NexPoint Capital, Inc., et al.; Notice of Application, 17741-17746 [2016-07101]
Download as PDF
Federal Register / Vol. 81, No. 61 / Wednesday, March 30, 2016 / Notices
INFORMATION CONTACT
17741
provided to the Commission in May
2016).
Because of the schedule for
development of the plan, the NRC will
not issue a comment response document
providing formal written responses to
comments which are received.
The NRC will post all comment
submissions at https://
www.regulations.gov as well as enter the
comment submissions into ADAMS.
The NRC does not routinely edit
comment submissions to remove
identifying or contact information.
If you are requesting or aggregating
comments from other persons for
submission to the NRC, then you should
inform those persons not to include
identifying or contact information that
they do not want to be publicly
disclosed in their comment submission.
Your request should state that the NRC
does not routinely edit comment
submissions to remove such information
before making the comment
submissions available to the public or
entering the comment into ADAMS.
I. Obtaining Information and
Submitting Comments
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section of this
document.
• Mail comments to: Cindy Bladey,
Office of Administration, Mail Stop:
OWFN–12–H08, U.S. Nuclear
Regulatory Commission, Washington,
DC 20555–0001.
For additional direction on obtaining
information and submitting comments,
see ‘‘Obtaining Information and
Submitting Comments’’ in the
SUPPLEMENTARY INFORMATION section of
this document.
FOR FURTHER INFORMATION CONTACT:
Todd Keene, Office of Nuclear Reactor
Regulation, U.S. Nuclear Regulatory
Commission, Washington, DC 20555–
0001; telephone: 301–415–1994; email:
Todd.Keene@nrc.gov.
SUPPLEMENTARY INFORMATION:
II. Background
[Release No. IC–32048; File No. 812–14430]
The NRC is requesting public
comments on a preliminary draft action
plan in an effort to gain an
understanding of stakeholder
perspectives of the digital I&C
regulatory challenges, priorities and
potential solutions. The development of
this action plan was directed by the
Commission in SRM–15–0106 (February
25, 2016) (ADAMS Accession No.
ML16056A614). In order to reach the
widest audience, the action plan will be
provided via email and posted on the
NRC public Web site, as well as
published in the Federal Register.
Additionally, a public meeting on the
preliminary draft action plan will be
held on March 30, 2016, at NRC
Headquarters. Additional information
concerning the public meeting can be
found on NRC’s Public Meeting
Schedule Web page; https://
meetings.nrc.gov/pmns/mtg.
The NRC staff has developed the
preliminary draft action plan to provide
a strategy to modernize the digital I&C
regulatory infrastructure in order to
improve the predictability and
consistency of the process for licensing
and oversight of industry stakeholders.
Improvements and modernization of the
NRC’s digital I&C regulatory processes
will improve efficiency of the oversight
of licensee implementation of digital
I&C equipment.
This preliminary draft action plan has
not been subject to all levels of NRC
management review. Accordingly, it
may be incomplete or in error in one or
more respects and may be subject to
further revision before the staff presents
an action plan regarding an integrated
strategy to modernize the NRC’s digital
instrumentation and controls regulatory
infrastructure to the Commission in a
SECY paper (currently scheduled to be
NexPoint Capital, Inc., et al.; Notice of
Application
A. Obtaining Information
Please refer to Docket ID NRC–2016–
0068 when contacting the NRC about
the availability of information for this
action. You may obtain publiclyavailable information related to this
action by any of the following methods:
• Federal Rulemaking Web site: Go to
https://www.regulations.gov and search
for Docket ID NRC–2016–0068.
• NRC’s Agencywide Documents
Access and Management System
(ADAMS): You may obtain publiclyavailable documents online in the
ADAMS Public Documents collection at
https://www.nrc.gov/reading-rm/
adams.html. To begin the search, select
‘‘ADAMS Public Documents’’ and then
select ‘‘Begin Web-based ADAMS
Search.’’ For problems with ADAMS,
please contact the NRC’s Public
Document Room (PDR) reference staff at
1–800–397–4209, 301–415–4737, or by
email to pdr.resource@nrc.gov. The
ADAMS accession number for each
document referenced in this notice (if
that document is available in ADAMS)
is provided the first time that a
document is referenced. The
preliminary draft action plan is
available in ADAMS under Accession
No. ML16075A466.
