Nuveen Fund Advisors, LLC, et al.; Notice of Application, 76338-76343 [2015-30867]
Download as PDF
76338
Federal Register / Vol. 80, No. 235 / Tuesday, December 8, 2015 / Notices
rules and applicable federal securities
laws.25
(4) Prior to the commencement of
trading, the Exchange will inform its
members in an Information Circular of
the special characteristics and risks
associated with trading the Shares.
Specifically, the Information Circular
will discuss the following: (a) The
procedures for purchases and
redemptions of Shares in Creation Units
(and that Shares are not individually
redeemable); (b) Nasdaq Rule 2111A,
which imposes suitability obligations on
Nasdaq members with respect to
recommending transactions in the
Shares to customers; (c) how and by
whom information regarding the
Intraday Indicative Value and the
Disclosed Portfolio is disseminated; (d)
the risks involved in trading the Shares
during the Pre-Market and Post-Market
Sessions when an updated Intraday
Indicative Value will not be calculated
or publicly disseminated; (e) the
requirement that members deliver a
prospectus to investors purchasing
newly issued Shares prior to or
concurrently with the confirmation of a
transaction; and (f) trading
information.26
(5) For initial and/or continued
listing, the Fund must be in compliance
with Rule 10A–3under the Act.27
(6) The Fund will limit its Equities
investments to companies with a market
capitalization of $250 million or more.28
(7) All Equities and any shares of
ETFs or closed-end investment
companies held by the Fund will be
listed on a U.S. exchange that is a
member of the ISG or a party to a
comprehensive surveillance sharing
agreement with the Exchange.29
(8) The Fund will not invest in
leveraged ETFs.30
(9) The Fund will not invest in futures
contracts, will not invest in options,
will not invest in swaps, and will not
invest in other derivative instruments.31
(10) A minimum of 100,000 Shares
will be outstanding at the
commencement of trading on the
Exchange.32
This approval order is based on all of
the Exchange’s representations,
including those set forth above and in
the Notice.
For the foregoing reasons, the
Commission finds that the proposed
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25 See
id.
id. at 66598–66599.
27 See 17 CFR 240.10A–3. See also Notice, supra
note 3, 80 FR at 66598.
28 See id. at 66595.
29 See id. at 66598.
30 See id. at 66595.
31 See id. at 66596.
32 See id. at 66598.
26 See
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rule change is consistent with Section
6(b)(5) of the Act 33 and the rules and
regulations thereunder applicable to a
national securities exchange.
IV. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Exchange Act,
that the proposed rule change (SR–
NASDAQ–2015–124) be, and it hereby
is, approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.34
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2015–30835 Filed 12–7–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
31924; File No. 812–14258]
Nuveen Fund Advisors, LLC, et al.;
Notice of Application
December 2, 2015.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order pursuant to sections 6(c) and 17(b)
of the Investment Company Act of 1940
(the ‘‘Act’’) for an exemption from
section 17(a) of the Act permitting
certain transactions.
AGENCY:
SUMMARY OF THE APPLICATION:
Applicants request an order (the
‘‘Order’’) that would permit certain
registered management investment
companies to engage in certain primary
and secondary market transactions in
fixed income instruments on a principal
basis (the ‘‘Transactions’’) with a USB
Trading Entity (defined below).
APPLICANTS: Nuveen Fund Advisors,
LLC (the ‘‘Adviser’’), Nuveen
Investments, Inc. (‘‘Nuveen’’), Nuveen
All Cap Energy MLP Opportunities
Fund, Nuveen AMT-Free Municipal
Income Fund, Nuveen AMT-Free
Municipal Value Fund, Nuveen Arizona
Premium Income Municipal Fund,
Nuveen Build America Bond Fund,
Nuveen Build America Bond
Opportunity Fund, Nuveen California
AMT-Free Municipal Income Fund,
Nuveen California Dividend Advantage
Municipal Fund, Nuveen California
Dividend Advantage Municipal Fund 2,
Nuveen California Dividend Advantage
Municipal Fund 3, Nuveen California
Municipal Value Fund 2, Nuveen
33 15
34 17
PO 00000
U.S.C. 78f(b)(5).
CFR 200.30–3(a)(12).
Frm 00079
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California Municipal Value Fund, Inc.,
Nuveen California Select Tax-Free
Income Portfolio, Nuveen Connecticut
Premium Income Municipal Fund,
Nuveen Core Equity Alpha Fund,
Nuveen Credit Strategies Income Fund,
Nuveen Diversified Dividend and
Income Fund, Nuveen Dividend
Advantage Municipal Fund, Nuveen
Dividend Advantage Municipal Fund 2,
Nuveen Dividend Advantage Municipal
Fund 3, Nuveen Dividend Advantage
Municipal Income Fund, Nuveen Dow
30SM Dynamic Overwrite Fund, Nuveen
Energy MLP Total Return Fund, Nuveen
Enhanced Municipal Value Fund,
Nuveen Flexible Investment Income
Fund, Nuveen Floating Rate Income
Fund, Nuveen Floating Rate Income
Opportunity Fund, Nuveen Georgia
Dividend Advantage Municipal Fund 2,
Nuveen Global High Income Fund,
Nuveen Global Equity Income Fund,
Nuveen High Income 2020 Target Term
Fund, Nuveen High Income December
2018 Target Term Fund, Nuveen High
Income December 2020 Target Term
Fund, Nuveen High Income December
2022 Target Term Fund, Nuveen
Intermediate Duration Municipal Term
Fund, Nuveen Intermediate Duration
Quality Municipal Term Fund, Nuveen
Investment Funds, Inc., Nuveen
Investment Quality Municipal Fund,
Inc., Nuveen Investment Trust, Nuveen
Investment Trust II, Nuveen Investment
Trust III, Nuveen Investment Trust V,
Nuveen Managed Accounts Portfolios
Trust, Nuveen Maryland Premium
Income Municipal Fund, Nuveen
Massachusetts Premium Income
Municipal Fund, Nuveen Michigan
Quality Income Municipal Fund,
Nuveen Minnesota Municipal Income
Fund, Nuveen Missouri Premium
Income Municipal Fund, Nuveen
Mortgage Opportunity Term Fund 2,
Nuveen Mortgage Opportunity Term
Fund, Nuveen Multi-Market Income
Fund, Nuveen Multistate Trust I,
Nuveen Multistate Trust II, Nuveen
Multistate Trust III, Nuveen Multistate
Trust IV, Nuveen Municipal Advantage
Fund, Inc., Nuveen Municipal High
Income Opportunity Fund, Nuveen
Municipal Income Fund, Inc., Nuveen
Municipal Market Opportunity Fund,
Inc., Nuveen Municipal Opportunity
Fund, Inc., Nuveen Municipal Trust,
Nuveen Municipal Value Fund, Inc.,
Nuveen Nasdaq 100 Dynamic Overwrite
Fund, Nuveen New Jersey Dividend
Advantage Municipal Fund, Nuveen
New Jersey Municipal Value Fund,
Nuveen New York AMT-Free Municipal
Income Fund, Nuveen New York
Dividend Advantage Municipal Fund,
Nuveen New York Municipal Value
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Fund 2, Nuveen New York Municipal
Value Fund, Inc., Nuveen New York
Select Tax-Free Income Portfolio,
Nuveen North Carolina Premium
Income Municipal Fund, Nuveen Ohio
Quality Income Municipal Fund,
Nuveen Pennsylvania Investment
Quality Municipal Fund, Nuveen
Pennsylvania Municipal Value Fund,
Nuveen Performance Plus Municipal
Fund, Inc., Nuveen Preferred and
Income Term Fund, Nuveen Preferred
Income Opportunities Fund, Nuveen
Premier Municipal Income Fund, Inc.,
Nuveen Premium Income Municipal
Fund 2, Inc., Nuveen Premium Income
Municipal Fund 4, Inc., Nuveen
Premium Income Municipal Fund, Inc.,
Nuveen Quality Income Municipal
Fund, Inc., Nuveen Quality Municipal
2018 Term Fund, Nuveen Quality
Municipal Fund, Inc., Nuveen Quality
Preferred Income Fund, Nuveen Quality
Preferred Income Fund 2, Nuveen
Quality Preferred Income Fund 3,
Nuveen Real Asset Income and Growth
Fund, Nuveen Real Estate Income Fund,
Nuveen S&P 500 Buy-Write Income
Fund, Nuveen S&P 500 Dynamic
Overwrite Fund, Nuveen Select
Maturities Municipal Fund, Nuveen
Select Quality Municipal Fund, Inc.,
Nuveen Select Tax-Free Income
Portfolio, Nuveen Select Tax-Free
Income Portfolio 2, Nuveen Select TaxFree Income Portfolio 3, Nuveen Senior
Income Fund, Nuveen Short Duration
Credit Opportunities Fund, Nuveen
Strategy Funds, Inc., Nuveen TaxAdvantaged Dividend Growth Fund,
Nuveen Tax-Advantaged Total Return
Strategy Fund, Nuveen Texas Quality
Income Municipal Fund, Nuveen
Virginia Premium Income Municipal
Fund, Diversified Real Asset Income
Fund (each a ‘‘Fund’’, collectively, the
‘‘Funds’’), U.S. Bancorp (‘‘USB’’), U.S.
