Third Avenue Trust and Third Avenue Management LLC; Notice of Application and Temporary Order, 79638-79640 [2015-32079]
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79638
Federal Register / Vol. 80, No. 245 / Tuesday, December 22, 2015 / Notices
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549 on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of such
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–BATS–
2015–110, and should be submitted on
or before January 12, 2016.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.14
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2015–32045 Filed 12–21–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–31943; 812–14593]
Third Avenue Trust and Third Avenue
Management LLC; Notice of
Application and Temporary Order
December 16, 2015.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application and a
temporary order under Section 22(e)(3)
of the Investment Company Act of 1940
(the ‘‘Act’’).
AGENCY:
Applicants
request a temporary order to permit
Third Avenue Focused Credit Fund (the
‘‘Fund’’), a series of Third Avenue Trust
(the ‘‘Trust’’), to suspend the right of
redemption of its outstanding
redeemable securities.
APPLICANTS: The Trust, on behalf of the
Fund, and Third Avenue Management
LLC (the ‘‘Adviser,’’ together with the
Trust, the ‘‘Applicants’’).
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SUMMARY OF APPLICATION:
14 17
CFR 200.30–3(a)(12).
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17:21 Dec 21, 2015
Jkt 238001
The application was filed
on December 16, 2015.
HEARING OR NOTIFICATION OF 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 January 7, 2016, and should be
accompanied by proof of service on
Applicants, in the form of an affidavit
or, for lawyers, a certificate of service.
Hearing requests should state the nature
of the writer’s interest, 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 Third Avenue
Management LLC 622 Third Avenue,
32nd Floor, New York, NY 10017.
FOR FURTHER INFORMATION CONTACT:
David Joire, Senior Special Counsel, at
(202) 551–6866 (Division of Investment
Management, Chief Counsel’s Office).
SUPPLEMENTARY INFORMATION: 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.
FILING DATE:
Background
1. The Adviser is the investment
adviser to the Fund. The Adviser is a
Delaware limited liability company that
is registered as an investment adviser
under the Investment Advisers Act of
1940. The Adviser managed assets of
approximately $8 billion as of
September 30, 2015.
2. The Trust is a Delaware statutory
trust and is registered with the
Commission under the 1940 Act as an
open-end management investment
company with five series. Each series of
the Trust has a different investment
objective and different investment
policies. The Fund is one such series.
3. The Fund is a non-diversified openend investment company. Its investment
objective is to seek long-term total
return, which may include investment
returns from a combination of sources
including capital appreciation, fees and
interest income.
4. The Fund has been subject to a
significant level of redemption requests
by the Fund’s investors over the past six
months. For example, the Fund has
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Fmt 4703
Sfmt 4703
experienced a total of $1.1 billion in
estimated net outflows for the year to
date through December 9, 2015, which
was more than 145% of its remaining
net asset value at that date. In November
2015, the Fund experienced a total of
$317 million in estimated net
redemptions, and the Fund’s
Institutional Class net asset value per
share fell from $7.81 to $7.08 and its
Retail Class net asset value per share fell
from $7.82 to $7.09.
5. The ongoing reduction in liquidity
in the Fund’s portfolio securities is
related to a number of factors, including
an imbalance between selling interest
and buying interest. The Fund increased
its cash position to over $200 million by
early December 2015 in anticipation of
tax selling and other redemptions.
6. During this period, Fund
management also kept the Board of
Trustees of the Trust (the ‘‘Board’’)
informed and reevaluated contingency
plans. On December 9, 2015, after
considering the environment the Fund
was in and the likelihood that
incremental sales of portfolio securities
to satisfy additional redemptions would
have to be made at prices that would
unfairly disadvantage all remaining
shareholders, the Board determined that
the fairest action on behalf of all
shareholders would be to adopt a plan
of liquidation. The Board determined to
implement this plan by placing the
remaining noncash assets in a
liquidating trust for the benefit of all
Fund shareholders and distributing
available cash. Relief from the
Commission in connection with the
plan’s implementation was not sought
by the Fund and the Adviser.