• NRC’s PDR: You may examine and
purchase copies of public documents at
the NRC’s PDR, Room O1–F21, One
White Flint North, 11555 Rockville
Pike, Rockville, Maryland 20852.
B. Submitting Comments
Please include Docket ID NRC–2016–
0068 in your comment submission.
The NRC cautions you not to include
identifying or contact information that
you do not want to be publicly
disclosed in your comment submission.
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Dated at Rockville, Maryland, this 24th day
of March, 2016.
For the Nuclear Regulatory Commission.
Sheldon D. Stuchell,
Chief, Generic Communications Branch,
Division of Policy and Rulemaking, Office
of Nuclear Reactor Regulation.
[FR Doc. 2016–07112 Filed 3–29–16; 8:45 am]
BILLING CODE 7590–01–P
SECURITIES AND EXCHANGE
COMMISSION
March 24, 2016.
AGENCY:
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under section 17(d) and section
57(i) of the Investment Company Act of
1940 (the ‘‘Act’’) and rule 17d–1 under
the Act to permit certain joint
transactions otherwise prohibited by
section 17(d) and section 57(a)(4) of the
Act and rule 17d–1 under the Act.
SUMMARY OF APPLICATION:
Applicants
request an order to permit a business
development company (‘‘BDC’’) and a
closed-end management investment
company to co-invest in portfolio
companies with each other and with
certain affiliated investment funds.
APPLICANTS: NexPoint Capital, Inc.
(‘‘NexPoint Capital’’), NexPoint Credit
Strategies Fund (‘‘NHF’’) (each of
NexPoint Capital and NHF, an ‘‘Existing
Investment Company’’ and collectively,
the ‘‘Existing Investment Companies’’),
NexPoint Advisors, L.P. (‘‘NexPoint
Advisors’’), Highland Multi Strategy
Credit Fund, L.P. (‘‘HMSCF’’) and
Highland Capital Healthcare Partners
(Master), L.P. (‘‘HCHP’’ and, collectively
with HMSCF, the ‘‘Existing Private
Funds’’), Highland Capital Management,
L.P., Highland Capital Healthcare
Advisors, L.P. and Acis Capital
Management, L.P. (each, a ‘‘Current
Adviser to Private Funds’’ and,
collectively, the ‘‘Current Advisers to
Private Funds,’’ and, the Current
Advisers to Private Funds collectively
with the Existing Investment
Companies, NexPoint Advisors and the
Existing Private Funds, the
‘‘Applicants’’).
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FILING DATES:
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The application was filed
on March 6, 2015 and amended on
August 28, 2015, December 21, 2015,
March 11, 2016, and March 18, 2016.
HEARING OR NOTIFICATION OF HEARING: An
order granting the requested relief will
be issued unless the Commission orders
a hearing. Interested persons may
request a hearing by writing to the
Commission’s Secretary and serving
applicants with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on April 18, 2016, 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 St.
NE., Washington, DC 20549–1090.
Applicants: 300 Crescent Court, Suite
700, Dallas, Texas 75201.
FOR FURTHER INFORMATION CONTACT: Jill
Ehrlich, Senior Counsel, at (202) 551–
6819, or Mary Kay Frech, Branch Chief,
at (202) 551–6821 (Division of
Investment Management, Chief
Counsel’s Office).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or for an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
Applicants’ Representations
1. NexPoint Capital, a Delaware
corporation, is an externally managed,
non-diversified, closed-end
management investment company that
has elected to be regulated as a BDC
under the Act.1 NexPoint Capital’s
investment objective is to generate
current income and capital appreciation
primarily through investments in
middle-market healthcare companies,
middle-market companies in nonhealthcare sectors, syndicated floating
rate debt of large nonpublic and public
1 Section 2(a)(48) defines a BDC to be any closedend investment company that operates for the
purpose of making investments in securities
described in sections 55(a)(1) through 55(a)(3) of the
Act and makes available significant managerial
assistance with respect to the issuers of such
securities.
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companies and collateralized loan
obligations. NexPoint Capital’s board of
directors currently consists of six
members, five of whom are not
‘‘interested persons’’ of NexPoint
Capital within the meaning of section
2(a)(19) of the Act (the ‘‘Independent
Directors’’).