Bank National Association (‘‘USBNA’’)
and U.S. Bancorp Investments, Inc.
(‘‘USBI’’).
FILING DATES: The application was filed
on December 27, 2013, and amended on
July 1, 2014, December 8, 2014, May 22,
2015, and October 22, 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 December 28, 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
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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, c/o Richard T. Prins, Esq.
Skadden, Arps, Slate, Meagher & Flom
LLP, Four Times Square, New York, NY
10036.
FOR FURTHER INFORMATION CONTACT:
Laura L. Solomon, Senior Counsel, at
(202) 551–6915, or Daniele Marchesani,
Branch Chief, at (202) 551–6821 (Chief
Counsel’s Office, Division of Investment
Management).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Applicants’ Representations
1. Each Fund is an open-end or
closed-end management investment
company registered under the Act and
is organized as a business trust or
corporation under the laws of
Massachusetts, Maryland or Minnesota,
or is a series thereof. The Funds have a
variety of investment objectives, but
each may invest a portion of its assets
in fixed-income instruments. ‘‘Fixedincome instruments’’ for purposes of the
Order means fixed-income securities
and interests in syndicated loans,
convertible bonds and convertible
preferred stock, as well as money
market instruments, such as treasury
instruments, commercial paper and
certificates of deposit.
2. The Adviser, a Delaware limited
liability company, is a direct wholly
owned subsidiary of Nuveen, a
Delaware corporation. The Adviser is
registered as an investment adviser
under the Investment Advisers Act of
1940 (the ‘‘Advisers Act’’). The Adviser
acts as investment adviser to the Funds
and has oversight over one or more subadvisers engaged by the Funds.1
1 Each Fund has (or may, in the future, have) one
or more affiliated or unaffiliated sub-advisers that
provide sub-advisory services (each, a ‘‘SubAdviser,’’ collectively, the ‘‘Sub-Advisers’’).
Applicants request the Order cover any such SubAdvisers, provided that any Sub-Adviser that relies
on the Order complies with the conditions of the
Order as though it were an Adviser.
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76339
3. USBNA is a national banking
association and a wholly owned
subsidiary of USB. USBNA Dealer
Division, an internal division of
USBNA, engages in bank permitted
dealer activities and is exempt from
registering as a broker-dealer pursuant
to the Securities Exchange Act of 1934
(‘‘1934 Act’’). USBI, a Delaware
corporation, is also a wholly owned
subsidiary of USB that is registered as
a broker-dealer with the Commission
under the 1934 Act. Each of USBI,
USBNA, USBNA Dealer Division, as
well as other affiliates of USB that are
controlled (within the meaning of
section 2(a)(9) of the Act) by USB and
are registered as broker-dealers or
exempt from registration as such (each,
a ‘‘USB Trading Entity,’’ and,
collectively, the ‘‘USB Trading
Entities’’), may seek to engage in
Transactions with the Funds.2
4. On December 31, 2010, Nuveen
completed its acquisition of a portion of
the asset management business of FAF
Advisors, Inc. (‘‘FAF Advisors’’), a
wholly owned subsidiary of USBNA
(the ‘‘FAF Acquisition’’). The open-end
funds previously advised by FAF
Advisors entered into investment
advisory agreements with the Adviser.
The Adviser continued to serve as
investment adviser to the open-end
funds and closed-end funds that it
advised prior to the FAF Acquisition.
5. Certain fiduciary account
investments maintained by USB
Fiduciary in certain of the Funds remain
after the FAF acquisition. USB
Fiduciary has discretionary authority
over, but no pecuniary interest in, such
investments. Because of these
investments, there may be affiliations
between the USB Trading Entities and
the Funds.
6. Applicants state that, because of
consolidation in the financial services
industry, a few major broker-dealers
account for a large percentage of the
market share in trading in fixed income
instruments. Applicants state that the
decline in the number of broker-dealers
and banks trading in the fixed-income
instruments in which the Funds seek to
invest and the increasing significance of
the few remaining institutions
demonstrate the importance to the
Funds of their relationships with such
entities, including the USB Trading
2 No director, officer or employee of the Funds or
the Adviser is or will be a director, officer or
employee of a USB Trading Entity. The board of
directors or board of trustees or other governing
body, as applicable (‘‘Board’’) of each Fund
currently has eleven members, of which nine
members are currently not interested persons of the
Fund and the chair of the Board of each Fund is
currently not an interested person, as defined in
section 2(a)(19) of the Act, of the Fund.
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Entities. For example, Applicants
further state that in the first half of 2015,
the USB Trading Entities were ranked
15th as a domestic book running lead
manager of U.S. investment grade
corporate bonds by volume, and ranked
6th as a lead and co-manager by number
of transactions. Applicants represent
that the USB Trading Entities’
underwriting market share was 37%
calculated as a percentage of the total
number of U.S. investment grade
corporate bond transactions in the
marketplace. On the municipal
securities side of the business, the USB
Trading Entities were ranked 66th in
fixed rate lead managed business, and
9th in variable rate demand note
underwriting in 2014. Applicants
further represent that as a variable rate
demand note underwriter the USB
Trading Entities achieved a 3% market
share in 2014. Applicants state the USB
Trading Entities ranked 5th in the
Overall Bookrunner League Tables by
number of deals with a 3% market
share, 3rd in the Domestic League
Tables and 5th in the Global League
Tables for private placements in 2014.
Applicants assert that these statistics
demonstrate the growth in demand for
its services and USB expects continued
growth on an ongoing basis in capital
markets transaction volumes for the
USB Trading Entities.
7. Applicants assert that prohibiting
the Funds from engaging in the
Transactions with the USB Trading
Entities would become increasingly
detrimental to the ongoing interests of
Fund shareholders by limiting the
Funds’ access to important trading
counterparties that have growing market
share in many of the types of
instruments that the Funds purchase.
Applicants submit that prohibiting the
Funds from engaging in Transactions
with the USB Trading Entities
unnecessarily reduces the opportunities
available to the Funds to obtain
competitive pricing and execution and
to access the markets for particular
fixed-income instruments that are
available from only a few dealers.
Applicants assert that precluding a
Fund from trading with a USB Trading
Entity may harm the Fund by, among
other things, preventing it from
obtaining the best pricing, terms and
quality of services otherwise available
in the market.
8. Applicants, therefore, request the
Order, pursuant to sections 6(c) and
17(b) of the Act exempting from section
17(a) of the Act 3 Transactions entered
3 Applicants are not seeking relief from the
provisions of sections 10(f), 17(d) or 17(e) of the Act
or rules 17d–1 or 17e–1 thereunder.
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into in the ordinary course of business
by a Fund with USB Trading Entities,
under the terms and conditions set forth
in the application.
9. The requested relief would include
(i) the Funds and any investment
company registered under the Act or
series thereof, whether now existing or
organized in the future, that is advised
by the Adviser or by any existing or
future entity that is controlling,
controlled by or under common control
with the Adviser or Nuveen and
registered as an investment adviser
under the Advisers Act; (ii) the Adviser;
and (iii) the USB Trading Entities; 4
provided that any entity that relies on
the Order complies with the terms and
conditions of the Order as though it
were an applicant.
10. The Order would be available only
in circumstances in which the USB
Trading Entity might be deemed to be (i)
an affiliated person (‘‘first-tier
affiliate’’), or an affiliated person of a
first-tier affiliate (a ‘‘second-tier
affiliate’’) of a Fund solely by reason of
a USB Fiduciary,5 being deemed to own,
control or hold with power to vote
through non-proprietary, trust or other
fiduciary account investments five
percent or more of the Fund’s total
outstanding voting securities (each, a
‘‘5% Fund’’); (ii) a first-tier affiliate of a
Fund solely by reason of USB Fiduciary
being deemed to beneficially own
through the fiduciary account
investments more than twenty-five
percent of the Fund’s total outstanding
voting securities or, by virtue of such
fiduciary account investments, to
control the Fund (each, a ‘‘25% Fund,’’
together with the 5% Funds, the
‘‘Owned Funds’’); and/or (iii) a secondtier affiliate of any Fund other than an
Owned Fund (each, an ‘‘Other Fund’’)
solely by reason of USB Fiduciary being
considered to own, control or hold with
power to vote a 5% Fund’s securities as
described in (i) or being deemed to
beneficially own a 25% Fund’s
4 All existing entities that currently intend to rely
on the requested relief are either named as
applicants or listed in Schedule A to the
application. Any other entity that relies on the
Order now or in the future will comply with the
terms and conditions set forth in the application.
