Advanced Series Trust, et al.; Notice of Application, 70578-70582 [2014-27981]
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70578
Federal Register / Vol. 79, No. 228 / Wednesday, November 26, 2014 / Notices
December 17, 2014. Reply comments are
due by January 7, 2015.
The Request and related filings are
available on the Commission’s Web site
(https://www.prc.gov). The Commission
encourages interested persons to review
the Request for further details.
The Commission appoints Kenneth E.
Richardson to serve as Public
Representative in this proceeding.
III. Ordering Paragraphs
It is ordered:
1. The Commission establishes Docket
No. MC2015–7 to consider matters
raised by the Request.
2. Pursuant to 39 U.S.C. 505, Kenneth
E. Richardson is appointed to serve as
an officer of the Commission (Public
Representative) to represent the
interests of the general public in this
proceeding.
3. Comments by interested persons
are due by December 17, 2014.
4. Reply comments are due by January
7, 2015.
5. The Secretary shall arrange for
publication of this order in the Federal
Register.
By the Commission.
Ruth Ann Abrams,
Acting Secretary.
[FR Doc. 2014–27968 Filed 11–25–14; 8:45 am]
BILLING CODE 7710–FW–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
31342; File No. 812–14159]
Advanced Series Trust, et al.; Notice of
Application
November 20, 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:
Applicants request an order
that would permit them to enter into
and materially amend subadvisory
agreements with Non-Affiliated SubAdvisors (as defined below) and
Wholly-Owned Sub-Advisors (as
defined below) without shareholder
approval and would grant relief from
certain disclosure requirements. The
requested order would supersede a prior
order that granted exemptive relief from
section 15(a) of the Act and rule 18f–2
under the Act solely with respect to
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SUMMARY:
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Non-Affiliated Sub-Advisors (‘‘Prior
Order’’).1
Applicants: Advanced Series Trust;
Prudential’s Gibraltar Fund, Inc.; The
Prudential Series Fund (collectively, the
‘‘Insurance Funds’’); Prudential Global
Total Return Fund, Inc.; Prudential
Investment Portfolios 2; Prudential
Investment Portfolios 3; Prudential
Investment Portfolios 4; Prudential
Investment Portfolios 5; Prudential
Investment Portfolios 6; Prudential
Investment Portfolios 7; Prudential
Investment Portfolios 8; Prudential
Investment Portfolios 9; Prudential
Investment Portfolios 12; Prudential
Investment Portfolios 16; Prudential
Investment Portfolios 18; Prudential
Investment Portfolios, Inc.; Prudential
Investment Portfolios, Inc. 10;
Prudential Investment Portfolios, Inc.
14; Prudential Investment Portfolios,
Inc. 15; Prudential Investment
Portfolios, Inc. 17; Prudential Jennison
Blend Fund, Inc.; Prudential Jennison
Mid-Cap Growth Fund, Inc.; Prudential
Jennison Natural Resources Fund, Inc.;
Prudential Jennison Small Company
Fund, Inc.; Prudential Money Mart
Assets, Inc.; Prudential National Muni
Fund, Inc.; Prudential Sector Funds,
Inc.; Prudential Short-Term Corporate
Bond Fund, Inc.; Prudential World
Fund, Inc.; The Prudential Variable
Contract Account–2; The Prudential
Variable Contract Account–10; The
Prudential Variable Contract Account–
11; The Target Portfolio Trust
(collectively, the ‘‘Retail Funds’’ and
together with the Insurance Funds, the
‘‘Prudential Investment Companies’’);
Prudential Investments LLC (‘‘PI’’); and
AST Investment Services, Inc.
(‘‘ASTIS’’).
DATES: The application was filed on
May 24, 2013, and amended on October
4, 2013, February 21, 2014, October 3,
2014 and November 18, 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
1 The Target Portfolio Trust and Prudential
Mutual Fund Management, Inc., Investment
Company Act Release Nos. 22139 (Aug. 13, 1996)
(notice) and 22215 (Sep. 11, 1996) (order).
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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: Brent J. Fields, Secretary,
U.S. Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
Applicants: Prudential Investments
LLC, 100 Mulberry Street, Gateway
Center Three, 14th Floor, Newark, New
Jersey 07102.
FOR FURTHER INFORMATION CONTACT:
Laura J. Riegel, Senior Counsel, at (202)
551–6873, 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. Each Prudential Investment
Company is organized as a either a
Massachusetts business trust, a
Delaware trust, a Maryland corporation
or a New Jersey insurance company
separate account, and is registered with
the Commission as an open-end
management investment company
under the Act. Each Prudential
Investment Company (other than
Prudential’s Gibraltar Fund, Inc., The
Prudential Variable Contract Account–2,
The Prudential Variable Contract
Account–10, and The Prudential
Variable Contract Account–11) may
offer shares of one or more series (each,
a ‘‘Series’’ and collectively, the
‘‘Series’’) with its own distinct
investment objectives, policies and
restrictions.2 PI is a New York limited
liability company and ASTIS is a
Connecticut corporation, and each is
registered as an investment adviser
2 The term ‘‘Series’’ includes the Prudential
Investment Companies that do not offer multiple
series. A Prudential Investment Company or
Subadvised Series (as defined below) may in the
future be organized as a master fund (each, a
‘‘Master Fund’’) in a master-feeder structure
pursuant to section 12(d)(1)(E) of the Act. Certain
Series, including any other investment company or
series thereof that is advised by an Advisor (as
defined below), may invest substantially all of their
assets in a Master Fund pursuant to section
12(d)(1)(E) of the Act (each a ‘‘Feeder Fund’’). No
Feeder Fund will engage any investment adviser or
sub-advisors other than through approving the
engagement of the applicable Master Fund’s
investment adviser and any sub-advisors.