7. On December 9, 2015, the Board
adopted a plan of liquidation for the
Fund (the ‘‘Plan of Liquidation’’),
pursuant to which the Board declared
two distributions, one of the remaining
net cash and one of the beneficial
interests in a liquidating trust
(‘‘Liquidating Trust’’). These
distributions were scheduled to be paid
on December 16, 2015. Interests in the
Liquidating Trust would not trade and
would, in general, be transferable only
by operation of law. The Adviser would
manage the Liquidating Trust’s assets
without charge and there would be
periodic distributions from the
Liquidating Trust as income is received
and assets are sold at fair prices. All
redemption requests as of December 9,
2015, were met by the Fund and the
sales of the shares of the Fund were
suspended as of December 10, 2015.
8. Upon announcement of the Plan of
Liquidation, the Commission staff
expressed concerns during discussions
with the Fund and the Adviser. In
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addition, the Fund received numerous
inquiries from shareholders and
intermediaries through which many
shareholders hold their shares in the
Fund. The Fund and the Adviser
reviewed the pros and cons of
alternatives with the Board at meetings
held on December 12, 2015 and
December 13, 2015, at which the Board
authorized moving forward with an
application for an order to suspend
redemptions. On December 14, 2015,
the Board met again and approved the
cancellation and rescission of the
distribution of beneficial interests in the
Liquidating Trust and the reconveyance
of the assets held in the Liquidating
Trust to the Fund together with the
assumption by the Fund of the liabilities
previously assumed by the Liquidating
Trust, conditioned upon receipt of the
requested relief. The Board did not
rescind the cash distribution, which
will proceed on December 16, 2015, and
also retained the Plan of Liquidation,
pursuant to which the Fund will
liquidate.
9. Applicants state that approximately
65% of the value of the Fund’s shares
is held by shareholders in the Fund’s
Institutional Class, and the rest is held
by investors in its Retail Class. If the
relief is not granted, and the Fund is
unable to suspend redemptions, the
institutional investors would likely be
best positioned to take advantage of any
redemption opportunity, to the
detriment of those investors—most
likely, retail investors—who remain in
the Fund. These remaining investors
would suffer a rapidly declining net
asset value and an even further
diminished liquidity of the Fund’s
securities portfolio. The relief would
help avoid such an outcome.
10. Applicants also state that the
Fund will not be engaged and does not
propose to engage, in any business
activities other than those necessary for
the winding-up of its affairs. Applicants
further state that relief permitting the
Fund to suspend redemptions in
connection with its liquidation would
permit the Fund to liquidate its assets
in an orderly manner and prevent the
Fund from being forced to sell assets at
unreasonably low prices to meet
redemptions.
Applicants’ Legal Analysis
1. Section 22(e)(1) of the Act provides
that a registered investment company
may not suspend the right of
redemption or postpone the date of
payment or satisfaction upon
redemption of any redeemable security
in accordance with its terms for more
than seven days after the tender of such
security to the company or its
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17:21 Dec 21, 2015
Jkt 238001
designated agent except for any period
during which the New York Stock
Exchange (‘‘NYSE’’) is closed other than
customary week-end and holiday
closings, or during which trading on the
NYSE is restricted.
2. Section 22(e)(3) of the Act provides
that redemptions may be suspended by
a registered investment company for
such other periods as the Commission
may by order permit for the protection
of security holders of the registered
investment company.
