Amplify Investments LLC and Amplify ETF Trust; Notice of Application, 36367-36372 [2015-15450]
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Federal Register / Vol. 80, No. 121 / Wednesday, June 24, 2015 / Notices
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Section 4204(c) of ERISA and
§ 4204.22(b) of the regulation require
PBGC to publish a notice of the
pendency of a request for a variance or
exemption in the Federal Register, and
to provide interested parties with an
opportunity to comment on the
proposed variance or exemption.
The Request
The PBGC has received a request from
Harrington Air Systems, LLC (‘‘HAS’’)
and its sister company J.C. Cannistraro,
LLC (‘‘JCC’’) (collectively, ‘‘Cannistraro’’
or the ‘‘Buyer’’) for an exemption from
the bond/escrow requirement of
§ 4204(a)(1)(B) with respect to the Sheet
Metal Workers National Pension Fund
(the ‘‘Fund’’) in connection with the
purchase of most of the assets of
Harrington Brothers Corporation
(‘‘HBC’’ or the ‘‘Seller’’) on February 28,
2014. HAS is an entity set up by JCC in
order to effectuate the purchase of
HBC’s assets. In the request, the Buyer
represents that HAS and JCC are
businesses under common control
pursuant to 26 CFR 1.414(c)-2 and
therefore treated as one employer under
ERISA. Additionally, the Buyer
represents, among other things, that:
1. Under the terms of the asset
purchase agreement, the Buyer paid the
Seller approximately $5.1 million in the
form of an unsecured promissory note
that may be adjusted post-closing based
on the performance of certain
construction contracts in place at the
time of the transaction.
2. The Buyer is obligated to contribute
to the Fund for the purchased
operations for substantially the same
contribution base units for which the
Seller had an obligation to contribute.
3. The Seller has agreed to be
secondarily liable for any withdrawal
liability it would have had with regard
to the sold operations (if not for § 4204)
should the Buyer withdraw from the
Fund within the five plan years
following the sale and fail to pay
withdrawal liability.
4. The estimated amount of unfunded
vested benefits allocable to the seller
with respect to the operations sold is
about $23.5 million.
5. The amount of the bond/escrow
required under § 4204(a)(1)(B) is $1.68
million.
6. After the close of the transaction,
the Buyer requested that the trustees of
the Fund waive the bond/escrow
requirements of ERISA § 4204. By its
counsel, the Fund denied the request on
the grounds that the Buyer had not
satisfied the income or asset tests under
PBGC’s regulations for an exemption
from the bond/escrow requirement of
§ 4204(a)(1)(B).
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7. The Fund determined that to
receive a waiver of the bond/escrow
requirement under the net income test
of 29 CFR 4204.13(a)(1), the average net
income needed for the three-year period
prior to the transaction should have
been $400,000 greater than the amount
reported.
8. The Buyer asserts that the threeyear average net income of JCC was
lowered due to an ‘‘aberrantly poor
year’’ in the construction industry in
Massachusetts in 2011. The Buyer states
that JCC’s average net income for the
years between 2011–2014 was
approximately $1 million more than
what was required to meet the net
income test under 29 CFR 4204.13(a)(1),
and that its net income for the 3 years
between 2012–2014 was approximately
$1.5 million more than what was
required.
9. The Buyer further asserts that, in
denying the Buyer’s request for a
waiver, the Fund looked only at the
average net income of JCC. It contends
that aggregating the net incomes of JCC
and HAS, two businesses under
common control under 26 CFR 1.414(c)2, shows that there ‘‘can be no serious
argument that a waiver will create risk
for the Fund, let alone substantial risk.’’
HAS’s anticipated net income for 2014
is approximately $300,000.
10. The Buyer’s request additionally
states that a variance of the bond/escrow
requirement in this instance furthers the
purposes of Title IV of ERISA because
Congress, in enacting Title IV, sought to
minimize intrusions into normal
business operations while protecting
plans. The Buyer asserts that HBC had
previously been a ‘‘struggling
enterprise’’ and that the transaction has
‘‘resulted in a more stable and
financially secure contributing
employer to the Fund.’’
Comments
All interested persons are invited to
submit written comments on the
pending exemption request. All
comments will be made part of the
administrative record.
Issued in Washington, DC, on this 16th day
of June, 2015.
Alice C. Maroni,
Acting Director, Pension Benefit Guaranty
Corporation.
[FR Doc. 2015–15415 Filed 6–23–15; 8:45 am]
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36367
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
31683; 812–14425]
Amplify Investments LLC and Amplify
ETF Trust; Notice of Application
June 18, 2015.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 12(d)(1)(J) of the
Investment Company Act of 1940 (the
‘‘Act’’) for exemptions from sections
12(d)(1)(A), (B), and (C) of the Act,
under sections 6(c) and 17(b) of the Act
for an exemption from section 17(a) of
the Act, and under section 6(c) of the
Act for an exemption from rule 12d1–
2(a) under the Act.
AGENCY:
Summary of the Application:
Applicants request an order that would
(a) permit certain registered open-end
management investment companies that
operate as ‘‘funds of funds’’ to acquire
shares of certain registered open-end
management investment companies,
registered closed-end management
investment companies, business
development companies, as defined by
section 2(a)(48) of the Act (‘‘business
development companies’’), and
registered unit investment trusts that are
within or outside the same group of
investment companies as the acquiring
investment companies and (b) permit
certain registered open-end management
investment companies relying on rule
12d1–2 under the Act to invest in
certain financial instruments.
Applicants: Amplify Investments LLC
(‘‘Adviser’’) and Amplify ETF Trust
(‘‘Trust’’).
Filing Dates: The application was
filed on February 20, 2015.
Hearing or Notification of Hearing: An
order granting the requested relief will
be issued unless the Commission orders
a hearing. Interested persons may
request a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on July 13, 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.
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Federal Register / Vol. 80, No. 121 / Wednesday, June 24, 2015 / Notices
Secretary, U.S. Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
Adviser and Trust, 3250 Lacey Road,
Suite 130, Downers Grove, Illinois
60515.
ADDRESSES:
FOR FURTHER INFORMATION CONTACT:
Kieran G. Brown, Senior Counsel, at
(202) 551–6773, or James M. Curtis,
Branch Chief, at (202) 551–6712
(Division of Investment Management,
Chief Counsel’s Office).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or for an applicant using the
‘‘Company’’ name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Applicants’ Representations
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1. The Trust is organized as a
Massachusetts business trust and
intends to register with the Commission
as an open-end management investment
company. The Trust intends to have
multiple series which pursue distinct
investment objectives and strategies.1
The Adviser, a Delaware limited
liability company, is a registered
investment adviser under the
Investment Advisers Act of 1940. The
Adviser, or an entity controlling,
controlled by, or under common control
with the Adviser, will serve as the
investment adviser to each of the
Funds.2
3. Applicants request relief to the
extent necessary to permit: (a) A Fund
(each, a ‘‘Fund of Funds,’’ and
collectively, the ‘‘Funds of Funds’’) to
acquire shares of registered open-end
management investment companies
(each an ‘‘Unaffiliated Open-End
Investment Company’’), registered
closed-end management investment
companies, business development
1 The Applicants request that the order apply not
only to any existing series of the Trust, but that the
order also extend to any future series of the Trust,
and any other existing or future registered open-end
management investment companies and any series
thereof that are part of the same group of
investment companies, as defined in section
12(d)(1)(G)(ii) of the Act, as the Trust and are
advised by the Adviser or any other investment
adviser controlling, controlled by, or under
common control with the Adviser (together with the
series of the Trust, each series a ‘‘Fund,’’ and
collectively, the ‘‘Funds’’). All entities that
currently intend to rely on the requested order are
named as applicants. Any other entity that relies on
the order in the future will comply with the terms
and conditions of the application.
2 All references to the term ‘‘Adviser’’ include
successors-in-interest to the Adviser. A successorin-interest is limited to an entity that results from
a reorganization into another jurisdiction or a
change in the type of business organization.
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companies (each registered closed-end
management investment company and
each business development company,
an ‘‘Unaffiliated Closed-End Investment
Company’’ and, together with the
Unaffiliated Open-End Investment
Companies, the ‘‘Unaffiliated
Investment Companies’’), and registered
unit investment trusts (‘‘UITs’’) (the
‘‘Unaffiliated Trusts,’’ and collectively
with the Unaffiliated Investment
Companies, the ‘‘Unaffiliated Funds’’),
in each case, that are not part of the
same ‘‘group of investment companies’’
as the Funds of Funds; 3 (b) the
Unaffiliated Funds, their principal
underwriters and any broker or dealer
registered under the Securities
Exchange Act of 1934 (the ‘‘1934 Act’’)
(‘‘Broker’’) to sell shares of such
Unaffiliated Funds to the Funds of
Funds; (c) the Funds of Funds to acquire
shares of other registered investment
companies, including open-end
management investment companies and
series thereof, closed-end management
investment companies and UITs, as well
as business development companies (if
any), in the same group of investment
companies as the Funds of Funds
(collectively, the ‘‘Affiliated Funds,’’
and, together with the Unaffiliated
Funds, the ‘‘Underlying Funds’’); 4 and
(d) the Affiliated Funds, their principal
underwriters and any Broker to sell
shares of the Affiliated Funds to the
Funds of Funds.5 Applicants also
request an order under sections 6(c) and
3 For purposes of the request for relief, the term
‘‘group of investment companies’’ means any two
or more investment companies, including closedend investment companies and business
development companies, that hold themselves out
to investors as related companies for purposes of
investment and investor services.
