Citicorp, et al.; Notice of Application and Temporary Order, 30293-30297 [2015-12756]
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Federal Register / Vol. 80, No. 101 / Wednesday, May 27, 2015 / Notices
general to protect investors and the
public interest.
The Exchange believes that the
proposed rule change removes
impediments to and perfects the
mechanism of a free and open market by
codifying that the Exchange may
directly provide to Clearing Participants
which guarantee that Participant’s
transactions on the Exchange the
Participant-designated risk settings in
the trading system, which are designed
to mitigate the potential risk of ‘‘rapid
fire’’ executions that could result in
large and unintended principal
positions and expose the Participant to
unnecessary market risk. The Exchange
believes that the proposed rule change
is consistent with the protection of
investors and the public interest
because it will permit Clearing
Participants with a financial interest in
a Participant’s risk settings to better
monitor and manage the potential risks
assumed by Participants with whom the
Clearing Participant has entered into a
letter of guarantee, thereby providing
Clearing Participants with greater
control and flexibility over setting their
own risk tolerance and exposure.
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B. Self-Regulatory Organization’s
Statement on Burden on Competition
The Exchange does not believe that
the proposed rule change will impose
any burden on competition not
necessary or appropriate in furtherance
of the purposes of the Act. In this regard
and as indicated above, the Exchange
notes that the rule change is being
proposed as a response to a filing
submitted by ISE.12 The proposed rule
change is not designed to address any
competitive issues and does not pose an
undue burden on non-Clearing
Participants because, unlike Clearing
Participants, non-Clearing Participants
do not guarantee the execution of a
Participant’s BOX Transactions. The
proposed rule change would provide
authority for the Exchange to directly
share risk settings with Clearing
Participants regarding the Participants
with whom the Clearing Participant has
executed a letter of guarantee so the
Clearing Participant can better monitor
and manage the potential risks assumed
by the Participants, thereby providing
them with greater control and flexibility
over setting their own risk tolerance and
exposure. The proposed rule change is
structured to offer the same
enhancement to all Clearing
Participants, regardless of size, and
would not impose a competitive burden
on any participant.
12 See
supra, note 6.
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C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
The Exchange has neither solicited
nor received comments on the proposed
rule change.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Because the foregoing proposed rule
change does not: (i) Significantly affect
the protection of investors or the public
interest; (ii) impose any significant
burden on competition; and (iii) become
operative for 30 days from the date on
which it was filed, or such shorter time
as the Commission may designate, it has
become effective pursuant to Section
19(b)(3)(A) of the Act 13 and Rule 19b–
4(f)(6) 14 thereunder. At any time within
60 days of the filing of the proposed rule
change, the Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is necessary or appropriate in the
public interest, for the protection of
investors, or otherwise in furtherance of
the purposes of the Act. If the
Commission takes such action, the
Commission will institute proceedings
to determine whether the proposed rule
change should be approved or
disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
30293
number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing will also be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–BOX–
2015–20 and should be submitted on or
before June 17, 2015.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.15
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2015–12686 Filed 5–26–15; 8:45 am]
BILLING CODE 8011–01–P
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
BOX–2015–20 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Brent J. Fields, Secretary, Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
All submissions should refer to File
Number SR–BOX–2015–20. This file
13 15
U.S.C. 78s(b)(3)(A).
CFR 240.19b–4(f)(6). As required under Rule
19b–4(f)(6)(iii), the Exchange provided the
Commission with written notice of its intent to file
the proposed rule change, along with a brief
description and the text of the proposed rule
change, at least five business days prior to the date
of filing of the proposed rule change, or such
shorter time as designated by the Commission.
14 17
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–31615; File No. 812–14468]
Citicorp, et al.; Notice of Application
and Temporary Order
May 20, 2015.
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 a guilty plea entered on May
SUMMARY OF APPLICATION:
15 17
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20, 2015, by the Settling Firm (as
defined below) in the United States
District Court for the District of
Connecticut (the ‘‘District Court’’) in
connection with a plea agreement (‘‘Plea
Agreement’’) between the Settling Firm
and the United States Department of
Justice (‘‘DOJ’’), 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: Citicorp, a Delaware
corporation, (the ‘‘Settling Firm’’),
Citigroup Global Markets Inc. (‘‘CGMI’’),
CEFOF GP I Corp. (‘‘CEFOF’’), CELFOF
GP Corp. (‘‘CELFOF’’), Citibank, N.A.
(‘‘Citibank’’), Citigroup Alternative
Investments LLC (‘‘Citigroup
Alternative’’), Citigroup Capital Partners
I GP I Corp. (‘‘CCP I’’), Citigroup Capital
Partners I GP II Corp. (‘‘CCP II’’),
Citigroup Private Equity (Offshore) LLC
(‘‘CPE (Offshore)’’), and Citigroup First
Investment Management Americas LLC
(‘‘CFIMA’’, and along, together with
CGMI, CEFOF, CELFOF, Citibank,
Citigroup Alternative, CCP I, CCP II, and
CPE (Offshore), the ‘‘Adviser
Applicants’’ and the Settling Firm
together with the Adviser Applicants,
the ‘‘Applicants’’).
FILING DATE: The application was filed
on May 20, 2015.
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 June 15, 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: The Settling Firm and
Citibank: 399 Park Avenue, New York,
NY 10043 CGMI, CEFOF, CELFOF,
Citigroup Alternative, CCP I, CCP II,
CPE (Offshore), and CFIMA: 388
Greenwich Street, New York, NY 10013.