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under the Investment Advisers Act of
1940 (‘‘Advisers Act’’). PI and ASTIS are
indirect wholly-owned subsidiaries of
Prudential Financial, Inc., a financial
services organization.
2. Applicants request an order to
permit the Advisor,3 subject to the
approval of the board of directors or
trustees of the applicable Series (each a
‘‘Board’’),4 including a majority of the
directors or trustees who are not
‘‘interested persons’’ of the Series or the
Advisor as defined in section 2(a)(19) of
the Act (the ‘‘Independent Board
Members’’), to, without obtaining
shareholder approval: (i) Select SubAdvisors 5 to manage all or a portion of
the assets of a Series and enter into SubAdvisory Agreements (as defined below)
with the Sub-Advisors; and (ii)
materially amend Sub-Advisory
Agreements with the Sub-Advisors.6
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
Advisor, uses the multi-manager
structure described in the application
(‘‘Multi-Manager Structure’’), and
complies with the terms and conditions
set forth in the application (each, a
3 The term ‘‘Advisor’’ means PI, ASTIS, or any
entity controlling, controlled by or under common
control with, PI, ASTIS, or successors to either of
them. For purposes of the requested order,
‘‘successor’’ is limited to an entity that results from
a reorganization into another jurisdiction or a
change in the type of business organization. Each
Advisor is, or will be, registered with the
Commission as an investment adviser under the
Advisers Act.
4 The term ‘‘Board’’ includes the board of
directors or trustees of any future Subadvised
Series.
5 A ‘‘Sub-Advisor’’ for a Series is (a) an indirect
or direct ‘‘wholly-owned subsidiary’’ (as such term
is defined in the Act) of the Advisor for that Series,
(b) a sister company of the Advisor for that 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 Advisor (each of (a) and (b), a
‘‘Wholly-Owned Sub-Advisor’’ and collectively, the
‘‘Wholly-Owned Sub-Advisors’’), or (c) an
investment sub-advisor for that Series that is not an
‘‘affiliated person’’ (as such term is defined in
section 2(a)(3) of the Act) of the Series, any Feeder
Fund invested in a Series that is a Master Fund, the
applicable Prudential Investment Company, or the
Advisor, except to the extent that an affiliation
arises solely because the sub-advisor serves as a
sub-advisor to a Series (each, a ‘‘Non-Affiliated SubAdvisor’’).
6 Shareholder approval will continue to be
required for any other sub-advisor changes (not
otherwise permitted by rule or other action of the
Commission or staff) and material amendments to
an existing Sub-Advisory Agreement (as defined
below) with any sub-advisor other than a NonAffiliated Sub-Advisor or Wholly-Owned SubAdvisor (all such changes referred to as ‘‘Ineligible
Sub-Advisor Changes’’).
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‘‘Subadvised Series’’).7 The requested
relief will not extend to any sub-advisor,
other than a Wholly-Owned SubAdvisor, who is an affiliated person, as
defined in section 2(a)(3) of the Act, of
the Subadvised Series, of any Feeder
Fund, or of the Advisor, other than by
reason of serving as a sub-advisor to one
or more of the Subadvised Series
(‘‘Affiliated Sub-Advisor’’).
3. PI serves as the investment adviser
to each Prudential Investment Company
pursuant to an investment advisory
agreement with the applicable
Prudential Investment Company, and
ASTIS serves as co-investment adviser
to certain Series of Advanced Series
Trust pursuant to an investment
advisory agreement with PI and
Advanced Series Trust (each, an
‘‘Investment Management Agreement’’
and together the ‘‘Investment
Management Agreements’’). The
Investment Management Agreement for
each existing Series was approved by
the applicable Board, including a
majority the Independent Board
Members, and by the shareholders of
that Series in the manner required by
sections 15(a) and 15(c) of the Act and
rule 18f–2 thereunder. The terms of
these Investment Management
Agreements comply with section 15(a)
of the Act. Each other Investment
Management Agreement will comply
with section 15(a) of the Act and will be
similarly approved.
4. Under the terms of each Investment
Management Agreement, the Advisor,
subject to the supervision of the Board,
provides continuous investment
management of the assets of each Series.
The Advisor periodically reviews a
Series’ investment policies and
strategies and, based on the need of a
particular Series, may recommend
changes to the investment policies and
strategies of the Series for consideration
by the Board. For its services to each
Series under the applicable Investment
Management Agreement, the Advisor
receives an investment management fee
from the Series based on the average net
assets of that Series.
5. Consistent with the terms of each
Investment Management Agreement, the
Advisor may, subject to the approval of
7 All registered open-end investment companies
that currently intend to rely on the requested order
are named as applicants. All Series that currently
are, or that currently intend to be, Subadvised
Series are identified in the application. 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 SubAdvisor, the trademark or trade name that is owned
by or publicly used to identify the Advisor that
serves as the primary adviser to the Subadvised
Series will precede the name of the Sub-Advisor.
