Eagle Point Credit Company Inc., et al.; Notice of Application, 9759-9763 [2015-03653]
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Federal Register / Vol. 80, No. 36 / Tuesday, February 24, 2015 / Notices
notices to the MSRB. Therefore, the total
annual burden on issuers to prepare and
submit 73,480 event notices to the
MSRB is estimated to be 146,960 hours.
Based on data from the MSRB through
September 2014 and annualized through
December 2014, issuers will submit
approximately 7,063 failure to file
notices to the MSRB in 2014.
Commission staff estimates that an
issuer will require approximately two
hours to prepare and submit failure to
file notices to the MSRB. Therefore, the
total annual burden on issuers to
prepare and submit 7,063 failure to file
notices to the MSRB is estimated to be
14,126 hours. Commission staff
estimates that the total annual burden
on broker-dealers to comply with Rule
15c2–12 is 22,500 hours. Finally,
Commission staff estimates that the
MSRB will incur an annual burden of
12,699 hours to collect, index, store,
retrieve, and make available the
pertinent documents under Rule 15c2–
12.
Based on data provided by the MSRB,
the Commission estimates that up to
65% of issuers may use designated
agents to submit some or all of their
continuing disclosure documents to the
MSRB. The Commission estimates that
the average total annual cost that may be
incurred by issuers that use the services
of a designated agent will be
$9,750,000.2 The Commission estimates
that the MSRB will incur total annual
costs of $10,000 based on the MSRB’s
estimates of the hardware and software
costs for the MSRB’s Electronic
Municipal Market Access (‘‘EMMA’’)
system in the MSRB’s fiscal year 2014.
Written comments are invited on: (a)
Whether the proposed collection of
information is necessary for the proper
performance of the functions of the
Commission, including whether the
information shall have practical utility;
(b) the accuracy of the Commission’s
estimates of the burden of the proposed
collection of information; (c) ways to
enhance the quality, utility, and clarity
of the information to be collected; and
(d) ways to minimize the burden of the
collection of information on
respondents, including through the use
of automated collection techniques or
other forms of information technology.
Consideration will be given to
comments and suggestions submitted in
writing within 30 days of this
publication.
An agency may not conduct or
sponsor, and a person is not required to
2 20,000 (number of issuers) × .65 (percentage of
issuers that may use designated agents) × $750
(estimated average annual cost for issuer’s use of
designated agent) = $9,750,000.
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respond to, a collection of information
unless it displays a currently valid OMB
control number.
The public may view background
documentation for this information
collection at the following Web site:
www.reginfo.gov. Comments should be
directed to (i) Desk Officer for the
Securities and Exchange Commission,
Office of Information and Regulatory
Affairs, Office of Management and
Budget, Room 10102, New Executive
Office Building, Washington, DC 20503,
or by sending an email to: Shagufta_
Ahmed@omb.eop.gov; and (ii) Pamela
Dyson, Director/Chief Information
Officer, Securities and Exchange
Commission, c/o Remi Pavlik-Simon,
100 F Street NE., Washington, DC
20549, or by sending an email to: PRA_
Mailbox@sec.gov. Comments must be
submitted to OMB within 30 days of
this notice.
February 18, 2015.
Brent J. Fields,
Secretary.
[FR Doc. 2015–03670 Filed 2–23–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–31457; File No. 812–14330]
Eagle Point Credit Company Inc., et al.;
Notice of Application
February 18, 2015.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under section 17(d) of the
Investment Company Act of 1940 (the
‘‘Act’’) and rule 17d–1 under the Act to
permit certain joint transactions
otherwise prohibited by section 17(d) of
the Act and rule 17d–1 under the Act.
AGENCY:
9759
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 March 16, 2015, and
should be accompanied by proof of
service on applicants, in the form of an
affidavit or, for lawyers, a certificate of
service. Hearing requests should state
the nature of the writer’s interest, the
reason for the request, and the issues
contested. Persons who wish to be
notified of a hearing may request
notification by writing to the
Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F St.
NE., Washington, DC 20549–1090.
Applicants: 20 Horseneck Lane,
Greenwich, CT 06830.
FOR FURTHER INFORMATION CONTACT:
Vanessa M. Meeks, Senior Counsel, or
Melissa R. Harke, Branch Chief, at (202)
551–6825 (Chief Counsel’s Office,
Division of Investment Management).
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. EPCC (formerly Eagle Point Credit
Company LLC) is a Delaware
corporation that is registered as a
closed-end management investment
company under the Act. EPCC’s primary
investment objective is to generate high
current income, with a secondary
objective to generate capital
SUMMARY: Summary of Application:
appreciation. EPCC seeks to achieve its
Applicants request an order to permit
investment objectives by investing
Eagle Point Credit Company Inc. to coprimarily in equity and junior debt
invest in portfolio companies with
tranches of collateralized loan
certain affiliated investment funds.
obligations (‘‘CLOs’’) that are
Applicants: Eagle Point Credit
collateralized by a diverse portfolio
Company Inc. (‘‘EPCC’’), Eagle Point
consisting primarily of below
Credit Management LLC (‘‘EPCM’’),
investment grade U.S. senior secured
Eagle Point Credit Partners LP (‘‘EPCP’’), loans. The board of directors of EPCC is
Eagle Point Credit GP I LP (‘‘General
currently comprised of six directors,
Partner’’), Eagle Point Credit Company
four of whom are not ‘‘interested
Sub LLC (‘‘EPCC Sub’’), Eagle Point
persons,’’ within the meaning of section
Credit Partners Sub Ltd. (‘‘EPCP Sub’’),
2(a)(19) of the Act (the ‘‘Non-Interested
and Eagle Point Credit Partners Sub III
Directors’’), of EPCC.
Ltd. (‘‘EPCP Sub III’’).
2. EPCP is a Cayman Islands
DATES: Filing Dates: The application was exempted limited partnership that
would be an investment company under
filed on July 10, 2014, and amended on
the 1940 Act but for Section 3(c)(7) of
November 20, 2014 and January 30,
the 1940 Act. EPCP’s investment
2015.
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objectives and strategies are equivalent,
in all material respects, to EPCC’s
Objectives and Strategies.1 The General
Partner has ultimate responsibility for
the management of EPCP.
3. Each of EPCP Sub and EPCP Sub
III is a Cayman Islands exempted
company. EPCP Sub is a direct, whollyowned special purpose subsidiary of
EPCP. EPCP Sub III is a direct, whollyowned special purpose subsidiary of
EPCP Sub. EPCP Sub and EPCP Sub III
are each excluded from registration as
an investment company under Section
3(c)(7) of the 1940 Act. All investment
decisions relating to the assets held at
EPCP Sub and EPCP Sub III are made by
EPCM as investment adviser to EPCP.
4. EPCM is a Delaware limited
liability company registered as an
investment adviser under the
Investment Advisers Act of 1940 (the
‘‘Advisers Act’’). EPCM serves as the
investment adviser to EPCC and EPCP.