5 USB Fiduciary includes USBNA, its trust bank
subsidiaries, U.S. Bank Trust National Association
and U.S. Bank Trust National Association SD, and
any successors. The term ‘‘successor’’ is limited to
the entity that results from a reorganization into
another jurisdiction, a change in the type of
business organization or a combination,
consolidation or reorganization of any of the
entities referred to in the previous sentence,
including any such combination, consolidation or
reorganization effected through the use of a ‘‘shell’’
entity controlled by any of the foregoing entities,
provided that such combination, consolidation or
reorganization does not result in a change of direct
or indirect control of such entities.
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securities as described in (ii), through
fiduciary account investments.6
11. The requested relief would not
extend to primary market Transactions
in fixed-income instruments, other than
repurchase agreements and variable rate
demand notes, of which USB or any
entity controlled by USB, including any
USB Trading Entity, is the primary
obligor.
12. Neither USB nor any USB
Affiliates control or will control (within
the meaning of section 2(a)(9) of the
Act), directly or indirectly, Nuveen or
the Adviser or any other non-Fund
entity under the control of Nuveen
(together, the ‘‘Nuveen Affiliates’’), and
neither USB nor any USB Affiliates will
exercise, or attempt to exercise, control
over any Fund. Applicants state that
only the fiduciary account investments
in the Owned Funds raise the affiliation
issues addressed by the requested relief.
Additionally, Nuveen has no beneficial
interest in, and will not control (within
the meaning of section 2(a)(9) of the
Act) directly or indirectly, USB, the
USB Trading Entities or any other USB
Affiliate.
13. Applicants state that the USB
Affiliates will not have any involvement
in the Advisers’ investment decisions or
decisions to engage in Transactions
pursuant to the Order, and will not
attempt to influence or control in any
way the placing by the Adviser of
orders, other than in the normal course
of sales activities of the same nature that
are being carried out during the same
time period with respect to unaffiliated
institutional clients of the USB Trading
Entity, or that existed between the USB
Trading Entity and FAF Advisors, if
any, prior to the consummation of the
FAF Acquisition.
14. Applicants assert that there is
substantial internal separation and
independent operation of the division of
USBNA that maintains fiduciary
accounts (‘‘USBNA Fiduciary Division’’)
and USBNA Dealer Division. USBNA
Fiduciary Division is subject to strict
fiduciary laws and regulations that
require USBNA Fiduciary Division to
act solely in the interests of the
principals or beneficiaries of the
accounts. Applicants represent that
6 Applicants note that there may be some
instances in which USB or an entity, including a
division thereof, controlled by USB (each, a ‘‘USB
Affiliate,’’ collectively, the ‘‘USB Affiliates’’) might
be deemed to own, control or hold with power to
vote less than five percent of the outstanding voting
securities of a Fund otherwise than through
fiduciary account investments (a ‘‘<5% holding’’).
References to potential affiliations arising ‘‘solely
by reason of’’ fiduciary account investments above
certain levels may include situations where
fiduciary account investments exceed such levels
only when added to a <5% holding.
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there is not, and will not be, any express
or implied understanding between a
USB Trading Entity and Nuveen or the
Adviser that the Adviser will cause a
Fund to enter into Transactions or give
preference to the USB Trading Entity in
effecting such Transactions between the
Fund and the USB Trading Entity.
15. USB Fiduciary undertakes to not
to exercise any voting power with
respect to shares that constitute five
percent or more of a Fund’s total
outstanding voting securities, including
in connection with the election of
directors/trustees (the ‘‘Non-Voting
Undertaking’’).
Applicants’ Legal Analysis
1. Section 17(a) of the Act, in relevant
part, prohibits an affiliated person of a
registered investment company, or any
affiliated person of such person, acting
as principal, from selling to or
purchasing from such company any
security or other property and from
borrowing money or other property from
such company. Section 17(b) of the Act
authorizes the Commission to exempt a
transaction from section 17(a) of the Act
if evidence establishes that the terms of
the proposed transaction, including the
consideration to be paid or received, are
reasonable and fair and do not involve
overreaching on the part of any person
concerned and the proposed transaction
is consistent with the policy of each
registered investment company
concerned and with the general
purposes of the Act.
2. Section 6(c) of the Act, in relevant
part, authorizes the Commission to
exempt any person or transaction, or
any class or classes of persons or
transactions, from any provision or
provisions of the Act, if and to the
extent that 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.
3. Section 2(a)(3) of the Act, in
relevant part, defines ‘‘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 such other person;
(b) any person 5% or more of whose
outstanding voting securities are
directly or indirectly owned by,
controlled, or held with power to vote,
by such person; and (c) any person
directly or indirectly controlling,
controlled by, or under common control
with, such other person.
4. Section 2(a)(9) of the Act, in
relevant part, defines ‘‘control’’ as ‘‘the
power to exercise a controlling
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influence over the management or
policies of a company, unless such
power is solely the result of an official
position with such company.’’ Section
2(a)(9) also provides that any person
who owns beneficially, either directly or
through one or more controlled
companies, more than 25% of the voting
securities of a company shall be
presumed to control such company, and
that any person who does not so own
more than 25% of the voting securities
of any company shall be presumed not
to control such company.
5. Applicants state that a USB Trading
Entity could be deemed to be a first-tier
affiliate or a second-tier affiliate of a 5%
Fund insofar as fiduciary account
investments of five percent or more of
an Owned Fund’s outstanding voting
securities could cause USB Fiduciary to
be viewed as owning, controlling or
holding with power to vote ‘‘voting
securities.’’ Were a USB Fiduciary
deemed to be a first-tier affiliate of a 5%
Fund, the USB Trading Entities (except
for USBNA Dealer Division) would then
be deemed to be second-tier affiliates of
the 5% Fund. USBNA Dealer Division,
on the other hand, could be deemed to
be a first-tier affiliate of the 5% Fund.
Additionally, a USB Trading Entity
could be deemed a first-tier affiliate of
a 25% Fund and a second-tier affiliate
of the Other Funds.7 Applicants submit
that, due to the fiduciary account
investments, any Transaction involving
a Fund and a USB Trading Entity that
is a first-tier affiliate or a second-tier
affiliate thereof, would be subject to the
prohibition of section 17(a) of the Act.
6. Applicants submit that the primary
purpose of section 17(a) is to prevent a
person with the power to control or
influence a registered investment
company from engaging in self-dealing
or overreaching, to the detriment of the
investment company’s shareholders.
Applicants submit that the policies
which section 17(a) of the Act was
meant to further are not implicated in
7 As discussed in the application, this conclusion
could be reached if, on account of the fiduciary
account investments, USB Fiduciary ‘‘beneficially
owned’’ greater than twenty-five percent of the 25%
Fund’s total outstanding voting securities. The
Owned Fund could then be presumed to be under
the control of USB Fiduciary, and thus of USB. As
wholly owned subsidiaries of USB, the USB
Trading Entities may also be presumed to be under
the control of USB. Accordingly, the 25% Fund and
the USB Trading Entities could be presumed to be
under the common control of USB and thus firsttier affiliates of each other. If the 25% Fund and the
Other Funds are deemed to be under the control of
their Adviser(s), then the 25% Fund and the Other
Funds could be deemed to be first-tier affiliates of
each other by virtue of being under common
control. Therefore, if the USB Trading Entities are
deemed to be first-tier affiliates of the 25% Fund,
they could be deemed to be second-tier affiliates of
the Other Funds.
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76341
the context of the requested Order
because USB and USB Trading Entities
are not able to cause a Fund to enter
into a Transaction or otherwise
influence portfolio decisions by the
Adviser on behalf of the Funds.
Applicants state that, as a result, no
USB Trading Entity is in a position to
cause a Fund to enter into Transactions
that are not in the best interests of the
Fund and its shareholders. Applicants
also state that there will be no conflict
of interest associated with the Adviser’s
decision to engage in a Transaction with
a USB Trading Entity on behalf of a
Fund. Applicants further submit that
the conditions to the requested Order
provide further protections against any
possibility of self-dealing or
overreaching by the USB Trading
Entities. Therefore, Applicants submit
that the Order satisfies the statutory
standards for relief.
