Royal Bank of Canada, et al.; Notice of Application and Temporary Order, 78519-78522 [2014-30225]
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Federal Register / Vol. 79, No. 249 / Tuesday, December 30, 2014 / Notices
advisers to register with the SEC.
Because the Applicant has regulatory
assets under management of more than
$100 million, it is not prohibited from
registering with Commission under
Section 203A(a) of the Advisers Act.
Therefore, absent relief, the Applicant
would be required to register under
Section 203(a) of the Advisers Act.
3. The Applicant submits that its
relationship with the Additional Family
Client does not change the nature of the
office into that of a commercial advisory
firm. In support of this argument, the
Applicant notes that if the Former
Sister-in-Law were the spouse of a lineal
descendant, rather than the sibling of a
former spouse of a lineal descendant,
there would be no question that each of
the persons presently being served by
the office would be a Family Member,
and that the related foundation would
meet the requirements of paragraph
(d)(4)(v) of the Family Office Rule
pertaining to charitable foundations.
The Applicant states that in requesting
the order, the office is not attempting to
expand its operations or engage in any
level of commercial activity to which
the Advisers Act is designed to apply.
Indeed, although the Additional Family
Client does not fall within the definition
of Family Member, she is considered to
be, and treated as, a member of the
Simon Family and the number of
natural persons who are not Family
Members as a percentage of the total
natural persons to whom the office
would provide Advisory Services if
relief were granted would be only
approximately 11 percent. The
Applicant maintains that, from the
perspective of the Simon Family, the
Applicant seeks to continue providing
Advisory Services exclusively to
members of a single family.
4. The Applicant also submits that
there is no public interest in requiring
the Applicant to be registered under the
Advisers Act. The Applicant states that
the office is a private organization that
was formed to be the ‘‘family office’’ for
the Simon Family, and that the office
does not have any public clients. The
Applicant maintains that the office’s
Advisory Services are tailored
exclusively to the needs of the Simon
Family and the Additional Family
Client. The Applicant argues that the
presence of the Additional Family
Client, who has been receiving Advisory
Services from the office for 26 years,
does not create any public interest that
would require the office to be registered
under the Advisers Act that is different
in any manner than the considerations
that apply to a ‘‘family office’’ that
complies in all respects with the Family
Office Rule.
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5. The Applicant argues that, although
the Family Office Rule largely codified
the exemptive orders that the
Commission had previously issued
before the enactment of the Dodd-Frank
Wall Street Reform and Consumer
Protection Act, the Commission
recognized in proposing the rule that
the exact representations, conditions, or
terms contained in every exemptive
order could not be captured in a rule of
general applicability. The Commission
noted that family offices would remain
free to seek a Commission exemptive
order to advise an individual or entity
that did not meet the proposed family
client definition, and that certain
situations may raise unique conflicts
and issues that are more appropriately
addressed through an exemptive order
process where the Commission can
consider the specific facts and
circumstances, than through a rule of
general applicability. The Applicant
maintains that its unusual
circumstances—providing Services to
Family Clients and to an Additional
Family Client for the past 26 years—
have not changed the nature of the
office’s operations into that of a
commercial advisory business, and that
an exemptive order is appropriate based
on the Applicant’s specific facts and
circumstances.
6. For the foregoing reasons, the
Applicant requests an order declaring it
to be a person not within the intent of
Section 202(a)(11) of the Advisers Act.
The Applicant submits that the order is
necessary and appropriate, in the public
interest, consistent with the protection
of investors, and consistent with the
purposes fairly intended by the policy
and provisions of the Advisers Act.
The Applicant’s Conditions
1. The Applicant will offer and
provide Advisory Services only to
Family Clients and to the Additional
Family Client, who will generally be
deemed to be, and be treated as if she
and the related foundation were, a
Family Client; provided, however, that
the Additional Family Client will be
deemed to be, and treated as if she were,
a Family Member for purposes of
paragraph (b)(1) and for purposes of
paragraph (d)(4)(vi) of the Family Office
Rule.
2. The Applicant will at all times be
wholly owned by Family Clients and
exclusively controlled (directly or
indirectly) by one or more Family
Members and/or Family Entities
(excluding the Additional Family
Client’s Family Entity) as defined in
paragraph (d)(5) of the Family Office
Rule.
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78519
3. At all times the assets beneficially
owned by Family Members and/or
Family Entities (excluding the
Additional Family Client’s Family
Entity) will account for at least 75
percent of the assets for which the
Applicant provides Advisory Services.
4. The Applicant will comply with all
the terms for exclusion from the
definition of investment adviser under
the Advisers Act set forth in the Family
Office Rule except for the limited
exception requested by this Application.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–30435 Filed 12–29–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–31388; File No. 812–14403]
Royal Bank of Canada, et al.; Notice of
Application and Temporary Order
December 19, 2014.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Temporary order and notice of
application for a permanent order under
section 9(c) of the Investment Company
Act of 1940 (‘‘Act’’).