5. Applicants seek an order (‘‘Order’’)
to permit one or more Regulated Funds 2
and/or one or more Affiliated Funds 3 to
participate in the same investment
opportunities through a proposed coinvestment program (the ‘‘CoInvestment Program’’) where such
participation would otherwise be
prohibited under rule 17d–1 by (a) coinvesting with each other in securities
issued by issuers in private placement
transactions in which an Adviser
negotiates terms in addition to price; 4
and (b) making additional investments
in securities of such issuers, including
through the exercise of warrants,
conversion privileges, and other rights
to purchase securities of the issuers
1 ‘‘Objectives and Strategies’’ means a Regulated
Fund’s (as defined below) investment objectives
and strategies, as described in the Regulated Fund’s
registration statement on Form N–2, other filings
the Regulated Fund has made with the Commission
under the Securities Act of 1933 (the ‘‘Securities
Act’’), or under the Securities Exchange Act of
1934, and the Regulated Fund’s reports to
shareholders.
2 ‘‘Regulated Fund’’ means EPCC and any Future
Regulated Fund. ‘‘Future Regulated Fund’’ means
any closed-end management investment company
(a) that is registered under the Act, (b) whose
investment adviser is an Adviser, and (c) that
intends to participate in the Co-Investment
Program. The term ‘‘Adviser’’ means (a) EPCM and
(b) any future investment adviser that controls, is
controlled by or is under common control with
EPCM and is registered as an investment adviser
under the Advisers Act.
3 ‘‘Affiliated Fund’’ means any of EPCP and any
Future Affiliated Fund. ‘‘Future Affiliated Fund’’
means any entity (a) whose investment adviser is
an Adviser, (b) that would be an investment
company but for section 3(c)(1) or 3(c)(7) of the Act,
and (c) that intends to participate in the CoInvestment Program.
4 The term ‘‘private placement transactions’’
means transactions in which the offer and sale of
securities by the issuer are exempt from registration
under the Securities Act.
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(‘‘Follow-On Investments’’). ‘‘CoInvestment Transaction’’ means any
transaction in which a Regulated Fund
(or its Wholly-Owned Investment Sub,
as defined below) participates together
with one or more other Regulated Funds
and/or one or more Affiliated Funds in
reliance on the requested Order.
‘‘Potential Co-Investment Transaction’’
means any investment opportunity in
which a Regulated Fund (or its WhollyOwned Investment Sub, as defined
below) could not participate together
with one or more Affiliated Funds and/
or one or more other Regulated Funds
without obtaining and relying on the
Order.5
6. Applicants state that a Regulated
Fund may, from time to time, form one
or more Wholly-Owned Investment
Subs.6 Such a subsidiary would be
prohibited from investing in a CoInvestment Transaction with any
Affiliated Fund or Regulated Fund
because it would be a company
controlled by its parent Regulated Fund
for purposes of rule 17d–1. Applicants
request that each Wholly-Owned
Investment Sub be permitted to
participate in Co-Investment
Transactions in lieu of its parent
Regulated Fund and that the WhollyOwned Investment Sub’s participation
in any such transaction be treated, for
purposes of the requested order, as
though the parent Regulated Fund were
participating directly. Applicants
represent that this treatment is justified
because a Wholly-Owned Investment
Sub would have no purpose other than
serving as a holding vehicle for the
Regulated Fund’s investments and,
therefore, no conflicts of interest could
arise between the Regulated Fund and
the Wholly-Owned Investment Sub. The
Regulated Fund’s Board would make all
relevant determinations under the
conditions with regard to a WhollyOwned Investment Sub’s participation
in a Co-Investment Transaction, and the
Regulated Fund’s Board would be
informed of, and take into
5 All existing entities that currently intend to rely
upon the requested Order have been named as
applicants. Any other existing or future entity that
subsequently relies on the Order will comply with
the terms and conditions of the application.
6 The term ‘‘Wholly-Owned Investment Sub’’
means an entity (i) that is wholly-owned by a
Regulated Fund (with the Regulated Fund at all
times holding, beneficially and of record, 100% of
the voting and economic interests); (ii) whose sole
business purpose is to hold one or more
investments and issue debt on behalf of the
Regulated Fund; (iii) with respect to which the
Regulated Fund’s board of directors or trustees has
the sole authority to make all determinations with
respect to the entity’s participation under the
conditions of the application; and (iv) that would
be an investment company but for section 3(c)(1) or
3(c)(7) of the Act.
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consideration, any proposed use of a
Wholly-Owned Investment Sub in the
Regulated Fund’s place. If the Regulated
Fund proposes to participate in the
same Co-Investment Transaction with
any of its Wholly-Owned Investment
Subs, the Board will also be informed
of, and take into consideration, the
relative participation of the Regulated
Fund and the Wholly-Owned
Investment Sub. EPCC Sub is a
Delaware limited liability company and
is a Wholly-Owned Investment Sub of
EPCC.
7. When considering Potential CoInvestment Transactions for any
Regulated Fund, the applicable Adviser
will consider only the Objectives and
Strategies, investment policies,
investment positions, capital available
for investment, and other pertinent
factors applicable to that Regulated
Fund. Due to the similarity in
Objectives and Strategies of certain
Regulated Funds with the investment
objectives, policies and strategies of
certain Affiliated Funds, the Adviser
expects that investments for a Regulated
Fund should also generally be
appropriate investments for one or more
other Regulated Funds and/or one or
more Affiliated Funds, with certain
exceptions based on available capital or
diversification.7
8. Other than pro rata dispositions
and Follow-On Investments as provided
in conditions 7 and 8, and after making
the determinations required in
conditions 1 and 2(a), the Adviser will
present each Potential Co-Investment
Transaction and the proposed allocation
to the directors of the Board eligible to
vote under section 57(o) of the Act
(‘‘Eligible Directors’’), and the ‘‘required
majority,’’ as defined in section 57(o) of
the Act (‘‘Required Majority’’) 8 will
approve each Co-Investment
Transaction prior to any investment by
the participating Regulated Fund.
9. With respect to the pro rata
dispositions and Follow-On Investments
provided in conditions 7 and 8, a
Regulated Fund may participate in a pro
rata disposition or Follow-On
Investment without obtaining prior
approval of the Required Majority if,
among other things: (i) The proposed
participation of each Regulated Fund
and Affiliated Fund in such disposition
is proportionate to its outstanding
investments in the issuer immediately
7 The Regulated Funds, however, will not be
obligated to invest, or co-invest, when investment
opportunities are referred to them.
8 Although each Regulated Fund will be a
registered closed-end fund, the Board members that
make up the Required Majority will be determined
as if the Regulated Fund were a BDC subject to
section 57(o).
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preceding the disposition or Follow-On
Investment, as the case may be; and (ii)
the Board of the Regulated Fund has
approved that Regulated Fund’s
participation in pro rata dispositions
and Follow-On Investments as being in
the best interests of the Regulated Fund.