FOR FURTHER INFORMATION CONTACT: Kyle
R. Ahlgren, Senior Counsel, Vanessa M.
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Meeks, Senior Counsel, or Holly HunterCeci, Branch Chief, at (202) 551–6825
(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. Citigroup Inc. (‘‘Citigroup’’ or
‘‘Citi’’), the parent company of the
Settling Firm, CGMI and the other
Adviser Applicants, is a global financial
holding company whose businesses
provide a broad range of financial
services. The Settling Firm is a financial
services holding company and the direct
parent company of Citibank. CGMI, a
New York corporation and an Affiliated
Person of the Settling Firm, is a full
service investment banking firm. CGMI
engages in securities underwriting, sales
and trading, investment banking,
financial advisory and investment
research services. CGMI is registered as
a broker-dealer under the Securities
Exchange Act of 1934 (‘‘Exchange Act’’)
and as an investment adviser under the
Investment Advisers Act of 1940
(‘‘Advisers Act’’). CGMI currently does
not perform Fund Service Activities (as
defined below) for any Fund1, but it
may seek to do so in the future. CFIMA,
a Delaware limited liability company
and an Affiliated Person of the Settling
Firm, is registered as an investment
adviser under the Advisers Act and
serves as investment adviser to one
Fund. CFIMA currently does not serve
as depositor or principal underwriter for
any Fund, but it may seek to do so in
the future. Each of CEFOF, CELFOF,
Citibank, Citigroup Alternative, CCP I,
CCP II and CPE (Offshore) (collectively,
the ‘‘ESC Advisers’’) is an Affiliated
Person of the Settling Firm and serves
as investment adviser to certain ESCs
(ESCs are included in the term ‘‘Funds’’)
sponsored by Citigroup and its
1 For purposes of the application ‘‘Funds’’ refers
to any registered investment company, business
development company, or employees’ securities
company (as defined in section 2(a)(13) of the Act)
for which a Covered Person serves or may in the
future serve as an investment adviser (as defined in
section 2(a)(20) of the Act), sub-adviser, general
partner or depositor, or any registered open-end
investment company, registered unit investment
trust or registered face amount certificate company
for which a Covered Person (as defined above)
serves or may in the future serve as principal
underwriter (as defined in section 2(a)(29) of the
Act).
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subsidiaries. None of the ESC Advisers
perform any Fund Service Activities for
any Funds other than the ESCs. The
ESCs have been exempted from all
provisions of the Act and the rules and
regulations thereunder, except for
certain sections, including section 9,
pursuant to a Commission order.2
2. While no existing company of
which the Settling Firm is an affiliated
person within the meaning of section
2(a)(3) of the Act (‘‘Affiliated Person’’),
other than the Adviser 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 (such activities, ‘‘Fund Service
Activities’’), Applicants request that any
relief granted also apply to any existing
company of which the Settling Firm is
an Affiliated Person, and to any other
company of which the Settling Firm
may become an Affiliated Person in the
future (together with the Applicants, the
‘‘Covered Persons’’) with respect to any
activity contemplated by section 9(a) of
the Act.
3. The DOJ has conducted an
investigation of certain conduct and
practices of Citi and others in the
foreign currency exchange (‘‘FX’’) spot
market. To resolve the DOJ’s
investigation, the Settling Firm entered
into the Plea Agreement, pursuant to
which the Settling Firm has pleaded
guilty to one count of an antitrust
violation of 15 U.S.C. 1. As set forth in
the Plea Agreement, from at least
December 2007 and continuing to at
least January 2013 (the ‘‘Relevant
Period’’), the Settling Firm, through one
London-based euro/U.S. dollar (‘‘EUR/
USD’’) trader employed by Citibank, a
subsidiary of the Settling Firm and an
Applicant hereto, and other traders at
unrelated financial services firms acting
as dealers in the FX spot market entered
into and engaged in a conspiracy to fix,
stabilize, maintain, increase or decrease
the price of, and rig bids and offers for,
the EUR/USD currency pair exchanged
in the FX spot market by agreeing to
eliminate competition in the purchase
and sale of the EUR/USD currency pair
in the United States and elsewhere (the
2 Greenwich Street Employees Fund, L.P., et al.,
Investment Company Act Release Nos. 25324 (Dec.
21, 2001) (notice) and 25367 (Jan. 16, 2002) (order).
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‘‘Conduct’’). The Conduct included near
daily conversations, some of which
were in code, in an exclusive electronic
chat room used by certain EUR/USD
traders, including the EUR/USD trader
employed by Citibank. The Conduct
forms the basis for the DOJ’s antitrust
charge that the Settling Firm violated 15
U.S.C. 1.