AGENCY:
Applicants
have received a temporary order
(‘‘Temporary Order’’) exempting them
from section 9(a) of the Act, with
respect to an injunction entered against
Royal Bank of Canada (‘‘RBC’’) on
December 18, 2014 by the United States
District Court for the Southern District
of New York (‘‘Court’’), in connection
with a consent order between RBC and
the United States Commodity Futures
Trading Commission (‘‘CFTC’’), until
the Commission takes final action on an
application for a permanent order (the
‘‘Permanent Order,’’ and with the
Temporary Order, the ‘‘Orders’’).
Applicants also have applied for a
Permanent Order.
APPLICANTS: RBC, RBC Europe Limited
(‘‘RBC EL’’), RBC Capital Markets
Arbitrage, S.A. (‘‘CMA’’), RBC Global
Asset Management (U.S.) Inc. (‘‘GAM
US’’), BlueBay Asset Management LLP
(‘‘BlueBay LLP’’), BlueBay Asset
Management USA LLC (‘‘BlueBay
USA’’), and RBC Global Asset
Management (UK) Limited (‘‘GAM UK’’)
(each an ‘‘Applicant’’ and collectively,
the ‘‘Applicants’’).
DATES: Filing Date: The application was
filed on December 19, 2014.
SUMMARY OF APPLICATION:
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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 January 12, 2015, 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: RBC: 200 Bay Street,
Toronto, Ontario, Canada M5J 2J5, GAM
US, 50 South 6th Street, Minneapolis,
MN 55402, BlueBay LLP, 77 Grosvenor
Street, London W1K 3JR United
Kingdom, BBAM USA, 4 Stamford
Plaza, 107 Elm Street, Suite 512,
Stamford, CT 06902, GAM UK and RBC
EL, Riverbank House, 2 Swan Lane,
London EC4R 3BF United Kingdom, and
CMA, 16 Rue Notre Dame, Luxembourg,
2240, Luxembourg.
FOR FURTHER INFORMATION CONTACT:
Bruce R. MacNeil, Senior Counsel, at
(202) 551–6817, or Melissa R. Harke,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Chief Counsel’s Office).
SUPPLEMENTARY INFORMATION: The
following is a temporary order and 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 name box,
at https://www.sec.gov/search/
search.htm, or by calling (202) 551–
8090.
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HEARING OR NOTIFICATION OF HEARING:
Applicants’ Representations
1. RBC is a Canadian-chartered bank
and a Canada-based global financial
services firm. RBC is the ultimate parent
of the other Applicants. RBC EL is a
United Kingdom-based subsidiary of
RBC that is registered in the United
Kingdom to engage in capital market
activities. CMA is a Luxembourg-based
subsidiary of RBC that engages
primarily in interdealer market making
and proprietary trading. GAM US is a
corporation formed under the laws of
Minnesota. BlueBay LLP is a limited
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liability partnership incorporated in
England and Wales. BlueBay USA is a
limited liability company formed under
the laws of Delaware. GAM UK is a
corporation formed under the laws of
the United Kingdom. GAM US, BlueBay
LLP, BlueBay USA and GAM UK are
each a wholly-owned subsidiary of RBC
and are each an investment adviser
registered under the Investment
Advisers Act of 1940. GAM US, BlueBay
LLP, BlueBay USA and GAM UK each
serve as investment adviser or
investment sub-adviser to investment
companies registered under the Act, or
series of such companies (each a
‘‘Fund’’) and are collectively referred to
as the ‘‘Fund Servicing Applicants.’’
2. While no existing company of
which RBC is an affiliated person
within the meaning of section 2(a)(3) of
the Act (‘‘Affiliated Person’’), other than
the Fund Servicing Applicants,
currently serves or acts as an investment
adviser or depositor of any Fund,
employees’ securities company or
investment company that has elected to
be treated as a business development
company under the Act, or principal
underwriter (as defined in section
2(a)(29) of the Act) for any open-end
management investment company
registered under the Act (‘‘Open-End
Fund’’), unit investment trust registered
under the Act (‘‘UIT’’), or face-amount
certificate company registered under the
Act (‘‘FACC’’) (such activities, ‘‘Fund
Services Activities’’),1 Applicants
request that any relief granted also
apply to any existing company of which
RBC is an Affiliated Person, other than
RBC EL and CMA, and to any other
company of which RBC may become an
Affiliated Person in the future (together
with the Fund Servicing Applicants, the
‘‘Covered Persons’’) with respect to any
activity contemplated by section 9(a) of
the Act.