4 Certain of the Underlying Funds may be
registered under the Act as either UITs or open-end
management investment companies and have
obtained exemptions from the Commission
necessary to permit their shares to be listed and
traded on a national securities exchange at
negotiated prices and, accordingly, to operate as
exchange-traded funds (collectively, ‘‘ETFs’’ and
each, an ‘‘ETF’’). In addition, certain of the
Underlying Funds may in the future pursue, their
investment objectives through a master-feeder
arrangement in reliance on section 12(d)(1)(E) of the
Act. In accordance with condition 12, a Fund of
Funds may not invest in an Underlying Fund that
operates as a feeder fund unless the feeder fund is
part of the same ‘‘group of investment companies’’
as its corresponding master fund or the Fund of
Funds. If a Fund of Funds invests in an Affiliated
Fund that operates as a feeder fund and the
corresponding master fund is not within the same
‘‘group of investment companies’’ as the Fund of
Funds and Affiliated Fund, the master fund would
be an Unaffiliated Fund for purposes of the
application and its conditions.
5 Applicants state that they do not believe that
investments in business development companies
present any particular considerations or concerns
that may be different from those presented by
investments in registered closed-end investment
companies.
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17(b) of the Act to exempt applicants
from section 17(a) to the extent
necessary to permit Underlying Funds
organized as open-end management
investment companies and UITs to sell
their shares to Funds of Funds and
redeem their shares from Funds of
Funds.
4. Applicants also request an
exemption under section 6(c) from rule
12d1–2 under the Act to permit any
existing or future Fund of Funds that
relies on section 12(d)(1)(G) of the Act
(‘‘Section 12(d)(1)(G) Fund of Funds’’)
and that otherwise complies with rule
12d1–2 under the Act, to also invest, to
the extent consistent with its investment
objective(s), policies, strategies and
limitations, in other financial
instruments that may not be securities
within the meaning of section 2(a)(36) of
the Act (‘‘Other Investments’’).
Applicants’ Legal Analysis
A. Section 12(d)(1)
1. Section 12(d)(1)(A) of the Act, in
relevant part, prohibits a registered
investment company from acquiring
shares of an investment company if the
securities represent more than 3% of the
total outstanding voting stock of the
acquired company, more than 5% of the
total assets of the acquiring company,
or, together with the securities of any
other investment companies, more than
10% of the total assets of the acquiring
company. Section 12(d)(1)(B) of the Act
prohibits a registered open-end
investment company, its principal
underwriter, and any Broker from
selling the investment company’s shares
to another investment company if the
sale will cause the acquiring company
to own more than 3% of the acquired
company’s voting stock, or if the sale
will cause more than 10% of the
acquired company’s voting stock to be
owned by investment companies
generally. Section 12(d)(1)(C) prohibits
an investment company from acquiring
any security issued by a registered
closed-end investment company if such
acquisition would result in the
acquiring company, any other
investment companies having the same
investment adviser, and companies
controlled by such investment
companies, collectively, owning more
than 10% of the outstanding voting
stock of the registered closed-end
investment company.
2. Section 12(d)(1)(J) of the Act
provides that the Commission may
exempt any person, security, or
transaction, or any class or classes of
persons, securities or transactions, from
any provision of section 12(d)(1) if the
exemption is consistent with the public
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interest and the protection of investors.
Applicants request an exemption under
section 12(d)(1)(J) of the Act from the
limitations of sections 12(d)(1)(A), (B)
and (C) to the extent necessary to
permit: (i) The Funds of Funds to
acquire shares of Underlying Funds in
excess of the limits set forth in section
12(d)(1)(A) and (C) of the Act; and (ii)
the Underlying Funds, their principal
underwriters and any Broker to sell
shares of the Underlying Funds to the
Funds of Funds in excess of the limits
set forth in section 12(d)(1)(B) of the
Act.
3. Applicants state that the proposed
arrangement will not give rise to the
policy concerns underlying sections
12(d)(1)(A), (B), and (C), which include
concerns about undue influence by a
fund of funds over underlying funds,
excessive layering of fees, and overly
complex fund structures. Accordingly,
applicants believe that the requested
exemption is consistent with the public
interest and the protection of investors.
4. Applicants submit that the
proposed structure will not result in the
exercise of undue influence by a Fund
of Funds or its affiliated persons over
the Underlying Funds. Applicants assert
that the concern about undue influence
does not arise in connection with a
Fund of Funds’ investment in the
Affiliated Funds because they are part of
the same group of investment
companies. To limit the control a Fund
of Funds or Fund of Funds Affiliate 6
may have over an Unaffiliated Fund,
applicants propose a condition
prohibiting the Adviser and any person
controlling, controlled by or under
common control with the Adviser, and
any investment company and any issuer
that would be an investment company
but for section 3(c)(1) or section 3(c)(7)
of the Act advised or sponsored by the
Adviser or any person controlling,
controlled by or under common control
with the Adviser (collectively, the
‘‘Group’’) from controlling (individually
or in the aggregate) an Unaffiliated Fund
within the meaning of section 2(a)(9) of
the Act. The same prohibition would
apply to any other investment adviser
within the meaning of section
2(a)(20)(B) of the Act to a Fund of Funds
(‘‘Sub-Adviser’’) and any person
controlling, controlled by or under
common control with the Sub-Adviser,
6 A ‘‘Fund of Funds Affiliate’’ is the Adviser, any
Sub-Adviser, promoter or principal underwriter of
a Fund of Funds, as well as any person controlling,
controlled by or under common control with any
of those entities. An ‘‘Unaffiliated Fund Affiliate’’
is an investment adviser(s), sponsor, promoter or
principal underwriter of any Unaffiliated Fund or
any person controlling, controlled by or under
common control with any of those entities.
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and any investment company or issuer
that would be an investment company
but for section 3(c)(1) or 3(c)(7) of the
Act (or portion of such investment
company or issuer) advised or
sponsored by the Sub-Adviser or any
person controlling, controlled by or
under common control with the SubAdviser (collectively, the ‘‘Sub-Adviser
Group’’).
5. With respect to closed-end
Underlying Funds, applicants note that
although closed-end funds may not be
unduly influenced by a holder’s right of
redemption, closed-end Underlying
Funds may be unduly influenced by a
holder’s ability to vote a large block of
stock. To address this concern,
applicants submit that, with respect to
a Fund’s investment in an Unaffiliated
Closed-End Investment Company, (i)
each member of the Group or SubAdviser Group that is an investment
company or an issuer that would be an
investment company but for section
3(c)(1) or 3(c)(7) of the Act will vote its
shares of the Unaffiliated Closed-End
Investment Company in the manner
prescribed by section 12(d)(1)(E) of the
Act and (ii) each other member of the
Group or Sub-Adviser Group will vote
its shares of the Unaffiliated Closed-End
Investment Company in the same
proportion as the vote of all other
holders of the same type of such
Unaffiliated Closed-End Investment
Company’s shares. Applicants state that,
in this way, an Unaffiliated Closed-End
Investment Company will be protected
from undue influence by a Fund of
Funds through the voting of the
Unaffiliated Closed-End Investment
Company’s shares.
6. Applicants propose other
conditions to limit the potential for
undue influence over the Unaffiliated
Funds, including that no Fund of Funds
or Fund of Funds Affiliate (except to the
extent it is acting in its capacity as an
investment adviser to an Unaffiliated
Investment Company or sponsor to an
Unaffiliated Trust) will cause an
Unaffiliated Fund to purchase a security
in an offering of securities during the
existence of any underwriting or selling
syndicate of which a principal
underwriter is an Underwriting Affiliate
(‘‘Affiliated Underwriting’’).7
7 An ‘‘Underwriting Affiliate’’ is a principal
underwriter in any underwriting or selling
syndicate that is an officer, director, trustee,
advisory board member, investment adviser, subadviser or employee of the Fund of Funds, or a
person of which any such officer, director, trustee,
investment adviser, sub-adviser, member of an
advisory board or employee is an affiliated person.
An Underwriting Affiliate does not include any
person whose relationship to an Unaffiliated Fund
is covered by section 10(f) of the Act.
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36369
7. To further ensure that an
Unaffiliated Investment Company
understands the implications of a Fund
of Funds’ investment under the
requested exemptive relief, prior to its
investment in the shares of an
Unaffiliated Investment Company in
excess of the limit of section
12(d)(1)(A)(i) of the Act, a Fund of
Funds and the Unaffiliated Investment
Company will execute an agreement
stating, without limitation, that each of
their boards of directors or trustees
(each, a ‘‘Board’’) and their investment
advisers understand the terms and
conditions of the order and agree to
fulfill their responsibilities under the
order (the ‘‘Participation Agreement’’).
