The Royal Bank of Scotland plc, et al.; Notice of Application and Temporary Order, 30311-30314 [2015-12757]
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Federal Register / Vol. 80, No. 101 / Wednesday, May 27, 2015 / Notices
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2015.5 On February 20, 2015, the
Commission issued an order instituting
proceedings pursuant to Section
19(b)(2)(B) of the Act 6 to determine
whether to approve or disapprove the
proposal. The order was published for
comment in the Federal Register on
February 26, 2015.7 The Commission
received a further four comments
regarding the proceedings or in response
to Amendment No. 1,8 to which FINRA
responded via letter on May 5, 2015.9
Section 19(b)(2) of the Act 10 provides
that, after initiating approval or
disapproval proceedings, the
Commission shall issue an order
approving or disapproving the proposed
rule change not later than 180 days after
the date of publication of notice of filing
of the proposed rule change. The
Commission may extend the period for
issuing an order approving or
disapproving the proposed rule change,
however, by not more than 60 days if
the Commission determines that a
longer period is appropriate and
publishes the reasons for such
determination. The proposal was
published for comment in the Federal
Register on November 24, 2014.11 The
180th day after publication of the notice
of the filing of the proposed rule change
in the Federal Register is May 23, 2015
and the 240th day after publication of
the notice of the filing of the proposed
rule change in the Federal Register is
July 22, 2015.
The Commission finds it appropriate
to designate a longer period within
which to issue an order approving or
disapproving the proposed rule change
so that it has sufficient time to consider
the proposed rule change, including the
5 Exchange Act Release No. 74490 (Mar. 12,
2015); 80 FR 14198 (Mar. 18, 2015).
6 15 U.S.C. 78s(b)(2)(B).
7 Exchange Act Release No. 74340 (Feb. 20, 2015);
80 FR 10538 (Feb. 26, 2015). Specifically, the
Commission instituted proceedings to allow for
additional analysis of the proposed rule change’s
consistency with Section 15A(b)(9) of the Act,
which requires that FINRA’s rules be designed to,
among other things, promote just and equitable
principles of trade, remove impediments to and
perfect the mechanism of a free and open market
and a national market system, and, in general, to
protect investors and the public interest. See id.
8 Letter from Stephanie R. Nicholas, WilmerHale,
dated Apr. 6, 2015, Letter from Kurt N. Schacht,
Managing Director, Standards and Financial Market
Integrity, and Linda L. Rittenhouse, Director,
Capital Markets Policy, CFA Institute, to Brent J.
Fields, Secretary, SEC, dated April 7, 2015, an
anonymous comment dated Apr. 8, 2015, and Letter
from William Beatty, President and Washington
(State) Securities Administrator, North American
Securities Administrators Association, Inc., dated
Apr. 17, 2015.
9 Letter from Philip Shaikun, Vice President and
Associate General Counsel, FINRA, dated May 5,
2015.
10 15 U.S.C. 78s(b)(2).
11 See supra note 3 and accompanying text.
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matters raised in the comment letters to
the proposed rule change.
Accordingly, the Commission,
pursuant to Section 19(b)(2) of the
Act,12 designates July 22, 2015 as the
date by which the Commission shall
either approve or disapprove the
proposed rule change (File No. SR–
FINRA–2014–048).
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.13
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2015–12690 Filed 5–26–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–31642; File No. 812–14469]
The Royal Bank of Scotland plc, 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 the Royal Bank of Scotland
plc (‘‘RBS’’ 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: RBS and Citizens
Investment Advisors (‘‘Citizens IA’’)
(each an ‘‘Applicant’’ and together, the
‘‘Applicants’’).
DATES: 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
SUMMARY OF APPLICATION:
12 15
13 17
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U.S.C. 78s(b)(2).
CFR 200.30–3(a)(57).
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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: RBS: RBS, Gogarburn, P.O.