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the applicable Board, including a
majority of the Independent Board
Members, and the shareholders of the
applicable Subadvised Series (if
required), delegate portfolio
management responsibilities of all or a
portion of the assets of a Subadvised
Series to one or more Sub-Advisors. The
Advisor continues to have overall
responsibility for the management and
investment of the assets of each
Subadvised Series, and the Advisor’s
responsibilities include, for example,
recommending the removal or
replacement of Sub-Advisors and
determining the portion of that
Subadvised Series’ assets to be managed
by any given Sub-Advisor and
reallocating those assets as necessary
from time to time.
6. The Advisor has entered into subadvisory agreements with various SubAdvisors (‘‘Sub-Advisory Agreements’’)
on behalf of the Subadvised Series. The
Advisor may also, in the future, enter
into Sub-Advisory Agreements on
behalf of other Series. Each current SubAdvisor is, and any future Sub-Advisor
will be, an ‘‘investment adviser’’ as
defined in section 2(a)(20)(B) of the Act
and registered as an investment adviser
under the Advisers Act or not subject to
such registration. The Sub-Advisory
Agreements were approved by the
applicable Board, including a majority
of the Independent Board Members, and
to the extent that the Prior Order did not
apply, the shareholders of the
applicable Subadvised Series in
accordance with sections 15(a) and 15(c)
of the Act and rule 18f–2 thereunder. In
addition, the terms of each SubAdvisory Agreement comply fully with
the requirements of section 15(a) of the
Act. The Sub-Advisors, subject to the
supervision of the Advisor and
oversight of the applicable Board,
determine the securities and other
instruments to be purchased, sold or
entered into by a Subadvised Series’
portfolio or a portion thereof, and place
orders with brokers or dealers that they
select. The Advisor will compensate
each Sub-Advisor out of the fee paid to
the Advisor under the relevant
Investment Management Agreement.
7. Each Subadvised Series will inform
shareholders of the hiring of a new SubAdvisor pursuant to the following
procedures (‘‘Modified Notice and
Access Procedures’’): (a) Within 90 days
after a new Sub-Advisor is hired for any
Subadvised Series, that Subadvised
Series will send its shareholders 8 either
8 If the Subadvised Series is a Master Fund, for
purposes of the Modified Notice and Access
Procedures, ‘‘shareholders’’ include both the
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a Multi-manager Notice or a Multimanager Notice and Multi-manager
Information Statement; 9 and (b) the
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.
Applicants state that, in the
circumstances described in the
application, a proxy solicitation to
approve the appointment of new SubAdvisors provides no more meaningful
information to shareholders than the
proposed Multi-manager Information
Statement. Applicants also state that the
applicable Board would comply with
the requirements of sections 15(a) and
15(c) of the Act before entering into or
amending Sub-Advisory Agreements.
8. 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 Advisor to
each Sub-Advisor. 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
Advisor and any Wholly-Owned SubAdvisors; (b) the aggregate fees paid to
Non-Affiliated Sub-Advisors; and (c) the
fee paid to each Affiliated Sub-Advisor
(collectively, the ‘‘Aggregate Fee
Disclosure’’). An exemption is requested
to permit the Subavised Series to
include only the Aggregate Fee
Disclosure. All other items required by
shareholders of the applicable Master Fund and the
shareholders of its Feeder Funds.
9 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 Sub-Advisor (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 Web site address; (d)
state the time period during which the Multimanager Information Statement will remain
available on that Web site; (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’’ 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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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
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. Form N–3 is the registration
statement used by separate accounts
offering variable annuity contracts. Item
21(a)(iii) of Form N–3 requires the
separate account to disclose the method
of computing the ‘‘advisory fee payable’’
by the separate account, including the
total dollar amounts ‘‘paid to the adviser
by the [r]egistrant or its [i]nsurance
[c]ompany under the investment
advisory contract for the last three fiscal
years.’’
4. 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.
5. Regulation S–X sets forth the
requirements for financial statements
required to be included as part of a
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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.
6. 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.
7. Applicants assert that the
shareholders expect the Advisor, subject
to the review and approval of the
applicable Board, to select the SubAdvisors 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 SubAdvisors 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 Advisor to perform the
duties for which the shareholders of the
Subadvised Series are paying the
Advisor—the selection, supervision and
evaluation of the Sub-Advisors—
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 each Investment Management
Agreement will continue to be fully
subject to section 15(a) of the Act 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 Management
Agreements.
8. Applicants assert that disclosure of
the individual fees that the Advisor
would pay to the Sub-Advisors 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 Sub-Advisors are to inform
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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
Advisor 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 Advisor’s ability to
negotiate the fees paid to Sub-Advisors.
Applicants state that the Advisor may
be able to negotiate rates that are below
a Sub-Advisor’s ‘‘posted’’ amounts if the
Advisor is not required to disclose the
Sub-Advisors’ fees to the public.
Applicants submit that the relief
requested to use Aggregate Fee
Disclosure will also encourage SubAdvisors to negotiate lower subadvisory fees with the Advisor if the
lower fees are not required to be made
public.
9. 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. 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.
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.
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Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions: 10
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 Sub10 A Subadvised Series relying on the order
granted hereunder will comply with conditions 8,
9, and 12 only if it relies on the relief that would
allow it to provide Aggregate Fee Disclosure.