2. NHF, a Delaware statutory trust, is
an externally managed, non-diversified,
closed-end management investment
company registered under the Act.
NHF’s investment objective is to
generate current income and capital
appreciation primarily through
investments in: (i) Secured and
unsecured floating and fixed rate loans;
(ii) bonds and other debt obligations;
(iii) debt obligations of stressed,
distressed and bankrupt issuers; (iv)
structured products, including but not
limited to, mortgage-backed and other
asset-backed securities and
collateralized debt obligations; and (v)
equities. NHF’s board of trustees
currently consists of six members, five
of whom are not ‘‘interested persons’’ of
NHF within the meaning of section
2(a)(19) of the Act (the ‘‘Independent
Trustees’’).
3. NexPoint Advisors, a Delaware
limited partnership, is registered under
the Investment Advisers Act of 1940
(‘‘Advisers Act’’) and is the investment
adviser of NexPoint Capital and NHF.
4. The Existing Private Funds are
entities formed under the laws of
Delaware or under the laws of the
Cayman Islands. In reliance on the
exclusion from the definition of
‘‘investment company’’ provided by
section 3(c)(1) or 3(c)(7) of the Act,
neither of the Existing Private Funds
will be registered under the Act.
Highland Capital Management, L.P.,
registered as an investment adviser
under the Advisers Act, serves as the
investment adviser to HMSCF, and Acis
Capital Management, L.P., registered as
an investment adviser under the
Advisers Act, serves as the investment
sub-adviser to HMSCF. Highland
Capital Healthcare Advisors, L.P.,
registered as an investment adviser
under the Advisers Act, serves as the
investment adviser to HCHP. NexPoint
Advisors expects that certain portfolio
companies that are appropriate
investments for a Private Fund 2 may
2 ‘‘Private Fund’’ means any Existing Private
Fund or any entity (a) whose investment adviser is
an Adviser, (b) that would be an investment
company but for section 3(c)(1) or 3(c)(7) of the Act,
and (c) that intends to participate in the CoInvestment Program (as defined below). ‘‘Adviser’’
means (a) NexPoint Advisors, (b) the Current
Advisers to Private Funds, and (c) any future
investment adviser that controls, is controlled by or
is under common control with any of NexPoint
Advisors or the Current Advisers to Private Funds
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also be appropriate for one or more
Investment Companies,3 with certain
exceptions based on available capital or
diversification.
5. Applicants seek an order
(‘‘Order’’) 4 to allow an Investment
Company to co-invest in the same
issuers of securities with one or more
other Investment Companies or Private
Funds (the ‘‘Co-Investment Program’’)
with which it may be prohibited from
co-investing by reason of section 17(d)
or section 57 of the Act. For purposes
of the application, a ‘‘Co-Investment
Transaction’’ means any transaction in
which an Investment Company (or one
of its Wholly Owned Investment
Subsidiaries, as defined below)
participates together with one or more
other Investment Companies and/or
Private Funds in reliance on the
requested Order. ‘‘Potential CoInvestment Transaction’’ means any
investment opportunity in which an
Investment Company (or a Wholly
Owned Investment Subsidiary) could
not participate together with one or
more other Investment Companies and/
or Private Funds without obtaining and
relying on the Order.
6. Each of the Investment Companies
may, from time to time and as
applicable, form a special purpose
subsidiary (a ‘‘Wholly-Owned
Investment Subsidiary’’).5 WhollyOwned Investment Subsidiaries would
be prohibited from investing in a Coand is registered as an investment adviser under the
Advisers Act.
3 The term ‘‘Investment Company’’ means any
Existing Investment Company and any future
closed-end investment company that (a) is
registered under the Act or has elected to be
regulated as a BDC under the Act, (b) will be
advised by an Adviser, and (c) that intends to
participate in the Co-Investment Program.
4 All existing entities that currently intend to rely
on the Order have been named as Applicants and
any entities that may rely on the Order in the future
will comply with the terms and conditions of the
application.