Applicants note that an Unaffiliated
Investment Company (including an ETF
or an Unaffiliated Closed-End
Investment Company) would also retain
its right to reject any initial investment
by a Fund of Funds in excess of the
limits in section 12(d)(1)(A)(i) of the Act
by declining to execute the Participation
Agreement with the Fund of Funds. In
addition, an Unaffiliated Investment
Company (other than an ETF or
Unaffiliated Closed-End Investment
Company whose shares are purchased
by a Fund of Funds in the secondary
market) will retain its right at all times
to reject any investment by a Fund of
Funds. Finally, solely upon notice to a
Fund of Funds, an Unaffiliated
Investment Company could terminate a
Participation Agreement with the Fund
of Funds effective at the end of the
notice period specified in the
Participation Agreement.
8. Applicants state that they do not
believe that the proposed arrangement
will result in excessive layering of fees.
The Board of each Fund of Funds,
including a majority of the trustees who
are not ‘‘interested persons’’ within the
meaning of section 2(a)(19) of the Act
(the ‘‘Independent Trustees’’), will find
that the management or advisory fees
charged under a Fund of Funds’
advisory contract are based on services
provided that are in addition to, rather
than duplicative of, services provided
under the advisory contract(s) of any
Underlying Fund in which the Fund of
Funds may invest. In addition, the
Adviser will waive fees otherwise
payable to it by a Fund of Funds in an
amount at least equal to any
compensation (including fees received
pursuant to any plan adopted by an
Unaffiliated Investment Company under
rule 12b–1 under the Act) received from
an Unaffiliated Fund by the Adviser, or
an affiliated person of the Adviser, other
than any advisory fees paid to the
Adviser or an affiliated person of the
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Adviser by the Unaffiliated Investment
Company, in connection with the
investment by the Fund of Funds in the
Unaffiliated Fund.
9. Applicants further state that any
sales charges and/or service fees
charged with respect to shares of a Fund
of Funds will not exceed the limits
applicable to funds of funds set forth in
in rule 2830 of the Conduct Rules of the
NASD (‘‘NASD Conduct Rule 2830’’).8
10. Applicants submit that the
proposed arrangement will not create an
overly complex fund structure.
Applicants note that no Underlying
Fund will acquire securities of any other
investment company or company
relying on section 3(c)(1) or 3(c)(7) of
the Act in excess of the limits contained
in section 12(d)(1)(A) of the Act, except
in certain circumstances identified in
condition 12 below.
B. Section 17(a)
1. Section 17(a) of the Act generally
prohibits sales or purchases of securities
between a registered investment
company and any affiliated person of
the company. Section 2(a)(3) of the Act
defines an ‘‘affiliated person’’ of another
person to include (a) any person directly
or indirectly owning, controlling, or
holding with power to vote, 5% or more
of the outstanding voting securities of
the other person; (b) any person 5% or
more of whose outstanding voting
securities are directly or indirectly
owned, controlled, or held with power
to vote by the other person; and (c) any
person directly or indirectly controlling,
controlled by, or under common control
with the other person.
2. Applicants state that the Funds of
Funds and the Affiliated Funds may be
deemed to be under the common control
of the Adviser and, therefore, affiliated
persons of one another. Applicants also
state that the Funds of Funds and the
Underlying Funds organized as openend management investment companies
and UITs may also be deemed to be
affiliated persons of one another if a
Fund of Funds owns 5% or more of the
outstanding voting securities of one or
more of such Underlying Funds.
Applicants state that the sale of shares
by Underlying Funds organized as openend management investment companies
and UITs to the Funds of Funds and the
purchase of those shares from the Funds
of Funds by such Underlying Funds
(through redemptions) could be deemed
to violate section 17(a).9
8 Any references to NASD Conduct Rule 2830
include any successor or replacement Financial
Industry Regulatory Authority rule to NASD
Conduct Rule 2830.
9 Applicants acknowledge that receipt of any
compensation by (a) an affiliated person of a Fund
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3. Section 17(b) of the Act authorizes
the Commission to grant an order
permitting a transaction otherwise
prohibited by section 17(a) if it finds
that (i) the terms of the proposed
transaction are fair and reasonable and
do not involve overreaching on the part
of any person concerned; (ii) the
proposed transaction is consistent with
the policies of each registered
investment company concerned; and
(iii) the proposed transaction is
consistent with the general purposes of
the Act. Section 6(c) of the Act permits
the Commission to exempt any person
or transactions from any provision of
the Act if such exemption is necessary
or appropriate in the public interest and
consistent with the protection of
investors and the purposes fairly
intended by the policy and provisions of
the Act.
4. Applicants submit that the
proposed transactions satisfy the
standards for relief under sections 17(b)
and 6(c) of the Act. Applicants state that
the terms of the transactions are
reasonable and fair and do not involve
overreaching. Applicants state that the
terms upon which an Underlying Fund
that is an open-end management
investment company will sell its shares
to or purchase its shares from a Fund of
Funds will be in accordance with the
rules and regulations under the Act.10
Applicants also state that the proposed
transactions will be consistent with the
policies of each Fund of Funds and
of Funds, or an affiliated person of such person, for
the purchase by the Fund of Funds of shares of an
Underlying Fund or (b) an affiliated person of an
Underlying Fund, or an affiliated person of such
person, for the sale by the Underlying Fund of its
shares to a Fund of Funds may be prohibited by
section 17(e) (1) of the Act. The Participation
Agreement also will include this acknowledgement.
10 Applicants note that a Fund of Funds generally
would purchase and sell shares of an Underlying
Fund that operates as an ETF through secondary
market transactions rather than through principal
transactions with the Underlying Fund. Applicants
nevertheless request relief from sections 17(a)(1)
and (2) to permit each Fund of Funds that is an
affiliated person, or an affiliated person of an
affiliated person, as defined in section 2(a)(3) of the
Act, of an ETF to purchase or redeem shares from
the ETF. Applicants are not seeking relief from
section 17(a) for, and the requested relief will not
apply to, transactions where an ETF could be
deemed an affiliated person, or an affiliated person
of an affiliated person, of a Fund of Funds because
an investment adviser to the ETF or an entity
controlling, controlled by or under common control
with the investment adviser to the ETF is also an
investment adviser to the Fund of Funds.
Applicants note that a Fund of Funds will purchase
and sell shares of an Underlying Fund that is a
closed-end fund through secondary market
transactions at market prices rather than through
principal transactions with the closed-end fund.
Accordingly, applicants are not requesting section
17(a) relief with respect to principal transactions
with closed-end funds (including business
development companies).
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Underlying Fund, and with the general
purposes of the Act.
C. Other Investments by Section
12(d)(1)(G) Funds of Funds
1. Section 12(d)(1)(G) of the Act
provides that section 12(d)(1) will not
apply to securities of an acquired
company purchased by an acquiring
company if: (i) The acquiring company
and acquired company are part of the
same ‘‘group of investment companies,’’
as defined in section 12(d)(1)(G)(ii) of
the Act; (ii) the acquiring company
holds only securities of acquired
companies that are part of the same
‘‘group of investment companies,’’ as
defined in section 12(d)(1)(G)(ii) of the
Act, government securities, and shortterm paper; (iii) the aggregate sales loads
and distribution-related fees of the
acquiring company and the acquired
company are not excessive under rules
adopted pursuant to section 22(b) or
section 22(c) of the Act by a securities
association registered under section 15A
of the 1934 Act or by the Commission;
and (iv) the acquired company has a
policy that prohibits it from acquiring
securities of registered open-end
management investment companies or
registered UITs in reliance on section
12(d)(1)(F) or (G) of the Act.
2. Rule 12d1–2 under the Act permits
a registered open-end investment
company or a registered UIT that relies
on section 12(d)(1)(G) of the Act to
acquire, in addition to securities issued
by another registered investment
company in the same group of
investment companies, government
securities, and short-term paper: (1)
Securities issued by an investment
company that is not in the same group
of investment companies, when the
acquisition is in reliance on section
12(d)(1)(A) or 12(d)(1)(F) of the Act; (2)
securities (other than securities issued
by an investment company); and (3)
securities issued by a money market
fund, when the investment is in reliance
on rule 12d1–1 under the Act. For the
purposes of rule 12d1–2, ‘‘securities’’
means any security as defined in section
2(a)(36) of the Act.
3. Applicants state that the proposed
arrangement would comply with rule
12d1–2 under the Act, but for the fact
that the Section 12(d)(1)(G) Funds of
Funds may invest a portion of their
assets in Other Investments. Applicants
request an order under section 6(c) of
the Act for an exemption from rule
12d1–2(a) to allow the Section
12(d)(1)(G) Funds of Funds to invest in
Other Investments. Applicants assert
that permitting a Section 12(d)(1)(G)
Fund of Funds to invest in Other
Investments as described in the
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application would not raise any of the
concerns that section 12(d)(1) of the Act
was intended to address.