Box 1000, Edinburgh, EH12 1HQ,
Scotland; Citizens IA: c/o Citizens Bank,
N.A., Mail Stop RC 03–30, One Citizens
Plaza, Providence, Rhode Island 02903.
FOR FURTHER INFORMATION CONTACT:
Parisa Haghshenas, 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. RBS is a company organized under
the laws of Scotland and is a whollyowned subsidiary of The Royal Bank of
Scotland Group plc (‘‘RBSG’’). RBS and
RBSG are international banking and
financial services companies that
provide a wide range of products and
services to customers around the world.
RBS and RBSG are both foreign banking
organizations for purposes of Section 8
of the International Banking Act of
1978, as amended, and Subpart B of
Regulation K, bank holding companies
for purposes of the Bank Holding
Company Act of 1956, as amended (the
‘‘BHC Act’’) and financial holding
companies for purposes of the BHC Act.
Citizens IA is a separately identifiable
department of Citizens Bank, N.A.,
which is an indirect subsidiary of RBSG
and bank subsidiary of Citizens
Financial Group, Inc.
2. Citizens IA is an investment adviser
registered under the Investment
Advisers Act of 1940, as amended.
Citizens IA serves as investment sub-
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adviser to one management investment
company registered under the Act (the
‘‘Fund’’). 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 Citizens IA as described
above) currently serves as an investment
adviser or depositor of any investment
company registered under the Act
(‘‘RIC’’), employees’ securities company
(‘‘ESC’’) or investment company that has
elected to be treated as a business
development company under the Act
(‘‘BDC’’), or principal underwriter for
any open-end registered investment
company under the Act (‘‘Open-End
Fund’’), unit investment trust registered
under the Act (‘‘UIT’’), or face-amount
certificate company registered under the
Act (‘‘FACC’’) (such activities, ‘‘Fund
Service Activities’’), Applicants request
that any relief granted by the
Commission pursuant to the application
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.1
3. On May 20, 2015, the United States
Department of Justice (the ‘‘Department
of Justice’’) filed a one-count criminal
information (the ‘‘Information’’) in the
U.S. District Court for the District of
Connecticut (the ‘‘District Court’’). The
Information charges that between
approximately December 2007 and
April 2010, the Settling Firm, through
one of its euro/U.S. dollar (‘‘EUR/USD’’)
traders, 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 foreign
currency exchange spot market (‘‘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
‘‘Conduct’’) in violation of Title 15,
United States Code, Section 1. The
Conduct involved 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 RBS.
4. Pursuant to the Plea Agreement, the
Settling Firm entered a plea of guilty
(the ‘‘Guilty Plea’’) on May 20, 2015 in
1 The Applicants and other Covered Persons may,
if the Orders are granted, in the future act in any
of the capacities contemplated by Section 9(a) of the
Act subject to the applicable conditions of the
Orders.
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16:45 May 26, 2015
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the District Court to the offense charged
in the Information. In the Plea
Agreement, the Settling Firm, among
other things, agreed to a fine of $395
million. The Applicants expect that the
District Court will enter a judgment
against the Settling Firm (the
‘‘Judgment’’) that will require remedies
that are materially the same as set forth
in the Plea Agreement. The individual
at the Settling Firm who was identified
by the Settling Firm, RBSG or any U.S.
or non-U.S. regulatory or enforcement
agencies as being responsible for the
Conduct has left RBS as of April 2010.
RBS and RBS Securities Inc. will also
enter into a settlement with the Board
of Governors of the Federal Reserve
System to resolve certain findings by the
Federal Reserve (the ‘‘Federal Reserve
Order’’). Additionally, RBS entered into
a settlement with the U.S. Commodity
Futures Trading Commission on
November 11, 2014 to resolve certain
findings by the CFTC (the ‘‘CFTC
Order’’) and with the U.K. Financial
Conduct Authority (‘‘FCA’’) on
November 11, 2014 to resolve certain
findings by the FCA (the ‘‘FCA 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. 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. The Settling Firm is an
Affiliated Person of Citizens IA within
the meaning of section 2(a)(3) of the Act.