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Advisors, will be, or has been, approved
by a majority of the/Subadvised Series’
outstanding voting securities as defined
in the Act, which in the case of a Master
Fund will include voting instructions
provided by shareholders of the Feeder
Funds investing in such Master Fund or
other voting arrangements that comply
with section 12(d)(1)(E)(iii)(aa) of the
Act (or, in the case on an insurancerelated Subadvised Series, pursuant to
the voting instructions provided by
contract owners with assets allocated to
any registered separate account for
which the Subadvised Series serves as
a funding medium), 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, and in the case of a
Master Fund relying on the requested
relief, the prospectus for each Feeder
Fund investing in such Master Fund,
will disclose the existence, substance
and effect of any order granted pursuant
to the application. Each Subadvised
Series (and any such Feeder Fund) will
hold itself out to the public as
employing the Multi-Manager Structure
described in the application. Each
prospectus will prominently disclose
that the Advisor has the ultimate
responsibility, subject to oversight by
the applicable Board, to oversee the
Sub-Advisors and recommend their
hiring, termination, and replacement.
3. The Advisor 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 applicable
Board, the Advisor will (a) set a
Subadvised Series’ overall investment
strategies, (b) evaluate, select, and
recommend Sub-Advisors to manage all
or a portion of a Subadvised Series’
assets, and (c) implement procedures
reasonably designed to ensure that SubAdvisors comply with a Subadvised
Series’ investment objective, policies
and restrictions. Subject to review by
the applicable Board, the Advisor will
(a) when appropriate, allocate and
reallocate a Subadvised Series’ assets
among Sub-Advisors; and (b) monitor
and evaluate the performance of SubAdvisors.
4. A Subadvised Series will not make
any Ineligible Sub-Advisor Changes
without the approval of the
shareholders of the applicable
Subadvised Series, which in the case of
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70581
a Master Fund will include voting
instructions provided by shareholders of
the Feeder Fund investing in such
Master Fund or other voting
arrangements that comply with section
12(d)(1)(E)(iii)(aa) of the Act.
5. A Subadvised Series will inform
shareholders, and if the Subadvised
Series is a Master Fund, shareholders of
any Feeder Funds, of the hiring of a new
Sub-Advisor within 90 days after the
hiring of the new Sub-Advisor pursuant
to the Modified Notice and Access
Procedures.
6. At all times, at least a majority of
the applicable 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 Advisor will provide the
applicable Board, no less frequently
than quarterly, with information about
the profitability of the Advisor on a per
Subadvised Series basis. The
information will reflect the impact on
profitability of the hiring or termination
of any sub-advisor during the applicable
quarter.
9. Whenever a sub-advisor is hired or
terminated, the Advisor will provide the
applicable Board with information
showing the expected impact on the
profitability of the Advisor.
10. Whenever a sub-advisor change is
proposed for a Subadvised Series with
an Affiliated Sub-Advisor or a WhollyOwned Sub-Advisor, the applicable
Board, including a majority of the
Independent Board Members, will make
a separate finding, reflected in the
applicable Board minutes, that such
change is in the best interests of the
Subadvised Series and its shareholders,
and if the Subadvised Series is a Master
Fund, the best interests of any
applicable Feeder Funds and their
respective shareholders, and does not
involve a conflict of interest from which
the Advisor or the Affiliated SubAdvisor or Wholly-Owned Sub-Advisor
derives an inappropriate advantage.
11. No Board member or officer of a
Prudential Investment Company, a
Subadvised Series, or a Feeder Fund
that invests in a Subadvised Series that
is a Master Fund, or director, manager
or officer of the Advisor, will own
directly or indirectly (other than
through a pooled investment vehicle
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Federal Register / Vol. 79, No. 228 / Wednesday, November 26, 2014 / Notices
that is not controlled by such person)
any interest in a Sub-Advisor except for
(a) ownership of interests in the Advisor
or any entity, other than a WhollyOwned Sub-Advisor, that controls, is
controlled by, or is under common
control with the Advisor, or (b)
ownership of less than 1% of the
outstanding securities of any class of
equity or debt of any publicly traded
company that is either a Sub-Advisor or
an entity that controls, is controlled by,
or is under common control with, a SubAdvisor.
12. Each Subadvised Series and any
Feeder Fund that invests in a
Subadvised Series that is a Master Fund
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
Management Agreement or SubAdvisory 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. 2014–27981 Filed 11–25–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
31341; File No. 813–366]
BlackRock, Inc., et al.; Notice of
Application
November 20, 2014.
Securities and Exchange
Commission.
ACTION: Notice of application for an
order under sections 6(b) and 6(e) of the
Investment Company Act of 1940 (the
‘‘Act’’) granting an exemption from all
provisions of the Act, and the rules and
regulations thereunder, except sections
9, 17, 30, 36 through 53 and the rules
and regulations under those sections.
With respect to sections 17(a), (d), (e),
(f), (g) and (j) and 30(a), (b), (e) and (h)
of the Act, and the rules and regulations
thereunder, and rule 38a–1 under the
Act, applicants request a limited
mstockstill on DSK4VPTVN1PROD with NOTICES
AGENCY:
VerDate Sep<11>2014
17:21 Nov 25, 2014
Jkt 235001
exemption as set forth in the
application.