5 The term ‘‘Wholly-Owned Investment
Subsidiary’’ means an entity (a) whose sole
business purpose is to hold one or more
investments and issue debt on behalf of such
Investment Company, to obtain debt financing for
those investments and, in the case of a Wholly
Owned Investment Subsidiary organized as a small
business investment company under the Small
Business Investment Act of 1958 (‘‘SBA Act’’), to
maintain a license under the SBA Act and issue
debentures guaranteed by the Small Business
Administration; (b) that is wholly owned by such
Investment Company (with the applicable
Investment Company at all times holding directly
or indirectly, beneficially and of record, 100% of
the voting and economic interests); (c) with respect
to which the board of directors or board of trustees,
as applicable, of such Investment Company has the
sole authority to make all determinations with
respect to the Wholly Owned Investment
Subsidiary’s participation under the conditions to
the application; and (d) that is an entity that would
be an investment company but for section 3(c)(1) or
3(c)(7) of the Act.
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Investment Transaction with any other
Investment Company or Private Fund
because the Wholly-Owned Investment
Subsidiary would be a company
controlled by the applicable Investment
Company for purposes of section 17(d)
and section 57(a)(4) and rule 17d–1.
Applicants request that any Wholly
Owned Investment Subsidiary be
permitted to participate in CoInvestment Transactions in lieu of the
Investment Company of which it is a
subsidiary and that the participation in
any such transaction by any Wholly
Owned Investment Subsidiary be
treated, for purposes of the Order, as
though the Investment Company of
which it is a subsidiary were
participating directly. Applicants
represent that this treatment is justified
because any Wholly Owned Investment
Subsidiary would have no purpose
other than serving as a holding and
financing vehicle for the applicable
Investment Company’s investments and,
therefore, no conflicts of interest could
arise between an Investment Company
and its Wholly Owned Investment
Subsidiary. The board of directors or
board of trustees, as applicable, of an
Investment Company would make all
relevant determinations under the
conditions with regard to the
participation of such Investment
Company’s Wholly Owned Investment
Subsidiary in a Co-Investment
Transaction, and the board of directors
or the board of trustees, as applicable,
of an Investment Company would be
informed of, and take into
consideration, any proposed use of any
Wholly Owned Investment Subsidiary
in such Investment Company’s place. If
an Investment Company proposes to
participate in the same Co-Investment
Transaction with any of its Wholly
Owned Investment Subsidiaries, the
board of directors or the board of
trustees, as applicable, of such
Investment Company will also be
informed of, and take into
consideration, the relative participation
of the Investment Company and the
Wholly Owned Investment Subsidiary.
7. Applicants represent that the
Adviser of another Investment Company
or a Private Fund will refer to the
Adviser of an Investment Company all
Potential Co-Investment Transactions
within such Investment Company’s
Objectives and Strategies 6 that are
6 ‘‘Objectives and Strategies’’ means the
Investment Company’s investment objectives and
strategies, as described in its registration statement
on Form N–2 and other filings made with the
Commission by such Investment Company under
the Securities Act of 1933, as amended (‘‘1933
Act’’), or the Act, any reports filed by such
Investment Company with the Commission under
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considered for such other Investment
Company or Private Fund, and such
investment opportunities may result in
a Co-Investment Transaction. For each
such referral, the applicable Adviser
will consider the investment objective,
investment policies, investment
position, investment strategies,
investment restrictions, regulatory and
tax requirements, capital available for
investment and other pertinent factors
applicable to such Investment
Company. Likewise, when selecting
investments for a Private Fund, the
applicable Adviser to the Private Fund
will select investments separately for
the Private Fund, considering the
investment objective, investment
policies, investment position,
investment strategies, investment
restrictions, regulatory and tax
requirements, capital available for
investment and other pertinent factors
applicable to such Private Fund. Each
Co-Investment Transaction and the
proposed allocation of such CoInvestment Transaction would be
approved prior to the actual investment
by the required majority (within the
meaning of section 57(o) of the Act) (the
‘‘Required Majority’’) 7 of the Investment
Company’s board of directors or board
of trustees, as applicable.
8. Other than pro rata dispositions
and follow-on investments 8 as provided
in conditions 7 and 8, and after making
the determinations required in
conditions 1 and 2(a), the applicable
Adviser will present each Potential CoInvestment Transaction and the
proposed allocation to the directors or
trustees of the applicable Investment
Company who are eligible to vote under
section 57(o) of the Act (‘‘Eligible
Directors’’), and the Required Majority
will approve each Co-Investment
Transaction prior to any investment by
such Investment Company.