If the Board does not so approve, any
such disposition or Follow-On
Investment will be submitted to the
Regulated Fund’s Eligible Directors. The
Board of any Regulated Fund may at any
time rescind, suspend or qualify its
approval of pro rata dispositions and
Follow-On Investments with the result
that all dispositions and/or Follow-On
Investments must be submitted to the
Eligible Directors.
10. No Non-Interested Director of a
Regulated Fund will have a financial
interest in any Co-Investment
Transaction, other than through share
ownership in one of the Regulated
Funds.
Applicants’ Legal Analysis
1. Section 17(d) of the Act and rule
17d–1 under the Act prohibit affiliated
persons of a registered investment
company from participating in joint
transactions with the company unless
the Commission has granted an order
permitting such transactions. In passing
upon applications under rule 17d–1, the
Commission considers whether the
company’s participation in the joint
transaction is consistent with the
provisions, policies, and purposes of the
Act and the extent to which such
participation is on a basis different from
or less advantageous than that of other
participants.
2. Applicants state that in the absence
of the requested relief, a Regulated Fund
would be, in some circumstances,
limited in its ability to participate in
attractive and appropriate investment
opportunities. Applicants believe that
the proposed terms and conditions will
ensure that the Co-Investment
Transactions are consistent with the
protection of each Regulated Fund’s
shareholders and with the purposes
intended by the policies and provisions
of the Act. Applicants state that the
Regulated Funds’ participation in the
Co-Investment Transactions will be
consistent with the provisions, policies,
and purposes of the Act and on a basis
that is not different from or less
advantageous than that of other
participants.
Applicants’ Conditions
Applicants agree that the Order will
be subject to the following conditions:
1. Each time an Adviser considers a
Potential Co-Investment Transaction for
an Affiliated Fund or another Regulated
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Fund that falls within a Regulated
Fund’s then-current Objectives and
Strategies, the Regulated Fund’s Adviser
will make an independent
determination of the appropriateness of
the investment for such Regulated Fund
in light of the Regulated Fund’s thencurrent circumstances.
2.(a) If the Adviser deems a Regulated
Fund’s participation in any Potential
Co-Investment Transaction to be
appropriate for the Regulated Fund, it
will then determine an appropriate level
of investment for the Regulated Fund.
(b) If the aggregate amount
recommended by the applicable Adviser
to be invested by the applicable
Regulated Fund in the Potential CoInvestment Transaction, together with
the amount proposed to be invested by
the other participating Regulated Funds
and Affiliated Funds, collectively, in the
same transaction, exceeds the amount of
the investment opportunity, the
investment opportunity will be
allocated among them pro rata based on
each participant’s ‘‘capital available for
investment’’ in the asset class being
allocated, up to the amount proposed to
be invested by each. The applicable
Adviser will provide the Eligible
Directors of each participating
Regulated Fund with information
concerning each participating party’s
available capital to assist the Eligible
Directors with their review of the
Regulated Fund’s investments for
compliance with these allocation
procedures.
(c) After making the determinations
required in conditions 1 and 2(a), the
applicable Adviser will distribute
written information concerning the
Potential Co-Investment Transaction
(including the amount proposed to be
invested by each participating Regulated
Fund and Affiliated Fund) to the
Eligible Directors of each participating
Regulated Fund for their consideration.
A Regulated Fund will co-invest with
one or more other Regulated Funds and/
or one or more Affiliated Funds only if,
prior to the Regulated Fund’s
participation in the Potential CoInvestment Transaction, a Required
Majority concludes that:
(i) The terms of the Potential CoInvestment Transaction, including the
consideration to be paid, are reasonable
and fair to the Regulated Fund and its
shareholders and do not involve
overreaching in respect of the Regulated
Fund or its shareholders on the part of
any person concerned;
(ii) the Potential Co-Investment
Transaction is consistent with:
(A) The interests of the shareholders
of the Regulated Fund; and
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9761
(B) the Regulated Fund’s then-current
Objectives and Strategies;
(iii) the investment by any other
Regulated Funds or Affiliated Funds
would not disadvantage the Regulated
Fund, and participation by the
Regulated Fund would not be on a basis
different from or less advantageous than
that of other Regulated Funds or
Affiliated Funds; provided that, if any
other Regulated Fund or Affiliated
Fund, but not the Regulated Fund itself,
gains the right to nominate a director for
election to a portfolio company’s board
of directors, the right to have a board
observer or any similar right to
participate in the governance or
management of the portfolio company,
such event shall not be interpreted to
prohibit the Required Majority from
reaching the conclusions required by
this condition (2)(c)(iii), if:
(A) The Eligible Directors will have
the right to ratify the selection of such
director, board observer or participant,
if any;
(B) the applicable Adviser agrees to,
and does, provide periodic reports to
the Regulated Fund’s Board with respect
to the actions of such director or the
information received by such board
observer or obtained through the
exercise of any similar right to
participate in the governance or
management of the portfolio company;
and
(C) any fees or other compensation
that any Affiliated Fund or any
Regulated Fund or any affiliated person
of any Affiliated Fund or any Regulated
Fund receives in connection with the
right of an Affiliated Fund or a
Regulated Fund to nominate a director
or appoint a board observer or otherwise
to participate in the governance or
management of the portfolio company
will be shared proportionately among
the participating Affiliated Funds (who
each may, in turn, share its portion with
its affiliated persons) and the
participating Regulated Funds in
accordance with the amount of each
party’s investment; and
(iv) the proposed investment by the
Regulated Fund will not benefit the
Adviser, the Affiliated Funds or the
other Regulated Funds or any affiliated
person of any of them (other than the
parties to the Co-Investment
Transaction), except (A) to the extent
permitted by condition 13, (B) to the
extent permitted by section 17(e) of the
Act, (C) indirectly, as a result of an
interest in the securities issued by one
of the parties to the Co-Investment
Transaction, or (D) in the case of fees or
other compensation described in
condition 2(c)(iii)(C).
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3. Each Regulated Fund has the right
to decline to participate in any Potential
Co-Investment Transaction or to invest
less than the amount proposed.
4. The applicable Adviser will present
to the Board of each Regulated Fund, on
a quarterly basis, a record of all
investments in Potential Co-Investment
Transactions made by any of the other
Regulated Funds or Affiliated Funds
during the preceding quarter that fell
within the Regulated Fund’s thencurrent Objectives and Strategies that
were not made available to the
Regulated Fund, and an explanation of
why the investment opportunities were
not offered to the Regulated Fund. All
information presented to the Board
pursuant to this condition will be kept
for the life of the Regulated Fund and
at least two years thereafter, and will be
subject to examination by the
Commission and its staff.
5. Except for Follow-On Investments
made in accordance with condition 8,9
a Regulated Fund will not invest in
reliance on the Order in any issuer in
which another Regulated Fund,
Affiliated Fund, or any affiliated person
of another Regulated Fund or Affiliated
Fund is an existing investor.