3. On April 22, 2012, the CFTC filed
a complaint, and on October 17, 2012,
an amended complaint which
superseded the original complaint (the
‘‘Complaint’’) in the Court captioned
Commodity Futures Trading
Commission v. Royal Bank of Canada
(the ‘‘Action’’). The Complaint alleged
that RBC entered into certain stock
futures contract transactions in ‘‘block
trades,’’ which are privately negotiated
transactions pursuant to exchange rules,
and that RBC entered into these block
trades through its branches and internal
trading accounts, and it traded opposite
RBC EL and CMA. The Complaint also
alleged a violation of Section 4c(a) of
1 RBC, RBC EL, and CMA are parties to the
application, but do not and will not engage in Fund
Services Activities.
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the Commodity Exchange Act (‘‘CEA’’),
whereby RBC entered into the block
trades with an express or implied
understanding that the positions
resulting from the trades would later be
offset or delivered opposite each other,
which achieved an economic and
futures market nullity for the RBC
corporate group because the RBC
corporate group as a whole was not
exposed to risk in the futures market.
Furthermore, the Complaint alleged
that, in violation of CFTC Regulation
1.38(a), the express or implied
understandings for later trades were not
reported to the OneChicago, LLC
(‘‘OneChicago’’) futures exchange
‘‘without delay,’’ as required by
OneChicago’s rules.
4. RBC and the CFTC have reached an
agreement to settle the Action. As part
of the agreement, the CFTC submitted a
consent order (‘‘Consent Order’’) to the
Court. RBC has consented to the entry
of the Consent Order by the Court,
without admitting or denying the
findings set forth therein (other than
those relating to the jurisdiction of the
Court and the jurisdiction of the CFTC
over the Conduct 2). On December 18,
2014 the Court entered the Consent
Order which enjoins RBC from violating
section 4c(a) of the CEA and CFTC
Regulation 1.38(a) (the ‘‘Injunction’’)
and required RBC to pay a civil
monetary penalty of $35,000,000.3
Applicants’ Legal Analysis
1. Section 9(a)(2) of the Act, in
relevant part, prohibits a person who
has been enjoined from engaging in or
continuing any conduct or practice in
connection with the purchase or sale of
a security, or in connection with
activities as an underwriter, broker or
dealer, from acting, amCFTC v. Royal
Bank of Canada, 12–CV–2497, (S.D.N.Y.
Dec. 18, 2014).ong other things, as an
investment adviser or depositor of any
registered investment company or a
principal underwriter for any Open-End
Fund, UIT or FACC. Section 9(a)(3) of
the Act makes the prohibition in section
9(a)(2) applicable to a company, any
affiliated person of which has been
disqualified under the provisions of
section 9(a)(2). Section 2(a)(3) of the Act
defines ‘‘affiliated person’’ to include,
among others, any person directly or
indirectly controlling, controlled by, or
under common control with, the other
person. Applicants state that, taken
together, sections 9(a)(2) and 9(a)(3)
2 The alleged conduct giving rise to the Injunction
(defined below) is referred to herein as the
‘‘Conduct.’’
3 See Consent Order, CFTC v. Royal Bank of
Canada, 12–cv–2497, Dkt. No. 124 (S.D.N.Y. Dec.
18, 2014).
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would have the effect of precluding the
Fund Servicing Applicants and Covered
Persons from engaging in Fund Services
Activities upon the entry of the
Injunction against RBC because RBC is
an Affiliated Person of each Fund
Servicing Applicant and Covered
Person.
2. Section 9(c) of the Act provides
that, upon application, the Commission
shall by order grant an exemption from
the disqualification provisions of
section 9(a) of the Act, either
unconditionally or on an appropriate
temporary or other conditional basis, to
any person if that person establishes
that: (a) The prohibitions of section 9(a),
as applied to the person, are unduly or
disproportionately severe or (b) the
conduct of the person has been such as
not to make it against the public interest
or the protection of investors to grant
the exemption. Applicants have filed an
application pursuant to section 9(c)
seeking a Temporary Order and a
Permanent Order exempting the Fund
Servicing Applicants and other Covered
Persons from the disqualification
provisions of section 9(a) of the Act. The
Fund Servicing Applicants and other
Covered Persons may, if the relief is
granted, in the future act in any of the
capacities contemplated by section 9(a)
of the Act subject to the applicable
terms and conditions of the Orders.
3. Applicants believe they meet the
standards for exemption specified in
section 9(c). Applicants state that the
prohibitions of section 9(a) as applied to
them would be unduly and
disproportionately severe and that the
conduct of Applicants has not been
such as to make it against the public
interest or the protection of investors to
grant the exemption from section 9(a).
4. Applicants state the Conduct did
not involve any of the Applicants
engaging in Fund Services Activities.
Applicants also state that the Conduct
did not involve any Fund or the assets
of any Fund. In addition, Applicants
state that the Conduct involved
proprietary trading in accounts owned
by RBC, RBC EL and CMA and was not
conducted on behalf of any Fund or
using assets of any Fund.