9. With respect to the pro rata
dispositions and follow-on investments
provided in conditions 7 and 8, the
Investment Companies may participate
in a pro rata disposition or follow-on
investment without obtaining prior
approval of the Required Majority if,
among other things: (i) The proposed
participation of such Investment
the Securities Exchange Act of 1934, as amended,
or the Act and such Investment Company’s reports
to stockholders.
7 In the case of an Investment Company that is a
registered closed-end fund, the directors or trustees
that make up the Required Majority will be
determined as if the Investment Company were a
BDC subject to section 57(o).
8 ‘‘Follow-on investment’’ means an additional
investment in an existing portfolio company,
including through the exercise of warrants,
conversion privileges or other rights to acquire
securities of the portfolio company.
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Company and each other Investment
Company or Private Fund in such
disposition or follow-on investment is
proportionate to its outstanding
investments in the issuer immediately
preceding the disposition or follow-on
investment, as the case may be; and (ii)
the board of directors or board of
trustees, as applicable, of the Investment
Company has approved such Investment
Company’s participation in pro rata
dispositions and follow-on investments
as being in the best interests of the
Investment Company. If such board
does not so approve, any such
disposition or follow-on investment will
be submitted to the Investment
Company’s Eligible Directors. The board
of directors or board of trustees, as
applicable, of an Investment Company
may at any time rescind, suspend or
qualify its approval of pro rata
dispositions and follow-on investments,
with the result that all dispositions and/
or follow-on investments must be
submitted to the Eligible Directors of
such Investment Company.
10. No Independent Director or
Independent Trustee of an Investment
Company will have a financial interest
in any Co-Investment Transaction, other
than indirectly through share ownership
in the Investment Company.
11. Under condition 14, if NexPoint
Advisors or its principals, or any person
controlling, controlled by, or under
common control with NexPoint
Advisors or its principals, and the
Private Funds (collectively, the
‘‘Holders’’) own in the aggregate more
than 25 percent of the outstanding
voting shares of an Investment Company
(the ‘‘Shares’’), then the Holders will
vote such Shares as directed by an
independent third party when voting on
matters specified in the condition.
Applicants believe that this condition
will ensure that the Independent
Directors or Independent Trustees will
act independently in evaluating the CoInvestment Program, because the ability
of NexPoint Advisors or its principals to
influence the Independent Directors or
Independent Trustees by a suggestion,
explicit or implied, that the
Independent Directors or Independent
Trustees can be removed will be limited
significantly. Applicants represent that
the Independent Directors or
Independent Trustees shall evaluate and
approve any independent third party,
taking into account its qualifications,
reputation for independence, cost to the
shareholders, and other factors that they
deem relevant.
Applicants’ Legal Analysis
1. Section 17(d) of the Act and rule
17d–1 under the Act prohibit affiliated
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persons of a registered investment
company from participating in joint
transactions with the company or a
company controlled by such company
unless the Commission has granted an
order permitting such transactions.
Section 57(a)(4) of the Act prohibits
certain affiliated persons of a BDC from
participating in joint transactions with
the BDC (or a company controlled by
such company) in contravention of rules
as prescribed by the Commission.
Section 57(i) of the Act provides that,
until the Commission prescribes rules
under section 57(a)(4), the
Commission’s rules under section 17(d)
of the Act applicable to registered
closed-end investment companies will
be deemed to apply to BDCs. Because
the Commission has not adopted any
rules under section 57(a)(4), rule 17d–1
applies to BDCs. NexPoint Advisors and
any other Investment Company or
Private Fund that it advises could be
deemed to be persons related to an
Investment Company in a manner
described by section 2(a)(3) or section
57(b), as applicable, and, therefore,
prohibited by section 17(d) or section
57(a)(4), as applicable, and rule 17d–1
from participating in the Co-Investment
Program. In addition, because the other
Advisers are ‘‘affiliated persons’’ of
NexPoint Advisors, such Advisers and
the Investment Companies and Private
Funds advised by any of them could be
deemed to be persons related to such
Investment Company in a manner
described by section 2(a)(3) or section
57(b), as applicable, and also prohibited
from participating in the Co-Investment
Program. Finally, because any Wholly
Owned Investment Subsidiary will be
controlled by an Investment Company,
it will subject to section 17(d) or section
57(a)(4), and thus also subject to the
provisions of rule 17d–1.