4. Consistent with its fiduciary
obligations under the Act, a Section
12(d)(1)(G) Fund of Funds’ Board will
review the advisory fees charged by the
Section 12(d)(1)(G) Fund of Funds’
investment adviser(s) to ensure that the
fees are based on services provided that
are in addition to, rather than
duplicative of, services provided
pursuant to the advisory agreement of
any investment company in which the
Section 12(d)(1)(G) Fund of Funds may
invest.
tkelley on DSK3SPTVN1PROD with NOTICES
Applicants’ Conditions
A. Investments by Funds of Funds in
Underlying Funds
Applicants agree that the order
granting the requested relief to permit
Funds of Funds to invest in Underlying
Funds shall be subject to the following
conditions:
1. The members of the Group will not
control (individually or in the aggregate)
an Unaffiliated Fund within the
meaning of section 2(a)(9) of the Act.
The members of a Sub-Adviser Group
will not control (individually or in the
aggregate) an Unaffiliated Fund within
the meaning of section 2(a)(9) of the Act.
With respect to a Fund’s investment in
an Unaffiliated Closed-End Investment
Company, (i) each member of the Group
or Sub-Adviser Group that is an
investment company or an issuer that
would be an investment company but
for section 3(c)(1) or 3(c)(7) of the Act
will vote its shares of the Unaffiliated
Closed-End Investment Company in the
manner prescribed by section
12(d)(1)(E) of the Act and (ii) each other
member of the Group or Sub-Adviser
Group will vote its shares of the
Unaffiliated Closed-End Investment
Company in the same proportion as the
vote of all other holders of the same
type of such Unaffiliated Closed-End
Investment Company’s shares. If, as a
result of a decrease in the outstanding
voting securities of any other
Unaffiliated Fund, the Group or a SubAdviser Group, each in the aggregate,
becomes a holder of more than 25
percent of the outstanding voting
securities of such Unaffiliated Fund,
then the Group or the Sub-Adviser
Group will vote its shares of the
Unaffiliated Fund in the same
proportion as the vote of all other
holders of the Unaffiliated Fund’s
shares. This condition will not apply to
a Sub-Adviser Group with respect to an
Unaffiliated Fund for which the SubAdviser or a person controlling,
controlled by or under common control
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16:43 Jun 23, 2015
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with the Sub-Adviser acts as the
investment adviser within the meaning
of section 2(a)(20)(A) of the Act (in the
case of an Unaffiliated Investment
Company) or as the sponsor (in the case
of an Unaffiliated Trust).
2. No Fund of Funds or Fund of
Funds Affiliate will cause any existing
or potential investment by the Fund of
Funds in an Unaffiliated Fund to
influence the terms of any services or
transactions between the Fund of Funds
or a Fund of Funds Affiliate and the
Unaffiliated Fund or an Unaffiliated
Fund Affiliate.
3. The Board of each Fund of Funds,
including a majority of the Independent
Trustees, will adopt procedures
reasonably designed to ensure that its
Adviser and any Sub-Adviser to the
Fund of Funds are conducting the
investment program of the Fund of
Funds without taking into account any
consideration received by the Fund of
Funds or Fund of Funds Affiliate from
an Unaffiliated Investment Company or
Unaffiliated Trust or any Unaffiliated
Fund Affiliate of such Unaffiliated
Investment Company or Unaffiliated
Trust in connection with any services or
transactions.
4. Once an investment by a Fund of
Funds in the securities of an
Unaffiliated Investment Company
exceeds the limit of section
12(d)(1)(A)(i) of the Act, the Board of
the Unaffiliated Investment Company,
including a majority of the Independent
Trustees, will determine that any
consideration paid by the Unaffiliated
Investment Company to a Fund of
Funds or a Fund of Funds Affiliate in
connection with any services or
transactions: (a) Is fair and reasonable in
relation to the nature and quality of the
services and benefits received by the
Unaffiliated Investment Company; (b) is
within the range of consideration that
the Unaffiliated Investment Company
would be required to pay to another
unaffiliated entity in connection with
the same services or transactions; and
(c) does not involve overreaching on the
part of any person concerned. This
condition does not apply with respect to
any services or transactions between an
Unaffiliated Investment Company and
its investment adviser(s), or any person
controlling, controlled by, or under
common control with such investment
adviser(s).
5. No Fund of Funds or Fund of
Funds Affiliate (except to the extent it
is acting in its capacity as an investment
adviser to an Unaffiliated Investment
Company or sponsor to an Unaffiliated
Trust) will cause an Unaffiliated Fund
to purchase a security in any Affiliated
Underwriting.
PO 00000
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36371
6. The Board of an Unaffiliated
Investment Company, including a
majority of the Independent Trustees,
will adopt procedures reasonably
designed to monitor any purchases of
securities by the Unaffiliated Investment
Company in an Affiliated Underwriting
once an investment by a Fund of Funds
in the securities of the Unaffiliated
Investment Company exceeds the limit
of section 12(d)(1)(A)(i) of the Act,
including any purchases made directly
from an Underwriting Affiliate. The
Board of the Unaffiliated Investment
Company will review these purchases
periodically, but no less frequently than
annually, to determine whether the
purchases were influenced by the
investment by the Fund of Funds in the
Unaffiliated Investment Company. The
Board of the Unaffiliated Investment
Company will consider, among other
things: (a) Whether the purchases were
consistent with the investment
objectives and policies of the
Unaffiliated Investment Company; (b)
how the performance of securities
purchased in an Affiliated Underwriting
compares to the performance of
comparable securities purchased during
a comparable period of time in
underwritings other than Affiliated
Underwritings or to a benchmark such
as a comparable market index; and (c)
whether the amount of securities
purchased by the Unaffiliated
Investment Company in Affiliated
Underwritings and the amount
purchased directly from an
Underwriting Affiliate have changed
significantly from prior years. The
Board of the Unaffiliated Investment
Company will take any appropriate
actions based on its review, including,
if appropriate, the institution of
procedures designed to ensure that
purchases of securities in Affiliated
Underwritings are in the best interests
of shareholders.
7. Each Unaffiliated Investment
Company will maintain and preserve
permanently, in an easily accessible
place, a written copy of the procedures
described in the preceding condition,
and any modifications to such
procedures, and will maintain and
preserve for a period of not less than six
years from the end of the fiscal year in
which any purchase in an Affiliated
Underwriting occurred, the first two
years in an easily accessible place, a
written record of each purchase of
securities in an Affiliated Underwriting
once an investment by a Fund of Funds
in the securities of an Unaffiliated
Investment Company exceeds the limit
of section 12(d)(1)(A)(i) of the Act,
setting forth (1) the party from whom
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Federal Register / Vol. 80, No. 121 / Wednesday, June 24, 2015 / Notices
the securities were acquired, (2) the
identity of the underwriting syndicate’s
members, (3) the terms of the purchase,
and (4) the information or materials
upon which the determinations of the
Board of the Unaffiliated Investment
Company were made.
8. Prior to its investment in shares of
an Unaffiliated Investment Company in
excess of the limit set forth in section
12(d)(1)(A)(i) of the Act, the Fund of
Funds and the Unaffiliated Investment
Company will execute a Participation
Agreement stating, without limitation,
that their Boards and their investment
advisers understand the terms and
conditions of the order and agree to
fulfill their responsibilities under the
order. At the time of its investment in
shares of an Unaffiliated Investment
Company in excess of the limit set forth
in section 12(d)(1)(A)(i), a Fund of
Funds will notify the Unaffiliated
Investment Company of the investment.
At such time, the Fund of Funds will
also transmit to the Unaffiliated
Investment Company a list of the names
of each Fund of Funds Affiliate and
Underwriting Affiliate. The Fund of
Funds will notify the Unaffiliated
Investment Company of any changes to
the list as soon as reasonably practicable
after a change occurs. The Unaffiliated
Investment Company and the Fund of
Funds will maintain and preserve a
copy of the order, the Participation
Agreement, and the list with any
updated information for the duration of
the investment and for a period of not
less than six years thereafter, the first
two years in an easily accessible place.
9. Before approving any advisory
contract under section 15 of the Act, the
Board of each Fund of Funds, including
a majority of the Independent Trustees,
shall find that the advisory fees charged
under the advisory contract are based on
services provided that are in addition to,
rather than duplicative of, services
provided under the advisory contract(s)
of any Underlying Fund in which the
Fund of Funds may invest. Such
finding, and the basis upon which the
finding was made, will be recorded fully
in the minute books of the appropriate
Fund of Funds.
10. The Adviser will waive fees
otherwise payable to it by a Fund of
Funds in an amount at least equal to any
compensation (including fees received
pursuant to any plan adopted by an
Unaffiliated Investment Company
pursuant to rule 12b–1 under the Act)
received from an Unaffiliated Fund by
the Adviser, or an affiliated person of
the Adviser, other than any advisory
fees paid to the Adviser or its affiliated
person by the Unaffiliated Investment
Company, in connection with the
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16:43 Jun 23, 2015
Jkt 235001
investment by the Fund of Funds in the
Unaffiliated Fund. Any Sub-Adviser
will waive fees otherwise payable to the
Sub-Adviser, directly or indirectly, by
the Fund of Funds in an amount at least
equal to any compensation received by
the Sub-Adviser, or an affiliated person
of the Sub-Adviser, from an Unaffiliated
Fund, other than any advisory fees paid
to the Sub-Adviser or its affiliated
person by the Unaffiliated Investment
Company, in connection with the
investment by the Fund of Funds in the
Unaffiliated Fund made at the direction
of the Sub-Adviser. In the event that the
Sub-Adviser waives fees, the benefit of
the waiver will be passed through to the
Fund of Funds.