5. Applicants state that: (a) None of
the current directors, officers or
employees of the Fund Servicing
Applicants (or any other persons serving
in such capacity during the time period
covered by the Complaint) participated
in the Conduct and (b) the personnel at
RBC, RBC EL, or CMA who participated
in the Conduct or who may
subsequently be identified by RBC, RBC
EL, CMA, or any U.S. or non-U.S.
regulatory or enforcement agency as
having been responsible for the Conduct
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have had no, and will not have any
involvement in providing Fund Services
Activities and will not serve as an
officer, director, or employee of any
Covered Person. Applicants assert that
because the personnel of the Fund
Servicing Applicants did not participate
in the Conduct, the shareholders of
Funds were not affected any differently
than if those Funds had received
services from any other non-affiliated
investment adviser or sub-adviser.
6. Applicants submit that section 9(a)
should not operate to bar them from
serving the Funds and their
shareholders in the absence of improper
practices relating to their Fund Services
Activities. Applicants state that the
section 9(a) disqualification could result
in substantial costs to the Funds to
which the Fund Servicing Applicants
provide investment advisory services,
and such Funds’ operations would be
disrupted, as they sought to engage new
advisers or sub-advisers. Applicants
assert that these effects would be
unduly severe given the Fund Servicing
Applicants’ lack of involvement in the
Conduct. Moreover, Applicants state
that RBC has taken remedial actions to
address the Conduct, as outlined in the
application. Thus, Applicants believe
that granting the exemption from
section 9(a), as requested, would be
consistent with the public interest and
the protection of investors.
7. Applicants state that the inability of
the Fund Servicing Applicants to
continue to provide investment advisory
services to Funds would result in those
Funds and their shareholders facing
unduly and disproportionately severe
hardships. Applicants state that they
will distribute to the boards of directors
of the Funds (the ‘‘Boards’’) written
materials describing the circumstances
that led to the Injunction and any
impact on the Funds, and the
application. The written materials will
include an offer to discuss the materials
at an in-person meeting with each Board
for which the Fund Servicing
Applicants provide Fund Services
Activities, including the directors who
are not ‘‘interested persons’’ of such
Funds as defined in section 2(a)(19) of
the Act, and their independent legal
counsel as defined in rule 0–1(a)(6)
under the Act. Applicants state they
will provide the Boards with the
information concerning the Injunction
and the application that is necessary for
those Funds to fulfill their disclosure
and other obligations under the federal
securities laws and will provide them a
copy of the Consent Order as entered by
the Court.
8. Applicants state that if the Fund
Servicing Applicants were barred under
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78521
section 9(a) of the Act from providing
investment advisory services to the
Funds, and were unable to obtain the
requested exemption, the effect on their
businesses and employees would be
unduly and disproportionately severe
because they have committed
substantial capital and other resources
to establishing an expertise in advising
Funds. Applicants further state that
prohibiting the Fund Servicing
Applicants from engaging in Fund
Services Activities would not only
adversely affect their businesses, but
would also adversely affect their
employees who are involved in those
activities. Applicants state that many of
these employees working for the Fund
Servicing Applicants could experience
significant difficulties in finding
alternative fund-related employment.
9. Applicants state that certain
affiliates of the Applicants have
previously received an order under
section 9(c) of the Act, as the result of
conduct that triggered section 9(a), as
described in greater detail in the
application.
Applicants’ Conditions
Applicants agree that any order
granted by the Commission pursuant to
the application will be subject to the
following conditions:
1. Any temporary exemption granted
pursuant to the application shall be
without prejudice to, and shall not limit
the Commission’s rights in any manner
with respect to, any Commission
investigation of, or administrative
proceedings involving or against,
Covered Persons, including without
limitation, the consideration by the
Commission of a permanent exemption
from section 9(a) of the Act requested
pursuant to the application or the
revocation or removal of any temporary
exemptions granted under the Act in
connection with the application.
2. Each Applicant and Covered Person
will adopt and implement policies and
procedures reasonably designed to
ensure that it will comply with any
terms and conditions of the Orders
within 60 days of the date of the
Permanent Order.
3. RBC will comply with the terms
and conditions of the Consent Order.
4. Applicants will provide written
notification to the Chief Counsel of the
Commission’s Division of Investment
Management with a copy to the Chief
Counsel of the Commission’s Division of
Enforcement of a material violation of
the terms and conditions of the Orders
or Consent Order within 30 days of
discovery of the material violation.
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Temporary Order
The Commission has considered the
matter and finds that Applicants have
made the necessary showing to justify
granting a temporary exemption.
Accordingly,
It is hereby ordered, pursuant to
section 9(c) of the Act, that the Fund
Servicing Applicants and any other
Covered Persons are granted a
temporary exemption from the
provisions of section 9(a), solely with
respect to the Injunction, subject to the
representations and conditions in the
application, from December 18, 2014,
until the Commission takes final action
on their application for a permanent
order.