Applicants’ Conditions
Applicants agree that the Order
granting the requested relief will be
subject to the following conditions:
A. Structural
(1) Neither USB nor any USB
Affiliates will control any Adviser or
any principal underwriters or promoters
for the Funds, directly or indirectly,
within the meaning of section 2(a)(9) of
the Act, and neither USB nor any USB
Affiliates will exercise, or attempt to
exercise, control over any Fund. The
Order will remain in effect only so long
as Nuveen, or another entity not
controlling, controlled by or under
common control with USB, primarily
controls the Adviser. In this regard,
pursuant to the Non-Voting
Undertaking, USB Fiduciary will not
exercise any voting authority that it
possesses with respect to shares that
constitute five percent or more of any
Fund’s total outstanding voting
securities. Instead, it will delegate to an
independent third party that is not
affiliated with either USB or any USB
Affiliate the voting of such shares.
(2) Neither USB nor any USB
Affiliates will directly or indirectly
consult with Nuveen or any Nuveen
Affiliate, including the Adviser, or any
portfolio manager of the Adviser
concerning purchase or sale
Transactions, or the selection of a broker
or dealer for any Transactions placed or
to be placed on behalf of a Fund, or
otherwise seek to influence the choice
of broker or dealer for any Transaction
by a Fund, other than in the normal
course of sales activities of the same
nature that are being carried out during
the same time period with respect to
unaffiliated institutional clients of the
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Lhorne on DSK9F6TC42PROD with NOTICES
USB Trading Entity, or that existed
between the USB Trading Entity and the
Adviser and the Nuveen Sub-Advisers,
if any, prior to the consummation of the
FAF Acquisition.
(3) No officer, director or employee of
an Owned Fund will directly or
indirectly seek to influence in any way
the terms of any Transaction covered by
the Order, other than in the normal
course of investment activities of the
same nature that are being carried out
during the same time period with
respect to unaffiliated broker-dealers, or
that existed between the USB Trading
Entity and the Adviser and the Nuveen
Sub-Advisers, if any, prior to the
consummation of the FAF Acquisition.
(4) Each USB Trading Entity will
adopt and implement policies that
prohibit the USB Trading Entity from (a)
linking any approval or action relating
to an Owned Fund to any action by any
Fund or by the Adviser relating to any
Fund, or (b) using the fiduciary account
investments in an Owned Fund as a
basis for seeking to persuade any Fund
or the Adviser to engage in business
with the USB Trading Entity.
(5) The Adviser and the USB Trading
Entities, with the assistance of their
respective legal/compliance
departments, will prepare guidelines for
their respective personnel to make
certain that Transactions effected
pursuant to the Order comply with its
terms and conditions, and that the
Adviser and the USB Trading Entities
maintain an arm’s-length relationship.
The respective legal/compliance
departments of the Adviser and the USB
Trading Entities will monitor
periodically the activities of the Adviser
and the USB Trading Entities,
respectively, to make certain that the
terms and conditions of the Order are
met.
B. Transactional
With respect to each Transaction
entered into or effected pursuant to the
Order on behalf of a Fund:
(1) Each Fund’s Board, including a
majority of its disinterested directors or
trustees, as applicable (‘‘Necessary
Majority’’), will approve, and the Fund
will implement, procedures governing
all Transactions pursuant to the Order
and the Fund’s Board will no less
frequently than quarterly review all
Transactions conducted pursuant to the
Order and receive and review a report
(the ‘‘Report’’), of those Transactions.
The Report which will be prepared by
the Adviser and reviewed and approved
by the Fund’s Chief Compliance Officer,
will indicate for each Transaction that
the terms and conditions of the Order
have been satisfied, and will include a
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14:17 Dec 07, 2015
Jkt 238001
discussion of any significant changes in
the volume, type or terms of
Transactions between the relevant
Funds and the USB Trading Entity, the
reasons for these changes, and a
determination that such changes are
appropriate. In addition, annually and
prior to entering into a Transaction with
a USB Trading Entity that no Fund has
previously traded with, the Board will
consider (i) whether the level of
Transactions with USB Trading Entities
is appropriate and (ii) whether
continued reliance on the Order in any
applicable category of fixed-income
instruments is appropriate in light of the
need of the Funds to have the USB
Trading Entities available as trading
counterparties, as evidenced by, among
other things, the aggregate market share
of the USB Trading Entities in each such
category.
(2) For each Transaction, the Adviser
will adhere to a ‘‘best execution’’
standard, will consider only the
interests of the Fund and will not take
into account the impact of the Fund’s
investment decision on the USB Trading
Entity. Before entering into any
Transaction, the Adviser will determine
that the Transaction is consistent with
the investment objective(s) and policies
of the Fund and is in the best interests
of the Fund and its shareholders.
(3) Each Fund will (a) for so long as
the Order is relied upon, maintain and
preserve in an easily accessible place a
written copy of the procedures and
conditions (and any modifications
thereto) that are described herein, and
(b) maintain and preserve for a period
of not less than six years from the end
of the fiscal year in which any
Transaction in which the Adviser
knows that both a USB Trading Entity
and a Fund directly or indirectly have
an interest occurs, the first two years in
an easily accessible place, a written
record of each such Transaction setting
forth a description of the security
purchased or sold by the Fund, a
description of the USB Trading Entity’s,
or affiliated person of the USB Trading
Entity’s interest or role in the
Transaction, the terms of the
Transaction, and the information or
materials upon which the determination
was made that such Transaction was
made in accordance with the procedures
and conditions set forth in the
application.
(4) Except for Transactions involving
repurchase agreements and variable rate
demand notes, before any secondary
market principal Transaction in fixedincome instruments is entered into
between a Fund and a USB Trading
Entity, the Adviser will obtain a
competitive quotation for the same
PO 00000
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Fmt 4703
Sfmt 4703
instruments (or in the case of
instruments for which quotations for the
same instruments are not available, a
competitive quotation for Comparable
Instruments)8 from at least two
unaffiliated market counterparties that
are in a position to quote favorable
market prices, except that if, after
reasonable efforts by the Adviser,
quotations are unavailable from two
such market counterparties, only one
other competitive quotation is required.
For each such Transaction, the Adviser
will determine, based upon the
quotations and such other relevant
information reasonably available to the
Adviser (such as available transaction
prices and any other information
regarding the value of the instruments),
that the price available from the USB
Trading Entity is at least as favorable as
that available from other sources.
(a) Repurchase Agreements. With
respect to Transactions involving
repurchase agreements, a Fund will
enter into such agreements only where
the Adviser has determined, based upon
information reasonably available to the
Adviser, that the income to be earned
from the repurchase agreement is at
least equal to that available from other
sources. Before any repurchase
agreements are entered into pursuant to
the Order, the Fund or the Adviser will
obtain competitive quotations from at
least two unaffiliated market
counterparties with respect to
repurchase agreements comparable to
the type of repurchase agreement
involved, except that if, after reasonable
efforts by the Adviser, quotations are
unavailable from two such market
counterparties, only one other
competitive quotation is required.
(b) Variable Rate Demand Notes. With
respect to each Transaction involving
variable rate demand notes for which
dealer quotes are not ordinarily
available, a Fund will only undertake
purchases and sales where the Adviser
has determined, based on relevant
information reasonably available to the
Adviser that the income earned from the
variable rate demand note is at least
equal to that of variable rate demand
notes of comparable quality that are
available from other sources.
(5) With respect to instruments
offered in a primary market
underwritten, or other primary market,
Transaction, the Fund will undertake
such purchase from a USB Trading
8 The term ‘‘Comparable Instruments’’ refers to
instruments with substantially identical maturities,
credit risk and repayment terms (including floating
or fixed-rate coupons, attached options, or any
other provisions that affect the expected size or
timing of the payments from the instruments) as the
instruments to be purchased or sold.
E:\FR\FM\08DEN1.SGM
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Federal Register / Vol. 80, No. 235 / Tuesday, December 8, 2015 / Notices
Entity only where the Adviser has
determined, based upon relevant
information reasonably available to the
Adviser that the instruments will be
purchased at a price that is not more
than the price paid by each other
purchaser of the instruments from, as
relevant, the USB Trading Entity or
other members of an underwriting
syndicate in that offering or in any
concurrent offering of instruments, and
on the same terms as such other
purchasers (except in the case of an
offering conducted under the laws of a
country other than the United States, for
any rights to purchase that are required
by law to be granted to existing holders
of the issuer). If no information
regarding concurrent purchasers of the
instruments is reasonably available to
the Adviser, the Fund may undertake
such purchase from a USB Trading
Entity when the Adviser has
determined, based upon information
reasonably available to the Adviser, that
the yield on the instruments to be
purchased is at least equal to that
available on Comparable Instruments
from other sources at that time.