Therefore, the Applicants state that the
Guilty Plea would result in a
disqualification of the Applicants for
ten years under section 9(a)(3) were they
to act in any of the capacities listed in
section 9(a) because they would become
the subject of a conviction described in
section 9(a)(1).
2. Section 9(c) of the Act provides
that, upon application, the Commission
shall by order grant an exemption from
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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 (i)
the scope of the misconduct was limited
and did not involve the Adviser
Applicant (as defined below) or Fund
Service Activities, (ii) application of the
statutory bar would impose significant
hardships on the Fund and its
shareholders, (iii) the prohibitions of
section 9(a), if applied to the Adviser
Applicant and other Covered Persons,
would be unduly or disproportionately
severe and (iv) the Conduct did not
constitute conduct that would make it
against the public interest or protection
of investors to grant the exemption from
section 9(a).
4. Applicants represent that the
Conduct did not involve the Adviser
Applicant nor did it involve any of the
Applicants acting in the capacity of
investment adviser, sub-adviser or
depositor to any RIC, or in the capacity
of principal underwriter for any OpenEnd Fund, UIT or FACC. Applicants
represent that the Conduct similarly did
not involve any RIC, Open-End Fund,
UIT or FACC with respect to which the
Applicants engaged in Fund Service
Activities. Instead, a single employee,
who was not employed by the Adviser
Applicant or engaged in Fund Service
Activities, was identified as being
responsible for the Conduct. That
employee is no longer employed, and
will not be employed in the future, by
the Applicants or any other Covered
Person. Applicants assert that, in light
of the limited scope of the Conduct, it
would be unduly and
disproportionately severe to impose a
section 9(a) disqualification on the
Applicants. Applicants further represent
that depriving the Fund of the Adviser
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Applicant as its sub-adviser because of
the activities of the Settling Firm would
be an unduly severe result, both for the
Adviser Applicant’s financial position
and for the shareholders of the Fund,
who would be deprived of the
knowledge and expertise of a key
service provider. Applicants assert that
the conduct of the Applicants has not
been such to make it against the public
interest or the protection of investors to
grant the exemption from section 9(a).
5. Applicants assert that the inability
of the Applicant, i.e., Citizens IA, that
serves as investment sub-adviser to the
Fund (the ‘‘Adviser Applicant’’) to
continue providing such services to the
Fund would result in the Fund and its
shareholders facing potential hardship,
as outlined in the application.
Applicants assert 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 Applicant because
those disqualifications would deprive
the Fund of the sub-advisory services
that shareholders expected the Fund
would receive when they decided to
invest in the Fund. Applicants also
assert that the prohibitions of section
9(a) could operate to the financial
detriment of the Fund and its
shareholders, which would be an
unduly and disproportionately severe
consequence given that the Adviser
Applicant was not involved in the
Conduct and that the Conduct did not
involve Fund Service Activities.
6. Applicants assert that if the Adviser
Applicant were barred under section
9(a) from providing investment advisory
services to the Fund and were unable to
obtain the requested exemption, the
effect on its business and employees
would be unduly and
disproportionately severe. Applicants
state that the Adviser Applicant has
committed substantial capital and other
resources to establishing expertise in
sub-advising RICs. Applicants further
state that prohibiting the Adviser
Applicant from engaging in Fund
Service Activities would not only
adversely affect its business, but would
also adversely affect its employees who
are involved in these activities. Many of
these employees could experience
significant difficulties in finding
alternative, fund-related employment. In
addition, Applicants assert that if the
Applicants or Covered Persons are
unable to expand their businesses in the
future because of the imposition of the
section 9(a) disqualification, it could
also have an adverse impact on their
businesses.