Applicants request an order to
exempt certain investment vehicles
formed for the benefit of eligible
employees of BlackRock, Inc. and its
affiliates (‘‘Partnerships’’) from certain
provisions of the Act. Each Partnership
will be an ‘‘employees’ securities
company’’ within the meaning of
section 2(a)(13) of the Act. Applicants:
BlackRock, Inc. (‘‘BlackRock’’),
BlackRock Energy Opportunity
(Employees) Fund, L.P. (the ‘‘Energy
Fund’’), Vesey Street Employee Fund
IV, L.P. (the ‘‘Vesey Street Fund’’),
BlackRock Energy Opportunity Fund
GP, LLC (the ‘‘Energy Fund GP’’),
BlackRock DivPEP IV, LLC (the ‘‘Vesey
Street Fund GP’’), BlackRock Capital
Management, Inc. (‘‘BCM’’), and
BlackRock Investment Management,
LLC (‘‘BIM’’).
DATES: The application was filed on
April 23, 2007, and amended on June
29, 2010, January 15, 2013, May 17,
2013, October 17, 2013, April 3, 2014,
and November 19, 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 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: Secretary, U.S. Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090;
Applicants, 40 East 52nd Street, New
York, NY 10022.
FOR FURTHER INFORMATION CONTACT:
Deepak T. Pai, Senior Counsel, at (202)
551–6876, 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 an applicant using the
Company’s name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Applicants’ Representations
1. BlackRock, a Delaware corporation,
and its affiliates provide investment
management, risk management and
advisory services to institutional and
retail clients around the world.
2. The Partnerships have been or will
be established primarily for the benefit
of key employees of BlackRock or of any
affiliate within the meaning of rule 12b–
2 under the Securities Exchange Act of
1934 (the ‘‘1934 Act’’) of BlackRock (all
such affiliates are subsidiaries of
BlackRock, and together with BlackRock
are referred to collectively as the
‘‘BlackRock Group’’ and individually as
a ‘‘BlackRock Group entity’’) as part of
a program designed to create capital
building opportunities that are
competitive with those at other financial
services firms and to facilitate the
BlackRock Group’s recruitment of high
caliber professionals. Each of the
Partnerships will be structured as a
limited liability company, limited
partnership, corporation, business trust
or other entity organized under the laws
of the state of Delaware or another U.S.
or non-U.S. jurisdiction or any other
‘‘issuer’’ (as defined in section 2(a)(22)
of the Act). Each Partnership will be an
‘‘employees’ securities company’’
within the meaning of section 2(a)(13) of
the Act and will operate as a diversified
or non-diversified closed-end
management investment company.
3. The Energy Fund was formed on
April 9, 2007 as a Delaware limited
partnership. The Energy Fund GP acts
as General Partner (as defined below) to
the Energy Fund. The Energy Fund
invests concurrently with BlackRock
Energy Opportunity Master Fund, L.P.,
a BlackRock Third Party Fund (as
defined below), which seeks to achieve
long term capital appreciation through
various types of non-control
investments in companies primarily
engaged in the energy and natural
resource industries. The Energy Fund is
no longer accepting additional
investors. BCM, an indirect whollyowned subsidiary of BlackRock, serves
as Investment Adviser (as defined
below) for the Energy Fund and
provides portfolio management,
research and administrative services for
the Energy Fund. The Vesey Street Fund
was formed on November 3, 2008 as a
Delaware limited partnership. The
Vesey Street Fund GP acts as General
Partner to the Vesey Street Fund. The
Vesey Street Fund invests concurrently
with Vesey Street Fund IV, L.P., a
BlackRock Third Party Fund, and other
SUMMARY:
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Agencies
[Federal Register Volume 79, Number 228 (Wednesday, November 26, 2014)]
[Notices]
[Pages 70578-70582]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-27981]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 31342; File No. 812-14159]
Advanced Series Trust, et al.; Notice of Application
November 20, 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: Applicants request an order that would permit them to enter
into and materially amend subadvisory agreements with Non-Affiliated
Sub-Advisors (as defined below) and Wholly-Owned Sub-Advisors (as
defined below) without shareholder approval and would grant relief from
certain disclosure requirements. The requested order would supersede a
prior order that granted exemptive relief from section 15(a) of the Act
and rule 18f-2 under the Act solely with respect to Non-Affiliated Sub-
Advisors (``Prior Order'').\1\
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\1\ The Target Portfolio Trust and Prudential Mutual Fund
Management, Inc., Investment Company Act Release Nos. 22139 (Aug.
13, 1996) (notice) and 22215 (Sep. 11, 1996) (order).
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Applicants: Advanced Series Trust; Prudential's Gibraltar Fund,
Inc.; The Prudential Series Fund (collectively, the ``Insurance
Funds''); Prudential Global Total Return Fund, Inc.; Prudential
Investment Portfolios 2; Prudential Investment Portfolios 3; Prudential
Investment Portfolios 4; Prudential Investment Portfolios 5; Prudential
Investment Portfolios 6; Prudential Investment Portfolios 7; Prudential
Investment Portfolios 8; Prudential Investment Portfolios 9; Prudential
Investment Portfolios 12; Prudential Investment Portfolios 16;
Prudential Investment Portfolios 18; Prudential Investment Portfolios,
Inc.; Prudential Investment Portfolios, Inc. 10; Prudential Investment
Portfolios, Inc. 14; Prudential Investment Portfolios, Inc. 15;
Prudential Investment Portfolios, Inc. 17; Prudential Jennison Blend
Fund, Inc.; Prudential Jennison Mid-Cap Growth Fund, Inc.; Prudential
Jennison Natural Resources Fund, Inc.; Prudential Jennison Small
Company Fund, Inc.; Prudential Money Mart Assets, Inc.; Prudential
National Muni Fund, Inc.; Prudential Sector Funds, Inc.; Prudential
Short-Term Corporate Bond Fund, Inc.; Prudential World Fund, Inc.; The
Prudential Variable Contract Account-2; The Prudential Variable
Contract Account-10; The Prudential Variable Contract Account-11; The
Target Portfolio Trust (collectively, the ``Retail Funds'' and together
with the Insurance Funds, the ``Prudential Investment Companies'');
Prudential Investments LLC (``PI''); and AST Investment Services, Inc.