4. Under the terms of the Plea
Agreement, the DOJ and the Settling
Firm have agreed that the District Court
should impose a sentence requiring the
Settling Firm to pay a criminal fine of
$925 million. The Plea Agreement also
provides for a three-year term of
probation, with conditions to include,
among other things, Citi’s continued
implementation of a compliance
program designed to prevent and detect
the Conduct throughout its operations,
and Citi’s further strengthening of its
compliance and internal controls as
required by other regulatory or
enforcement agencies that have
addressed the Conduct, including the
U.S. Commodity Futures Trading
Commission (‘‘CFTC’’), pursuant to its
settlement with Citibank on November
11, 2014, requiring remedial measures
to strengthen the control framework
governing Citi’s FX trading business (the
‘‘CFTC Order’’); the U.S. Treasury
Department’s Office of the Comptroller
of the Currency (‘‘OCC’’), pursuant to its
settlement with Citibank on November
11, 2014, requiring remedial measures
to improve the control framework
governing Citi’s wholesale trading and
benchmark activities (the ‘‘OCC Order’’);
the U.K. Financial Conduct Authority
(‘‘FCA’’), pursuant to its settlement with
Citibank on November 11, 2014 (the
‘‘FCA Order’’); and the U.S. Board of
Governors of the Federal Reserve
System (‘‘FRB’’), pursuant to its
settlement with Citigroup entered into
concurrently with the DOJ resolution,
requiring remedial measures to improve
controls for FX trading and activities
involving commodities and interest rate
products where Citi acts as principal
(the ‘‘FRB Order’’).
Applicants’ Legal Analysis
1. Section 9(a)(1) of the Act provides,
in pertinent part, that a person may not
serve or act as an investment adviser or
depositor of any registered investment
company or a principal underwriter for
any registered open-end investment
company, registered unit investment
trust, or registered face-amount
certificate company, if such person
within ten years has been convicted of
any felony or misdemeanor, including
those arising out of such person’s
conduct as a bank or an Affiliated
Person of a bank. Section 2(a)(10) of the
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Act defines the term ‘‘convicted’’ to
include a plea of guilty. Section 9(a)(3)
of the Act extends the prohibitions of
section 9(a)(1) to a company any
Affiliated Person of which has been
disqualified under the provisions of
section 9(a)(1). 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 the
Settling Firm is an Affiliated Person of
each of the other Applicants within the
meaning of section 2(a)(3). Applicants
state that the guilty plea would result in
a disqualification of each Adviser
Applicant for ten years under section
9(a) of the Act because the Settling Firm
would become the subject of a
conviction described in 9(a)(1).
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
Applicants and other Covered Persons
from the disqualification provisions of
section 9(a) of the Act. The 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 assert that the
(i) scope of the Conduct was limited and
did not involve the Settling Firm or its
Affiliated Persons performing Fund
Service Activities, (ii) application of the
statutory bar would impose potentially
severe hardship on the Fund and its
shareholders, (iii) prohibitions of
section 9(a), if applied to the
Applicants, would be unduly or
disproportionately severe, and (iv) that
the Conduct did not constitute conduct
that would make it against the public
interest or the protection of investors to
grant the exemption from section 9(a).
4. Applicants assert that the Conduct
did not involve any of the Applicants
acting as an investment adviser or
depositor of any Fund, ESC, or business
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30295
development company or principal
underwriter for any Open-End Fund,
UIT, or face amount certificate company
registered under the Act. Applicants
state that the Conduct similarly did not
involve any Fund, ESC, or business
development company with respect to
which Applicants engaged in Fund
Service Activities. Applicants also
represent that the employment of the
one trader who engaged in the Conduct
was terminated, and that the trader will
not be rehired. Moreover, the Applicant
represents that no Adviser Applicant
(other than Citibank, as employer of the
one relevant FX trader) was involved in
the Conduct.
5. Applicants further represent that:
(i) None of the current or former
directors, officers or employees of any
Applicant involved in performing Fund
Service Activities during the Relevant
Period had any knowledge of, or had
any involvement in, the Conduct; (ii) no
current or former employee of any
Applicant or of any other Covered
Person who previously has been or who
subsequently may be identified by an
Applicant or any U.S. or non-U.S.
regulatory or enforcement agency as
having been responsible for the Conduct
will have any involvement in
performing Fund Service Activities or
will be an officer, director, or employee
of any Applicant or of any other
Covered Person; (iii) no employee of any
Applicant or of any other Covered
Person who was involved in the
Conduct had any, or will have any
future, involvement in the Covered
Persons’ activities in any capacity
described in section 9(a) of the Act; and
(iv) because no personnel of any
Applicant providing Fund Service
Activities had any involvement in the
Conduct, shareholders of the Funds
were not affected any differently than if
the Funds had received services from
any other non-affiliated investment
adviser or principal underwriter.
6. Applicants state that if the Adviser
Applicants were disqualified under
section 9(a) of the Act from performing
Fund Service Activities and were
unable to obtain the requested
exemption, the effect on the Funds’
shareholders, the Adviser Applicants’
employees, and on the Adviser
Applicants’ future businesses could be
severe. Applicants assert that, with
respect to the ESC Advisers in
particular, their disqualification from
providing advisory or sub-advisory
services to the ESCs would not be in the
public interest or in furtherance of the
protection of investors, and indeed such
disqualification would frustrate the
expectations of the eligible employees
who invested in the ESCs. In addition,
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the Applicants state that Adviser
Applicants have committed substantial
resources to establishing an expertise in
providing services covered by section
9(a) and that prohibiting the Adviser
Applicants from providing Fund Service
Activities to the Funds not only would
affect Adviser Applicants’ current and
future businesses adversely, but also the
employees of the Adviser Applicants.
Applicants also assert that the Conduct
did not constitute conduct that would
make it against the public interest or
protection of investors to issue the
Orders.
7. Applicants assert that the Adviser
Applicants’ inability to continue to
serve as investment adviser or subadviser of the Funds (including as
general partner providing investment
advisory services to ESCs) would result
in the Funds and their shareholders
facing potentially severe hardship.