3. Applicants submit that granting the
requested relief would be for the
protection of the shareholders of the
Fund, as provided in Section 22(e)(3) of
the Act. Applicants assert that, in
requesting an order by the Commission,
the Board’s goal is to ensure that the
Fund’s shareholders will be treated
appropriately in view of the otherwise
detrimental effect on the Fund of the
ongoing reduction in the liquidity of the
Fund’s portfolio securities, the very
recent extreme difficulty the Fund has
encountered in selling portfolio
securities at prices the Adviser deemed
to be fair and the ongoing redemptions
that the Fund expected. Applicants
further state that the requested relief is
intended to permit an orderly
liquidation of the portfolio securities at
what Applicants consider to be fair
values and ensure that all of the
shareholders of the Fund are protected
in the process by allowing the
realization of fair value for these
investments.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
(1) Pending liquidating distributions,
the Fund will invest proceeds of cash
dispositions of portfolio securities
solely in U.S. government securities,
cash equivalents, securities eligible for
purchase by a registered money market
fund with legal maturities not in excess
of 90 days and, if determined to be
necessary to protect the value of a
portfolio position in a rights offering or
other dilutive transaction, additional
securities of the affected issuer.
(2) The Fund will make liquidating
cash distributions pro rata at least
quarterly in an amount not less than all
cash proceeds from dispositions of
portfolio securities during such quarter
not required to provide for liabilities,
reserves, and for so long as the Board
determines that maintaining regulated
investment company status under
subchapter M of the Internal Revenue
Code of 1986, as amended, is important
for the protection of shareholders, the
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Fmt 4703
Sfmt 4703
79639
maintenance of diversification required
for such tax status.
(3) The Fund and the Adviser will
make and keep true, accurate and
current all appropriate records,
including but not limited to those
surrounding the events leading to the
requested relief, the plan for the orderly
liquidation of Fund assets, the sale of
Fund portfolio securities, the
distribution of Fund assets, and
communications with shareholders
(including any complaints from
shareholders and responses thereto).
(4) The Fund and the Adviser will
promptly make available to staff of the
Commission all files, books, records and
personnel as requested, relating to the
Fund and the Liquidating Trust.
(5) The Fund and the Adviser will
provide periodic reporting to
Commission staff regarding the status of
the liquidation and distributions.
(6) Neither the Adviser nor any of its
affiliates will receive any fee for
managing the Fund.
(7) The Fund is in liquidation and
will not be engaged and does not
propose to engage in any business
activities other than those necessary for
the protection of its assets, the
protection of shareholders and the
winding-up of its affairs.
(8) The Adviser will appropriately
convey accurate and timely information
to shareholders of the Fund with regard
to the status of the Fund and its
liquidation on the Adviser’s Web site,
including without limitation
information concerning the dates and
amounts of distributions, press releases,
and periodic reports, and will maintain
a toll-free number to respond to
shareholder inquiries.
(9) The Fund and the Adviser shall
consult with Commission staff prior to
making any material amendments to the
Plan of Liquidation.
(10) The Fund will comply with the
requirements of Section 30 of the Act
and the rules thereunder and will file a
report containing a liquidation audit,
i.e., audited financial statements dated
as of or near the final distribution date,
promptly following the Fund’s final
liquidating distribution.
(11) The Fund and the Adviser will
comply with all provisions of the
Federal securities laws.
(12) The relief granted pursuant to the
application shall be without prejudice
to, and shall not limit the Commission’s
rights in any manner with respect to,
any Commission investigation of, or
legal proceedings involving or against
the Applicants.
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Federal Register / Vol. 80, No. 245 / Tuesday, December 22, 2015 / Notices
Commission Finding
Based on the representations and
conditions in the application, the
Commission permits the temporary
suspension of the right of redemption
for the protection of the Fund’s security
holders. Under the circumstances
described in the application, which
require immediate action to protect the
Fund’s security holders, the
Commission concludes that it is not
practicable to give notice or an
opportunity to request a hearing before
issuing the order.
IT IS ORDERED, pursuant to Section
22(e)(3) of the Act, that the requested
relief from Section 22(e) of the Act is
granted with respect to the Fund until
it has liquidated, or until the
Commission rescinds the order granted
herein. This order shall be in effect as
of December 16, 2015, with suspension
of redemption requests as requested by
the Applicants to be effective as of
December 10, 2015.