11. Any sales charges and/or service
fees charged with respect to shares of a
Fund of Funds will not exceed the
limits applicable to funds of funds set
forth in NASD Conduct Rule 2830.
12. No Underlying Fund will acquire
securities of any other investment
company or company relying on section
3(c)(1) or 3(c)(7) of the Act, in excess of
the limits contained in section
12(d)(1)(A) of the Act, except to the
extent that such Underlying Fund: (a)
Acquires such securities in compliance
with section 12(d)(1)(E) of the Act and
either is an Affiliated Fund or is in the
same ‘‘group of investment companies’’
as its corresponding master fund; (b)
receives securities of another
investment company as a dividend or as
a result of a plan of reorganization of a
company (other than a plan devised for
the purpose of evading section 12(d)(1)
of the Act); or (c) acquires (or is deemed
to have acquired) securities of another
investment company pursuant to
exemptive relief from the Commission
permitting such Underlying Fund to: (i)
Acquire securities of one or more
investment companies for short-term
cash management purposes or (ii)
engage in inter-fund borrowing and
lending transactions.
B. Other Investments by Section
12(d)(1)(G) Funds of Funds
Applicants agree that the order
granting the requested relief to permit
Section 12(d)(1)(G) Funds of Funds to
invest in Other Investments shall be
subject to the following condition:
1. Applicants will comply with all
provisions of rule 12d1–2 under the Act,
except for paragraph (a)(2) to the extent
that it restricts any Section 12(d)(1)(G)
Fund of Funds from investing in Other
Investments as described in the
application.
PO 00000
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For the Commission, by the Division of
Investment Management, pursuant to
delegated authority.
Brent J. Fields,
Secretary.
[FR Doc. 2015–15450 Filed 6–23–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–75247; File No. SR–
NYSEArca–2015–42]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Filing of Proposed
Rule Change, as Modified by
Amendment No. 1, Relating to the
Listing and Trading of Shares of
Newfleet Multi-Sector Unconstrained
Bond ETF under NYSE Arca Equities
Rule 8.600
June 18, 2015.
Pursuant to section 19(b)(1) 1 of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that, on June 5,
2015, NYSE Arca, Inc. (the ‘‘Exchange’’
or ‘‘NYSE Arca’’) filed with the
Securities and Exchange Commission
(the ‘‘Commission’’) the proposed rule
change as described in Items I and II
below, which Items have been prepared
by the self-regulatory organization. On
June 15, 2015, NYSE Arca filed
Amendment No. 1 to the proposed rule
change.4 The Commission is publishing
this notice to solicit comments on the
proposed rule change from interested
persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to list and
trade shares of the following under
NYSE Arca Equities Rule 8.600
(‘‘Managed Fund Shares’’): Newfleet
Multi-Sector Unconstrained Bond ETF.
The text of the proposed rule change is
available on the Exchange’s Web site at
www.nyse.com, at the principal office of
the Exchange, and at the Commission’s
Public Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
1 15
U.S.C.78s(b)(1).
U.S.C. 78a.
3 17 CFR 240.19b–4.
4 Amendment No. 1 replaces and supersedes the
filing in its entirety.
2 15
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Agencies
[Federal Register Volume 80, Number 121 (Wednesday, June 24, 2015)]
[Notices]
[Pages 36367-36372]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-15450]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 31683; 812-14425]
Amplify Investments LLC and Amplify ETF Trust; Notice of
Application
June 18, 2015.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under section 12(d)(1)(J)
of the Investment Company Act of 1940 (the ``Act'') for exemptions from
sections 12(d)(1)(A), (B), and (C) of the Act, under sections 6(c) and
17(b) of the Act for an exemption from section 17(a) of the Act, and
under section 6(c) of the Act for an exemption from rule 12d1-2(a)
under the Act.
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Summary of the Application: Applicants request an order that would
(a) permit certain registered open-end management investment companies
that operate as ``funds of funds'' to acquire shares of certain
registered open-end management investment companies, registered closed-
end management investment companies, business development companies, as
defined by section 2(a)(48) of the Act (``business development
companies''), and registered unit investment trusts that are within or
outside the same group of investment companies as the acquiring
investment companies and (b) permit certain registered open-end
management investment companies relying on rule 12d1-2 under the Act to
invest in certain financial instruments.
Applicants: Amplify Investments LLC (``Adviser'') and Amplify ETF
Trust (``Trust'').
Filing Dates: The application was filed on February 20, 2015.
Hearing or Notification of Hearing: An order granting the requested
relief will be issued unless the Commission orders a hearing.
Interested persons may request a hearing by writing to the Commission's
Secretary and serving applicants with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 p.m. on July 13, 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.
[[Page 36368]]
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street NE., Washington, DC 20549-1090. Adviser and Trust, 3250 Lacey
Road, Suite 130, Downers Grove, Illinois 60515.
FOR FURTHER INFORMATION CONTACT: Kieran G. Brown, Senior Counsel, at
(202) 551-6773, or James M. Curtis, Branch Chief, at (202) 551-6712
(Division of Investment Management, Chief Counsel's Office).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or for an
applicant using the ``Company'' name box, at https://www.sec.gov/search/search.htm or by calling (202) 551-8090.
Applicants' Representations
1. The Trust is organized as a Massachusetts business trust and
intends to register with the Commission as an open-end management
investment company. The Trust intends to have multiple series which
pursue distinct investment objectives and strategies.\1\ The Adviser, a
Delaware limited liability company, is a registered investment adviser
under the Investment Advisers Act of 1940. The Adviser, or an entity
controlling, controlled by, or under common control with the Adviser,
will serve as the investment adviser to each of the Funds.\2\
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\1\ The Applicants request that the order apply not only to any
existing series of the Trust, but that the order also extend to any
future series of the Trust, and any other existing or future
registered open-end management investment companies and any series
thereof that are part of the same group of investment companies, as
defined in section 12(d)(1)(G)(ii) of the Act, as the Trust and are
advised by the Adviser or any other investment adviser controlling,
controlled by, or under common control with the Adviser (together
with the series of the Trust, each series a ``Fund,'' and
collectively, the ``Funds''). All entities that currently intend to
rely on the requested order are named as applicants. Any other
entity that relies on the order in the future will comply with the
terms and conditions of the application.
\2\ All references to the term ``Adviser'' include successors-
in-interest to the Adviser. A successor-in-interest is limited to an
entity that results from a reorganization into another jurisdiction
or a change in the type of business organization.
---------------------------------------------------------------------------
3. Applicants request relief to the extent necessary to permit: (a)
A Fund (each, a ``Fund of Funds,'' and collectively, the ``Funds of
Funds'') to acquire shares of registered open-end management investment
companies (each an ``Unaffiliated Open-End Investment Company''),
registered closed-end management investment companies, business
development companies (each registered closed-end management investment
company and each business development company, an ``Unaffiliated
Closed-End Investment Company'' and, together with the Unaffiliated
Open-End Investment Companies, the ``Unaffiliated Investment
Companies''), and registered unit investment trusts (``UITs'') (the
``Unaffiliated Trusts,'' and collectively with the Unaffiliated
Investment Companies, the ``Unaffiliated Funds''), in each case, that
are not part of the same ``group of investment companies'' as the Funds
of Funds; \3\ (b) the Unaffiliated Funds, their principal underwriters
and any broker or dealer registered under the Securities Exchange Act
of 1934 (the ``1934 Act'') (``Broker'') to sell shares of such
Unaffiliated Funds to the Funds of Funds; (c) the Funds of Funds to
acquire shares of other registered investment companies, including
open-end management investment companies and series thereof, closed-end
management investment companies and UITs, as well as business
development companies (if any), in the same group of investment
companies as the Funds of Funds (collectively, the ``Affiliated
Funds,'' and, together with the Unaffiliated Funds, the ``Underlying
Funds''); \4\ and (d) the Affiliated Funds, their principal
underwriters and any Broker to sell shares of the Affiliated Funds to
the Funds of Funds.\5\ Applicants also request an order under sections
6(c) and 17(b) of the Act to exempt applicants from section 17(a) to
the extent necessary to permit Underlying Funds organized as open-end
management investment companies and UITs to sell their shares to Funds
of Funds and redeem their shares from Funds of Funds.
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\3\ For purposes of the request for relief, the term ``group of
investment companies'' means any two or more investment companies,
including closed-end investment companies and business development
companies, that hold themselves out to investors as related
companies for purposes of investment and investor services.
\4\ Certain of the Underlying Funds may be registered under the
Act as either UITs or open-end management investment companies and
have obtained exemptions from the Commission necessary to permit
their shares to be listed and traded on a national securities
exchange at negotiated prices and, accordingly, to operate as
exchange-traded funds (collectively, ``ETFs'' and each, an ``ETF'').