Applicants argue that neither the
protection of investors nor the public
interest would be served by permitting
the section 9(a) disqualifications to
apply to the Adviser Applicants because
those disqualifications would deprive
the shareholders of the Funds of the
investment advisory or sub-advisory
services provided by the Adviser
Applicants (including as general partner
providing investment advisory services
to ESCs) that shareholders expected the
Funds would receive when they
decided to invest in the Funds.
Applicants also outline a number of
other uncertainties, inefficiencies, and
expenses that they submit would result
from the prohibitions of section 9(a) and
operate to the detriment of the financial
interests of the Funds and their
shareholders.
8. Applicants have agreed that neither
they nor any of the other Covered
Persons will employ any of the current
or former employees of Citi or any
Covered Person who previously have
been or who subsequently may be
identified by the Settling Firm or any
U.S. or non-U.S. regulatory or
enforcement agency as having been
responsible for the Conduct without
first making a further application to the
Commission pursuant to section 9(c).
Applicants have also agreed that each
Applicant (and any Covered Person)
will adopt and implement policies and
procedures reasonably designed to
ensure compliance with the terms and
conditions of the Orders. In addition,
the Settling Firm, Citibank and
Citigroup has agreed to comply in all
material respects with the material
terms and conditions of the Plea
Agreement, the CFTC Order, the OCC
Order, the FRB Order, the FCA Order,
or any other orders issued by regulatory
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or enforcement agencies addressing the
Conduct.
9. Applicants further state that Citi
has implemented remedial measures to
protect against conduct similar to the
Conduct, as described in greater detail
in the application. These include certain
remedial measures as required by the
Plea Agreement, the CFTC Order, the
OCC Order, the FRB Order, and the FCA
Order, including improvements to the
oversight, internal controls, compliance,
risk management and audit programs for
FX trading and related sales activities.
Specifically, Citi represents that it has
strengthened its governance structure
and enhanced the overall control
environment in FX trading, as well as
other wholesale trading and benchmark
activities. These efforts include (i) the
establishment of a new Supervision and
Controls Team within the Foreign
Exchange and Local Markets business;
(ii) the appointment of a Global Head of
Markets Compliance to provide
direction and oversight over the regional
compliance personnel within Markets,
and to coordinate global initiatives, best
practices, policies and procedures and
emerging issues in Markets; (iii) the
establishment of a senior working group
comprised of members of Markets,
Compliance and Information
Technology to coordinate initiatives that
will focus on the development of
enhanced tools designed to improve
detection of market misconduct through
transaction monitoring and
communications surveillance; (iv) the
establishment of and enhancements to
transaction monitoring and
communications surveillance processes
in the jurisdictions in which Citibank
engages in FX trading; and (v)
enhancements to Citibank’s compliance
risk assessment and compliance testing
procedures around controls for the
detection and prevention of employee
misconduct in FX trading.
10. To provide further assurance that
the exemptive relief being requested
would be consistent with the public
interest and the protection of investors,
the Applicants have undertaken to
distribute, as soon as reasonably
practicable, written materials describing
the circumstances that led to the Plea
Agreement and the application to, and
to offer to meet in person to discuss the
materials with, the boards of directors or
trustees of each Fund (excluding, for
this purpose, the ESCs) for which the
Adviser Applicants serve as investment
adviser or sub-adviser, including the
directors or trustees who are not
‘‘interested persons’’ as defined in
section 2(a)(19) of the Act, and their
independent legal counsel, if any.
Further, the Applicants will provide
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each Fund (excluding, for this purpose,
the ESCs) with the information
concerning the Plea Agreement and the
application necessary for the Fund to
fulfill its disclosure and other
obligations under the federal securities
laws and will provide it a copy of the
Plea Agreement.
11. Applicants state that certain of the
Applicants and their affiliates have
previously received orders 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. Neither the Applicants nor any of
the other Covered Persons will employ
any of the current or former employees
of the Settling Firm or any Covered
Person who previously has been or who
subsequently may be identified by the
Settling Firm or any U.S. or non-U.S.
regulatory or enforcement agency as
having been responsible for the
Conduct, without first making a further
application to the Commission pursuant
to section 9(c).
3. Each Adviser Applicant and
Covered Person will adopt and
implement policies and procedures
reasonably designed to ensure that it
will comply with the terms and
conditions of the Orders within 60 days
of the date of the Permanent Order or,
with respect to condition 4, such date as
may be contemplated by the Plea
Agreement, or the CFTC Order, the OCC
Order, the FRB Order, the FCA Order,
or any other orders issued by regulatory
or enforcement agencies addressing the
Conduct.
4. The Settling Firm, Citibank and
Citigroup will comply in all material
respects with the material terms and
conditions of the Plea Agreement, the
CFTC Order, the OCC Order, the FRB
Order, the FCA Order, or any other
orders issued by regulatory or
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Federal Register / Vol. 80, No. 101 / Wednesday, May 27, 2015 / Notices
enforcement agencies addressing the
Conduct.
5. 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 any of the
Orders within 30 days of discovery of
the material violation.
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
Applicants and any other Covered
Persons are granted a temporary
exemption from the provisions of
section 9(a), solely with respect to the
guilty plea entered into pursuant to the
Plea Agreement, subject to the
representations and conditions in the
application, from June 15, 2015 until the
Commission takes final action on their
application for a permanent order.