By the Commission.
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–30225 Filed 12–29–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–73909; File No. SR–
NYSEArca–2014–140]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Amending Exchange
Rules Regarding Trade Nullification
and Price Adjustment
December 22, 2014.
mstockstill on DSK4VPTVN1PROD with NOTICES
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on December
16, 2014, NYSE Arca, Inc. (the
‘‘Exchange’’ or ‘‘NYSE Arca’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the self-regulatory
organization. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of the Substance
of the Proposed Rule Change
The Exchange proposes to amend
exchange rules regarding trade
nullification and price adjustment. The
text of the proposed rule change is
available on the Exchange’s Web site at
www.nyse.com, at the principal office of
the Exchange, and at the Commission’s
Public Reference Room.
1 15
2 17
U.S.C. 78s(b)(1).
CFR 240.19b–4.
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II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
of those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange is proposing to add
Rule 6.77A, ‘‘Trade Nullification and
Price Adjustment Procedure.’’ 3 As
proposed, Rule 6.77A would allow for
transactions to be nullified if both
parties to the transaction agree to the
nullification and allow the price of
executions to be adjusted if the price
adjustment is agreed to by both parties
to the transaction and authorized by the
Exchange.4 The Exchange is also
proposing to make other conforming
administrative changes to streamline the
rules governing this subject with the
Exchange’s rules.
Background
Currently, pursuant to Commentary
.02 of Rule 6.77, the Exchange allows for
parties to agree to nullify an execution.
Commentary .02 of Rule 6.77 also states
that once both parties agree to the trade
nullification, one party must ‘‘promptly
notify the Exchange for dissemination of
cancellation information to the Options
Price Reporting Authority.’’ In addition,
the Exchange currently allows for a
mutual price adjustment for trades that
meet the obvious error (or catastrophic
error) requirements pursuant to
Exchange Rule 6.87 if those mutual
agreements are done within specific
timeframes.5 The Exchange is now
proposing to relocate the
aforementioned trade nullification
3 The Exchange notes that there are efforts by the
exchanges to create a uniform trade nullification
and adjustment rule. Should the uniform rule be
approved and effective, the Exchange will amend
its rules appropriately.
4 The Exchange notes that, as proposed, Rule
6.77A would only apply to trades that were
executed on the Exchange and, as such, any orders
that were either fully or partially routed to, or
executed, on another exchange would not be subject
to the proposed Rule 6.77A.
5 See Rule 6.87(a)(3) and (7) and 6.87(d)(3).
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language and add a provision to allow
parties to mutually adjust prices of
executions outside of those done in
obvious error. The Exchange’s proposal
is based upon similar rules of the
Chicago Board Options Exchange
(‘‘CBOE’’) and Miami International
Securities Exchange, LLC (‘‘MIAX’’).6
Proposed Rule 6.77A
The Exchange is proposing to add
Rule 6.77A, ‘‘Trade Nullification and
Price Adjustment Procedure,’’ which
would: (a) Allow for any trades on the
Exchange to be nullified if both parties
to the trade agree to such nullification,
and (b) allow for prices of executions to
be adjusted if the price adjustment is
agreed upon by both parties to the trade
and authorized by the Exchange.7
As stated above, the Exchange
currently allows for trades to be
nullified based upon mutual
agreement.8 With the proposed addition
of Rule 6.77A, the Exchange is only
renumbering and relocating this
provision and is not proposing a
substantive change to the rule itself. The
Exchange believes that having the
provision as a standalone rule would
make it easier for OTP Holders to locate.
In addition, the Exchange believes this
administrative change would streamline
the provisions surrounding this notion
to put in one place.
The Exchange is also proposing to add
a provision allowing OTP Holders to
mutually agree to adjust a price of an
execution. The Exchange believes this
provision is necessary given the benefits
of adjusting a trade price rather than
nullifying the trade completely. Because
options trades are used to hedge
transactions in other markets, including
securities and futures, many OTP
Holders, and their customers, would
rather adjust prices of executions rather
than nullify the transactions and, thus,
lose a hedge altogether. As such, the
Exchange believes it is in the best
interest of investors to allow for price
adjustments as well as nullifications. In
addition, the Exchange believes it is in
the nature of a fair and orderly market
to allow for price adjustments rather
than only cancellations because an
adjustment would result in the least
amount of disruption to the overall
market. The Exchange also notes that
current Exchange rules allow for prices
of trades to be adjusted at the consent
6 See CBOE Rule 6.19 and Securities Exchange
Act Release No. 72970 (September 3, 2014), 79 FR
53498 (September 9, 2014) (SR–CBOE–2014–066)
and MIAX Rule 531 and Release No. 73463 (October
29, 2014), 79 FR 65445 (November 4, 2014) (SR–
MIAX–2014–54).