In addition, certain of the Underlying Funds may in the future
pursue, their investment objectives through a master-feeder
arrangement in reliance on section 12(d)(1)(E) of the Act. In
accordance with condition 12, a Fund of Funds may not invest in an
Underlying Fund that operates as a feeder fund unless the feeder
fund is part of the same ``group of investment companies'' as its
corresponding master fund or the Fund of Funds. If a Fund of Funds
invests in an Affiliated Fund that operates as a feeder fund and the
corresponding master fund is not within the same ``group of
investment companies'' as the Fund of Funds and Affiliated Fund, the
master fund would be an Unaffiliated Fund for purposes of the
application and its conditions.
\5\ Applicants state that they do not believe that investments
in business development companies present any particular
considerations or concerns that may be different from those
presented by investments in registered closed-end investment
companies.
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4. Applicants also request an exemption under section 6(c) from
rule 12d1-2 under the Act to permit any existing or future Fund of
Funds that relies on section 12(d)(1)(G) of the Act (``Section
12(d)(1)(G) Fund of Funds'') and that otherwise complies with rule
12d1-2 under the Act, to also invest, to the extent consistent with its
investment objective(s), policies, strategies and limitations, in other
financial instruments that may not be securities within the meaning of
section 2(a)(36) of the Act (``Other Investments'').
Applicants' Legal Analysis
A. Section 12(d)(1)
1. Section 12(d)(1)(A) of the Act, in relevant part, prohibits a
registered investment company from acquiring shares of an investment
company if the securities represent more than 3% of the total
outstanding voting stock of the acquired company, more than 5% of the
total assets of the acquiring company, or, together with the securities
of any other investment companies, more than 10% of the total assets of
the acquiring company. Section 12(d)(1)(B) of the Act prohibits a
registered open-end investment company, its principal underwriter, and
any Broker from selling the investment company's shares to another
investment company if the sale will cause the acquiring company to own
more than 3% of the acquired company's voting stock, or if the sale
will cause more than 10% of the acquired company's voting stock to be
owned by investment companies generally. Section 12(d)(1)(C) prohibits
an investment company from acquiring any security issued by a
registered closed-end investment company if such acquisition would
result in the acquiring company, any other investment companies having
the same investment adviser, and companies controlled by such
investment companies, collectively, owning more than 10% of the
outstanding voting stock of the registered closed-end investment
company.
2. Section 12(d)(1)(J) of the Act provides that the Commission may
exempt any person, security, or transaction, or any class or classes of
persons, securities or transactions, from any provision of section
12(d)(1) if the exemption is consistent with the public
[[Page 36369]]
interest and the protection of investors. Applicants request an
exemption under section 12(d)(1)(J) of the Act from the limitations of
sections 12(d)(1)(A), (B) and (C) to the extent necessary to permit:
(i) The Funds of Funds to acquire shares of Underlying Funds in excess
of the limits set forth in section 12(d)(1)(A) and (C) of the Act; and
(ii) the Underlying Funds, their principal underwriters and any Broker
to sell shares of the Underlying Funds to the Funds of Funds in excess
of the limits set forth in section 12(d)(1)(B) of the Act.
3. Applicants state that the proposed arrangement will not give
rise to the policy concerns underlying sections 12(d)(1)(A), (B), and
(C), which include concerns about undue influence by a fund of funds
over underlying funds, excessive layering of fees, and overly complex
fund structures. Accordingly, applicants believe that the requested
exemption is consistent with the public interest and the protection of
investors.
4. Applicants submit that the proposed structure will not result in
the exercise of undue influence by a Fund of Funds or its affiliated
persons over the Underlying Funds. Applicants assert that the concern
about undue influence does not arise in connection with a Fund of
Funds' investment in the Affiliated Funds because they are part of the
same group of investment companies. To limit the control a Fund of
Funds or Fund of Funds Affiliate \6\ may have over an Unaffiliated
Fund, applicants propose a condition prohibiting the Adviser and any
person controlling, controlled by or under common control with the
Adviser, and any investment company and any issuer that would be an
investment company but for section 3(c)(1) or section 3(c)(7) of the
Act advised or sponsored by the Adviser or any person controlling,
controlled by or under common control with the Adviser (collectively,
the ``Group'') from controlling (individually or in the aggregate) an
Unaffiliated Fund within the meaning of section 2(a)(9) of the Act. The
same prohibition would apply to any other investment adviser within the
meaning of section 2(a)(20)(B) of the Act to a Fund of Funds (``Sub-
Adviser'') and any person controlling, controlled by or under common
control with the Sub-Adviser, and any investment company or issuer that
would be an investment company but for section 3(c)(1) or 3(c)(7) of
the Act (or portion of such investment company or issuer) advised or
sponsored by the Sub-Adviser or any person controlling, controlled by
or under common control with the Sub-Adviser (collectively, the ``Sub-
Adviser Group'').
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\6\ A ``Fund of Funds Affiliate'' is the Adviser, any Sub-
Adviser, promoter or principal underwriter of a Fund of Funds, as
well as any person controlling, controlled by or under common
control with any of those entities. An ``Unaffiliated Fund
Affiliate'' is an investment adviser(s), sponsor, promoter or
principal underwriter of any Unaffiliated Fund or any person
controlling, controlled by or under common control with any of those
entities.
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5. With respect to closed-end Underlying Funds, applicants note
that although closed-end funds may not be unduly influenced by a
holder's right of redemption, closed-end Underlying Funds may be unduly
influenced by a holder's ability to vote a large block of stock. To
address this concern, applicants submit that, with respect to a Fund's
investment in an Unaffiliated Closed-End Investment Company, (i) each
member of the Group or Sub-Adviser Group that is an investment company
or an issuer that would be an investment company but for section
3(c)(1) or 3(c)(7) of the Act will vote its shares of the Unaffiliated
Closed-End Investment Company in the manner prescribed by section
12(d)(1)(E) of the Act and (ii) each other member of the Group or Sub-
Adviser Group will vote its shares of the Unaffiliated Closed-End
Investment Company in the same proportion as the vote of all other
holders of the same type of such Unaffiliated Closed-End Investment
Company's shares. Applicants state that, in this way, an Unaffiliated
Closed-End Investment Company will be protected from undue influence by
a Fund of Funds through the voting of the Unaffiliated Closed-End
Investment Company's shares.
6. Applicants propose other conditions to limit the potential for
undue influence over the Unaffiliated Funds, including that no Fund of
Funds or Fund of Funds Affiliate (except to the extent it is acting in
its capacity as an investment adviser to an Unaffiliated Investment
Company or sponsor to an Unaffiliated Trust) will cause an Unaffiliated
Fund to purchase a security in an offering of securities during the
existence of any underwriting or selling syndicate of which a principal
underwriter is an Underwriting Affiliate (``Affiliated
Underwriting'').\7\
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\7\ An ``Underwriting Affiliate'' is a principal underwriter in
any underwriting or selling syndicate that is an officer, director,
trustee, advisory board member, investment adviser, sub-adviser or
employee of the Fund of Funds, or a person of which any such
officer, director, trustee, investment adviser, sub-adviser, member
of an advisory board or employee is an affiliated person. An
Underwriting Affiliate does not include any person whose
relationship to an Unaffiliated Fund is covered by section 10(f) of
the Act.
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7. To further ensure that an Unaffiliated Investment Company
understands the implications of a Fund of Funds' investment under the
requested exemptive relief, prior to its investment in the shares of an
Unaffiliated Investment Company in excess of the limit of section
12(d)(1)(A)(i) of the Act, a Fund of Funds and the Unaffiliated
Investment Company will execute an agreement stating, without
limitation, that each of their boards of directors or trustees (each, a
``Board'') and their investment advisers understand the terms and
conditions of the order and agree to fulfill their responsibilities
under the order (the ``Participation Agreement''). Applicants note that
an Unaffiliated Investment Company (including an ETF or an Unaffiliated
Closed-End Investment Company) would also retain its right to reject
any initial investment by a Fund of Funds in excess of the limits in
section 12(d)(1)(A)(i) of the Act by declining to execute the
Participation Agreement with the Fund of Funds. In addition, an
Unaffiliated Investment Company (other than an ETF or Unaffiliated
Closed-End Investment Company whose shares are purchased by a Fund of
Funds in the secondary market) will retain its right at all times to
reject any investment by a Fund of Funds. Finally, solely upon notice
to a Fund of Funds, an Unaffiliated Investment Company could terminate
a Participation Agreement with the Fund of Funds effective at the end
of the notice period specified in the Participation Agreement.
8. Applicants state that they do not believe that the proposed
arrangement will result in excessive layering of fees. The Board of
each Fund of Funds, including a majority of the trustees who are not
``interested persons'' within the meaning of section 2(a)(19) of the
Act (the ``Independent Trustees''), will find that the management or
advisory fees charged under a Fund of Funds' advisory contract are
based on services provided that are in addition to, rather than
duplicative of, services provided under the advisory contract(s) of any
Underlying Fund in which the Fund of Funds may invest. In addition, the
Adviser will waive fees otherwise payable to it by a Fund of Funds in
an amount at least equal to any compensation (including fees received
pursuant to any plan adopted by an Unaffiliated Investment Company
under rule 12b-1 under the Act) received from an Unaffiliated Fund by
the Adviser, or an affiliated person of the Adviser, other than any
advisory fees paid to the Adviser or an affiliated person of the
[[Page 36370]]
Adviser by the Unaffiliated Investment Company, in connection with the
investment by the Fund of Funds in the Unaffiliated Fund.