By the Commission.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2015–12756 Filed 5–26–15; 8:45 am]
BILLING CODE P
Institution and settlement of
administrative proceedings;
Opinion; and
Other matters relating to enforcement
proceedings.
At times, changes in Commission
priorities require alterations in the
scheduling of meeting items.
For further information and to
ascertain what, if any, matters have been
added, deleted or postponed, please
contact the Office of the Secretary at
(202) 551–5400.
Dated: May 21, 2015.
Lynn M. Powalski,
Deputy Secretary.
[FR Doc. 2015–12960 Filed 5–22–15; 4:15 pm]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–31612; File No. 812–14465]
UBS AG, et al.; Notice of Application
and Temporary Order
May 20, 2015.
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 a guilty plea entered on May
20, 2015, by UBS AG (‘‘UBS AG’’ or the
‘‘Settling Firm’’) in the United States
District Court for the District of
Connecticut (the ‘‘District Court’’) in
connection with a plea agreement (‘‘Plea
Agreement’’) between the Settling Firm
and the United States Department of
Justice (‘‘DOJ’’), 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: UBS AG (‘‘UBS AG’’ or the
‘‘Settling Firm’’), UBS IB Co-Investment
2001 GP Limited (‘‘ESC GP’’), UBS
Alternative and Quantitative
Investments LLC (‘‘UBS Alternative’’),
UBS O’Connor LLC (‘‘UBS O’Connor’’),
UBS Global Asset Management
(Americas) Inc. (‘‘UBS Global AM
Americas’’), and UBS Global Asset
Management (US) Inc. (‘‘UBS Global
AM US’’) (each an ‘‘Applicant’’ and
together, the ‘‘Applicants’’).
FILING DATE: The application was filed
on May 20, 2015.
SUMMARY OF APPLICATION:
SECURITIES AND EXCHANGE
COMMISSION
mstockstill on DSK4VPTVN1PROD with NOTICES
Sunshine Act Meeting
Notice is hereby given, pursuant to
the provisions of the Government in the
Sunshine Act, Public Law 94–409, that
the Securities and Exchange
Commission will hold a Closed Meeting
on Thursday, May 28, 2015 at 2 p.m.
Commissioners, Counsel to the
Commissioners, the Secretary to the
Commission, and recording secretaries
will attend the Closed Meeting. Certain
staff members who have an interest in
the matters also may be present.
The General Counsel of the
Commission, or her designee, has
certified that, in her opinion, one or
more of the exemptions set forth in
5 U.S.C. 552b(c)(3), (5), (7), 9(B) and (10)
and 17 CFR 200.402(a)(3), (5), (7), 9(ii)
and (10), permit consideration of the
scheduled matter at the Closed Meeting.
Commissioner Aguilar, as duty
officer, voted to consider the items
listed for the Closed Meeting in closed
session.
The subject matter of the Closed
Meeting will be:
Institution of injunctive actions;
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16:45 May 26, 2015
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30297
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 June 15, 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: UBS AG and ESC GP:
c/o UBS Investment Bank, 677
Washington Boulevard, Stamford, CT
06901; UBS Alternative: 677
Washington Boulevard, Stamford, CT
06901; UBS O’Connor and UBS Global
AM Americas: One North Wacker Drive,
Chicago, IL 60606; UBS Global AM US:
1285 Avenue of the Americas, 12th
Floor, New York, NY 10019.
FOR FURTHER INFORMATION CONTACT:
David Joire, Senior Counsel, Parisa
Haghshenas, Senior Counsel, or Holly
Hunter-Ceci, Branch Chief, at (202) 551–
6825 (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.
HEARING OR NOTIFICATION OF HEARING:
Applicants’ Representations
1. As set forth below, the Applicants
collectively serve as investment adviser
(as defined in section 2(a)(20) of the
Act) to 90 investment management
companies registered under the Act or
series thereof and to two employees’
securities companies (‘‘ESCs’’), and as
principal underwriter (as defined in
section 2(a)(29) of the Act) to eight
open-end registered investment
companies under the Act (‘‘Open-End
Funds’’) (each a ‘‘Fund,’’ collectively,
‘‘Funds’’).
2. UBS AG, a company organized
under the laws of Switzerland, is a
E:\FR\FM\27MYN1.SGM
27MYN1
Agencies
[Federal Register Volume 80, Number 101 (Wednesday, May 27, 2015)]
[Notices]
[Pages 30293-30297]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-12756]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-31615; File No. 812-14468]
Citicorp, et al.; Notice of Application and Temporary Order
May 20, 2015.
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'').
-----------------------------------------------------------------------
Summary of Application: Applicants have received a temporary order
(``Temporary Order'') exempting them from section 9(a) of the Act, with
respect to a guilty plea entered on May
[[Page 30294]]
20, 2015, by the Settling Firm (as defined below) in the United States
District Court for the District of Connecticut (the ``District Court'')
in connection with a plea agreement (``Plea Agreement'') between the
Settling Firm and the United States Department of Justice (``DOJ''),
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: Citicorp, a Delaware corporation, (the ``Settling Firm''),
Citigroup Global Markets Inc. (``CGMI''), CEFOF GP I Corp. (``CEFOF''),
CELFOF GP Corp. (``CELFOF''), Citibank, N.A. (``Citibank''), Citigroup
Alternative Investments LLC (``Citigroup Alternative''), Citigroup
Capital Partners I GP I Corp. (``CCP I''), Citigroup Capital Partners I
GP II Corp. (``CCP II''), Citigroup Private Equity (Offshore) LLC
(``CPE (Offshore)''), and Citigroup First Investment Management
Americas LLC (``CFIMA'', and along, together with CGMI, CEFOF, CELFOF,
Citibank, Citigroup Alternative, CCP I, CCP II, and CPE (Offshore), the
``Adviser Applicants'' and the Settling Firm together with the Adviser
Applicants, the ``Applicants'').