7 See note 5 supra.
8 See Commentary .02 of Rule 6.77.
E:\FR\FM\30DEN1.SGM
30DEN1
Agencies
[Federal Register Volume 79, Number 249 (Tuesday, December 30, 2014)]
[Notices]
[Pages 78519-78522]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-30225]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-31388; File No. 812-14403]
Royal Bank of Canada, et al.; Notice of Application and Temporary
Order
December 19, 2014.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Temporary order and notice of application for a permanent
order under section 9(c) of the Investment Company Act of 1940
(``Act'').
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SUMMARY OF APPLICATION: Applicants have received a temporary order
(``Temporary Order'') exempting them from section 9(a) of the Act, with
respect to an injunction entered against Royal Bank of Canada (``RBC'')
on December 18, 2014 by the United States District Court for the
Southern District of New York (``Court''), in connection with a consent
order between RBC and the United States Commodity Futures Trading
Commission (``CFTC''), until the Commission takes final action on an
application for a permanent order (the ``Permanent Order,'' and with
the Temporary Order, the ``Orders''). Applicants also have applied for
a Permanent Order.
APPLICANTS: RBC, RBC Europe Limited (``RBC EL''), RBC Capital Markets
Arbitrage, S.A. (``CMA''), RBC Global Asset Management (U.S.) Inc.
(``GAM US''), BlueBay Asset Management LLP (``BlueBay LLP''), BlueBay
Asset Management USA LLC (``BlueBay USA''), and RBC Global Asset
Management (UK) Limited (``GAM UK'') (each an ``Applicant'' and
collectively, the ``Applicants'').
DATES: Filing Date: The application was filed on December 19, 2014.
[[Page 78520]]
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 January 12, 2015, 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: RBC: 200 Bay Street,
Toronto, Ontario, Canada M5J 2J5, GAM US, 50 South 6th Street,
Minneapolis, MN 55402, BlueBay LLP, 77 Grosvenor Street, London W1K 3JR
United Kingdom, BBAM USA, 4 Stamford Plaza, 107 Elm Street, Suite 512,
Stamford, CT 06902, GAM UK and RBC EL, Riverbank House, 2 Swan Lane,
London EC4R 3BF United Kingdom, and CMA, 16 Rue Notre Dame, Luxembourg,
2240, Luxembourg.
FOR FURTHER INFORMATION CONTACT: Bruce R. MacNeil, Senior Counsel, at
(202) 551-6817, or Melissa R. Harke, Branch Chief, at (202) 551-6821
(Division of Investment Management, Chief Counsel's Office).
SUPPLEMENTARY INFORMATION: The following is a temporary order and 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 name box, at https://www.sec.gov/search/search.htm, or by calling (202) 551-8090.
Applicants' Representations
1. RBC is a Canadian-chartered bank and a Canada-based global
financial services firm. RBC is the ultimate parent of the other
Applicants. RBC EL is a United Kingdom-based subsidiary of RBC that is
registered in the United Kingdom to engage in capital market
activities. CMA is a Luxembourg-based subsidiary of RBC that engages
primarily in interdealer market making and proprietary trading. GAM US
is a corporation formed under the laws of Minnesota. BlueBay LLP is a
limited liability partnership incorporated in England and Wales.
BlueBay USA is a limited liability company formed under the laws of
Delaware. GAM UK is a corporation formed under the laws of the United
Kingdom. GAM US, BlueBay LLP, BlueBay USA and GAM UK are each a wholly-
owned subsidiary of RBC and are each an investment adviser registered
under the Investment Advisers Act of 1940. GAM US, BlueBay LLP, BlueBay
USA and GAM UK each serve as investment adviser or investment sub-
adviser to investment companies registered under the Act, or series of
such companies (each a ``Fund'') and are collectively referred to as
the ``Fund Servicing Applicants.''
2. While no existing company of which RBC is an affiliated person
within the meaning of section 2(a)(3) of the Act (``Affiliated
Person''), other than the Fund Servicing Applicants, currently serves
or acts as an investment adviser or depositor of any Fund, employees'
securities company or investment company that has elected to be treated
as a business development company under the Act, or principal
underwriter (as defined in section 2(a)(29) of the Act) for any open-
end management investment company registered under the Act (``Open-End
Fund''), unit investment trust registered under the Act (``UIT''), or
face-amount certificate company registered under the Act (``FACC'')
(such activities, ``Fund Services Activities''),\1\ Applicants request
that any relief granted also apply to any existing company of which RBC
is an Affiliated Person, other than RBC EL and CMA, and to any other
company of which RBC may become an Affiliated Person in the future
(together with the Fund Servicing Applicants, the ``Covered Persons'')
with respect to any activity contemplated by section 9(a) of the Act.