By the Commission.
Brent J. Fields,
Secretary.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.5
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2015–32079 Filed 12–21–15; 8:45 am]
BILLING CODE 8011–01–P
[FR Doc. 2015–32050 Filed 12–21–15; 8:45 am]
SECURITIES AND EXCHANGE
COMMISSION
BILLING CODE 8011–01–P
[Release No. 34–76669; File No. SR–
NYSEMKT–2015–80]
Self-Regulatory Organizations; NYSE
MKT LLC; Notice of Designation of a
Longer Period for Commission Action
on Proposed Rule Change Deleting
Rule 410B—Equities Governing
Reporting Requirements for OffExchange Transactions
December 16, 2015.
mstockstill on DSK4VPTVN1PROD with NOTICES
change, or within such longer period up
to 90 days as the Commission may
designate if it finds such longer period
to be appropriate and publishes its
reasons for so finding or as to which the
self-regulatory organization consents,
the Commission shall either approve the
proposed rule change, disapprove the
proposed rule change, or institute
proceedings to determine whether the
proposed rule change should be
disapproved. The 45th day for this filing
is December 17, 2015. The Commission
is extending this 45-day time period.
The Commission finds it appropriate
to designate a longer period within
which to take action on the proposed
rule change, so that it has sufficient time
to consider this proposed rule change.
Accordingly, the Commission,
pursuant to Section 19(b)(2) of the Act,4
designates January 31, 2016, as the date
by which the Commission should either
approve or disapprove, or institute
proceedings to determine whether to
disapprove, the proposed rule change
(File No. SR–NYSEMKT–2015–80).
On October 16, 2015, NYSE MKT LLC
(the ‘‘Exchange’’ or ‘‘NYSE MKT’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to delete Rule 410B—Equities
governing reporting requirements for
off-Exchange transactions. The proposed
rule change was published for comment
in the Federal Register on November 2,
2015.3
Section 19(b)(2) of the Act 3 provides
that within 45 days of the publication of
notice of the filing of a proposed rule
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 76276
(October 27, 2015), 80 FR 67454.
3 15 U.S.C. 78s(b)(2).
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–76663; File No. SR–BX–
2015–078]
Self-Regulatory Organizations;
NASDAQ OMX BX, Inc.; Notice of Filing
and Immediate Effectiveness of
Proposed Rule Change Relating to
Order Exposure
December 16, 2015.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on December
2, 2015, NASDAQ OMX BX, Inc. (‘‘BX’’
or ‘‘Exchange’’) filed with the Securities
and Exchange Commission (‘‘SEC’’ or
‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III, below, which Items have been
prepared by the Exchange. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
VerDate Sep<11>2014
17:21 Dec 21, 2015
Jkt 238001
4 15
U.S.C. 78s(b)(2).
5 17 CFR 200.30–3(a)(31).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
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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
Exchange 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 these
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 aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to amend BX
Rules at Chapter VII, Section 12,
entitled ‘‘Order Exposure
Requirements’’ to specifically state that
orders entered into BX PRISM are not
subject to the rule at Section 12.
Recently, the Exchange’s BX PRISM rule
was approved by the Commission.3 BX
PRISM is a price-improvement
mechanism on the Exchange’s options
platform, in which a BX Participant (an
‘‘Initiating Participant’’) may
electronically submit for execution a
two-sided paired order, where one side
is an order it represents as agent on
behalf of a Public Customer,
Professional customer, broker-dealer, or
any other entity (‘‘PRISM Order’’) and
the other side is principal interest or
any other order it represents as agent (an
‘‘Initiating Order’’) provided that the
member first exposes the PRISM Order
in the PRISM Auction (‘‘Auction’’)
pursuant to the Rule. This mechanism is
3 See Securities Exchange Act Release No. 76301
(October 29, 2015), 80 FR 68347 (November 4, 2015)
(SR–BX–2015–032) (Order Granting Accelerated
Approval of a Proposed Rule Change, as Modified
by Amendment Nos. 1 and 2, To Adopt a New Price
Improvement Auction, BX PRISM).