6. A Regulated Fund will not
participate in any Potential CoInvestment Transaction unless the
terms, conditions, price, class of
securities to be purchased, settlement
date, and registration rights will be the
same for each participating Regulated
Fund and Affiliated Fund. The grant to
an Affiliated Fund or another Regulated
Fund, but not the Regulated Fund, of
the right to nominate a director for
election to a portfolio company’s board
of directors, the right to have an
observer on the board of directors or
similar rights to participate in the
governance or management of a
portfolio company will not be
interpreted so as to violate this
condition 6, if conditions 2(c)(iii)(A), (B)
and (C) are met.
7. (a) If any Affiliated Fund or any
Regulated Fund elects to sell, exchange
or otherwise dispose of an interest in a
security that was acquired in a CoInvestment Transaction, the applicable
Adviser will:
(i) Notify each Regulated Fund that
participated in the Co-Investment
Transaction of the proposed disposition
at the earliest practical time; and
(ii) formulate a recommendation as to
participation by each Regulated Fund in
the disposition.
9 This exception applies only to Follow-On
Investments by a Regulated Fund in issuers in
which that Regulated Fund already holds
investments.
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(b) Each Regulated Fund will have the
right to participate in such disposition
on a proportionate basis, at the same
price and on the same terms and
conditions as those applicable to the
participating Affiliated Funds and
Regulated Funds.
(c) A Regulated Fund may participate
in such disposition without obtaining
prior approval of the Required Majority
if: (i) The proposed participation of each
Regulated Fund and each Affiliated
Fund in such disposition is
proportionate to its outstanding
investments in the issuer immediately
preceding the disposition; (ii) the Board
of the Regulated Fund has approved as
being in the best interests of the
Regulated Fund the ability to participate
in such dispositions on a pro rata basis
(as described in greater detail in the
application); and (iii) the Board of the
Regulated Fund is provided on a
quarterly basis with a list of all
dispositions made in accordance with
this condition. In all other cases, the
Adviser will provide its written
recommendation as to the Regulated
Fund’s participation to the Eligible
Directors, and the Regulated Fund will
participate in such disposition solely to
the extent that a Required Majority
determines that it is in the Regulated
Fund’s best interests.
(d) Each Affiliated Fund and each
Regulated Fund will bear its own
expenses in connection with any such
disposition.
8.(a) If any Affiliated Fund or any
Regulated Fund desires to make a
Follow-On Investment in a portfolio
company whose securities were
acquired in a Co-Investment
Transaction, the applicable Adviser
will:
(i) Notify each Regulated Fund that
participated in the Co-Investment
Transaction of the proposed transaction
at the earliest practical time; and
(ii) formulate a recommendation as to
the proposed participation, including
the amount of the proposed Follow-On
Investment, by each Regulated Fund.
(b) A Regulated Fund may participate
in such Follow-On Investment without
obtaining prior approval of the Required
Majority if: (i) The proposed
participation of each Regulated Fund
and each Affiliated Fund in such
investment is proportionate to its
outstanding investments in the issuer
immediately preceding the Follow-On
Investment; and (ii) the Board of the
Regulated Fund has approved as being
in the best interests of the Regulated
Fund the ability to participate in
Follow-On Investments on a pro rata
basis (as described in greater detail in
the application). In all other cases, the
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Adviser will provide its written
recommendation as to the Regulated
Fund’s participation to the Eligible
Directors, and the Regulated Fund will
participate in such Follow-On
Investment solely to the extent that a
Required Majority determines that it is
in the Regulated Fund’s best interests.
(c) If, with respect to any Follow-On
Investment:
(i) The amount of the opportunity is
not based on the Regulated Funds’ and
the Affiliated Funds’ outstanding
investments immediately preceding the
Follow-On Investment; and
(ii) the aggregate amount
recommended by the Adviser to be
invested by each Regulated Fund in the
Follow-On Investment, together with
the amount proposed to be invested by
the participating Affiliated Funds in the
same transaction, exceeds the amount of
the opportunity; then the amount
invested by each such party will be
allocated among them pro rata based on
each participant’s ‘‘capital available for
investment’’ in the asset class being
allocated, up to the amount proposed to
be invested by each.
(d) The acquisition of Follow-On
Investments as permitted by this
condition will be considered a CoInvestment Transaction for all purposes
and subject to the other conditions set
forth in the application.
9. Each Regulated Fund will maintain
the records required by section 57(f)(3)
of the Act as if each of the Regulated
Funds was a business development
company and each of the investments
permitted under these conditions was
approved by the Required Majority
under section 57(f).
10. The Non-Interested Directors of
each Regulated Fund will be provided
quarterly for review all information
concerning Potential Co-Investment
Transactions and Co-Investment
Transactions, including investments
made by other Regulated Funds or
Affiliated Funds that the Regulated
Fund considered but declined to
participate in, so that the Non-Interested
Directors may determine whether all
investments made during the preceding
quarter, including those investments
that the Regulated Fund considered but
declined to participate in, comply with
the conditions of the Order. In addition,
the Non-Interested Directors will
consider at least annually the continued
appropriateness for the Regulated Fund
of participating in new and existing CoInvestment Transactions.
11. No Non-Interested Director of a
Regulated Fund will also be a director,
general partner, managing member or
principal, or otherwise an ‘‘affiliated
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tkelley on DSK3SPTVN1PROD with NOTICES
person’’ (as defined in the Act) of an
Affiliated Fund.
12. The expenses, if any, associated
with acquiring, holding or disposing of
any securities acquired in a CoInvestment Transaction (including,
without limitation, the expenses of the
distribution of any such securities
registered for sale under the 1933 Act)
will, to the extent not payable by the
Adviser under its respective investment
advisory agreements with Affiliated
Funds and the Regulated Funds, be
shared by the Regulated Funds and the
Affiliated Funds in proportion to the
relative amounts of the securities held
or to be acquired or disposed of, as the
case may be.
13. Any transaction fee (including,
without limitation, break-up or
commitment fees but excluding broker’s
fees contemplated by section 17(e) of
the Act), received in connection with a
Co-Investment Transaction will be
distributed to the participating
Regulated Funds and Affiliated Funds
on a pro rata basis based on the amounts
they invested or committed, as the case
may be, in such Co-Investment
Transaction. If any transaction fee is to
be held by the Adviser pending
consummation of the transaction, the
fee will be deposited into an account
maintained by the Adviser at a bank or
banks having the qualifications
prescribed in section 26(a)(1) of the Act,
and the account will earn a competitive
rate of interest that will also be divided
pro rata among the participating
Regulated Funds and Affiliated Funds
based on the amounts they invest in
such Co-Investment Transaction. None
of the Affiliated Funds, the Adviser, the
other Regulated Funds or any affiliated
person of the Regulated Funds or
Affiliated Funds will receive additional
compensation or remuneration of any
kind as a result of or in connection with
a Co-Investment Transaction (other than
(a) in the case of the Regulated Funds
and the Affiliated Funds, the pro rata
transaction fees described above and
fees or other compensation described in
condition 2(c)(iii)(C); and (b) in the case
of the Adviser, investment advisory fees
paid in accordance with the agreement
between the Adviser and the Regulated
Fund or Affiliated Fund.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Brent J. Fields,
Secretary.
