4) and rule 17d-1 without a prior exemptive order of the
Commission to the extent that the Affiliated Funds fall within the
category of persons described by section 57(b) vis-[agrave]-vis the
Company. Applicants state that Company's ability to complete Co-
Investment Transactions in portfolio companies will increase favorable
investment opportunities for the Company.
4. Applicants believe that Co-Investment Transactions would
necessarily be fair to the Company because they would only occur if TSL
Advisers determined that the investment opportunity exceeded the
Company's desired investment in the
[[Page 69893]]
opportunity. Applicants believe that the proposed terms and conditions
will ensure that the terms on which Co-Investment Transactions may be
made are consistent with the participation of the Company being on a
basis that is neither different from nor less advantageous than other
participants, thus protecting the shareholders of the Company from
being disadvantaged, and are consistent with the purposes intended by
the policies and provisions of the Act.
Applicants' Conditions
Applicants agree that the Order granting the requested relief will
be subject to the following conditions:
1. The Company will receive an Allocation Preference with respect
to all Origination Opportunities and potential Follow-On Investments.
The Advisers will ensure that TSL Advisers and the Company are notified
of all Origination Opportunities. Each time TSL Advisers considers a
Potential Co-Investment for the Company, it will make an independent
determination of the appropriateness of the investment for the Company
in light of the Company's then-current circumstances.
2. (a) If TSL Advisers deems the Company's participation in any
Potential Co-Investment Transaction to be appropriate for the Company,
it will then determine an appropriate level of investment for the
Company.
(b) The Company has the right to participate in the Potential Co-
Investment Transaction to the full extent TSL Advisers deems
appropriate, and the participating Affiliated Funds will be allocated
the remaining excess amount.
(c) After making the determinations required in conditions 1 and
2(a) above, TSL Advisers will distribute written information concerning
the Potential Co-Investment Transaction, including the amounts proposed
to be invested by the Affiliated Funds, to the Eligible Directors for
their consideration. The Company will co-invest with one or more
Affiliated Funds only if, prior to the Company's and any Affiliated
Fund's participation in the Co-Investment Transaction, a Required
Majority concludes that:
(i) The terms of the transaction, including the consideration to be
paid, are reasonable and fair and do not involve overreaching in
respect of the Company or its shareholders on the part of any person
concerned;
(ii) the transaction is consistent with:
(A) The interests of the shareholders of the Company; and
(B) the Company's then-current Objectives and Strategies;
(iii) the investment by the Affiliated Fund(s) would not
disadvantage the Company, and participation by the Company is not on a
basis different from or less advantageous than that of an Affiliated
Fund; provided that, if an Affiliated Fund, but not the Company, gains
the right to nominate a director for election to a portfolio company's
board of directors or the right to have a board observer or any similar
right to participate in the governance or management of the portfolio
company, such event will not be interpreted to prohibit the Required
Majority from reaching the conclusions required by this condition
(2)(c)(iii), if:
(A) The Eligible Directors will have the right to ratify the
selection of such director or board observer, if any;
(B) the applicable Adviser agrees to, and does, provide periodic
reports to the Company's Board with respect to the actions of the
director or the information received by the board observer or obtained
through the exercise of any similar right to participate in the
governance or management of the portfolio company; and
(C) any fees or other compensation that the Affiliated Fund or any
affiliated person of an Affiliated Fund receives in connection with the
right of the Affiliated Fund to nominate a director or appoint a board
observer or otherwise to participate in the governance or management of
the portfolio company will be shared proportionately among the
Affiliated Fund (which may, in turn, share its portion with its
affiliated persons) and the Company in accordance with the amount of
each party's investment; and
(iv) the proposed investment by the Company will not benefit any
Adviser, Affiliated Fund or any affiliated person thereof (other than
the participating Affiliated Funds), except (A) to the extent permitted
by condition 12, (B) to the extent permitted by section 17(e) or 57(k)
of the Act, as applicable, (C) in the case of fees or other
compensation described in condition 2(c)(iii)(C), or (D) indirectly, as
a result of an interest in the securities issued by one of the parties
to the Co-Investment Transaction.
3. The Company has the right to decline to participate in any
Potential Co-Investment Transaction or to invest less than the amount
proposed.
4. Except for Follow-On Investments made in accordance with
condition 7, the Company will not invest in reliance on the Order in
any issuer in which any Affiliated Fund or any affiliated person of an
Affiliated Fund is an existing investor.
5. The Company will not participate in any Potential Co-Investment
Transaction unless the terms, conditions, price, class of securities to
be purchased, settlement date, and registration rights will be the same
for the Company as for the participating Affiliated Funds. The grant to
an Affiliated Fund, but not the Company, of the right to nominate a
director for election to a portfolio company's board of directors, the
right to have an observer on the board of directors or similar rights
to participate in the governance or management of the portfolio company
will not be interpreted so as to violate this condition 5, if
conditions 2(c)(iii)(A), (B) and (C) are met.