1 15
2 17
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend BX
Rules at Chapter VII, Section 12,
entitled ‘‘Order Exposure
Requirements,’’ to make clear that BX
PRISM is an exception to this rule.
The text of the proposed rule change
is available on the Exchange’s Web site
at https://
nasdaqomxbx.cchwallstreet.com, at the
principal office of the Exchange, and at
the Commission’s Public Reference
Room.
Sfmt 4703
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Agencies
[Federal Register Volume 80, Number 245 (Tuesday, December 22, 2015)]
[Notices]
[Pages 79638-79640]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-32079]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-31943; 812-14593]
Third Avenue Trust and Third Avenue Management LLC; Notice of
Application and Temporary Order
December 16, 2015.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application and a temporary order under Section
22(e)(3) of the Investment Company Act of 1940 (the ``Act'').
-----------------------------------------------------------------------
Summary of Application: Applicants request a temporary order to permit
Third Avenue Focused Credit Fund (the ``Fund''), a series of Third
Avenue Trust (the ``Trust''), to suspend the right of redemption of its
outstanding redeemable securities.
Applicants: The Trust, on behalf of the Fund, and Third Avenue
Management LLC (the ``Adviser,'' together with the Trust, the
``Applicants'').
Filing Date: The application was filed on December 16, 2015.
Hearing or Notification of 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 January 7, 2016,
and should be accompanied by proof of service on Applicants, in the
form of an affidavit or, for lawyers, a certificate of service. Hearing
requests should state the nature of the writer's interest, 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 Third Avenue
Management LLC 622 Third Avenue, 32nd Floor, New York, NY 10017.
FOR FURTHER INFORMATION CONTACT: David Joire, Senior Special Counsel,
at (202) 551-6866 (Division of Investment Management, Chief Counsel's
Office).
SUPPLEMENTARY INFORMATION: 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.
Background
1. The Adviser is the investment adviser to the Fund. The Adviser
is a Delaware limited liability company that is registered as an
investment adviser under the Investment Advisers Act of 1940. The
Adviser managed assets of approximately $8 billion as of September 30,
2015.
2. The Trust is a Delaware statutory trust and is registered with
the Commission under the 1940 Act as an open-end management investment
company with five series. Each series of the Trust has a different
investment objective and different investment policies. The Fund is one
such series.
3. The Fund is a non-diversified open-end investment company. Its
investment objective is to seek long-term total return, which may
include investment returns from a combination of sources including
capital appreciation, fees and interest income.
4. The Fund has been subject to a significant level of redemption
requests by the Fund's investors over the past six months. For example,
the Fund has experienced a total of $1.1 billion in estimated net
outflows for the year to date through December 9, 2015, which was more
than 145% of its remaining net asset value at that date. In November
2015, the Fund experienced a total of $317 million in estimated net
redemptions, and the Fund's Institutional Class net asset value per
share fell from $7.81 to $7.08 and its Retail Class net asset value per
share fell from $7.82 to $7.09.
5. The ongoing reduction in liquidity in the Fund's portfolio
securities is related to a number of factors, including an imbalance
between selling interest and buying interest. The Fund increased its
cash position to over $200 million by early December 2015 in
anticipation of tax selling and other redemptions.