[FR Doc. 2015–03653 Filed 2–23–15; 8:45 am]
BILLING CODE 8011–01–P
VerDate Sep<11>2014
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Jkt 235001
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
31458; 812–14341]
Realty Capital Income Funds Trust, et
al.; Notice of Application
February18, 2015.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 12(d)(1)(J) of the
Investment Company Act of 1940 (the
‘‘1940 Act’’) for exemptions from
sections 12(d)(1)(A), (B), and (C) of the
1940 Act, under sections 6(c) and 17(b)
of the 1940 Act for an exemption from
section 17(a) of the 1940 Act, and under
section 6(c) of the 1940 Act for an
exemption from rule 12d1–2(a) under
the 1940 Act.
AGENCY:
9763
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, 405 Park Avenue, 15th
Floor, New York, NY 10022.
FOR FURTHER INFORMATION CONTACT:
Emerson S. Davis, Senior Counsel, at
(202) 551–6868, or Daniele Marchesani,
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.
Summary of the Application:
Applicants request an order that would
(a) permit certain registered open-end
management investment companies that
operate as ‘‘funds of funds’’ to acquire
shares of certain registered open-end
management investment companies,
registered closed-end management
investment companies, ‘‘business
development companies,’’ as defined by
section 2(a)(48) of the 1940 Act, and
registered unit investment trusts that are
within or outside the same group of
investment companies as the acquiring
investment companies and (b) permit
certain registered open-end management
investment companies relying on rule
12d1–2 under the 1940 Act to invest in
certain financial instruments.
Applicants: Realty Capital Income
Funds Trust (‘‘Trust’’), National Fund
Advisors, LLC (‘‘Adviser’’), and Realty
Capital Securities, LLC (the
‘‘Distributor’’).
Applicants’ Representations
1. The Trust is an open-end
management company registered under
the 1940 Act and organized as a
Delaware statutory trust. The Trust has
multiple series which pursue distinct
investment objectives and strategies.1
2. The Adviser, a Delaware limited
liability company, is a registered
investment adviser under the
Investment Advisers Act of 1940 and
serves as the investment adviser to each
of the Funds of Funds (as defined
below).2 The Distributor is a Broker (as
defined below) and serves as the
existing Funds’ principal underwriter
and distributor.
3. Applicants request relief to the
extent necessary to permit: (a) A Fund
(each, a ‘‘Fund of Funds,’’ and
collectively, the ‘‘Funds of Funds’’) to
Filing Dates: The application
was filed on August 1, 2014, and
amended on December 3, 2014 and on
February 6, 2015.
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 March 16, 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
1 The applicants request that the order apply not
only to any existing series of the Trust, but that the
order also extend to any future series of the Trust,
and any other existing or future registered open-end
management investment companies and any series
thereof that are, or may in the future be, advised
by the Adviser or any other investment adviser
controlling, controlled by, or under common
control with the Adviser (included in the term
‘‘Adviser’’) and that are part of the same group of
investment companies, as defined in Section
12(d)(1)(G)(ii) of the Investment Company Act of
1940, as amended (the ‘‘1940 Act’’), as the Trust
(together with the existing series of the Trust, each
series a ‘‘Fund,’’ and collectively, the ‘‘Funds’’). All
entities that currently intend to rely on the
requested order are named as applicants. Any other
entity that relies on the order in the future will
comply with the terms and conditions of the
application.
2 All references to the term ‘‘Adviser’’ include
successors-in-interest to the Adviser. A successorin-interest is limited to an entity that results from
a reorganization into another jurisdiction or a
change in the type of business organization.
SUMMARY:
DATES:
PO 00000
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Agencies
[Federal Register Volume 80, Number 36 (Tuesday, February 24, 2015)]
[Notices]
[Pages 9759-9763]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2015-03653]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-31457; File No. 812-14330]
Eagle Point Credit Company Inc., et al.; Notice of Application
February 18, 2015.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application for an order under section 17(d) of the
Investment Company Act of 1940 (the ``Act'') and rule 17d-1 under the
Act to permit certain joint transactions otherwise prohibited by
section 17(d) of the Act and rule 17d-1 under the Act.
-----------------------------------------------------------------------
SUMMARY: Summary of Application: Applicants request an order to permit
Eagle Point Credit Company Inc. to co-invest in portfolio companies
with certain affiliated investment funds.
Applicants: Eagle Point Credit Company Inc. (``EPCC''), Eagle Point
Credit Management LLC (``EPCM''), Eagle Point Credit Partners LP
(``EPCP''), Eagle Point Credit GP I LP (``General Partner''), Eagle
Point Credit Company Sub LLC (``EPCC Sub''), Eagle Point Credit
Partners Sub Ltd. (``EPCP Sub''), and Eagle Point Credit Partners Sub
III Ltd. (``EPCP Sub III'').
DATES: Filing Dates: The application was filed on July 10, 2014, and
amended on November 20, 2014 and January 30, 2015.
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 March 16, 2015, and should be accompanied by proof of
service on applicants, in the form of an affidavit or, for lawyers, a
certificate of service. Hearing requests should state the nature of the
writer's interest, the reason for the request, and the issues
contested. Persons who wish to be notified of a hearing may request
notification by writing to the Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
St. NE., Washington, DC 20549-1090. Applicants: 20 Horseneck Lane,
Greenwich, CT 06830.
FOR FURTHER INFORMATION CONTACT: Vanessa M. Meeks, Senior Counsel, or
Melissa R. Harke, Branch Chief, at (202) 551-6825 (Chief Counsel's
Office, Division of Investment Management).
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. EPCC (formerly Eagle Point Credit Company LLC) is a Delaware
corporation that is registered as a closed-end management investment
company under the Act. EPCC's primary investment objective is to
generate high current income, with a secondary objective to generate
capital appreciation. EPCC seeks to achieve its investment objectives
by investing primarily in equity and junior debt tranches of
collateralized loan obligations (``CLOs'') that are collateralized by a
diverse portfolio consisting primarily of below investment grade U.S.
senior secured loans. The board of directors of EPCC is currently
comprised of six directors, four of whom are not ``interested
persons,'' within the meaning of section 2(a)(19) of the Act (the
``Non-Interested Directors''), of EPCC.
2. EPCP is a Cayman Islands exempted limited partnership that would
be an investment company under the 1940 Act but for Section 3(c)(7) of
the 1940 Act. EPCP's investment
[[Page 9760]]
objectives and strategies are equivalent, in all material respects, to
EPCC's Objectives and Strategies.\1\ The General Partner has ultimate
responsibility for the management of EPCP.
---------------------------------------------------------------------------
\1\ ``Objectives and Strategies'' means a Regulated Fund's (as
defined below) investment objectives and strategies, as described in
the Regulated Fund's registration statement on Form N-2, other
filings the Regulated Fund has made with the Commission under the
Securities Act of 1933 (the ``Securities Act''), or under the
Securities Exchange Act of 1934, and the Regulated Fund's reports to
shareholders.