(6) The commission, fee, spread, or
other remuneration to be received by the
USB Trading Entities must be
reasonable and fair compared to the
commission, fee, spread, or other
remuneration received by others in
connection with comparable
transactions involving similar
instruments being purchased or sold
during a comparable period of time.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2015–30867 Filed 12–7–15; 8:45 am]
BILLING CODE 8011–01–P
Lhorne on DSK9F6TC42PROD with NOTICES
[Release No. 34–76539; File No. SR–NYSE–
2015–61]
Self-Regulatory Organizations; New
York Stock Exchange LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change Amending Rule
132 To Delete Supplementary Material
.40 Requiring Members Effecting
Transactions on the NYSE Trading
Floor To Submit Certain Data Elements
and Badge Information and To Make a
Conforming Change
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934 (the
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend
Rule 132 to delete Supplementary
Material .40 requiring members effecting
transactions on the NYSE trading Floor
(the ‘‘Trading Floor’’) to submit certain
data elements and badge information
and to make a conforming change. 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
and discussed any comments it received
on the proposed rule change. The text
of those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and the
Statutory Basis for, the Proposed Rule
Change
SECURITIES AND EXCHANGE
COMMISSION
December 2, 2015.
‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that on November
20, 2015, New York Stock Exchange
LLC (‘‘NYSE’’ or the ‘‘Exchange’’) filed
with the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I, II, and III below, which Items
have been prepared by the selfregulatory organization. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
1. Purpose
The Exchange proposes to amend
Rule 132 to delete Supplementary
Material .40, which requires members to
submit certain data elements and badge
information for transactions effected on
the Trading Floor and to make a
conforming change.
Rule 132 requires clearing member
organizations submitting a transaction
to comparison to include the audit trail
data elements set forth in
Supplementary Material .30, including a
specification of the account type for
which the transaction was effected
2 15
1 15
U.S.C.78s(b)(1).
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14:17 Dec 07, 2015
3 17
Jkt 238001
PO 00000
U.S.C. 78a.
CFR 240.19b–4.
Frm 00084
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76343
according to defined account categories.
Consistent with this requirement,
Supplementary Material .40 requires
members 4 effecting transactions on the
Trading Floor as agent or otherwise to
supply these audit trail data elements to
their clearing member organization and
to promptly provide the reporter in the
Crowd (or other designated Exchange
representative) with the member’s
broker badge number or alpha symbol.
The Exchange proposes to delete Rule
132.40 as obsolete. Rule 132.40 was
adopted at a time when manual
transactions on the Trading Floor were
recorded on paper order tickets. The
rule was designed to improve trade
documentation and ensure that broker
badge information was captured
correctly for Crowd trades (i.e., verbal
executions between two Floor brokers or
between a Floor broker and a specialist).
Currently, however, all information
regarding transactions at the Exchange,
including the audit trail data elements
of Rule 132.30 and badge information
for manual transactions, is captured and
transmitted electronically by Exchange
systems. Because these data elements no
longer need to be separately submitted
by members, Rule 132.40 is obsolete and
therefore can be deleted.
The Exchange also proposes to amend
Rule 9217, which sets forth the list of
rules under which a member
organization or covered person may be
subject to a fine under a minor rule
violation plan as set forth in Rule
9216(b). Rule 9217 permits a summary
fine for failures to collect and/or submit
all audit trail data specified in Rule 132.
The Exchange proposes to delete the
clause ‘‘and/or submit’’ to reflect
elimination of the submission
requirement set forth in Supplementary
Material .40 of Rule 132. The Exchange
believes this proposed change will add
transparency and clarity to the
Exchange’s rules.
2. Statutory Basis
The Exchange believes that the
proposed rule change is consistent with
Section 6(b) of the Act,5 in general, and
furthers the objectives of Section 6(b)(5)
of the Act,6 in particular, because it is
designed to prevent fraudulent and
manipulative acts and practices,
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 protect investors and the
4 Under Rule 2(a), a member is a natural person
associated with a member organization and in the
context of Rule 132.40, refers to Floor brokers only.
5 15 U.S.C. 78f(b).
6 15 U.S.C. 78f(b)(5).
E:\FR\FM\08DEN1.SGM
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Agencies
[Federal Register Volume 80, Number 235 (Tuesday, December 8, 2015)]
[Notices]
[Pages 76338-76343]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-30867]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 31924; File No. 812-14258]
Nuveen Fund Advisors, LLC, et al.; Notice of Application
December 2, 2015.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order pursuant to sections 6(c)
and 17(b) of the Investment Company Act of 1940 (the ``Act'') for an
exemption from section 17(a) of the Act permitting certain
transactions.
-----------------------------------------------------------------------
Summary of the Application: Applicants request an order (the ``Order'')
that would permit certain registered management investment companies to
engage in certain primary and secondary market transactions in fixed
income instruments on a principal basis (the ``Transactions'') with a
USB Trading Entity (defined below).
Applicants: Nuveen Fund Advisors, LLC (the ``Adviser''), Nuveen
Investments, Inc. (``Nuveen''), Nuveen All Cap Energy MLP Opportunities
Fund, Nuveen AMT-Free Municipal Income Fund, Nuveen AMT-Free Municipal
Value Fund, Nuveen Arizona Premium Income Municipal Fund, Nuveen Build
America Bond Fund, Nuveen Build America Bond Opportunity Fund, Nuveen
California AMT-Free Municipal Income Fund, Nuveen California Dividend
Advantage Municipal Fund, Nuveen California Dividend Advantage
Municipal Fund 2, Nuveen California Dividend Advantage Municipal Fund
3, Nuveen California Municipal Value Fund 2, Nuveen California
Municipal Value Fund, Inc., Nuveen California Select Tax-Free Income
Portfolio, Nuveen Connecticut Premium Income Municipal Fund, Nuveen
Core Equity Alpha Fund, Nuveen Credit Strategies Income Fund, Nuveen
Diversified Dividend and Income Fund, Nuveen Dividend Advantage
Municipal Fund, Nuveen Dividend Advantage Municipal Fund 2, Nuveen
Dividend Advantage Municipal Fund 3, Nuveen Dividend Advantage
Municipal Income Fund, Nuveen Dow 30\SM\ Dynamic Overwrite Fund, Nuveen
Energy MLP Total Return Fund, Nuveen Enhanced Municipal Value Fund,
Nuveen Flexible Investment Income Fund, Nuveen Floating Rate Income
Fund, Nuveen Floating Rate Income Opportunity Fund, Nuveen Georgia
Dividend Advantage Municipal Fund 2, Nuveen Global High Income Fund,
Nuveen Global Equity Income Fund, Nuveen High Income 2020 Target Term
Fund, Nuveen High Income December 2018 Target Term Fund, Nuveen High
Income December 2020 Target Term Fund, Nuveen High Income December 2022
Target Term Fund, Nuveen Intermediate Duration Municipal Term Fund,
Nuveen Intermediate Duration Quality Municipal Term Fund, Nuveen
Investment Funds, Inc., Nuveen Investment Quality Municipal Fund, Inc.,
Nuveen Investment Trust, Nuveen Investment Trust II, Nuveen Investment
Trust III, Nuveen Investment Trust V, Nuveen Managed Accounts
Portfolios Trust, Nuveen Maryland Premium Income Municipal Fund, Nuveen
Massachusetts Premium Income Municipal Fund, Nuveen Michigan Quality
Income Municipal Fund, Nuveen Minnesota Municipal Income Fund, Nuveen
Missouri Premium Income Municipal Fund, Nuveen Mortgage Opportunity
Term Fund 2, Nuveen Mortgage Opportunity Term Fund, Nuveen Multi-Market
Income Fund, Nuveen Multistate Trust I, Nuveen Multistate Trust II,
Nuveen Multistate Trust III, Nuveen Multistate Trust IV, Nuveen
Municipal Advantage Fund, Inc., Nuveen Municipal High Income
Opportunity Fund, Nuveen Municipal Income Fund, Inc., Nuveen Municipal
Market Opportunity Fund, Inc., Nuveen Municipal Opportunity Fund, Inc.,
Nuveen Municipal Trust, Nuveen Municipal Value Fund, Inc., Nuveen
Nasdaq 100 Dynamic Overwrite Fund, Nuveen New Jersey Dividend Advantage
Municipal Fund, Nuveen New Jersey Municipal Value Fund, Nuveen New York
AMT-Free Municipal Income Fund, Nuveen New York Dividend Advantage
Municipal Fund, Nuveen New York Municipal Value
[[Page 76339]]
Fund 2, Nuveen New York Municipal Value Fund, Inc., Nuveen New York
Select Tax-Free Income Portfolio, Nuveen North Carolina Premium Income
Municipal Fund, Nuveen Ohio Quality Income Municipal Fund, Nuveen
Pennsylvania Investment Quality Municipal Fund, Nuveen Pennsylvania
Municipal Value Fund, Nuveen Performance Plus Municipal Fund, Inc.,
Nuveen Preferred and Income Term Fund, Nuveen Preferred Income
Opportunities Fund, Nuveen Premier Municipal Income Fund, Inc., Nuveen
Premium Income Municipal Fund 2, Inc., Nuveen Premium Income Municipal
Fund 4, Inc., Nuveen Premium Income Municipal Fund, Inc., Nuveen
Quality Income Municipal Fund, Inc., Nuveen Quality Municipal 2018 Term
Fund, Nuveen Quality Municipal Fund, Inc., Nuveen Quality Preferred
Income Fund, Nuveen Quality Preferred Income Fund 2, Nuveen Quality
Preferred Income Fund 3, Nuveen Real Asset Income and Growth Fund,
Nuveen Real Estate Income Fund, Nuveen S&P 500 Buy-Write Income Fund,
Nuveen S&P 500 Dynamic Overwrite Fund, Nuveen Select Maturities
Municipal Fund, Nuveen Select Quality Municipal Fund, Inc., Nuveen
Select Tax-Free Income Portfolio, Nuveen Select Tax-Free Income
Portfolio 2, Nuveen Select Tax-Free Income Portfolio 3, Nuveen Senior
Income Fund, Nuveen Short Duration Credit Opportunities Fund, Nuveen
Strategy Funds, Inc., Nuveen Tax-Advantaged Dividend Growth Fund,
Nuveen Tax-Advantaged Total Return Strategy Fund, Nuveen Texas Quality
Income Municipal Fund, Nuveen Virginia Premium Income Municipal Fund,
Diversified Real Asset Income Fund (each a ``Fund'', collectively, the
``Funds''), U.S. Bancorp (``USB''), U.S. Bank National Association
(``USBNA'') and U.S. Bancorp Investments, Inc. (``USBI'').