6. During this period, Fund management also kept the Board of
Trustees of the Trust (the ``Board'') informed and reevaluated
contingency plans. On December 9, 2015, after considering the
environment the Fund was in and the likelihood that incremental sales
of portfolio securities to satisfy additional redemptions would have to
be made at prices that would unfairly disadvantage all remaining
shareholders, the Board determined that the fairest action on behalf of
all shareholders would be to adopt a plan of liquidation. The Board
determined to implement this plan by placing the remaining noncash
assets in a liquidating trust for the benefit of all Fund shareholders
and distributing available cash. Relief from the Commission in
connection with the plan's implementation was not sought by the Fund
and the Adviser.
7. On December 9, 2015, the Board adopted a plan of liquidation for
the Fund (the ``Plan of Liquidation''), pursuant to which the Board
declared two distributions, one of the remaining net cash and one of
the beneficial interests in a liquidating trust (``Liquidating
Trust''). These distributions were scheduled to be paid on December 16,
2015. Interests in the Liquidating Trust would not trade and would, in
general, be transferable only by operation of law. The Adviser would
manage the Liquidating Trust's assets without charge and there would be
periodic distributions from the Liquidating Trust as income is received
and assets are sold at fair prices. All redemption requests as of
December 9, 2015, were met by the Fund and the sales of the shares of
the Fund were suspended as of December 10, 2015.
8. Upon announcement of the Plan of Liquidation, the Commission
staff expressed concerns during discussions with the Fund and the
Adviser. In
[[Page 79639]]
addition, the Fund received numerous inquiries from shareholders and
intermediaries through which many shareholders hold their shares in the
Fund. The Fund and the Adviser reviewed the pros and cons of
alternatives with the Board at meetings held on December 12, 2015 and
December 13, 2015, at which the Board authorized moving forward with an
application for an order to suspend redemptions. On December 14, 2015,
the Board met again and approved the cancellation and rescission of the
distribution of beneficial interests in the Liquidating Trust and the
reconveyance of the assets held in the Liquidating Trust to the Fund
together with the assumption by the Fund of the liabilities previously
assumed by the Liquidating Trust, conditioned upon receipt of the
requested relief. The Board did not rescind the cash distribution,
which will proceed on December 16, 2015, and also retained the Plan of
Liquidation, pursuant to which the Fund will liquidate.
9. Applicants state that approximately 65% of the value of the
Fund's shares is held by shareholders in the Fund's Institutional
Class, and the rest is held by investors in its Retail Class. If the
relief is not granted, and the Fund is unable to suspend redemptions,
the institutional investors would likely be best positioned to take
advantage of any redemption opportunity, to the detriment of those
investors--most likely, retail investors--who remain in the Fund. These
remaining investors would suffer a rapidly declining net asset value
and an even further diminished liquidity of the Fund's securities
portfolio. The relief would help avoid such an outcome.
10. Applicants also state that the Fund will not be engaged and
does not propose to engage, in any business activities other than those
necessary for the winding-up of its affairs. Applicants further state
that relief permitting the Fund to suspend redemptions in connection
with its liquidation would permit the Fund to liquidate its assets in
an orderly manner and prevent the Fund from being forced to sell assets
at unreasonably low prices to meet redemptions.
Applicants' Legal Analysis
1. Section 22(e)(1) of the Act provides that a registered
investment company may not suspend the right of redemption or postpone
the date of payment or satisfaction upon redemption of any redeemable
security in accordance with its terms for more than seven days after
the tender of such security to the company or its designated agent
except for any period during which the New York Stock Exchange
(``NYSE'') is closed other than customary week-end and holiday
closings, or during which trading on the NYSE is restricted.
2. Section 22(e)(3) of the Act provides that redemptions may be
suspended by a registered investment company for such other periods as
the Commission may by order permit for the protection of security
holders of the registered investment company.