---------------------------------------------------------------------------
3. Each of EPCP Sub and EPCP Sub III is a Cayman Islands exempted
company. EPCP Sub is a direct, wholly-owned special purpose subsidiary
of EPCP. EPCP Sub III is a direct, wholly-owned special purpose
subsidiary of EPCP Sub. EPCP Sub and EPCP Sub III are each excluded
from registration as an investment company under Section 3(c)(7) of the
1940 Act. All investment decisions relating to the assets held at EPCP
Sub and EPCP Sub III are made by EPCM as investment adviser to EPCP.
4. EPCM is a Delaware limited liability company registered as an
investment adviser under the Investment Advisers Act of 1940 (the
``Advisers Act''). EPCM serves as the investment adviser to EPCC and
EPCP.
5. Applicants seek an order (``Order'') to permit one or more
Regulated Funds \2\ and/or one or more Affiliated Funds \3\ to
participate in the same investment opportunities through a proposed co-
investment program (the ``Co-Investment Program'') where such
participation would otherwise be prohibited under rule 17d-1 by (a) co-
investing with each other in securities issued by issuers in private
placement transactions in which an Adviser negotiates terms in addition
to price; \4\ and (b) making additional investments in securities of
such issuers, including through the exercise of warrants, conversion
privileges, and other rights to purchase securities of the issuers
(``Follow-On Investments''). ``Co-Investment Transaction'' means any
transaction in which a Regulated Fund (or its Wholly-Owned Investment
Sub, as defined below) participates together with one or more other
Regulated Funds and/or one or more Affiliated Funds in reliance on the
requested Order. ``Potential Co-Investment Transaction'' means any
investment opportunity in which a Regulated Fund (or its Wholly-Owned
Investment Sub, as defined below) could not participate together with
one or more Affiliated Funds and/or one or more other Regulated Funds
without obtaining and relying on the Order.\5\
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\2\ ``Regulated Fund'' means EPCC and any Future Regulated Fund.
``Future Regulated Fund'' means any closed-end management investment
company (a) that is registered under the Act, (b) whose investment
adviser is an Adviser, and (c) that intends to participate in the
Co-Investment Program. The term ``Adviser'' means (a) EPCM and (b)
any future investment adviser that controls, is controlled by or is
under common control with EPCM and is registered as an investment
adviser under the Advisers Act.
\3\ ``Affiliated Fund'' means any of EPCP and any Future
Affiliated Fund. ``Future Affiliated Fund'' means any entity (a)
whose investment adviser is an Adviser, (b) that would be an
investment company but for section 3(c)(1) or 3(c)(7) of the Act,
and (c) that intends to participate in the Co-Investment Program.
\4\ The term ``private placement transactions'' means
transactions in which the offer and sale of securities by the issuer
are exempt from registration under the Securities Act.
\5\ All existing entities that currently intend to rely upon the
requested Order have been named as applicants. Any other existing or
future entity that subsequently relies on the Order will comply with
the terms and conditions of the application.
---------------------------------------------------------------------------
6. Applicants state that a Regulated Fund may, from time to time,
form one or more Wholly-Owned Investment Subs.\6\ Such a subsidiary
would be prohibited from investing in a Co-Investment Transaction with
any Affiliated Fund or Regulated Fund because it would be a company
controlled by its parent Regulated Fund for purposes of rule 17d-1.
Applicants request that each Wholly-Owned Investment Sub be permitted
to participate in Co-Investment Transactions in lieu of its parent
Regulated Fund and that the Wholly-Owned Investment Sub's participation
in any such transaction be treated, for purposes of the requested
order, as though the parent Regulated Fund were participating directly.
Applicants represent that this treatment is justified because a Wholly-
Owned Investment Sub would have no purpose other than serving as a
holding vehicle for the Regulated Fund's investments and, therefore, no
conflicts of interest could arise between the Regulated Fund and the
Wholly-Owned Investment Sub. The Regulated Fund's Board would make all
relevant determinations under the conditions with regard to a Wholly-
Owned Investment Sub's participation in a Co-Investment Transaction,
and the Regulated Fund's Board would be informed of, and take into
consideration, any proposed use of a Wholly-Owned Investment Sub in the
Regulated Fund's place. If the Regulated Fund proposes to participate
in the same Co-Investment Transaction with any of its Wholly-Owned
Investment Subs, the Board will also be informed of, and take into
consideration, the relative participation of the Regulated Fund and the
Wholly-Owned Investment Sub. EPCC Sub is a Delaware limited liability
company and is a Wholly-Owned Investment Sub of EPCC.
---------------------------------------------------------------------------
\6\ The term ``Wholly-Owned Investment Sub'' means an entity (i)
that is wholly-owned by a Regulated Fund (with the Regulated Fund at
all times holding, beneficially and of record, 100% of the voting
and economic interests); (ii) whose sole business purpose is to hold
one or more investments and issue debt on behalf of the Regulated
Fund; (iii) with respect to which the Regulated Fund's board of
directors or trustees has the sole authority to make all
determinations with respect to the entity's participation under the
conditions of the application; and (iv) that would be an investment
company but for section 3(c)(1) or 3(c)(7) of the Act.
---------------------------------------------------------------------------
7. When considering Potential Co-Investment Transactions for any
Regulated Fund, the applicable Adviser will consider only the
Objectives and Strategies, investment policies, investment positions,
capital available for investment, and other pertinent factors
applicable to that Regulated Fund. Due to the similarity in Objectives
and Strategies of certain Regulated Funds with the investment
objectives, policies and strategies of certain Affiliated Funds, the
Adviser expects that investments for a Regulated Fund should also
generally be appropriate investments for one or more other Regulated
Funds and/or one or more Affiliated Funds, with certain exceptions
based on available capital or diversification.\7\
---------------------------------------------------------------------------
\7\ The Regulated Funds, however, will not be obligated to
invest, or co-invest, when investment opportunities are referred to
them.
---------------------------------------------------------------------------
8. Other than pro rata dispositions and Follow-On Investments as
provided in conditions 7 and 8, and after making the determinations
required in conditions 1 and 2(a), the Adviser will present each
Potential Co-Investment Transaction and the proposed allocation to the
directors of the Board eligible to vote under section 57(o) of the Act
(``Eligible Directors''), and the ``required majority,'' as defined in
section 57(o) of the Act (``Required Majority'') \8\ will approve each
Co-Investment Transaction prior to any investment by the participating
Regulated Fund.
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\8\ Although each Regulated Fund will be a registered closed-end
fund, the Board members that make up the Required Majority will be
determined as if the Regulated Fund were a BDC subject to section
57(o).