6. (a) If any of the Affiliated Funds elects to sell, exchange or
otherwise dispose of an interest in a security that was acquired by the
Company and such Affiliated Fund in a Co-Investment Transaction, then:
(i) The relevant Adviser will notify the Company of the proposed
disposition at the earliest practical time; and
(ii) TSL Advisers will formulate a recommendation as to
participation by the Company in the disposition.
(b) The Company will have the right to participate in such
disposition on a proportionate basis, at the same price and on the same
terms and conditions as those applicable to the participating
Affiliated Fund(s).
(c) The Company may participate in such disposition without
obtaining prior approval of the Required Majority if: (i) The proposed
participation of the Company and each participating Affiliated Fund in
such disposition is proportionate to its outstanding investment in the
issuer immediately preceding the disposition; (ii) the Board has
approved as being in the best interests of the Company the ability to
participate in such dispositions on a pro rata basis (as described in
greater detail in the application); and (iii) the Board is provided on
a quarterly basis with a list of all dispositions made in accordance
with this condition. In all other cases, TSL Advisers will provide its
written recommendation as to the Company's participation to the
Eligible Directors, and the Company will participate in such
disposition solely to the extent that a Required Majority determines
that it is in the Company's best interests.
(d) The Company and each participating Affiliated Fund will bear
its own expenses in connection with any such disposition.
7. (a) If any Affiliated Fund desires to make a Follow-On
Investment then:
[[Page 69894]]
(i) The relevant Adviser will notify the Company of the proposed
transaction at the earliest practical time; and
(ii) TSL Advisers will formulate a recommendation as to the
proposed participation, including the amount of the proposed Follow-On
Investment, by the Company.
(b) The Company has the right to participate in the Follow-On
Investment to the full extent TSL Advisers deems appropriate, and the
participating Affiliated Funds will be allocated the remaining excess
amount.
(c) TSL Advisers will provide its written recommendation as to the
Company's participation to the Eligible Directors, and the Company will
participate in such Follow-On Investment solely to the extent that a
Required Majority determines that it is in the Company's best interest.
(d) The acquisition of Follow-On Investments as permitted by this
condition will be considered a Co-Investment Transaction for all
purposes and subject to the other conditions set forth in the
application.
8. The Independent Directors will be provided quarterly for review
all information concerning Potential Co-Investment Transactions and Co-
Investment Transactions, including investments made by an Affiliated
Fund that the Company participated in and investments made by an
Affiliated Fund that the Company considered but declined to co-invest
in, so that the Independent Directors may determine whether all
investments made during the preceding quarter, including those
investments that the Company considered but declined to participate in,
comply with the conditions of the Order. In addition, the Independent
Directors will consider at least annually the continued appropriateness
for the Company of participating in new and existing Co-Investment
Transactions.
9. The Company will maintain the records required by section
57(f)(3) of the Act as if each of the investments permitted under these
conditions were approved by the Required Majority under section 57(f).
10. No Independent Director will also be a director, general
partner, managing member or principal, or otherwise an ``affiliated
person'' (as defined in the Act) of any of the Affiliated Funds.
11. The expenses, if any, associated with acquiring, holding or
disposing of any securities acquired in a Co-Investment Transaction
(including, without limitation, the expenses of the distribution of any
such securities registered for sale under the Securities Act) will, to
the extent not payable by the Advisers to Affiliated Funds under their
respective investment advisory agreements with the Affiliated Funds, be
shared by the Company and the Affiliated Funds in proportion to the
relative amounts of the securities to be acquired, held or disposed of,
as the case may be.
12. Any transaction fee (including any break-up fees or commitment
fees but excluding broker's fees contemplated section 17(e) or 57(k) of
the Act, as applicable), received in connection with a Co-Investment
Transaction will be distributed to the Company and the Affiliated Funds
on a pro rata basis based on the amount they invested or committed, as
the case may be, in such Co-Investment Transaction. If any transaction
fee is to be held by an Adviser pending consummation of the
transaction, the fee will be deposited into an account maintained by
such investment adviser at a bank or banks having the qualifications
prescribed in section 26(a)(1) of the Act, and the account will earn a
competitive rate of interest that will also be divided pro rata among
the Company and the Affiliated Funds based on the amount they invest in
such Co-Investment Transaction. None of the Affiliated Funds, Advisers,
nor any affiliated person of the Company will receive additional
compensation or remuneration of any kind as a result of or in
connection with a Co-Investment Transaction (other than (a) in the case
of the Company and the Affiliated Funds, the pro rata transaction fees
described above and fees or other compensation described in condition
2(c)(iii)(C); and (b) in the case of the Advisers, investment advisory
fees paid in accordance with the Company's and the Affiliated Funds'
respective investment advisory agreements).
For the Commission, by the Division of Investment Management,
under delegated authority.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-27696 Filed 11-21-14; 8:45 am]
BILLING CODE 8011-01-P