Filing Date: The application was filed on May 20, 2015.
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 June 15, 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: The Settling Firm
and Citibank: 399 Park Avenue, New York, NY 10043 CGMI, CEFOF, CELFOF,
Citigroup Alternative, CCP I, CCP II, CPE (Offshore), and CFIMA: 388
Greenwich Street, New York, NY 10013.
FOR FURTHER INFORMATION CONTACT: Kyle R. Ahlgren, Senior Counsel,
Vanessa M. Meeks, Senior Counsel, or Holly Hunter-Ceci, Branch Chief,
at (202) 551-6825 (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. Citigroup Inc. (``Citigroup'' or ``Citi''), the parent company
of the Settling Firm, CGMI and the other Adviser Applicants, is a
global financial holding company whose businesses provide a broad range
of financial services. The Settling Firm is a financial services
holding company and the direct parent company of Citibank. CGMI, a New
York corporation and an Affiliated Person of the Settling Firm, is a
full service investment banking firm. CGMI engages in securities
underwriting, sales and trading, investment banking, financial advisory
and investment research services. CGMI is registered as a broker-dealer
under the Securities Exchange Act of 1934 (``Exchange Act'') and as an
investment adviser under the Investment Advisers Act of 1940
(``Advisers Act''). CGMI currently does not perform Fund Service
Activities (as defined below) for any Fund\1\, but it may seek to do so
in the future. CFIMA, a Delaware limited liability company and an
Affiliated Person of the Settling Firm, is registered as an investment
adviser under the Advisers Act and serves as investment adviser to one
Fund. CFIMA currently does not serve as depositor or principal
underwriter for any Fund, but it may seek to do so in the future. Each
of CEFOF, CELFOF, Citibank, Citigroup Alternative, CCP I, CCP II and
CPE (Offshore) (collectively, the ``ESC Advisers'') is an Affiliated
Person of the Settling Firm and serves as investment adviser to certain
ESCs (ESCs are included in the term ``Funds'') sponsored by Citigroup
and its subsidiaries. None of the ESC Advisers perform any Fund Service
Activities for any Funds other than the ESCs. The ESCs have been
exempted from all provisions of the Act and the rules and regulations
thereunder, except for certain sections, including section 9, pursuant
to a Commission order.\2\
---------------------------------------------------------------------------
\1\ For purposes of the application ``Funds'' refers to any
registered investment company, business development company, or
employees' securities company (as defined in section 2(a)(13) of the
Act) for which a Covered Person serves or may in the future serve as
an investment adviser (as defined in section 2(a)(20) of the Act),
sub-adviser, general partner or depositor, or any registered open-
end investment company, registered unit investment trust or
registered face amount certificate company for which a Covered
Person (as defined above) serves or may in the future serve as
principal underwriter (as defined in section 2(a)(29) of the Act).
\2\ Greenwich Street Employees Fund, L.P., et al., Investment
Company Act Release Nos. 25324 (Dec. 21, 2001) (notice) and 25367
(Jan. 16, 2002) (order).
---------------------------------------------------------------------------
2. While no existing company of which the Settling Firm is an
affiliated person within the meaning of section 2(a)(3) of the Act
(``Affiliated Person''), other than the Adviser 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
(such activities, ``Fund Service Activities''), Applicants request that
any relief granted also apply to any existing company of which the
Settling Firm is an Affiliated Person, and to any other company of
which the Settling Firm may become an Affiliated Person in the future
(together with the Applicants, the ``Covered Persons'') with respect to
any activity contemplated by section 9(a) of the Act.
3. The DOJ has conducted an investigation of certain conduct and
practices of Citi and others in the foreign currency exchange (``FX'')
spot market. To resolve the DOJ's investigation, the Settling Firm
entered into the Plea Agreement, pursuant to which the Settling Firm
has pleaded guilty to one count of an antitrust violation of 15 U.S.C.
1. As set forth in the Plea Agreement, from at least December 2007 and
continuing to at least January 2013 (the ``Relevant Period''), the
Settling Firm, through one London-based euro/U.S. dollar (``EUR/USD'')
trader employed by Citibank, a subsidiary of the Settling Firm and an
Applicant hereto, and other traders at unrelated financial services
firms acting as dealers in the FX spot market entered into and engaged
in a conspiracy to fix, stabilize, maintain, increase or decrease the
price of, and rig bids and offers for, the EUR/USD currency pair
exchanged in the FX spot market by agreeing to eliminate competition in
the purchase and sale of the EUR/USD currency pair in the United States
and elsewhere (the
[[Page 30295]]
``Conduct''). The Conduct included near daily conversations, some of
which were in code, in an exclusive electronic chat room used by
certain EUR/USD traders, including the EUR/USD trader employed by
Citibank. The Conduct forms the basis for the DOJ's antitrust charge
that the Settling Firm violated 15 U.S.C. 1.