9. Applicants further state that any sales charges and/or service
fees charged with respect to shares of a Fund of Funds will not exceed
the limits applicable to funds of funds set forth in in rule 2830 of
the Conduct Rules of the NASD (``NASD Conduct Rule 2830'').\8\
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\8\ Any references to NASD Conduct Rule 2830 include any
successor or replacement Financial Industry Regulatory Authority
rule to NASD Conduct Rule 2830.
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10. Applicants submit that the proposed arrangement will not create
an overly complex fund structure. Applicants note that no Underlying
Fund will acquire securities of any other investment company or company
relying on section 3(c)(1) or 3(c)(7) of the Act in excess of the
limits contained in section 12(d)(1)(A) of the Act, except in certain
circumstances identified in condition 12 below.
B. Section 17(a)
1. Section 17(a) of the Act generally prohibits sales or purchases
of securities between a registered investment company and any
affiliated person of the company. Section 2(a)(3) of the Act defines an
``affiliated person'' of another person to include (a) any person
directly or indirectly owning, controlling, or holding with power to
vote, 5% or more of the outstanding voting securities of the other
person; (b) any person 5% or more of whose outstanding voting
securities are directly or indirectly owned, controlled, or held with
power to vote by the other person; and (c) any person directly or
indirectly controlling, controlled by, or under common control with the
other person.
2. Applicants state that the Funds of Funds and the Affiliated
Funds may be deemed to be under the common control of the Adviser and,
therefore, affiliated persons of one another. Applicants also state
that the Funds of Funds and the Underlying Funds organized as open-end
management investment companies and UITs may also be deemed to be
affiliated persons of one another if a Fund of Funds owns 5% or more of
the outstanding voting securities of one or more of such Underlying
Funds. Applicants state that the sale of shares by Underlying Funds
organized as open-end management investment companies and UITs to the
Funds of Funds and the purchase of those shares from the Funds of Funds
by such Underlying Funds (through redemptions) could be deemed to
violate section 17(a).\9\
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\9\ Applicants acknowledge that receipt of any compensation by
(a) an affiliated person of a Fund of Funds, or an affiliated person
of such person, for the purchase by the Fund of Funds of shares of
an Underlying Fund or (b) an affiliated person of an Underlying
Fund, or an affiliated person of such person, for the sale by the
Underlying Fund of its shares to a Fund of Funds may be prohibited
by section 17(e) (1) of the Act. The Participation Agreement also
will include this acknowledgement.
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3. Section 17(b) of the Act authorizes the Commission to grant an
order permitting a transaction otherwise prohibited by section 17(a) if
it finds that (i) the terms of the proposed transaction are fair and
reasonable and do not involve overreaching on the part of any person
concerned; (ii) the proposed transaction is consistent with the
policies of each registered investment company concerned; and (iii) the
proposed transaction is consistent with the general purposes of the
Act. Section 6(c) of the Act permits the Commission to exempt any
person or transactions from any provision of the Act if such exemption
is necessary or appropriate in the public interest and consistent with
the protection of investors and the purposes fairly intended by the
policy and provisions of the Act.
4. Applicants submit that the proposed transactions satisfy the
standards for relief under sections 17(b) and 6(c) of the Act.
Applicants state that the terms of the transactions are reasonable and
fair and do not involve overreaching. Applicants state that the terms
upon which an Underlying Fund that is an open-end management investment
company will sell its shares to or purchase its shares from a Fund of
Funds will be in accordance with the rules and regulations under the
Act.\10\ Applicants also state that the proposed transactions will be
consistent with the policies of each Fund of Funds and Underlying Fund,
and with the general purposes of the Act.
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\10\ Applicants note that a Fund of Funds generally would
purchase and sell shares of an Underlying Fund that operates as an
ETF through secondary market transactions rather than through
principal transactions with the Underlying Fund. Applicants
nevertheless request relief from sections 17(a)(1) and (2) to permit
each Fund of Funds that is an affiliated person, or an affiliated
person of an affiliated person, as defined in section 2(a)(3) of the
Act, of an ETF to purchase or redeem shares from the ETF. Applicants
are not seeking relief from section 17(a) for, and the requested
relief will not apply to, transactions where an ETF could be deemed
an affiliated person, or an affiliated person of an affiliated
person, of a Fund of Funds because an investment adviser to the ETF
or an entity controlling, controlled by or under common control with
the investment adviser to the ETF is also an investment adviser to
the Fund of Funds. Applicants note that a Fund of Funds will
purchase and sell shares of an Underlying Fund that is a closed-end
fund through secondary market transactions at market prices rather
than through principal transactions with the closed-end fund.
Accordingly, applicants are not requesting section 17(a) relief with
respect to principal transactions with closed-end funds (including
business development companies).
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C. Other Investments by Section 12(d)(1)(G) Funds of Funds
1. Section 12(d)(1)(G) of the Act provides that section 12(d)(1)
will not apply to securities of an acquired company purchased by an
acquiring company if: (i) The acquiring company and acquired company
are part of the same ``group of investment companies,'' as defined in
section 12(d)(1)(G)(ii) of the Act; (ii) the acquiring company holds
only securities of acquired companies that are part of the same ``group
of investment companies,'' as defined in section 12(d)(1)(G)(ii) of the
Act, government securities, and short-term paper; (iii) the aggregate
sales loads and distribution-related fees of the acquiring company and
the acquired company are not excessive under rules adopted pursuant to
section 22(b) or section 22(c) of the Act by a securities association
registered under section 15A of the 1934 Act or by the Commission; and
(iv) the acquired company has a policy that prohibits it from acquiring
securities of registered open-end management investment companies or
registered UITs in reliance on section 12(d)(1)(F) or (G) of the Act.
2. Rule 12d1-2 under the Act permits a registered open-end
investment company or a registered UIT that relies on section
12(d)(1)(G) of the Act to acquire, in addition to securities issued by
another registered investment company in the same group of investment
companies, government securities, and short-term paper: (1) Securities
issued by an investment company that is not in the same group of
investment companies, when the acquisition is in reliance on section
12(d)(1)(A) or 12(d)(1)(F) of the Act; (2) securities (other than
securities issued by an investment company); and (3) securities issued
by a money market fund, when the investment is in reliance on rule
12d1-1 under the Act. For the purposes of rule 12d1-2, ``securities''
means any security as defined in section 2(a)(36) of the Act.
3. Applicants state that the proposed arrangement would comply with
rule 12d1-2 under the Act, but for the fact that the Section
12(d)(1)(G) Funds of Funds may invest a portion of their assets in
Other Investments. Applicants request an order under section 6(c) of
the Act for an exemption from rule 12d1-2(a) to allow the Section
12(d)(1)(G) Funds of Funds to invest in Other Investments. Applicants
assert that permitting a Section 12(d)(1)(G) Fund of Funds to invest in
Other Investments as described in the
[[Page 36371]]
application would not raise any of the concerns that section 12(d)(1)
of the Act was intended to address.
4. Consistent with its fiduciary obligations under the Act, a
Section 12(d)(1)(G) Fund of Funds' Board will review the advisory fees
charged by the Section 12(d)(1)(G) Fund of Funds' investment adviser(s)
to ensure that the fees are based on services provided that are in
addition to, rather than duplicative of, services provided pursuant to
the advisory agreement of any investment company in which the Section
12(d)(1)(G) Fund of Funds may invest.
Applicants' Conditions
A. Investments by Funds of Funds in Underlying Funds
Applicants agree that the order granting the requested relief to
permit Funds of Funds to invest in Underlying Funds shall be subject to
the following conditions:
1. The members of the Group will not control (individually or in
the aggregate) an Unaffiliated Fund within the meaning of section
2(a)(9) of the Act. The members of a Sub-Adviser Group will not control
(individually or in the aggregate) an Unaffiliated Fund within the
meaning of section 2(a)(9) of the Act. With respect to a Fund's
investment in an Unaffiliated Closed-End Investment Company, (i) each
member of the Group or Sub-Adviser Group that is an investment company
or an issuer that would be an investment company but for section
3(c)(1) or 3(c)(7) of the Act will vote its shares of the Unaffiliated
Closed-End Investment Company in the manner prescribed by section
12(d)(1)(E) of the Act and (ii) each other member of the Group or Sub-
Adviser Group will vote its shares of the Unaffiliated Closed-End
Investment Company in the same proportion as the vote of all other
holders of the same type of such Unaffiliated Closed-End Investment
Company's shares. If, as a result of a decrease in the outstanding
voting securities of any other Unaffiliated Fund, the Group or a Sub-
Adviser Group, each in the aggregate, becomes a holder of more than 25
percent of the outstanding voting securities of such Unaffiliated Fund,
then the Group or the Sub-Adviser Group will vote its shares of the
Unaffiliated Fund in the same proportion as the vote of all other
holders of the Unaffiliated Fund's shares. This condition will not
apply to a Sub-Adviser Group with respect to an Unaffiliated Fund for
which the Sub-Adviser or a person controlling, controlled by or under
common control with the Sub-Adviser acts as the investment adviser
within the meaning of section 2(a)(20)(A) of the Act (in the case of an
Unaffiliated Investment Company) or as the sponsor (in the case of an
Unaffiliated Trust).