Filing Dates: The application was filed on December 27, 2013, and
amended on July 1, 2014, December 8, 2014, May 22, 2015, and October
22, 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 December 28, 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, c/o Richard T.
Prins, Esq. Skadden, Arps, Slate, Meagher & Flom LLP, Four Times
Square, New York, NY 10036.
FOR FURTHER INFORMATION CONTACT: Laura L. Solomon, Senior Counsel, at
(202) 551-6915, or Daniele Marchesani, Branch Chief, at (202) 551-6821
(Chief Counsel's Office, Division of Investment Management).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or an applicant
using the Company name box, at https://www.sec.gov/search/search.htm or
by calling (202) 551-8090.
Applicants' Representations
1. Each Fund is an open-end or closed-end management investment
company registered under the Act and is organized as a business trust
or corporation under the laws of Massachusetts, Maryland or Minnesota,
or is a series thereof. The Funds have a variety of investment
objectives, but each may invest a portion of its assets in fixed-income
instruments. ``Fixed-income instruments'' for purposes of the Order
means fixed-income securities and interests in syndicated loans,
convertible bonds and convertible preferred stock, as well as money
market instruments, such as treasury instruments, commercial paper and
certificates of deposit.
2. The Adviser, a Delaware limited liability company, is a direct
wholly owned subsidiary of Nuveen, a Delaware corporation. The Adviser
is registered as an investment adviser under the Investment Advisers
Act of 1940 (the ``Advisers Act''). The Adviser acts as investment
adviser to the Funds and has oversight over one or more sub-advisers
engaged by the Funds.\1\
---------------------------------------------------------------------------
\1\ Each Fund has (or may, in the future, have) one or more
affiliated or unaffiliated sub-advisers that provide sub-advisory
services (each, a ``Sub-Adviser,'' collectively, the ``Sub-
Advisers''). Applicants request the Order cover any such Sub-
Advisers, provided that any Sub-Adviser that relies on the Order
complies with the conditions of the Order as though it were an
Adviser.
---------------------------------------------------------------------------
3. USBNA is a national banking association and a wholly owned
subsidiary of USB. USBNA Dealer Division, an internal division of
USBNA, engages in bank permitted dealer activities and is exempt from
registering as a broker-dealer pursuant to the Securities Exchange Act
of 1934 (``1934 Act''). USBI, a Delaware corporation, is also a wholly
owned subsidiary of USB that is registered as a broker-dealer with the
Commission under the 1934 Act. Each of USBI, USBNA, USBNA Dealer
Division, as well as other affiliates of USB that are controlled
(within the meaning of section 2(a)(9) of the Act) by USB and are
registered as broker-dealers or exempt from registration as such (each,
a ``USB Trading Entity,'' and, collectively, the ``USB Trading
Entities''), may seek to engage in Transactions with the Funds.\2\
---------------------------------------------------------------------------
\2\ No director, officer or employee of the Funds or the Adviser
is or will be a director, officer or employee of a USB Trading
Entity. The board of directors or board of trustees or other
governing body, as applicable (``Board'') of each Fund currently has
eleven members, of which nine members are currently not interested
persons of the Fund and the chair of the Board of each Fund is
currently not an interested person, as defined in section 2(a)(19)
of the Act, of the Fund.
---------------------------------------------------------------------------
4. On December 31, 2010, Nuveen completed its acquisition of a
portion of the asset management business of FAF Advisors, Inc. (``FAF
Advisors''), a wholly owned subsidiary of USBNA (the ``FAF
Acquisition''). The open-end funds previously advised by FAF Advisors
entered into investment advisory agreements with the Adviser. The
Adviser continued to serve as investment adviser to the open-end funds
and closed-end funds that it advised prior to the FAF Acquisition.
5. Certain fiduciary account investments maintained by USB
Fiduciary in certain of the Funds remain after the FAF acquisition. USB
Fiduciary has discretionary authority over, but no pecuniary interest
in, such investments. Because of these investments, there may be
affiliations between the USB Trading Entities and the Funds.
6. Applicants state that, because of consolidation in the financial
services industry, a few major broker-dealers account for a large
percentage of the market share in trading in fixed income instruments.
Applicants state that the decline in the number of broker-dealers and
banks trading in the fixed-income instruments in which the Funds seek
to invest and the increasing significance of the few remaining
institutions demonstrate the importance to the Funds of their
relationships with such entities, including the USB Trading
[[Page 76340]]
Entities. For example, Applicants further state that in the first half
of 2015, the USB Trading Entities were ranked 15th as a domestic book
running lead manager of U.S. investment grade corporate bonds by
volume, and ranked 6th as a lead and co-manager by number of
transactions. Applicants represent that the USB Trading Entities'
underwriting market share was 37% calculated as a percentage of the
total number of U.S. investment grade corporate bond transactions in
the marketplace. On the municipal securities side of the business, the
USB Trading Entities were ranked 66th in fixed rate lead managed
business, and 9th in variable rate demand note underwriting in 2014.
Applicants further represent that as a variable rate demand note
underwriter the USB Trading Entities achieved a 3% market share in
2014. Applicants state the USB Trading Entities ranked 5th in the
Overall Bookrunner League Tables by number of deals with a 3% market
share, 3rd in the Domestic League Tables and 5th in the Global League
Tables for private placements in 2014. Applicants assert that these
statistics demonstrate the growth in demand for its services and USB
expects continued growth on an ongoing basis in capital markets
transaction volumes for the USB Trading Entities.
7. Applicants assert that prohibiting the Funds from engaging in
the Transactions with the USB Trading Entities would become
increasingly detrimental to the ongoing interests of Fund shareholders
by limiting the Funds' access to important trading counterparties that
have growing market share in many of the types of instruments that the
Funds purchase. Applicants submit that prohibiting the Funds from
engaging in Transactions with the USB Trading Entities unnecessarily
reduces the opportunities available to the Funds to obtain competitive
pricing and execution and to access the markets for particular fixed-
income instruments that are available from only a few dealers.
Applicants assert that precluding a Fund from trading with a USB
Trading Entity may harm the Fund by, among other things, preventing it
from obtaining the best pricing, terms and quality of services
otherwise available in the market.
8. Applicants, therefore, request the Order, pursuant to sections
6(c) and 17(b) of the Act exempting from section 17(a) of the Act \3\
Transactions entered into in the ordinary course of business by a Fund
with USB Trading Entities, under the terms and conditions set forth in
the application.
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\3\ Applicants are not seeking relief from the provisions of
sections 10(f), 17(d) or 17(e) of the Act or rules 17d-1 or 17e-1
thereunder.
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9. The requested relief would include (i) the Funds and any
investment company registered under the Act or series thereof, whether
now existing or organized in the future, that is advised by the Adviser
or by any existing or future entity that is controlling, controlled by
or under common control with the Adviser or Nuveen and registered as an
investment adviser under the Advisers Act; (ii) the Adviser; and (iii)
the USB Trading Entities; \4\ provided that any entity that relies on
the Order complies with the terms and conditions of the Order as though
it were an applicant.
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\4\ All existing entities that currently intend to rely on the
requested relief are either named as applicants or listed in
Schedule A to the application. Any other entity that relies on the
Order now or in the future will comply with the terms and conditions
set forth in the application.