4. Under the terms of the Plea Agreement, the DOJ and the Settling
Firm have agreed that the District Court should impose a sentence
requiring the Settling Firm to pay a criminal fine of $925 million. The
Plea Agreement also provides for a three-year term of probation, with
conditions to include, among other things, Citi's continued
implementation of a compliance program designed to prevent and detect
the Conduct throughout its operations, and Citi's further strengthening
of its compliance and internal controls as required by other regulatory
or enforcement agencies that have addressed the Conduct, including the
U.S. Commodity Futures Trading Commission (``CFTC''), pursuant to its
settlement with Citibank on November 11, 2014, requiring remedial
measures to strengthen the control framework governing Citi's FX
trading business (the ``CFTC Order''); the U.S. Treasury Department's
Office of the Comptroller of the Currency (``OCC''), pursuant to its
settlement with Citibank on November 11, 2014, requiring remedial
measures to improve the control framework governing Citi's wholesale
trading and benchmark activities (the ``OCC Order''); the U.K.
Financial Conduct Authority (``FCA''), pursuant to its settlement with
Citibank on November 11, 2014 (the ``FCA Order''); and the U.S. Board
of Governors of the Federal Reserve System (``FRB''), pursuant to its
settlement with Citigroup entered into concurrently with the DOJ
resolution, requiring remedial measures to improve controls for FX
trading and activities involving commodities and interest rate products
where Citi acts as principal (the ``FRB Order'').
Applicants' Legal Analysis
1. Section 9(a)(1) of the Act provides, in pertinent part, that a
person may not serve or act as an investment adviser or depositor of
any registered investment company or a principal underwriter for any
registered open-end investment company, registered unit investment
trust, or registered face-amount certificate company, if such person
within ten years has been convicted of any felony or misdemeanor,
including those arising out of such person's conduct as a bank or an
Affiliated Person of a bank. Section 2(a)(10) of the Act defines the
term ``convicted'' to include a plea of guilty. Section 9(a)(3) of the
Act extends the prohibitions of section 9(a)(1) to a company any
Affiliated Person of which has been disqualified under the provisions
of section 9(a)(1). 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 the Settling Firm is an Affiliated Person
of each of the other Applicants within the meaning of section 2(a)(3).
Applicants state that the guilty plea would result in a
disqualification of each Adviser Applicant for ten years under section
9(a) of the Act because the Settling Firm would become the subject of a
conviction described in 9(a)(1).
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 Applicants and
other Covered Persons from the disqualification provisions of section
9(a) of the Act. The 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 assert that the (i) scope of the
Conduct was limited and did not involve the Settling Firm or its
Affiliated Persons performing Fund Service Activities, (ii) application
of the statutory bar would impose potentially severe hardship on the
Fund and its shareholders, (iii) prohibitions of section 9(a), if
applied to the Applicants, would be unduly or disproportionately
severe, and (iv) that the Conduct did not constitute conduct that would
make it against the public interest or the protection of investors to
grant the exemption from section 9(a).
4. Applicants assert that the Conduct did not involve any of the
Applicants acting as an investment adviser or depositor of any Fund,
ESC, or business development company or principal underwriter for any
Open-End Fund, UIT, or face amount certificate company registered under
the Act. Applicants state that the Conduct similarly did not involve
any Fund, ESC, or business development company with respect to which
Applicants engaged in Fund Service Activities. Applicants also
represent that the employment of the one trader who engaged in the
Conduct was terminated, and that the trader will not be rehired.
Moreover, the Applicant represents that no Adviser Applicant (other
than Citibank, as employer of the one relevant FX trader) was involved
in the Conduct.
5. Applicants further represent that: (i) None of the current or
former directors, officers or employees of any Applicant involved in
performing Fund Service Activities during the Relevant Period had any
knowledge of, or had any involvement in, the Conduct; (ii) no current
or former employee of any Applicant or of any other Covered Person who
previously has been or who subsequently may be identified by an
Applicant or any U.S. or non-U.S. regulatory or enforcement agency as
having been responsible for the Conduct will have any involvement in
performing Fund Service Activities or will be an officer, director, or
employee of any Applicant or of any other Covered Person; (iii) no
employee of any Applicant or of any other Covered Person who was
involved in the Conduct had any, or will have any future, involvement
in the Covered Persons' activities in any capacity described in section
9(a) of the Act; and (iv) because no personnel of any Applicant
providing Fund Service Activities had any involvement in the Conduct,
shareholders of the Funds were not affected any differently than if the
Funds had received services from any other non-affiliated investment
adviser or principal underwriter.
6. Applicants state that if the Adviser Applicants were
disqualified under section 9(a) of the Act from performing Fund Service
Activities and were unable to obtain the requested exemption, the
effect on the Funds' shareholders, the Adviser Applicants' employees,
and on the Adviser Applicants' future businesses could be severe.
Applicants assert that, with respect to the ESC Advisers in particular,
their disqualification from providing advisory or sub-advisory services
to the ESCs would not be in the public interest or in furtherance of
the protection of investors, and indeed such disqualification would
frustrate the expectations of the eligible employees who invested in
the ESCs. In addition,
[[Page 30296]]
the Applicants state that Adviser Applicants have committed substantial
resources to establishing an expertise in providing services covered by
section 9(a) and that prohibiting the Adviser Applicants from providing
Fund Service Activities to the Funds not only would affect Adviser
Applicants' current and future businesses adversely, but also the
employees of the Adviser Applicants. Applicants also assert that the
Conduct did not constitute conduct that would make it against the
public interest or protection of investors to issue the Orders.