3. Applicants submit that granting the requested relief would be
for the protection of the shareholders of the Fund, as provided in
Section 22(e)(3) of the Act. Applicants assert that, in requesting an
order by the Commission, the Board's goal is to ensure that the Fund's
shareholders will be treated appropriately in view of the otherwise
detrimental effect on the Fund of the ongoing reduction in the
liquidity of the Fund's portfolio securities, the very recent extreme
difficulty the Fund has encountered in selling portfolio securities at
prices the Adviser deemed to be fair and the ongoing redemptions that
the Fund expected. Applicants further state that the requested relief
is intended to permit an orderly liquidation of the portfolio
securities at what Applicants consider to be fair values and ensure
that all of the shareholders of the Fund are protected in the process
by allowing the realization of fair value for these investments.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
(1) Pending liquidating distributions, the Fund will invest
proceeds of cash dispositions of portfolio securities solely in U.S.
government securities, cash equivalents, securities eligible for
purchase by a registered money market fund with legal maturities not in
excess of 90 days and, if determined to be necessary to protect the
value of a portfolio position in a rights offering or other dilutive
transaction, additional securities of the affected issuer.
(2) The Fund will make liquidating cash distributions pro rata at
least quarterly in an amount not less than all cash proceeds from
dispositions of portfolio securities during such quarter not required
to provide for liabilities, reserves, and for so long as the Board
determines that maintaining regulated investment company status under
subchapter M of the Internal Revenue Code of 1986, as amended, is
important for the protection of shareholders, the maintenance of
diversification required for such tax status.
(3) The Fund and the Adviser will make and keep true, accurate and
current all appropriate records, including but not limited to those
surrounding the events leading to the requested relief, the plan for
the orderly liquidation of Fund assets, the sale of Fund portfolio
securities, the distribution of Fund assets, and communications with
shareholders (including any complaints from shareholders and responses
thereto).
(4) The Fund and the Adviser will promptly make available to staff
of the Commission all files, books, records and personnel as requested,
relating to the Fund and the Liquidating Trust.
(5) The Fund and the Adviser will provide periodic reporting to
Commission staff regarding the status of the liquidation and
distributions.
(6) Neither the Adviser nor any of its affiliates will receive any
fee for managing the Fund.
(7) The Fund is in liquidation and will not be engaged and does not
propose to engage in any business activities other than those necessary
for the protection of its assets, the protection of shareholders and
the winding-up of its affairs.
(8) The Adviser will appropriately convey accurate and timely
information to shareholders of the Fund with regard to the status of
the Fund and its liquidation on the Adviser's Web site, including
without limitation information concerning the dates and amounts of
distributions, press releases, and periodic reports, and will maintain
a toll-free number to respond to shareholder inquiries.
(9) The Fund and the Adviser shall consult with Commission staff
prior to making any material amendments to the Plan of Liquidation.
(10) The Fund will comply with the requirements of Section 30 of
the Act and the rules thereunder and will file a report containing a
liquidation audit, i.e., audited financial statements dated as of or
near the final distribution date, promptly following the Fund's final
liquidating distribution.
(11) The Fund and the Adviser will comply with all provisions of
the Federal securities laws.
(12) The relief granted pursuant to the application shall be
without prejudice to, and shall not limit the Commission's rights in
any manner with respect to, any Commission investigation of, or legal
proceedings involving or against the Applicants.
[[Page 79640]]
Commission Finding
Based on the representations and conditions in the application, the
Commission permits the temporary suspension of the right of redemption
for the protection of the Fund's security holders. Under the
circumstances described in the application, which require immediate
action to protect the Fund's security holders, the Commission concludes
that it is not practicable to give notice or an opportunity to request
a hearing before issuing the order.
IT IS ORDERED, pursuant to Section 22(e)(3) of the Act, that the
requested relief from Section 22(e) of the Act is granted with respect
to the Fund until it has liquidated, or until the Commission rescinds
the order granted herein. This order shall be in effect as of December
16, 2015, with suspension of redemption requests as requested by the
Applicants to be effective as of December 10, 2015.
By the Commission.
Brent J. Fields,
Secretary.
[FR Doc. 2015-32079 Filed 12-21-15; 8:45 am]
BILLING CODE 8011-01-P