7. Applicants represent that: (i) None
of the current or former directors,
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officers or employees of Citizens IA had
any knowledge of, or had any
involvement in, the Conduct; (ii) no
current or former employee of the
Settling Firm or of any other 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 agencies as
having been responsible for the Conduct
will have any involvement in providing
Fund Service Activities on behalf of any
Covered Person or will be an officer,
director, or employee of any Applicants
or of any other Covered Person; (iii) no
employee of the Settling Firm 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 the personnel of Citizens IA
did not have any involvement in the
Conduct, shareholders of the Fund were
not affected any differently than if the
Fund had received services from any
other non-affiliated investment adviser
or principal underwriter.
8. Applicants have agreed that neither
they nor any of the other Covered
Persons will employ any of the current
or former employees of Settling Firm or
any Covered Person who previously
have been or who subsequently may be
identified by the Settling Firm, RBSG 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).
9. 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
granted under section 9(c).
10. In addition, the Settling Firm has
agreed to comply in all material respects
with the material terms and conditions
of the Plea Agreement, the CFTC Order,
the Federal Reserve Order, the FCA
Order, or any other orders issued by
regulatory or enforcement agencies
addressing the Conduct. Applicants
further state that RBS and its affiliates
have undertaken certain remedial
measures, as described in greater detail
in the application. These include certain
remedial measures as required by the
Plea Agreement, the CFTC Order, the
Federal Reserve Order, and the FCA
Order, including improvements to the
oversight, internal controls, compliance,
risk management and audit programs for
FX trading. Specifically, Applicants
represent that RBSG and RBS have
taken a number of steps to enhance its
internal controls, policies and
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30313
procedures relating to its FX activities.
These changes, include, but are not
limited to the following: Restricting
participation by traders in multi-bank
chat rooms; prohibiting mobile
communication devices on dealing
floors; strengthening surveillance of
electronic, audio and trade
communications at FX desks; mandating
regular training for all FX employees
concerning appropriate trading
behavior; enhancing policies,
procedures and guidance related to
market color, client orders and FX fix
orders; and improving customer
disclosures relating to and enhancing
controls around FX fix orders.
11. As a result, Applicants submit that
granting an exemption as requested in
the application would be consistent
with the public interest and the
protection of investors.
12. To provide further assurance that
the exemptive relief being requested
herein would be consistent with the
public interest and the protection of the
investors, the Applicants agree that they
will, as soon as reasonably practical,
distribute to the board of trustees
(‘‘Board’’) of the Fund written materials
describing the circumstances that led to
the Guilty Plea, any impact on the Fund
and the application. The written
materials will include an offer to
discuss the materials at an in-person
meeting with the Board of the Fund,
including the directors who are not
‘‘interested persons’’ of the Fund as
defined in section 2(a)(19) of the Act
and their independent legal counsel as
defined in rule 0–1(a)(6) under the Act.
The Applicants undertake to provide
the Fund’s Board with all 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
Judgment as entered by the District
Court.
13. Applicants state that certain of the
Applicants and their affiliates have
previously received an order under
section 9(c) of the Act, as the result of
conduct that triggered section 9(a), as
described in greater detail in the
application.
Applicants’ Conditions
Applicants agree that any order
granted by the Commission pursuant to
the application will be subject to the
following conditions:
1. Any temporary exemption granted
pursuant to the application shall be
without prejudice to, and shall not limit
the Commission’s rights in any manner
with respect to, any Commission
investigation of, or administrative
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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, RBSG or any U.S. or nonU.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 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 Federal Reserve
Order, the FCA Order, or any other
orders issued by regulatory or
enforcement agencies addressing the
Conduct.
4. The Settling Firm will comply in
all material respects with the material
terms and conditions of the Plea
Agreement, with the material terms of
the CFTC Order, the Federal Reserve
Order, the FCA Order or any other
orders issued by regulatory or
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
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application, from May 20, 2015 until the
Commission takes final action on their
application for a permanent order.