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\1\ RBC, RBC EL, and CMA are parties to the application, but do
not and will not engage in Fund Services Activities.
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3. On April 22, 2012, the CFTC filed a complaint, and on October
17, 2012, an amended complaint which superseded the original complaint
(the ``Complaint'') in the Court captioned Commodity Futures Trading
Commission v. Royal Bank of Canada (the ``Action''). The Complaint
alleged that RBC entered into certain stock futures contract
transactions in ``block trades,'' which are privately negotiated
transactions pursuant to exchange rules, and that RBC entered into
these block trades through its branches and internal trading accounts,
and it traded opposite RBC EL and CMA. The Complaint also alleged a
violation of Section 4c(a) of the Commodity Exchange Act (``CEA''),
whereby RBC entered into the block trades with an express or implied
understanding that the positions resulting from the trades would later
be offset or delivered opposite each other, which achieved an economic
and futures market nullity for the RBC corporate group because the RBC
corporate group as a whole was not exposed to risk in the futures
market. Furthermore, the Complaint alleged that, in violation of CFTC
Regulation 1.38(a), the express or implied understandings for later
trades were not reported to the OneChicago, LLC (``OneChicago'')
futures exchange ``without delay,'' as required by OneChicago's rules.
4. RBC and the CFTC have reached an agreement to settle the Action.
As part of the agreement, the CFTC submitted a consent order (``Consent
Order'') to the Court. RBC has consented to the entry of the Consent
Order by the Court, without admitting or denying the findings set forth
therein (other than those relating to the jurisdiction of the Court and
the jurisdiction of the CFTC over the Conduct \2\). On December 18,
2014 the Court entered the Consent Order which enjoins RBC from
violating section 4c(a) of the CEA and CFTC Regulation 1.38(a) (the
``Injunction'') and required RBC to pay a civil monetary penalty of
$35,000,000.\3\
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\2\ The alleged conduct giving rise to the Injunction (defined
below) is referred to herein as the ``Conduct.''
\3\ See Consent Order, CFTC v. Royal Bank of Canada, 12-cv-2497,
Dkt. No. 124 (S.D.N.Y. Dec. 18, 2014).
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Applicants' Legal Analysis
1. Section 9(a)(2) of the Act, in relevant part, prohibits a person
who has been enjoined from engaging in or continuing any conduct or
practice in connection with the purchase or sale of a security, or in
connection with activities as an underwriter, broker or dealer, from
acting, amCFTC v. Royal Bank of Canada, 12-CV-2497, (S.D.N.Y. Dec. 18,
2014).ong other things, as an investment adviser or depositor of any
registered investment company or a principal underwriter for any Open-
End Fund, UIT or FACC. Section 9(a)(3) of the Act makes the prohibition
in section 9(a)(2) applicable to a company, any affiliated person of
which has been disqualified under the provisions of section 9(a)(2).
Section 2(a)(3) of the Act defines ``affiliated person'' to include,
among others, any person directly or indirectly controlling, controlled
by, or under common control with, the other person. Applicants state
that, taken together, sections 9(a)(2) and 9(a)(3)
[[Page 78521]]
would have the effect of precluding the Fund Servicing Applicants and
Covered Persons from engaging in Fund Services Activities upon the
entry of the Injunction against RBC because RBC is an Affiliated Person
of each Fund Servicing Applicant and Covered Person.
2. Section 9(c) of the Act provides that, upon application, the
Commission shall by order grant an exemption from the disqualification
provisions of section 9(a) of the Act, either unconditionally or on an
appropriate temporary or other conditional basis, to any person if that
person establishes that: (a) The prohibitions of section 9(a), as
applied to the person, are unduly or disproportionately severe or (b)
the conduct of the person has been such as not to make it against the
public interest or the protection of investors to grant the exemption.
Applicants have filed an application pursuant to section 9(c) seeking a
Temporary Order and a Permanent Order exempting the Fund Servicing
Applicants and other Covered Persons from the disqualification
provisions of section 9(a) of the Act. The Fund Servicing Applicants
and other Covered Persons may, if the relief is granted, in the future
act in any of the capacities contemplated by section 9(a) of the Act
subject to the applicable terms and conditions of the Orders.
3. Applicants believe they meet the standards for exemption
specified in section 9(c). Applicants state that the prohibitions of
section 9(a) as applied to them would be unduly and disproportionately
severe and that the conduct of Applicants has not been such as to make
it against the public interest or the protection of investors to grant
the exemption from section 9(a).
4. Applicants state the Conduct did not involve any of the
Applicants engaging in Fund Services Activities. Applicants also state
that the Conduct did not involve any Fund or the assets of any Fund. In
addition, Applicants state that the Conduct involved proprietary
trading in accounts owned by RBC, RBC EL and CMA and was not conducted
on behalf of any Fund or using assets of any Fund.