7. Applicants assert that the Adviser Applicants' inability to
continue to serve as investment adviser or sub-adviser of the Funds
(including as general partner providing investment advisory services to
ESCs) would result in the Funds and their shareholders facing
potentially severe hardship. Applicants argue that neither the
protection of investors nor the public interest would be served by
permitting the section 9(a) disqualifications to apply to the Adviser
Applicants because those disqualifications would deprive the
shareholders of the Funds of the investment advisory or sub-advisory
services provided by the Adviser Applicants (including as general
partner providing investment advisory services to ESCs) that
shareholders expected the Funds would receive when they decided to
invest in the Funds. Applicants also outline a number of other
uncertainties, inefficiencies, and expenses that they submit would
result from the prohibitions of section 9(a) and operate to the
detriment of the financial interests of the Funds and their
shareholders.
8. Applicants have agreed that neither they nor any of the other
Covered Persons will employ any of the current or former employees of
Citi or any Covered Person who previously have been or who subsequently
may be identified by the Settling Firm or any U.S. or non-U.S.
regulatory or enforcement agency as having been responsible for the
Conduct without first making a further application to the Commission
pursuant to section 9(c). Applicants have also agreed that each
Applicant (and any Covered Person) will adopt and implement policies
and procedures reasonably designed to ensure compliance with the terms
and conditions of the Orders. In addition, the Settling Firm, Citibank
and Citigroup has agreed to comply in all material respects with the
material terms and conditions of the Plea Agreement, the CFTC Order,
the OCC Order, the FRB Order, the FCA Order, or any other orders issued
by regulatory or enforcement agencies addressing the Conduct.
9. Applicants further state that Citi has implemented remedial
measures to protect against conduct similar to the Conduct, as
described in greater detail in the application. These include certain
remedial measures as required by the Plea Agreement, the CFTC Order,
the OCC Order, the FRB Order, and the FCA Order, including improvements
to the oversight, internal controls, compliance, risk management and
audit programs for FX trading and related sales activities.
Specifically, Citi represents that it has strengthened its governance
structure and enhanced the overall control environment in FX trading,
as well as other wholesale trading and benchmark activities. These
efforts include (i) the establishment of a new Supervision and Controls
Team within the Foreign Exchange and Local Markets business; (ii) the
appointment of a Global Head of Markets Compliance to provide direction
and oversight over the regional compliance personnel within Markets,
and to coordinate global initiatives, best practices, policies and
procedures and emerging issues in Markets; (iii) the establishment of a
senior working group comprised of members of Markets, Compliance and
Information Technology to coordinate initiatives that will focus on the
development of enhanced tools designed to improve detection of market
misconduct through transaction monitoring and communications
surveillance; (iv) the establishment of and enhancements to transaction
monitoring and communications surveillance processes in the
jurisdictions in which Citibank engages in FX trading; and (v)
enhancements to Citibank's compliance risk assessment and compliance
testing procedures around controls for the detection and prevention of
employee misconduct in FX trading.
10. To provide further assurance that the exemptive relief being
requested would be consistent with the public interest and the
protection of investors, the Applicants have undertaken to distribute,
as soon as reasonably practicable, written materials describing the
circumstances that led to the Plea Agreement and the application to,
and to offer to meet in person to discuss the materials with, the
boards of directors or trustees of each Fund (excluding, for this
purpose, the ESCs) for which the Adviser Applicants serve as investment
adviser or sub-adviser, including the directors or trustees who are not
``interested persons'' as defined in section 2(a)(19) of the Act, and
their independent legal counsel, if any. Further, the Applicants will
provide each Fund (excluding, for this purpose, the ESCs) with the
information concerning the Plea Agreement and the application necessary
for the Fund to fulfill its disclosure and other obligations under the
federal securities laws and will provide it a copy of the Plea
Agreement.
11. Applicants state that certain of the Applicants and their
affiliates have previously received orders 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. Neither the Applicants nor any of the other Covered Persons will
employ any of the current or former employees of the Settling Firm or
any Covered Person who previously has been or who subsequently may be
identified by the Settling Firm or any U.S. or non-U.S. regulatory or
enforcement agency as having been responsible for the Conduct, without
first making a further application to the Commission pursuant to
section 9(c).
3. Each Adviser Applicant and Covered Person will adopt and
implement policies and procedures reasonably designed to ensure that it
will comply with the terms and conditions of the Orders within 60 days
of the date of the Permanent Order or, with respect to condition 4,
such date as may be contemplated by the Plea Agreement, or the CFTC
Order, the OCC Order, the FRB Order, the FCA Order, or any other orders
issued by regulatory or enforcement agencies addressing the Conduct.
4. The Settling Firm, Citibank and Citigroup will comply in all
material respects with the material terms and conditions of the Plea
Agreement, the CFTC Order, the OCC Order, the FRB Order, the FCA Order,
or any other orders issued by regulatory or
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enforcement agencies addressing the Conduct.
5. 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 any of the
Orders within 30 days of discovery of the material violation.
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
Applicants and any other Covered Persons are granted a temporary
exemption from the provisions of section 9(a), solely with respect to
the guilty plea entered into pursuant to the Plea Agreement, subject to
the representations and conditions in the application, from June 15,
2015 until the Commission takes final action on their application for a
permanent order.
By the Commission.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2015-12756 Filed 5-26-15; 8:45 am]
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