By the Commission.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2015–12757 Filed 5–26–15; 8:45 am]
BILLING CODE P
SECURITIES AND EXCHANGE
COMMISSION
Proposed Collection; Comment
Request
Upon Written Request, Copies Available
From: Securities and Exchange
Commission, Office of FOIA Services,
100 F Street NE., Washington, DC
20549–2736
Extension:
Rule 23c–3 and Form N–23c–3, OMB
Control No. 3235–0422, SEC File No.
270–373.
Notice is hereby given that, pursuant
to the Paperwork Reduction Act of 1995
(44 U.S.C. 3501 et. seq.), the Securities
and Exchange Commission (the
‘‘Commission’’) is soliciting comments
on the collection of information
summarized below. The Commission
plans to submit this existing collection
of information to the Office of
Management and Budget (‘‘OMB’’) for
extension and approval.
Rule 23c–3 (17 CFR 270.23c–3) under
the Investment Company Act of 1940
(15 U.S.C. 80a–1 et seq.) permits a
registered closed-end investment
company (‘‘closed-end fund’’ or ‘‘fund’’)
that meets certain requirements to
repurchase common stock of which it is
the issuer from shareholders at periodic
intervals, pursuant to repurchase offers
made to all holders of the stock. The
rule enables these funds to offer their
shareholders a limited ability to resell
their shares in a manner that previously
was available only to open-end
investment company shareholders. To
protect shareholders, a closed-end fund
that relies on rule 23c–3 must send
shareholders a notification that contains
specified information each time the
fund makes a repurchase offer (on a
quarterly, semi-annual, or annual basis,
or, for certain funds, on a discretionary
basis not more often than every two
years). The fund also must file copies of
the shareholder notification with the
Commission (electronically through the
Commission’s Electronic Data
Gathering, Analysis, and Retrieval
System (‘‘EDGAR’’)) on Form N–23c–3,
a filing that provides certain
information about the fund and the type
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of offer the fund is making.1 The fund
must describe in its annual report to
shareholders the fund’s policy
concerning repurchase offers and the
results of any repurchase offers made
during the reporting period. The fund’s
board of directors must adopt written
procedures designed to ensure that the
fund’s investment portfolio is
sufficiently liquid to meet its repurchase
obligations and other obligations under
the rule. The board periodically must
review the composition of the fund’s
portfolio and change the liquidity
procedures as necessary. The fund also
must file copies of advertisements and
other sales literature with the
Commission as if it were an open-end
investment company subject to section
24 of the Investment Company Act (15
U.S.C. 80a–24) and the rules that
implement section 24. Rule 24b–3 under
the Investment Company Act (17 CFR
270.24b–3), however, exempts the fund
from that requirement if the materials
are filed instead with the Financial
Industry Regulatory Authority
(‘‘FINRA’’).
The requirement that the fund send a
notification to shareholders of each offer
is intended to ensure that a fund
provides material information to
shareholders about the terms of each
offer. The requirement that copies be
sent to the Commission is intended to
enable the Commission to monitor the
fund’s compliance with the notification
requirement. The requirement that the
shareholder notification be attached to
Form N–23c–3 is intended to ensure
that the fund provides basic information
necessary for the Commission to process
the notification and to monitor the
fund’s use of repurchase offers. The
requirement that the fund describe its
current policy on repurchase offers and
the results of recent offers in the annual
shareholder report is intended to
provide shareholders current
information about the fund’s repurchase
policies and its recent experience. The
requirement that the board approves
and review written procedures designed
to maintain portfolio liquidity is
intended to ensure that the fund has
enough cash or liquid securities to meet
its repurchase obligations, and that
written procedures are available for
review by shareholders and examination
by the Commission. The requirement
that the fund file advertisements and
sales literature as if it were an open-end
fund is intended to facilitate the review
1 Form N–23c–3, entitled ‘‘Notification of
Repurchase Offer Pursuant to Rule 23c–3,’’ requires
the fund to state its registration number, its full
name and address, the date of the accompanying
shareholder notification, and the type of offer being
made (periodic, discretionary, or both).