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10. The Order would be available only in circumstances in which the
USB Trading Entity might be deemed to be (i) an affiliated person
(``first-tier affiliate''), or an affiliated person of a first-tier
affiliate (a ``second-tier affiliate'') of a Fund solely by reason of a
USB Fiduciary,\5\ being deemed to own, control or hold with power to
vote through non-proprietary, trust or other fiduciary account
investments five percent or more of the Fund's total outstanding voting
securities (each, a ``5% Fund''); (ii) a first-tier affiliate of a Fund
solely by reason of USB Fiduciary being deemed to beneficially own
through the fiduciary account investments more than twenty-five percent
of the Fund's total outstanding voting securities or, by virtue of such
fiduciary account investments, to control the Fund (each, a ``25%
Fund,'' together with the 5% Funds, the ``Owned Funds''); and/or (iii)
a second-tier affiliate of any Fund other than an Owned Fund (each, an
``Other Fund'') solely by reason of USB Fiduciary being considered to
own, control or hold with power to vote a 5% Fund's securities as
described in (i) or being deemed to beneficially own a 25% Fund's
securities as described in (ii), through fiduciary account
investments.\6\
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\5\ USB Fiduciary includes USBNA, its trust bank subsidiaries,
U.S. Bank Trust National Association and U.S. Bank Trust National
Association SD, and any successors. The term ``successor'' is
limited to the entity that results from a reorganization into
another jurisdiction, a change in the type of business organization
or a combination, consolidation or reorganization of any of the
entities referred to in the previous sentence, including any such
combination, consolidation or reorganization effected through the
use of a ``shell'' entity controlled by any of the foregoing
entities, provided that such combination, consolidation or
reorganization does not result in a change of direct or indirect
control of such entities.
\6\ Applicants note that there may be some instances in which
USB or an entity, including a division thereof, controlled by USB
(each, a ``USB Affiliate,'' collectively, the ``USB Affiliates'')
might be deemed to own, control or hold with power to vote less than
five percent of the outstanding voting securities of a Fund
otherwise than through fiduciary account investments (a ``<5%
holding''). References to potential affiliations arising ``solely by
reason of'' fiduciary account investments above certain levels may
include situations where fiduciary account investments exceed such
levels only when added to a <5% holding.
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11. The requested relief would not extend to primary market
Transactions in fixed-income instruments, other than repurchase
agreements and variable rate demand notes, of which USB or any entity
controlled by USB, including any USB Trading Entity, is the primary
obligor.
12. Neither USB nor any USB Affiliates control or will control
(within the meaning of section 2(a)(9) of the Act), directly or
indirectly, Nuveen or the Adviser or any other non-Fund entity under
the control of Nuveen (together, the ``Nuveen Affiliates''), and
neither USB nor any USB Affiliates will exercise, or attempt to
exercise, control over any Fund. Applicants state that only the
fiduciary account investments in the Owned Funds raise the affiliation
issues addressed by the requested relief. Additionally, Nuveen has no
beneficial interest in, and will not control (within the meaning of
section 2(a)(9) of the Act) directly or indirectly, USB, the USB
Trading Entities or any other USB Affiliate.
13. Applicants state that the USB Affiliates will not have any
involvement in the Advisers' investment decisions or decisions to
engage in Transactions pursuant to the Order, and will not attempt to
influence or control in any way the placing by the Adviser of orders,
other than in the normal course of sales activities of the same nature
that are being carried out during the same time period with respect to
unaffiliated institutional clients of the USB Trading Entity, or that
existed between the USB Trading Entity and FAF Advisors, if any, prior
to the consummation of the FAF Acquisition.
14. Applicants assert that there is substantial internal separation
and independent operation of the division of USBNA that maintains
fiduciary accounts (``USBNA Fiduciary Division'') and USBNA Dealer
Division. USBNA Fiduciary Division is subject to strict fiduciary laws
and regulations that require USBNA Fiduciary Division to act solely in
the interests of the principals or beneficiaries of the accounts.
Applicants represent that
[[Page 76341]]
there is not, and will not be, any express or implied understanding
between a USB Trading Entity and Nuveen or the Adviser that the Adviser
will cause a Fund to enter into Transactions or give preference to the
USB Trading Entity in effecting such Transactions between the Fund and
the USB Trading Entity.
15. USB Fiduciary undertakes to not to exercise any voting power
with respect to shares that constitute five percent or more of a Fund's
total outstanding voting securities, including in connection with the
election of directors/trustees (the ``Non-Voting Undertaking'').
Applicants' Legal Analysis
1. Section 17(a) of the Act, in relevant part, prohibits an
affiliated person of a registered investment company, or any affiliated
person of such person, acting as principal, from selling to or
purchasing from such company any security or other property and from
borrowing money or other property from such company. Section 17(b) of
the Act authorizes the Commission to exempt a transaction from section
17(a) of the Act if evidence establishes that the terms of the proposed
transaction, including the consideration to be paid or received, are
reasonable and fair and do not involve overreaching on the part of any
person concerned and the proposed transaction is consistent with the
policy of each registered investment company concerned and with the
general purposes of the Act.
2. Section 6(c) of the Act, in relevant part, authorizes the
Commission to exempt any person or transaction, or any class or classes
of persons or transactions, from any provision or provisions of the
Act, if and to the extent that 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.
3. Section 2(a)(3) of the Act, in relevant part, defines
``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 such other
person; (b) any person 5% or more of whose outstanding voting
securities are directly or indirectly owned by, controlled, or held
with power to vote, by such person; and (c) any person directly or
indirectly controlling, controlled by, or under common control with,
such other person.
4. Section 2(a)(9) of the Act, in relevant part, defines
``control'' as ``the power to exercise a controlling influence over the
management or policies of a company, unless such power is solely the
result of an official position with such company.'' Section 2(a)(9)
also provides that any person who owns beneficially, either directly or
through one or more controlled companies, more than 25% of the voting
securities of a company shall be presumed to control such company, and
that any person who does not so own more than 25% of the voting
securities of any company shall be presumed not to control such
company.
5. Applicants state that a USB Trading Entity could be deemed to be
a first-tier affiliate or a second-tier affiliate of a 5% Fund insofar
as fiduciary account investments of five percent or more of an Owned
Fund's outstanding voting securities could cause USB Fiduciary to be
viewed as owning, controlling or holding with power to vote ``voting
securities.'' Were a USB Fiduciary deemed to be a first-tier affiliate
of a 5% Fund, the USB Trading Entities (except for USBNA Dealer
Division) would then be deemed to be second-tier affiliates of the 5%
Fund. USBNA Dealer Division, on the other hand, could be deemed to be a
first-tier affiliate of the 5% Fund. Additionally, a USB Trading Entity
could be deemed a first-tier affiliate of a 25% Fund and a second-tier
affiliate of the Other Funds.\7\ Applicants submit that, due to the
fiduciary account investments, any Transaction involving a Fund and a
USB Trading Entity that is a first-tier affiliate or a second-tier
affiliate thereof, would be subject to the prohibition of section 17(a)
of the Act.
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\7\ As discussed in the application, this conclusion could be
reached if, on account of the fiduciary account investments, USB
Fiduciary ``beneficially owned'' greater than twenty-five percent of
the 25% Fund's total outstanding voting securities. The Owned Fund
could then be presumed to be under the control of USB Fiduciary, and
thus of USB. As wholly owned subsidiaries of USB, the USB Trading
Entities may also be presumed to be under the control of USB.
Accordingly, the 25% Fund and the USB Trading Entities could be
presumed to be under the common control of USB and thus first-tier
affiliates of each other. If the 25% Fund and the Other Funds are
deemed to be under the control of their Adviser(s), then the 25%
Fund and the Other Funds could be deemed to be first-tier affiliates
of each other by virtue of being under common control. Therefore, if
the USB Trading Entities are deemed to be first-tier affiliates of
the 25% Fund, they could be deemed to be second-tier affiliates of
the Other Funds.
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6. Applicants submit that the primary purpose of section 17(a) is
to prevent a person with the power to control or influence a registered
investment company from engaging in self-dealing or overreaching, to
the detriment of the investment company's shareholders. Applicants
submit that the policies which section 17(a) of the Act was meant to
further are not implicated in the context of the requested Order
because USB and USB Trading Entities are not able to cause a Fund to
enter into a Transaction or otherwise influence portfolio decisions by
the Adviser on behalf of the Funds. Applicants state that, as a result,
no USB Trading Entity is in a position to cause a Fund to enter into
Transactions that are not in the best interests of the Fund and its
shareholders. Applicants also state that there will be no conflict of
interest associated with the Adviser's decision to engage in a
Transaction with a USB Trading Entity on behalf of a Fund. Applicants
further submit that the conditions to the requested Order provide
further protections against any possibility of self-dealing or
overreaching by the USB Trading Entities. Therefore, Applicants submit
that the Order satisfies the statutory standards for relief.