---------------------------------------------------------------------------
9. With respect to the pro rata dispositions and Follow-On
Investments provided in conditions 7 and 8, a Regulated Fund may
participate in a pro rata disposition or Follow-On Investment without
obtaining prior approval of the Required Majority if, among other
things: (i) The proposed participation of each Regulated Fund and
Affiliated Fund in such disposition is proportionate to its outstanding
investments in the issuer immediately
[[Page 9761]]
preceding the disposition or Follow-On Investment, as the case may be;
and (ii) the Board of the Regulated Fund has approved that Regulated
Fund's participation in pro rata dispositions and Follow-On Investments
as being in the best interests of the Regulated Fund. If the Board does
not so approve, any such disposition or Follow-On Investment will be
submitted to the Regulated Fund's Eligible Directors. The Board of any
Regulated Fund may at any time rescind, suspend or qualify its approval
of pro rata dispositions and Follow-On Investments with the result that
all dispositions and/or Follow-On Investments must be submitted to the
Eligible Directors.
10. No Non-Interested Director of a Regulated Fund will have a
financial interest in any Co-Investment Transaction, other than through
share ownership in one of the Regulated Funds.
Applicants' Legal Analysis
1. Section 17(d) of the Act and rule 17d-1 under the Act prohibit
affiliated persons of a registered investment company from
participating in joint transactions with the company unless the
Commission has granted an order permitting such transactions. In
passing upon applications under rule 17d-1, the Commission considers
whether the company's participation in the joint transaction is
consistent with the provisions, policies, and purposes of the Act and
the extent to which such participation is on a basis different from or
less advantageous than that of other participants.
2. Applicants state that in the absence of the requested relief, a
Regulated Fund would be, in some circumstances, limited in its ability
to participate in attractive and appropriate investment opportunities.
Applicants believe that the proposed terms and conditions will ensure
that the Co-Investment Transactions are consistent with the protection
of each Regulated Fund's shareholders and with the purposes intended by
the policies and provisions of the Act. Applicants state that the
Regulated Funds' participation in the Co-Investment Transactions will
be consistent with the provisions, policies, and purposes of the Act
and on a basis that is not different from or less advantageous than
that of other participants.
Applicants' Conditions
Applicants agree that the Order will be subject to the following
conditions:
1. Each time an Adviser considers a Potential Co-Investment
Transaction for an Affiliated Fund or another Regulated Fund that falls
within a Regulated Fund's then-current Objectives and Strategies, the
Regulated Fund's Adviser will make an independent determination of the
appropriateness of the investment for such Regulated Fund in light of
the Regulated Fund's then-current circumstances.
2.(a) If the Adviser deems a Regulated Fund's participation in any
Potential Co-Investment Transaction to be appropriate for the Regulated
Fund, it will then determine an appropriate level of investment for the
Regulated Fund.
(b) If the aggregate amount recommended by the applicable Adviser
to be invested by the applicable Regulated Fund in the Potential Co-
Investment Transaction, together with the amount proposed to be
invested by the other participating Regulated Funds and Affiliated
Funds, collectively, in the same transaction, exceeds the amount of the
investment opportunity, the investment opportunity will be allocated
among them pro rata based on each participant's ``capital available for
investment'' in the asset class being allocated, up to the amount
proposed to be invested by each. The applicable Adviser will provide
the Eligible Directors of each participating Regulated Fund with
information concerning each participating party's available capital to
assist the Eligible Directors with their review of the Regulated Fund's
investments for compliance with these allocation procedures.
(c) After making the determinations required in conditions 1 and
2(a), the applicable Adviser will distribute written information
concerning the Potential Co-Investment Transaction (including the
amount proposed to be invested by each participating Regulated Fund and
Affiliated Fund) to the Eligible Directors of each participating
Regulated Fund for their consideration. A Regulated Fund will co-invest
with one or more other Regulated Funds and/or one or more Affiliated
Funds only if, prior to the Regulated Fund's participation in the
Potential Co-Investment Transaction, a Required Majority concludes
that:
(i) The terms of the Potential Co-Investment Transaction, including
the consideration to be paid, are reasonable and fair to the Regulated
Fund and its shareholders and do not involve overreaching in respect of
the Regulated Fund or its shareholders on the part of any person
concerned;
(ii) the Potential Co-Investment Transaction is consistent with:
(A) The interests of the shareholders of the Regulated Fund; and
(B) the Regulated Fund's then-current Objectives and Strategies;
(iii) the investment by any other Regulated Funds or Affiliated
Funds would not disadvantage the Regulated Fund, and participation by
the Regulated Fund would not be on a basis different from or less
advantageous than that of other Regulated Funds or Affiliated Funds;
provided that, if any other Regulated Fund or Affiliated Fund, but not
the Regulated Fund itself, gains the right to nominate a director for
election to a portfolio company's board of directors, the right to have
a board observer or any similar right to participate in the governance
or management of the portfolio company, such event shall not be
interpreted to prohibit the Required Majority from reaching the
conclusions required by this condition (2)(c)(iii), if:
(A) The Eligible Directors will have the right to ratify the
selection of such director, board observer or participant, if any;
(B) the applicable Adviser agrees to, and does, provide periodic
reports to the Regulated Fund's Board with respect to the actions of
such director or the information received by such board observer or
obtained through the exercise of any similar right to participate in
the governance or management of the portfolio company; and
(C) any fees or other compensation that any Affiliated Fund or any
Regulated Fund or any affiliated person of any Affiliated Fund or any
Regulated Fund receives in connection with the right of an Affiliated
Fund or a Regulated Fund to nominate a director or appoint a board
observer or otherwise to participate in the governance or management of
the portfolio company will be shared proportionately among the
participating Affiliated Funds (who each may, in turn, share its
portion with its affiliated persons) and the participating Regulated
Funds in accordance with the amount of each party's investment; and
(iv) the proposed investment by the Regulated Fund will not benefit
the Adviser, the Affiliated Funds or the other Regulated Funds or any
affiliated person of any of them (other than the parties to the Co-
Investment Transaction), except (A) to the extent permitted by
condition 13, (B) to the extent permitted by section 17(e) of the Act,
(C) indirectly, as a result of an interest in the securities issued by
one of the parties to the Co-Investment Transaction, or (D) in the case
of fees or other compensation described in condition 2(c)(iii)(C).
[[Page 9762]]
3. Each Regulated Fund has the right to decline to participate in
any Potential Co-Investment Transaction or to invest less than the
amount proposed.
4. The applicable Adviser will present to the Board of each
Regulated Fund, on a quarterly basis, a record of all investments in
Potential Co-Investment Transactions made by any of the other Regulated
Funds or Affiliated Funds during the preceding quarter that fell within
the Regulated Fund's then-current Objectives and Strategies that were
not made available to the Regulated Fund, and an explanation of why the
investment opportunities were not offered to the Regulated Fund. All
information presented to the Board pursuant to this condition will be
kept for the life of the Regulated Fund and at least two years
thereafter, and will be subject to examination by the Commission and
its staff.
5. Except for Follow-On Investments made in accordance with
condition 8,\9\ a Regulated Fund will not invest in reliance on the
Order in any issuer in which another Regulated Fund, Affiliated Fund,
or any affiliated person of another Regulated Fund or Affiliated Fund
is an existing investor.
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\9\ This exception applies only to Follow-On Investments by a
Regulated Fund in issuers in which that Regulated Fund already holds
investments.