5. Applicants state that: (a) None of the current directors,
officers or employees of the Fund Servicing Applicants (or any other
persons serving in such capacity during the time period covered by the
Complaint) participated in the Conduct and (b) the personnel at RBC,
RBC EL, or CMA who participated in the Conduct or who may subsequently
be identified by RBC, RBC EL, CMA, or any U.S. or non-U.S. regulatory
or enforcement agency as having been responsible for the Conduct have
had no, and will not have any involvement in providing Fund Services
Activities and will not serve as an officer, director, or employee of
any Covered Person. Applicants assert that because the personnel of the
Fund Servicing Applicants did not participate in the Conduct, the
shareholders of Funds were not affected any differently than if those
Funds had received services from any other non-affiliated investment
adviser or sub-adviser.
6. Applicants submit that section 9(a) should not operate to bar
them from serving the Funds and their shareholders in the absence of
improper practices relating to their Fund Services Activities.
Applicants state that the section 9(a) disqualification could result in
substantial costs to the Funds to which the Fund Servicing Applicants
provide investment advisory services, and such Funds' operations would
be disrupted, as they sought to engage new advisers or sub-advisers.
Applicants assert that these effects would be unduly severe given the
Fund Servicing Applicants' lack of involvement in the Conduct.
Moreover, Applicants state that RBC has taken remedial actions to
address the Conduct, as outlined in the application. Thus, Applicants
believe that granting the exemption from section 9(a), as requested,
would be consistent with the public interest and the protection of
investors.
7. Applicants state that the inability of the Fund Servicing
Applicants to continue to provide investment advisory services to Funds
would result in those Funds and their shareholders facing unduly and
disproportionately severe hardships. Applicants state that they will
distribute to the boards of directors of the Funds (the ``Boards'')
written materials describing the circumstances that led to the
Injunction and any impact on the Funds, and the application. The
written materials will include an offer to discuss the materials at an
in-person meeting with each Board for which the Fund Servicing
Applicants provide Fund Services Activities, including the directors
who are not ``interested persons'' of such Funds as defined in section
2(a)(19) of the Act, and their independent legal counsel as defined in
rule 0-1(a)(6) under the Act. Applicants state they will provide the
Boards with the information concerning the Injunction and the
application that is necessary for those Funds to fulfill their
disclosure and other obligations under the federal securities laws and
will provide them a copy of the Consent Order as entered by the Court.
8. Applicants state that if the Fund Servicing Applicants were
barred under section 9(a) of the Act from providing investment advisory
services to the Funds, and were unable to obtain the requested
exemption, the effect on their businesses and employees would be unduly
and disproportionately severe because they have committed substantial
capital and other resources to establishing an expertise in advising
Funds. Applicants further state that prohibiting the Fund Servicing
Applicants from engaging in Fund Services Activities would not only
adversely affect their businesses, but would also adversely affect
their employees who are involved in those activities. Applicants state
that many of these employees working for the Fund Servicing Applicants
could experience significant difficulties in finding alternative fund-
related employment.
9. Applicants state that certain affiliates of the Applicants have
previously received an order under section 9(c) of the Act, as the
result of conduct that triggered section 9(a), as described in greater
detail in the application.
Applicants' Conditions
Applicants agree that any order granted by the Commission pursuant
to the application will be subject to the following conditions:
1. Any temporary exemption granted pursuant to the application
shall be without prejudice to, and shall not limit the Commission's
rights in any manner with respect to, any Commission investigation of,
or administrative proceedings involving or against, Covered Persons,
including without limitation, the consideration by the Commission of a
permanent exemption from section 9(a) of the Act requested pursuant to
the application or the revocation or removal of any temporary
exemptions granted under the Act in connection with the application.
2. Each Applicant and Covered Person will adopt and implement
policies and procedures reasonably designed to ensure that it will
comply with any terms and conditions of the Orders within 60 days of
the date of the Permanent Order.
3. RBC will comply with the terms and conditions of the Consent
Order.
4. Applicants will provide written notification to the Chief
Counsel of the Commission's Division of Investment Management with a
copy to the Chief Counsel of the Commission's Division of Enforcement
of a material violation of the terms and conditions of the Orders or
Consent Order within 30 days of discovery of the material violation.
[[Page 78522]]
Temporary Order
The Commission has considered the matter and finds that Applicants
have made the necessary showing to justify granting a temporary
exemption.
Accordingly,
It is hereby ordered, pursuant to section 9(c) of the Act, that the
Fund Servicing Applicants and any other Covered Persons are granted a
temporary exemption from the provisions of section 9(a), solely with
respect to the Injunction, subject to the representations and
conditions in the application, from December 18, 2014, until the
Commission takes final action on their application for a permanent
order.
By the Commission.
Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-30225 Filed 12-29-14; 8:45 am]
BILLING CODE 8011-01-P