Applicants' Conditions
Applicants agree that the Order granting the requested relief will
be subject to the following conditions:
A. Structural
(1) Neither USB nor any USB Affiliates will control any Adviser or
any principal underwriters or promoters for the Funds, directly or
indirectly, within the meaning of section 2(a)(9) of the Act, and
neither USB nor any USB Affiliates will exercise, or attempt to
exercise, control over any Fund. The Order will remain in effect only
so long as Nuveen, or another entity not controlling, controlled by or
under common control with USB, primarily controls the Adviser. In this
regard, pursuant to the Non-Voting Undertaking, USB Fiduciary will not
exercise any voting authority that it possesses with respect to shares
that constitute five percent or more of any Fund's total outstanding
voting securities. Instead, it will delegate to an independent third
party that is not affiliated with either USB or any USB Affiliate the
voting of such shares.
(2) Neither USB nor any USB Affiliates will directly or indirectly
consult with Nuveen or any Nuveen Affiliate, including the Adviser, or
any portfolio manager of the Adviser concerning purchase or sale
Transactions, or the selection of a broker or dealer for any
Transactions placed or to be placed on behalf of a Fund, or otherwise
seek to influence the choice of broker or dealer for any Transaction by
a Fund, other than in the normal course of sales activities of the same
nature that are being carried out during the same time period with
respect to unaffiliated institutional clients of the
[[Page 76342]]
USB Trading Entity, or that existed between the USB Trading Entity and
the Adviser and the Nuveen Sub-Advisers, if any, prior to the
consummation of the FAF Acquisition.
(3) No officer, director or employee of an Owned Fund will directly
or indirectly seek to influence in any way the terms of any Transaction
covered by the Order, other than in the normal course of investment
activities of the same nature that are being carried out during the
same time period with respect to unaffiliated broker-dealers, or that
existed between the USB Trading Entity and the Adviser and the Nuveen
Sub-Advisers, if any, prior to the consummation of the FAF Acquisition.
(4) Each USB Trading Entity will adopt and implement policies that
prohibit the USB Trading Entity from (a) linking any approval or action
relating to an Owned Fund to any action by any Fund or by the Adviser
relating to any Fund, or (b) using the fiduciary account investments in
an Owned Fund as a basis for seeking to persuade any Fund or the
Adviser to engage in business with the USB Trading Entity.
(5) The Adviser and the USB Trading Entities, with the assistance
of their respective legal/compliance departments, will prepare
guidelines for their respective personnel to make certain that
Transactions effected pursuant to the Order comply with its terms and
conditions, and that the Adviser and the USB Trading Entities maintain
an arm's-length relationship. The respective legal/compliance
departments of the Adviser and the USB Trading Entities will monitor
periodically the activities of the Adviser and the USB Trading
Entities, respectively, to make certain that the terms and conditions
of the Order are met.
B. Transactional
With respect to each Transaction entered into or effected pursuant
to the Order on behalf of a Fund:
(1) Each Fund's Board, including a majority of its disinterested
directors or trustees, as applicable (``Necessary Majority''), will
approve, and the Fund will implement, procedures governing all
Transactions pursuant to the Order and the Fund's Board will no less
frequently than quarterly review all Transactions conducted pursuant to
the Order and receive and review a report (the ``Report''), of those
Transactions. The Report which will be prepared by the Adviser and
reviewed and approved by the Fund's Chief Compliance Officer, will
indicate for each Transaction that the terms and conditions of the
Order have been satisfied, and will include a discussion of any
significant changes in the volume, type or terms of Transactions
between the relevant Funds and the USB Trading Entity, the reasons for
these changes, and a determination that such changes are appropriate.
In addition, annually and prior to entering into a Transaction with a
USB Trading Entity that no Fund has previously traded with, the Board
will consider (i) whether the level of Transactions with USB Trading
Entities is appropriate and (ii) whether continued reliance on the
Order in any applicable category of fixed-income instruments is
appropriate in light of the need of the Funds to have the USB Trading
Entities available as trading counterparties, as evidenced by, among
other things, the aggregate market share of the USB Trading Entities in
each such category.
(2) For each Transaction, the Adviser will adhere to a ``best
execution'' standard, will consider only the interests of the Fund and
will not take into account the impact of the Fund's investment decision
on the USB Trading Entity. Before entering into any Transaction, the
Adviser will determine that the Transaction is consistent with the
investment objective(s) and policies of the Fund and is in the best
interests of the Fund and its shareholders.
(3) Each Fund will (a) for so long as the Order is relied upon,
maintain and preserve in an easily accessible place a written copy of
the procedures and conditions (and any modifications thereto) that are
described herein, and (b) maintain and preserve for a period of not
less than six years from the end of the fiscal year in which any
Transaction in which the Adviser knows that both a USB Trading Entity
and a Fund directly or indirectly have an interest occurs, the first
two years in an easily accessible place, a written record of each such
Transaction setting forth a description of the security purchased or
sold by the Fund, a description of the USB Trading Entity's, or
affiliated person of the USB Trading Entity's interest or role in the
Transaction, the terms of the Transaction, and the information or
materials upon which the determination was made that such Transaction
was made in accordance with the procedures and conditions set forth in
the application.
(4) Except for Transactions involving repurchase agreements and
variable rate demand notes, before any secondary market principal
Transaction in fixed-income instruments is entered into between a Fund
and a USB Trading Entity, the Adviser will obtain a competitive
quotation for the same instruments (or in the case of instruments for
which quotations for the same instruments are not available, a
competitive quotation for Comparable Instruments)\8\ from at least two
unaffiliated market counterparties that are in a position to quote
favorable market prices, except that if, after reasonable efforts by
the Adviser, quotations are unavailable from two such market
counterparties, only one other competitive quotation is required. For
each such Transaction, the Adviser will determine, based upon the
quotations and such other relevant information reasonably available to
the Adviser (such as available transaction prices and any other
information regarding the value of the instruments), that the price
available from the USB Trading Entity is at least as favorable as that
available from other sources.
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\8\ The term ``Comparable Instruments'' refers to instruments
with substantially identical maturities, credit risk and repayment
terms (including floating or fixed-rate coupons, attached options,
or any other provisions that affect the expected size or timing of
the payments from the instruments) as the instruments to be
purchased or sold.
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(a) Repurchase Agreements. With respect to Transactions involving
repurchase agreements, a Fund will enter into such agreements only
where the Adviser has determined, based upon information reasonably
available to the Adviser, that the income to be earned from the
repurchase agreement is at least equal to that available from other
sources. Before any repurchase agreements are entered into pursuant to
the Order, the Fund or the Adviser will obtain competitive quotations
from at least two unaffiliated market counterparties with respect to
repurchase agreements comparable to the type of repurchase agreement
involved, except that if, after reasonable efforts by the Adviser,
quotations are unavailable from two such market counterparties, only
one other competitive quotation is required.
(b) Variable Rate Demand Notes. With respect to each Transaction
involving variable rate demand notes for which dealer quotes are not
ordinarily available, a Fund will only undertake purchases and sales
where the Adviser has determined, based on relevant information
reasonably available to the Adviser that the income earned from the
variable rate demand note is at least equal to that of variable rate
demand notes of comparable quality that are available from other
sources.
(5) With respect to instruments offered in a primary market
underwritten, or other primary market, Transaction, the Fund will
undertake such purchase from a USB Trading
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Entity only where the Adviser has determined, based upon relevant
information reasonably available to the Adviser that the instruments
will be purchased at a price that is not more than the price paid by
each other purchaser of the instruments from, as relevant, the USB
Trading Entity or other members of an underwriting syndicate in that
offering or in any concurrent offering of instruments, and on the same
terms as such other purchasers (except in the case of an offering
conducted under the laws of a country other than the United States, for
any rights to purchase that are required by law to be granted to
existing holders of the issuer). If no information regarding concurrent
purchasers of the instruments is reasonably available to the Adviser,
the Fund may undertake such purchase from a USB Trading Entity when the
Adviser has determined, based upon information reasonably available to
the Adviser, that the yield on the instruments to be purchased is at
least equal to that available on Comparable Instruments from other
sources at that time.
(6) The commission, fee, spread, or other remuneration to be
received by the USB Trading Entities must be reasonable and fair
compared to the commission, fee, spread, or other remuneration received
by others in connection with comparable transactions involving similar
instruments being purchased or sold during a comparable period of time.
For the Commission, by the Division of Investment Management,
under delegated authority.
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2015-30867 Filed 12-7-15; 8:45 am]
BILLING CODE 8011-01-P