E:\FR\FM\27MYN1.SGM
27MYN1
Agencies
[Federal Register Volume 80, Number 101 (Wednesday, May 27, 2015)]
[Notices]
[Pages 30311-30314]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-12757]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-31642; File No. 812-14469]
The Royal Bank of Scotland plc, 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'').
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Summary of Application: Applicants have received a temporary order
(``Temporary Order'') exempting them from section 9(a) of the Act, with
respect to a guilty plea entered on May 20, 2015, by the Royal Bank of
Scotland plc (``RBS'' 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: RBS and Citizens Investment Advisors (``Citizens IA'')
(each an ``Applicant'' and together, the ``Applicants'').
DATES: 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: RBS: RBS, Gogarburn,
P.O. Box 1000, Edinburgh, EH12 1HQ, Scotland; Citizens IA: c/o Citizens
Bank, N.A., Mail Stop RC 03-30, One Citizens Plaza, Providence, Rhode
Island 02903.
FOR FURTHER INFORMATION CONTACT: Parisa Haghshenas, 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. RBS is a company organized under the laws of Scotland and is a
wholly-owned subsidiary of The Royal Bank of Scotland Group plc
(``RBSG''). RBS and RBSG are international banking and financial
services companies that provide a wide range of products and services
to customers around the world. RBS and RBSG are both foreign banking
organizations for purposes of Section 8 of the International Banking
Act of 1978, as amended, and Subpart B of Regulation K, bank holding
companies for purposes of the Bank Holding Company Act of 1956, as
amended (the ``BHC Act'') and financial holding companies for purposes
of the BHC Act. Citizens IA is a separately identifiable department of
Citizens Bank, N.A., which is an indirect subsidiary of RBSG and bank
subsidiary of Citizens Financial Group, Inc.
2. Citizens IA is an investment adviser registered under the
Investment Advisers Act of 1940, as amended. Citizens IA serves as
investment sub-
[[Page 30312]]
adviser to one management investment company registered under the Act
(the ``Fund''). 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 Citizens IA as described above)
currently serves as an investment adviser or depositor of any
investment company registered under the Act (``RIC''), employees'
securities company (``ESC'') or investment company that has elected to
be treated as a business development company under the Act (``BDC''),
or principal underwriter for any open-end registered investment company
under the Act (``Open-End Fund''), unit investment trust registered
under the Act (``UIT''), or face-amount certificate company registered
under the Act (``FACC'') (such activities, ``Fund Service
Activities''), Applicants request that any relief granted by the
Commission pursuant to the application 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.\1\
---------------------------------------------------------------------------
\1\ The Applicants and other Covered Persons may, if the Orders
are granted, in the future act in any of the capacities contemplated
by Section 9(a) of the Act subject to the applicable conditions of
the Orders.
---------------------------------------------------------------------------
3. On May 20, 2015, the United States Department of Justice (the
``Department of Justice'') filed a one-count criminal information (the
``Information'') in the U.S. District Court for the District of
Connecticut (the ``District Court''). The Information charges that
between approximately December 2007 and April 2010, the Settling Firm,
through one of its euro/U.S. dollar (``EUR/USD'') traders, 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 foreign currency exchange spot market
(``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 ``Conduct'') in violation of Title 15, United States
Code, Section 1. The Conduct involved 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 RBS.
4. Pursuant to the Plea Agreement, the Settling Firm entered a plea
of guilty (the ``Guilty Plea'') on May 20, 2015 in the District Court
to the offense charged in the Information. In the Plea Agreement, the
Settling Firm, among other things, agreed to a fine of $395 million.
The Applicants expect that the District Court will enter a judgment
against the Settling Firm (the ``Judgment'') that will require remedies
that are materially the same as set forth in the Plea Agreement. The
individual at the Settling Firm who was identified by the Settling
Firm, RBSG or any U.S. or non-U.S. regulatory or enforcement agencies
as being responsible for the Conduct has left RBS as of April 2010. RBS
and RBS Securities Inc. will also enter into a settlement with the
Board of Governors of the Federal Reserve System to resolve certain
findings by the Federal Reserve (the ``Federal Reserve Order'').