2. Rule 17d–1, as made applicable to
BDCs by section 57(i), prohibits any
person who is related to a BDC in a
manner described in section 57(b),
acting as principal, from participating
in, or effecting any transaction in
connection with, any joint enterprise or
other joint arrangement or profit-sharing
plan in which the BDC is a participant,
absent an order from the Commission.
In passing upon applications under rule
17d–1, the Commission considers
whether the company’s participation in
the joint transaction is consistent with
the provisions, policies, and purposes of
the Act and the extent to which such
participation is on a basis different from
or less advantageous than that of other
participants.
3. Applicants state that they expect
that co-investment in portfolio
companies by the Investment
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Companies and the Private Funds will
increase favorable investment
opportunities for each participant.
4. Applicants submit that the fact that
the Required Majority will approve each
Co-Investment Transaction before
investment, and other protective
conditions set forth in the application,
will ensure that each Investment
Company will be treated fairly.
Applicants state that each Investment
Company’s participation in the CoInvestment Transactions will be
consistent with the provisions, policies,
and purposes of the Act and on a basis
that is not different from, or less
advantageous than, that of the other
Investment Companies or the Private
Funds.
Applicants’ Conditions
Applicants agree that any order
granting the requested relief will be
subject to the following conditions:
1. Each time an Adviser considers a
Potential Co-Investment Transaction for
a Private Fund or another Investment
Company that falls within an
Investment Company’s then-current
Objectives and Strategies, the
Investment Company’s Adviser will
make an independent determination of
the appropriateness of such investment
for such Investment Company in light of
such Investment Company’s thencurrent circumstances.
2. (a) If the applicable Adviser deems
an Investment Company’s participation
in any Potential Co-Investment
Transaction to be appropriate for such
Investment Company, it will then
determine an appropriate level of
investment for such Investment
Company;
(b) If the aggregate amount
recommended by the applicable Adviser
to be invested in such Potential CoInvestment Transaction by an
Investment Company, together with the
amount proposed to be invested by the
other participating Investment
Companies and Private Funds,
collectively, in the same transaction,
exceeds the amount of the investment
opportunity, then the investment
opportunity will be allocated among
them pro rata based on each
participating party’s capital available for
investment in the asset class being
allocated, up to the amount proposed to
be invested by each party. The
applicable Adviser will provide the
Eligible Directors of each participating
Investment Company with information
concerning each participating party’s
available capital to assist the Eligible
Directors with their review of such
Investment Company’s investments for
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compliance with these allocation
procedures; and
(c) After making the determinations
required in conditions 1 and 2(a), the
applicable Adviser will distribute
written information concerning the
Potential Co-Investment Transaction,
including the amount proposed to be
invested by each Investment Company
and each Private Fund, to the Eligible
Directors of each participating
Investment Company for their
consideration. An Investment Company
will co-invest with one or more other
Investment Companies and/or Private
Funds only if, prior to the Investment
Company’s participation in the Potential
Co-Investment Transaction, the
Required Majority concludes that:
(i) The terms of the Potential CoInvestment Transaction, including the
consideration to be paid, are reasonable
and fair to such Investment Company
and its stockholders and do not involve
overreaching in respect of such
Investment Company or its stockholders
on the part of any person concerned;
(ii) the Potential Co-Investment
Transaction is consistent with:
(A) The interests of the stockholders
of such Investment Company; and
(B) such Investment Company’s thencurrent Objectives and Strategies;
(iii) the investment by another
Investment Company or any Private
Fund would not disadvantage such
Investment Company, and participation
by such Investment Company would not
be on a basis different from, or less
advantageous than, that of any other
Investment Company or Private Fund;
provided, that if any other Investment
Company or Private Fund, but not such
Investment Company itself, gains the
right to nominate a director for election
to a portfolio company’s board of
directors or the right to have a board
observer or any similar right to
participate in the governance or
management of the portfolio company,
such event will not be interpreted to
prohibit the Required Majority from
reaching the conclusions required by
this condition (2)(c)(iii), if
(A) The Eligible Directors will have
the right to ratify the selection of such
director or board observer, if any;
(B) the Advisers agree to, and do,
provide periodic reports to each
Investment Company’s board of
directors or board of trustees, as
applicable, with respect to the actions of
such director or the information
received by such board observer or
obtained through the exercise of any
similar right to participate in the
governance or management of the
portfolio company; and
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(C) any fees or other compensation
that any other Investment Company,
Private Fund or any affiliated person of
another Investment Company or Private
Fund receives in connection with the
right of such other Investment Company
or Private Fund to nominate a director
or appoint a board observer or otherwise
to participate in the governance or
management of the portfolio company
will be shared proportionately among
the participating Private Funds (which
each may, in turn, share their portion
with their affiliated persons) and the
participating Investment Companies in
accordance with the amount of each
party’s investment; and
(iv) the proposed investment by the
Investment Company will not benefit
the other Investment Companies, the
Advisers, the Private Funds or any
affiliated person of any of them (other
than the parties to the Co-Investment
Transaction), except (A) to the extent
permitted by condition 13; (B) to the
extent permitted by sections 17(e) or
57(k) of the Act, as applicable; (C)
indirectly, as a result of an interest in
the securities issued by one of the
parties to the Co-Investment
Transaction; or (D) in the case of fees or
other compensation described in
condition 2(c)(iii)(C).