(``ASTIS'').
DATES: The application was filed on May 24, 2013, and amended on
October 4, 2013, February 21, 2014, October 3, 2014 and November 18,
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: Brent J. Fields, Secretary, U.S. Securities and Exchange
Commission, 100 F Street NE., Washington, DC 20549-1090. Applicants:
Prudential Investments LLC, 100 Mulberry Street, Gateway Center Three,
14th Floor, Newark, New Jersey 07102.
FOR FURTHER INFORMATION CONTACT: Laura J. Riegel, Senior Counsel, at
(202) 551-6873, 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. Each Prudential Investment Company is organized as a either a
Massachusetts business trust, a Delaware trust, a Maryland corporation
or a New Jersey insurance company separate account, and is registered
with the Commission as an open-end management investment company under
the Act. Each Prudential Investment Company (other than Prudential's
Gibraltar Fund, Inc., The Prudential Variable Contract Account-2, The
Prudential Variable Contract Account-10, and The Prudential Variable
Contract Account-11) may offer shares of one or more series (each, a
``Series'' and collectively, the ``Series'') with its own distinct
investment objectives, policies and restrictions.\2\ PI is a New York
limited liability company and ASTIS is a Connecticut corporation, and
each is registered as an investment adviser
[[Page 70579]]
under the Investment Advisers Act of 1940 (``Advisers Act''). PI and
ASTIS are indirect wholly-owned subsidiaries of Prudential Financial,
Inc., a financial services organization.
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\2\ The term ``Series'' includes the Prudential Investment
Companies that do not offer multiple series. A Prudential Investment
Company or Subadvised Series (as defined below) may in the future be
organized as a master fund (each, a ``Master Fund'') in a master-
feeder structure pursuant to section 12(d)(1)(E) of the Act. Certain
Series, including any other investment company or series thereof
that is advised by an Advisor (as defined below), may invest
substantially all of their assets in a Master Fund pursuant to
section 12(d)(1)(E) of the Act (each a ``Feeder Fund''). No Feeder
Fund will engage any investment adviser or sub-advisors other than
through approving the engagement of the applicable Master Fund's
investment adviser and any sub-advisors.
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2. Applicants request an order to permit the Advisor,\3\ subject to
the approval of the board of directors or trustees of the applicable
Series (each a ``Board''),\4\ including a majority of the directors or
trustees who are not ``interested persons'' of the Series or the
Advisor as defined in section 2(a)(19) of the Act (the ``Independent
Board Members''), to, without obtaining shareholder approval: (i)
Select Sub-Advisors \5\ to manage all or a portion of the assets of a
Series and enter into Sub-Advisory Agreements (as defined below) with
the Sub-Advisors; and (ii) materially amend Sub-Advisory Agreements
with the Sub-Advisors.\6\ 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 Advisor, uses the multi-manager
structure described in the application (``Multi-Manager Structure''),
and complies with the terms and conditions set forth in the application
(each, a ``Subadvised Series'').\7\ The requested relief will not
extend to any sub-advisor, other than a Wholly-Owned Sub-Advisor, who
is an affiliated person, as defined in section 2(a)(3) of the Act, of
the Subadvised Series, of any Feeder Fund, or of the Advisor, other
than by reason of serving as a sub-advisor to one or more of the
Subadvised Series (``Affiliated Sub-Advisor'').
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\3\ The term ``Advisor'' means PI, ASTIS, or any entity
controlling, controlled by or under common control with, PI, ASTIS,
or successors to either of them. For purposes of the requested
order, ``successor'' is limited to an entity that results from a
reorganization into another jurisdiction or a change in the type of
business organization. Each Advisor is, or will be, registered with
the Commission as an investment adviser under the Advisers Act.
\4\ The term ``Board'' includes the board of directors or
trustees of any future Subadvised Series.
\5\ A ``Sub-Advisor'' for a Series is (a) an indirect or direct
``wholly-owned subsidiary'' (as such term is defined in the Act) of
the Advisor for that Series, (b) a sister company of the Advisor for
that 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 Advisor (each
of (a) and (b), a ``Wholly-Owned Sub-Advisor'' and collectively, the
``Wholly-Owned Sub-Advisors''), or (c) an investment sub-advisor for
that Series that is not an ``affiliated person'' (as such term is
defined in section 2(a)(3) of the Act) of the Series, any Feeder
Fund invested in a Series that is a Master Fund, the applicable
Prudential Investment Company, or the Advisor, except to the extent
that an affiliation arises solely because the sub-advisor serves as
a sub-advisor to a Series (each, a ``Non-Affiliated Sub-Advisor'').
\6\ Shareholder approval will continue to be required for any
other sub-advisor changes (not otherwise permitted by rule or other
action of the Commission or staff) and material amendments to an
existing Sub-Advisory Agreement (as defined below) with any sub-
advisor other than a Non-Affiliated Sub-Advisor or Wholly-Owned Sub-
Advisor (all such changes referred to as ``Ineligible Sub-Advisor
Changes'').