2. No Fund of Funds or Fund of Funds Affiliate will cause any
existing or potential investment by the Fund of Funds in an
Unaffiliated Fund to influence the terms of any services or
transactions between the Fund of Funds or a Fund of Funds Affiliate and
the Unaffiliated Fund or an Unaffiliated Fund Affiliate.
3. The Board of each Fund of Funds, including a majority of the
Independent Trustees, will adopt procedures reasonably designed to
ensure that its Adviser and any Sub-Adviser to the Fund of Funds are
conducting the investment program of the Fund of Funds without taking
into account any consideration received by the Fund of Funds or Fund of
Funds Affiliate from an Unaffiliated Investment Company or Unaffiliated
Trust or any Unaffiliated Fund Affiliate of such Unaffiliated
Investment Company or Unaffiliated Trust in connection with any
services or transactions.
4. Once an investment by a Fund of Funds in the securities of an
Unaffiliated Investment Company exceeds the limit of section
12(d)(1)(A)(i) of the Act, the Board of the Unaffiliated Investment
Company, including a majority of the Independent Trustees, will
determine that any consideration paid by the Unaffiliated Investment
Company to a Fund of Funds or a Fund of Funds Affiliate in connection
with any services or transactions: (a) Is fair and reasonable in
relation to the nature and quality of the services and benefits
received by the Unaffiliated Investment Company; (b) is within the
range of consideration that the Unaffiliated Investment Company would
be required to pay to another unaffiliated entity in connection with
the same services or transactions; and (c) does not involve
overreaching on the part of any person concerned. This condition does
not apply with respect to any services or transactions between an
Unaffiliated Investment Company and its investment adviser(s), or any
person controlling, controlled by, or under common control with such
investment adviser(s).
5. No Fund of Funds or Fund of Funds Affiliate (except to the
extent it is acting in its capacity as an investment adviser to an
Unaffiliated Investment Company or sponsor to an Unaffiliated Trust)
will cause an Unaffiliated Fund to purchase a security in any
Affiliated Underwriting.
6. The Board of an Unaffiliated Investment Company, including a
majority of the Independent Trustees, will adopt procedures reasonably
designed to monitor any purchases of securities by the Unaffiliated
Investment Company in an Affiliated Underwriting once an investment by
a Fund of Funds in the securities of the Unaffiliated Investment
Company exceeds the limit of section 12(d)(1)(A)(i) of the Act,
including any purchases made directly from an Underwriting Affiliate.
The Board of the Unaffiliated Investment Company will review these
purchases periodically, but no less frequently than annually, to
determine whether the purchases were influenced by the investment by
the Fund of Funds in the Unaffiliated Investment Company. The Board of
the Unaffiliated Investment Company will consider, among other things:
(a) Whether the purchases were consistent with the investment
objectives and policies of the Unaffiliated Investment Company; (b) how
the performance of securities purchased in an Affiliated Underwriting
compares to the performance of comparable securities purchased during a
comparable period of time in underwritings other than Affiliated
Underwritings or to a benchmark such as a comparable market index; and
(c) whether the amount of securities purchased by the Unaffiliated
Investment Company in Affiliated Underwritings and the amount purchased
directly from an Underwriting Affiliate have changed significantly from
prior years. The Board of the Unaffiliated Investment Company will take
any appropriate actions based on its review, including, if appropriate,
the institution of procedures designed to ensure that purchases of
securities in Affiliated Underwritings are in the best interests of
shareholders.
7. Each Unaffiliated Investment Company will maintain and preserve
permanently, in an easily accessible place, a written copy of the
procedures described in the preceding condition, and any modifications
to such procedures, and will maintain and preserve for a period of not
less than six years from the end of the fiscal year in which any
purchase in an Affiliated Underwriting occurred, the first two years in
an easily accessible place, a written record of each purchase of
securities in an Affiliated Underwriting once an investment by a Fund
of Funds in the securities of an Unaffiliated Investment Company
exceeds the limit of section 12(d)(1)(A)(i) of the Act, setting forth
(1) the party from whom
[[Page 36372]]
the securities were acquired, (2) the identity of the underwriting
syndicate's members, (3) the terms of the purchase, and (4) the
information or materials upon which the determinations of the Board of
the Unaffiliated Investment Company were made.
8. Prior to its investment in shares of an Unaffiliated Investment
Company in excess of the limit set forth in section 12(d)(1)(A)(i) of
the Act, the Fund of Funds and the Unaffiliated Investment Company will
execute a Participation Agreement stating, without limitation, that
their Boards and their investment advisers understand the terms and
conditions of the order and agree to fulfill their responsibilities
under the order. At the time of its investment in shares of an
Unaffiliated Investment Company in excess of the limit set forth in
section 12(d)(1)(A)(i), a Fund of Funds will notify the Unaffiliated
Investment Company of the investment. At such time, the Fund of Funds
will also transmit to the Unaffiliated Investment Company a list of the
names of each Fund of Funds Affiliate and Underwriting Affiliate. The
Fund of Funds will notify the Unaffiliated Investment Company of any
changes to the list as soon as reasonably practicable after a change
occurs. The Unaffiliated Investment Company and the Fund of Funds will
maintain and preserve a copy of the order, the Participation Agreement,
and the list with any updated information for the duration of the
investment and for a period of not less than six years thereafter, the
first two years in an easily accessible place.
9. Before approving any advisory contract under section 15 of the
Act, the Board of each Fund of Funds, including a majority of the
Independent Trustees, shall find that the advisory fees charged under
the advisory contract are based on services provided that are in
addition to, rather than duplicative of, services provided under the
advisory contract(s) of any Underlying Fund in which the Fund of Funds
may invest. Such finding, and the basis upon which the finding was
made, will be recorded fully in the minute books of the appropriate
Fund of Funds.
10. The Adviser will waive fees otherwise payable to it by a Fund
of Funds in an amount at least equal to any compensation (including
fees received pursuant to any plan adopted by an Unaffiliated
Investment Company pursuant to rule 12b-1 under the Act) received from
an Unaffiliated Fund by the Adviser, or an affiliated person of the
Adviser, other than any advisory fees paid to the Adviser or its
affiliated person by the Unaffiliated Investment Company, in connection
with the investment by the Fund of Funds in the Unaffiliated Fund. Any
Sub-Adviser will waive fees otherwise payable to the Sub-Adviser,
directly or indirectly, by the Fund of Funds in an amount at least
equal to any compensation received by the Sub-Adviser, or an affiliated
person of the Sub-Adviser, from an Unaffiliated Fund, other than any
advisory fees paid to the Sub-Adviser or its affiliated person by the
Unaffiliated Investment Company, in connection with the investment by
the Fund of Funds in the Unaffiliated Fund made at the direction of the
Sub-Adviser. In the event that the Sub-Adviser waives fees, the benefit
of the waiver will be passed through to the Fund of Funds.
11. Any sales charges and/or service fees charged with respect to
shares of a Fund of Funds will not exceed the limits applicable to
funds of funds set forth in NASD Conduct Rule 2830.
12. No Underlying Fund will acquire securities of any other
investment company or company relying on section 3(c)(1) or 3(c)(7) of
the Act, in excess of the limits contained in section 12(d)(1)(A) of
the Act, except to the extent that such Underlying Fund: (a) Acquires
such securities in compliance with section 12(d)(1)(E) of the Act and
either is an Affiliated Fund or is in the same ``group of investment
companies'' as its corresponding master fund; (b) receives securities
of another investment company as a dividend or as a result of a plan of
reorganization of a company (other than a plan devised for the purpose
of evading section 12(d)(1) of the Act); or (c) acquires (or is deemed
to have acquired) securities of another investment company pursuant to
exemptive relief from the Commission permitting such Underlying Fund
to: (i) Acquire securities of one or more investment companies for
short-term cash management purposes or (ii) engage in inter-fund
borrowing and lending transactions.
B. Other Investments by Section 12(d)(1)(G) Funds of Funds
Applicants agree that the order granting the requested relief to
permit Section 12(d)(1)(G) Funds of Funds to invest in Other
Investments shall be subject to the following condition:
1. Applicants will comply with all provisions of rule 12d1-2 under
the Act, except for paragraph (a)(2) to the extent that it restricts
any Section 12(d)(1)(G) Fund of Funds from investing in Other
Investments as described in the application.
For the Commission, by the Division of Investment Management,
pursuant to delegated authority.
Brent J. Fields,
Secretary.
[FR Doc. 2015-15450 Filed 6-23-15; 8:45 am]
BILLING CODE 8011-01-P