---------------------------------------------------------------------------
6. A Regulated Fund will not participate in any Potential Co-
Investment Transaction unless the terms, conditions, price, class of
securities to be purchased, settlement date, and registration rights
will be the same for each participating Regulated Fund and Affiliated
Fund. The grant to an Affiliated Fund or another Regulated Fund, but
not the Regulated Fund, of the right to nominate a director for
election to a portfolio company's board of directors, the right to have
an observer on the board of directors or similar rights to participate
in the governance or management of a portfolio company will not be
interpreted so as to violate this condition 6, if conditions
2(c)(iii)(A), (B) and (C) are met.
7. (a) If any Affiliated Fund or any Regulated Fund elects to sell,
exchange or otherwise dispose of an interest in a security that was
acquired in a Co-Investment Transaction, the applicable Adviser will:
(i) Notify each Regulated Fund that participated in the Co-
Investment Transaction of the proposed disposition at the earliest
practical time; and
(ii) formulate a recommendation as to participation by each
Regulated Fund in the disposition.
(b) Each Regulated Fund will have the right to participate in such
disposition on a proportionate basis, at the same price and on the same
terms and conditions as those applicable to the participating
Affiliated Funds and Regulated Funds.
(c) A Regulated Fund may participate in such disposition without
obtaining prior approval of the Required Majority if: (i) The proposed
participation of each Regulated Fund and each Affiliated Fund in such
disposition is proportionate to its outstanding investments in the
issuer immediately preceding the disposition; (ii) the Board of the
Regulated Fund has approved as being in the best interests of the
Regulated Fund the ability to participate in such dispositions on a pro
rata basis (as described in greater detail in the application); and
(iii) the Board of the Regulated Fund is provided on a quarterly basis
with a list of all dispositions made in accordance with this condition.
In all other cases, the Adviser will provide its written recommendation
as to the Regulated Fund's participation to the Eligible Directors, and
the Regulated Fund will participate in such disposition solely to the
extent that a Required Majority determines that it is in the Regulated
Fund's best interests.
(d) Each Affiliated Fund and each Regulated Fund will bear its own
expenses in connection with any such disposition.
8.(a) If any Affiliated Fund or any Regulated Fund desires to make
a Follow-On Investment in a portfolio company whose securities were
acquired in a Co-Investment Transaction, the applicable Adviser will:
(i) Notify each Regulated Fund that participated in the Co-
Investment Transaction of the proposed transaction at the earliest
practical time; and
(ii) formulate a recommendation as to the proposed participation,
including the amount of the proposed Follow-On Investment, by each
Regulated Fund.
(b) A Regulated Fund may participate in such Follow-On Investment
without obtaining prior approval of the Required Majority if: (i) The
proposed participation of each Regulated Fund and each Affiliated Fund
in such investment is proportionate to its outstanding investments in
the issuer immediately preceding the Follow-On Investment; and (ii) the
Board of the Regulated Fund has approved as being in the best interests
of the Regulated Fund the ability to participate in Follow-On
Investments on a pro rata basis (as described in greater detail in the
application). In all other cases, the Adviser will provide its written
recommendation as to the Regulated Fund's participation to the Eligible
Directors, and the Regulated Fund will participate in such Follow-On
Investment solely to the extent that a Required Majority determines
that it is in the Regulated Fund's best interests.
(c) If, with respect to any Follow-On Investment:
(i) The amount of the opportunity is not based on the Regulated
Funds' and the Affiliated Funds' outstanding investments immediately
preceding the Follow-On Investment; and
(ii) the aggregate amount recommended by the Adviser to be invested
by each Regulated Fund in the Follow-On Investment, together with the
amount proposed to be invested by the participating Affiliated Funds in
the same transaction, exceeds the amount of the opportunity; then the
amount invested by each such party will be allocated among them pro
rata based on each participant's ``capital available for investment''
in the asset class being allocated, up to the amount proposed to be
invested by each.
(d) The acquisition of Follow-On Investments as permitted by this
condition will be considered a Co-Investment Transaction for all
purposes and subject to the other conditions set forth in the
application.
9. Each Regulated Fund will maintain the records required by
section 57(f)(3) of the Act as if each of the Regulated Funds was a
business development company and each of the investments permitted
under these conditions was approved by the Required Majority under
section 57(f).
10. The Non-Interested Directors of each Regulated Fund will be
provided quarterly for review all information concerning Potential Co-
Investment Transactions and Co-Investment Transactions, including
investments made by other Regulated Funds or Affiliated Funds that the
Regulated Fund considered but declined to participate in, so that the
Non-Interested Directors may determine whether all investments made
during the preceding quarter, including those investments that the
Regulated Fund considered but declined to participate in, comply with
the conditions of the Order. In addition, the Non-Interested Directors
will consider at least annually the continued appropriateness for the
Regulated Fund of participating in new and existing Co-Investment
Transactions.
11. No Non-Interested Director of a Regulated Fund will also be a
director, general partner, managing member or principal, or otherwise
an ``affiliated
[[Page 9763]]
person'' (as defined in the Act) of an Affiliated Fund.
12. The expenses, if any, associated with acquiring, holding or
disposing of any securities acquired in a Co-Investment Transaction
(including, without limitation, the expenses of the distribution of any
such securities registered for sale under the 1933 Act) will, to the
extent not payable by the Adviser under its respective investment
advisory agreements with Affiliated Funds and the Regulated Funds, be
shared by the Regulated Funds and the Affiliated Funds in proportion to
the relative amounts of the securities held or to be acquired or
disposed of, as the case may be.
13. Any transaction fee (including, without limitation, break-up or
commitment fees but excluding broker's fees contemplated by section
17(e) of the Act), received in connection with a Co-Investment
Transaction will be distributed to the participating Regulated Funds
and Affiliated Funds on a pro rata basis based on the amounts they
invested or committed, as the case may be, in such Co-Investment
Transaction. If any transaction fee is to be held by the Adviser
pending consummation of the transaction, the fee will be deposited into
an account maintained by the Adviser at a bank or banks having the
qualifications prescribed in section 26(a)(1) of the Act, and the
account will earn a competitive rate of interest that will also be
divided pro rata among the participating Regulated Funds and Affiliated
Funds based on the amounts they invest in such Co-Investment
Transaction. None of the Affiliated Funds, the Adviser, the other
Regulated Funds or any affiliated person of the Regulated Funds or
Affiliated Funds will receive additional compensation or remuneration
of any kind as a result of or in connection with a Co-Investment
Transaction (other than (a) in the case of the Regulated Funds and the
Affiliated Funds, the pro rata transaction fees described above and
fees or other compensation described in condition 2(c)(iii)(C); and (b)
in the case of the Adviser, investment advisory fees paid in accordance
with the agreement between the Adviser and the Regulated Fund or
Affiliated Fund.
For the Commission, by the Division of Investment Management,
under delegated authority.
Brent J. Fields,
Secretary.
[FR Doc. 2015-03653 Filed 2-23-15; 8:45 am]
BILLING CODE 8011-01-P