Additionally, RBS entered into a settlement with the U.S. Commodity
Futures Trading Commission on November 11, 2014 to resolve certain
findings by the CFTC (the ``CFTC Order'') and with the U.K. Financial
Conduct Authority (``FCA'') on November 11, 2014 to resolve certain
findings by the FCA (the ``FCA 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. 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. The Settling Firm is an
Affiliated Person of Citizens IA within the meaning of section 2(a)(3)
of the Act. Therefore, the Applicants state that the Guilty Plea would
result in a disqualification of the Applicants for ten years under
section 9(a)(3) were they to act in any of the capacities listed in
section 9(a) because they would become the subject of a conviction
described in section 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 (i) the scope of the
misconduct was limited and did not involve the Adviser Applicant (as
defined below) or Fund Service Activities, (ii) application of the
statutory bar would impose significant hardships on the Fund and its
shareholders, (iii) the prohibitions of section 9(a), if applied to the
Adviser Applicant and other Covered Persons, would be unduly or
disproportionately severe and (iv) the Conduct did not constitute
conduct that would make it against the public interest or protection of
investors to grant the exemption from section 9(a).
4. Applicants represent that the Conduct did not involve the
Adviser Applicant nor did it involve any of the Applicants acting in
the capacity of investment adviser, sub-adviser or depositor to any
RIC, or in the capacity of principal underwriter for any Open-End Fund,
UIT or FACC. Applicants represent that the Conduct similarly did not
involve any RIC, Open-End Fund, UIT or FACC with respect to which the
Applicants engaged in Fund Service Activities. Instead, a single
employee, who was not employed by the Adviser Applicant or engaged in
Fund Service Activities, was identified as being responsible for the
Conduct. That employee is no longer employed, and will not be employed
in the future, by the Applicants or any other Covered Person.
Applicants assert that, in light of the limited scope of the Conduct,
it would be unduly and disproportionately severe to impose a section
9(a) disqualification on the Applicants. Applicants further represent
that depriving the Fund of the Adviser
[[Page 30313]]
Applicant as its sub-adviser because of the activities of the Settling
Firm would be an unduly severe result, both for the Adviser Applicant's
financial position and for the shareholders of the Fund, who would be
deprived of the knowledge and expertise of a key service provider.
Applicants assert that the conduct of the Applicants has not been such
to make it against the public interest or the protection of investors
to grant the exemption from section 9(a).
5. Applicants assert that the inability of the Applicant, i.e.,
Citizens IA, that serves as investment sub-adviser to the Fund (the
``Adviser Applicant'') to continue providing such services to the Fund
would result in the Fund and its shareholders facing potential
hardship, as outlined in the application. Applicants assert 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 Applicant because those disqualifications would deprive the
Fund of the sub-advisory services that shareholders expected the Fund
would receive when they decided to invest in the Fund. Applicants also
assert that the prohibitions of section 9(a) could operate to the
financial detriment of the Fund and its shareholders, which would be an
unduly and disproportionately severe consequence given that the Adviser
Applicant was not involved in the Conduct and that the Conduct did not
involve Fund Service Activities.
6. Applicants assert that if the Adviser Applicant were barred
under section 9(a) from providing investment advisory services to the
Fund and were unable to obtain the requested exemption, the effect on
its business and employees would be unduly and disproportionately
severe. Applicants state that the Adviser Applicant has committed
substantial capital and other resources to establishing expertise in
sub-advising RICs. Applicants further state that prohibiting the
Adviser Applicant from engaging in Fund Service Activities would not
only adversely affect its business, but would also adversely affect its
employees who are involved in these activities. Many of these employees
could experience significant difficulties in finding alternative, fund-
related employment. In addition, Applicants assert that if the
Applicants or Covered Persons are unable to expand their businesses in
the future because of the imposition of the section 9(a)
disqualification, it could also have an adverse impact on their
businesses.