\7\ All registered open-end investment companies that currently
intend to rely on the requested order are named as applicants. All
Series that currently are, or that currently intend to be,
Subadvised Series are identified in the application. 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 Sub-Advisor, the
trademark or trade name that is owned by or publicly used to
identify the Advisor that serves as the primary adviser to the
Subadvised Series will precede the name of the Sub-Advisor.
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3. PI serves as the investment adviser to each Prudential
Investment Company pursuant to an investment advisory agreement with
the applicable Prudential Investment Company, and ASTIS serves as co-
investment adviser to certain Series of Advanced Series Trust pursuant
to an investment advisory agreement with PI and Advanced Series Trust
(each, an ``Investment Management Agreement'' and together the
``Investment Management Agreements''). The Investment Management
Agreement for each existing Series was approved by the applicable
Board, including a majority the Independent Board Members, and by the
shareholders of that Series in the manner required by sections 15(a)
and 15(c) of the Act and rule 18f-2 thereunder. The terms of these
Investment Management Agreements comply with section 15(a) of the Act.
Each other Investment Management Agreement will comply with section
15(a) of the Act and will be similarly approved.
4. Under the terms of each Investment Management Agreement, the
Advisor, subject to the supervision of the Board, provides continuous
investment management of the assets of each Series. The Advisor
periodically reviews a Series' investment policies and strategies and,
based on the need of a particular Series, may recommend changes to the
investment policies and strategies of the Series for consideration by
the Board. For its services to each Series under the applicable
Investment Management Agreement, the Advisor receives an investment
management fee from the Series based on the average net assets of that
Series.
5. Consistent with the terms of each Investment Management
Agreement, the Advisor may, subject to the approval of the applicable
Board, including a majority of the Independent Board Members, and the
shareholders of the applicable Subadvised Series (if required),
delegate portfolio management responsibilities of all or a portion of
the assets of a Subadvised Series to one or more Sub-Advisors. The
Advisor continues to have overall responsibility for the management and
investment of the assets of each Subadvised Series, and the Advisor's
responsibilities include, for example, recommending the removal or
replacement of Sub-Advisors and determining the portion of that
Subadvised Series' assets to be managed by any given Sub-Advisor and
reallocating those assets as necessary from time to time.
6. The Advisor has entered into sub-advisory agreements with
various Sub-Advisors (``Sub-Advisory Agreements'') on behalf of the
Subadvised Series. The Advisor may also, in the future, enter into Sub-
Advisory Agreements on behalf of other Series. Each current Sub-Advisor
is, and any future Sub-Advisor will be, an ``investment adviser'' as
defined in section 2(a)(20)(B) of the Act and registered as an
investment adviser under the Advisers Act or not subject to such
registration. The Sub-Advisory Agreements were approved by the
applicable Board, including a majority of the Independent Board
Members, and to the extent that the Prior Order did not apply, the
shareholders of the applicable Subadvised Series in accordance with
sections 15(a) and 15(c) of the Act and rule 18f-2 thereunder. In
addition, the terms of each Sub-Advisory Agreement comply fully with
the requirements of section 15(a) of the Act. The Sub-Advisors, subject
to the supervision of the Advisor and oversight of the applicable
Board, determine the securities and other instruments to be purchased,
sold or entered into by a Subadvised Series' portfolio or a portion
thereof, and place orders with brokers or dealers that they select. The
Advisor will compensate each Sub-Advisor out of the fee paid to the
Advisor under the relevant Investment Management Agreement.
7. Each Subadvised Series will inform shareholders of the hiring of
a new Sub-Advisor pursuant to the following procedures (``Modified
Notice and Access Procedures''): (a) Within 90 days after a new Sub-
Advisor is hired for any Subadvised Series, that Subadvised Series will
send its shareholders \8\ either
[[Page 70580]]
a Multi-manager Notice or a Multi-manager Notice and Multi-manager
Information Statement; \9\ 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. Applicants state that, in the
circumstances described in the application, a proxy solicitation to
approve the appointment of new Sub-Advisors provides no more meaningful
information to shareholders than the proposed Multi-manager Information
Statement. Applicants also state that the applicable 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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\8\ If the Subadvised Series is a Master Fund, for purposes of
the Modified Notice and Access Procedures, ``shareholders'' include
both the shareholders of the applicable Master Fund and the
shareholders of its Feeder Funds.
\9\ 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 Sub-Advisor (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 Web site address; (d) state the time period during which
the Multi-manager Information Statement will remain available on
that Web site; (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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8. 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 Advisor to each Sub-Advisor.
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 Advisor and any Wholly-Owned Sub-
Advisors; (b) the aggregate fees paid to Non-Affiliated Sub-Advisors;
and (c) the fee paid to each Affiliated Sub-Advisor (collectively, the
``Aggregate Fee Disclosure''). An exemption is requested to permit the
Subavised 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 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. Form N-3 is the registration statement used by separate accounts
offering variable annuity contracts. Item 21(a)(iii) of Form N-3
requires the separate account to disclose the method of computing the
``advisory fee payable'' by the separate account, including the total
dollar amounts ``paid to the adviser by the [r]egistrant or its
[i]nsurance [c]ompany under the investment advisory contract for the
last three fiscal years.''
4. 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.
5. 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.
6. 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.
7. Applicants assert that the shareholders expect the Advisor,
subject to the review and approval of the applicable Board, to select
the Sub-Advisors 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 Sub-Advisors 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 Advisor to perform the
duties for which the shareholders of the Subadvised Series are paying
the Advisor--the selection, supervision and evaluation of the Sub-
Advisors--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 each Investment Management Agreement will
continue to be fully subject to section 15(a) of the Act 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 Management Agreements.
8. Applicants assert that disclosure of the individual fees that
the Advisor would pay to the Sub-Advisors 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
Sub-Advisors are to inform
[[Page 70581]]
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
Advisor 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 Advisor's ability to negotiate the fees
paid to Sub-Advisors. Applicants state that the Advisor may be able to
negotiate rates that are below a Sub-Advisor's ``posted'' amounts if
the Advisor is not required to disclose the Sub-Advisors' fees to the
public. Applicants submit that the relief requested to use Aggregate
Fee Disclosure will also encourage Sub-Advisors to negotiate lower sub-
advisory fees with the Advisor if the lower fees are not required to be
made public.
9. 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.
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.
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: \10\
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\10\ A Subadvised Series relying on the order granted hereunder
will comply with conditions 8, 9, and 12 only if it relies on the
relief that would allow it to provide Aggregate Fee Disclosure.
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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 Sub-
Advisors, will be, or has been, approved by a majority of the/
Subadvised Series' outstanding voting securities as defined in the Act,
which in the case of a Master Fund will include voting instructions
provided by shareholders of the Feeder Funds investing in such Master
Fund or other voting arrangements that comply with section
12(d)(1)(E)(iii)(aa) of the Act (or, in the case on an insurance-
related Subadvised Series, pursuant to the voting instructions provided
by contract owners with assets allocated to any registered separate
account for which the Subadvised Series serves as a funding medium),
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, and in the case of a
Master Fund relying on the requested relief, the prospectus for each
Feeder Fund investing in such Master Fund, will disclose the existence,
substance and effect of any order granted pursuant to the application.
Each Subadvised Series (and any such Feeder Fund) will hold itself out
to the public as employing the Multi-Manager Structure described in the
application. Each prospectus will prominently disclose that the Advisor
has the ultimate responsibility, subject to oversight by the applicable
Board, to oversee the Sub-Advisors and recommend their hiring,
termination, and replacement.
3. The Advisor 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 applicable Board, the Advisor
will (a) set a Subadvised Series' overall investment strategies, (b)
evaluate, select, and recommend Sub-Advisors to manage all or a portion
of a Subadvised Series' assets, and (c) implement procedures reasonably
designed to ensure that Sub-Advisors comply with a Subadvised Series'
investment objective, policies and restrictions. Subject to review by
the applicable Board, the Advisor will (a) when appropriate, allocate
and reallocate a Subadvised Series' assets among Sub-Advisors; and (b)
monitor and evaluate the performance of Sub-Advisors.
4. A Subadvised Series will not make any Ineligible Sub-Advisor
Changes without the approval of the shareholders of the applicable
Subadvised Series, which in the case of a Master Fund will include
voting instructions provided by shareholders of the Feeder Fund
investing in such Master Fund or other voting arrangements that comply
with section 12(d)(1)(E)(iii)(aa) of the Act.
5. A Subadvised Series will inform shareholders, and if the
Subadvised Series is a Master Fund, shareholders of any Feeder Funds,
of the hiring of a new Sub-Advisor within 90 days after the hiring of
the new Sub-Advisor pursuant to the Modified Notice and Access
Procedures.
6. At all times, at least a majority of the applicable 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 Advisor will provide the applicable Board, no less
frequently than quarterly, with information about the profitability of
the Advisor on a per Subadvised Series basis. The information will
reflect the impact on profitability of the hiring or termination of any
sub-advisor during the applicable quarter.
9. Whenever a sub-advisor is hired or terminated, the Advisor will
provide the applicable Board with information showing the expected
impact on the profitability of the Advisor.
10. Whenever a sub-advisor change is proposed for a Subadvised
Series with an Affiliated Sub-Advisor or a Wholly-Owned Sub-Advisor,
the applicable Board, including a majority of the Independent Board
Members, will make a separate finding, reflected in the applicable
Board minutes, that such change is in the best interests of the
Subadvised Series and its shareholders, and if the Subadvised Series is
a Master Fund, the best interests of any applicable Feeder Funds and
their respective shareholders, and does not involve a conflict of
interest from which the Advisor or the Affiliated Sub-Advisor or
Wholly-Owned Sub-Advisor derives an inappropriate advantage.
11. No Board member or officer of a Prudential Investment Company,
a Subadvised Series, or a Feeder Fund that invests in a Subadvised
Series that is a Master Fund, or director, manager or officer of the
Advisor, will own directly or indirectly (other than through a pooled
investment vehicle
[[Page 70582]]
that is not controlled by such person) any interest in a Sub-Advisor
except for (a) ownership of interests in the Advisor or any entity,
other than a Wholly-Owned Sub-Advisor, that controls, is controlled by,
or is under common control with the Advisor, or (b) ownership of less
than 1% of the outstanding securities of any class of equity or debt of
any publicly traded company that is either a Sub-Advisor or an entity
that controls, is controlled by, or is under common control with, a
Sub-Advisor.
12. Each Subadvised Series and any Feeder Fund that invests in a
Subadvised Series that is a Master Fund 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 Management 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. 2014-27981 Filed 11-25-14; 8:45 am]
BILLING CODE 8011-01-P