7. Applicants represent that: (i) None of the current or former
directors, officers or employees of Citizens IA had any knowledge of,
or had any involvement in, the Conduct; (ii) no current or former
employee of the Settling Firm or of any other 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
agencies as having been responsible for the Conduct will have any
involvement in providing Fund Service Activities on behalf of any
Covered Person or will be an officer, director, or employee of any
Applicants or of any other Covered Person; (iii) no employee of the
Settling Firm 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 the personnel of Citizens IA did not have any
involvement in the Conduct, shareholders of the Fund were not affected
any differently than if the Fund had received services from any other
non-affiliated investment adviser or principal underwriter.
8. Applicants have agreed that neither they nor any of the other
Covered Persons will employ any of the current or former employees of
Settling Firm or any Covered Person who previously have been or who
subsequently may be identified by the Settling Firm, RBSG 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).
9. 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 granted under section 9(c).
10. In addition, the Settling Firm has agreed to comply in all
material respects with the material terms and conditions of the Plea
Agreement, the CFTC Order, the Federal Reserve Order, the FCA Order, or
any other orders issued by regulatory or enforcement agencies
addressing the Conduct. Applicants further state that RBS and its
affiliates have undertaken certain remedial measures, as described in
greater detail in the application. These include certain remedial
measures as required by the Plea Agreement, the CFTC Order, the Federal
Reserve Order, and the FCA Order, including improvements to the
oversight, internal controls, compliance, risk management and audit
programs for FX trading. Specifically, Applicants represent that RBSG
and RBS have taken a number of steps to enhance its internal controls,
policies and procedures relating to its FX activities. These changes,
include, but are not limited to the following: Restricting
participation by traders in multi-bank chat rooms; prohibiting mobile
communication devices on dealing floors; strengthening surveillance of
electronic, audio and trade communications at FX desks; mandating
regular training for all FX employees concerning appropriate trading
behavior; enhancing policies, procedures and guidance related to market
color, client orders and FX fix orders; and improving customer
disclosures relating to and enhancing controls around FX fix orders.
11. As a result, Applicants submit that granting an exemption as
requested in the application would be consistent with the public
interest and the protection of investors.
12. To provide further assurance that the exemptive relief being
requested herein would be consistent with the public interest and the
protection of the investors, the Applicants agree that they will, as
soon as reasonably practical, distribute to the board of trustees
(``Board'') of the Fund written materials describing the circumstances
that led to the Guilty Plea, any impact on the Fund and the
application. The written materials will include an offer to discuss the
materials at an in-person meeting with the Board of the Fund, including
the directors who are not ``interested persons'' of the Fund as defined
in section 2(a)(19) of the Act and their independent legal counsel as
defined in rule 0-1(a)(6) under the Act. The Applicants undertake to
provide the Fund's Board with all 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 Judgment as entered by the District
Court.
13. Applicants state that certain of the Applicants and their
affiliates have previously received an order under section 9(c) of the
Act, as the result of conduct that triggered section 9(a), as described
in greater detail in the application.
Applicants' Conditions
Applicants agree that any order granted by the Commission pursuant
to the application will be subject to the following conditions:
1. Any temporary exemption granted pursuant to the application
shall be without prejudice to, and shall not limit the Commission's
rights in any manner with respect to, any Commission investigation of,
or administrative
[[Page 30314]]
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, RBSG 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 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 Federal Reserve Order, the FCA Order, or any other orders issued by
regulatory or enforcement agencies addressing the Conduct.
4. The Settling Firm will comply in all material respects with the
material terms and conditions of the Plea Agreement, with the material
terms of the CFTC Order, the Federal Reserve Order, the FCA Order or
any other orders issued by regulatory or 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 May 20,
2015 until the Commission takes final action on their application for a
permanent order.
By the Commission.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2015-12757 Filed 5-26-15; 8:45 am]
BILLING CODE P