3. Each Investment Company has the
right to decline to participate in any
Potential Co-Investment Transaction or
to invest less than the amount proposed.
4. The applicable Adviser will present
to the board of directors or the board of
trustees, as applicable, of each
Investment Company, on a quarterly
basis, a record of all investments in
Potential Co-Investment Transactions
made by any of the other Investment
Companies and the Private Funds
during the preceding quarter that fell
within such Investment Company’s
then-current Objectives and Strategies
that were not made available to such
Investment Company and an
explanation of why the investment
opportunities were not offered to such
Investment Company. All information
presented to a board pursuant to this
condition will be kept for the life of
such Investment Company and at least
two years thereafter, and will be subject
to examination by the Commission and
its staff.
5. Except for follow-on investments
made in accordance with condition 8,9
an Investment Company will not invest
in reliance on the Order in any issuer in
which any other Investment Company,
9 This exception applies only to follow-on
investments by an Investment Company in issuers
in which that Investment Company already holds
investments.
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18:06 Mar 29, 2016
Jkt 238001
Private Fund or any affiliated person of
another Investment Company or Private
Fund is an existing investor.
6. An Investment Company will not
participate in any Potential CoInvestment Transaction unless the
terms, conditions, price, class of
securities to be purchased, settlement
date and registration rights will be the
same for each participating Investment
Company and Private Fund. The grant
to another participant, but not such
Investment Company, of the right to
nominate a director for election to a
portfolio company’s board of directors,
the right to have an observer on the
board of directors or similar rights to
participate in the governance or
management of the portfolio company
will not be interpreted so as to violate
this condition 6, if conditions
2(c)(iii)(A), (B) and (C) are met.
7. (a) If any Investment Company or
Private Fund elects to sell, exchange or
otherwise dispose of an interest in a
security that was acquired in a CoInvestment Transaction, the applicable
Advisers will:
(i) Notify each Investment Company
that participated in the Co-Investment
Transaction of the proposed disposition
at the earliest practical time; and
(ii) formulate a recommendation as to
participation by such Investment
Company in any such disposition.
(b) Each Investment Company will
have the right to participate in such
disposition on a proportionate basis, at
the same price and on the same terms
and conditions as those applicable to
any participating Private Funds and
other participating Investment
Companies.
(c) An Investment Company may
participate in such disposition without
obtaining prior approval of the Required
Majority if: (i) The proposed
participation of such Investment
Company and of each other participant
in such disposition is proportionate to
its outstanding investment in the issuer
immediately preceding the disposition;
(ii) the board of directors or board of
trustees, as applicable, of such
Investment Company has approved as
being in the best interests of such
Investment Company the ability to
participate in such dispositions on a pro
rata basis (as described in greater detail
in the application); and (iii) such board
is provided on a quarterly basis with a
list of all dispositions made in
accordance with this condition. In all
other cases, the applicable Adviser will
provide its written recommendation as
to an Investment Company’s
participation to the Eligible Directors of
such Investment Company, and the
Investment Company will participate in
PO 00000
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Sfmt 4703
17745
such disposition solely to the extent that
the Required Majority determines that it
is in the Investment Company’s best
interests.
(d) Each Investment Company and
each other participant will bear its own
expenses in connection with any such
disposition.
8. (a) If any Investment Company or
Private Fund desires to make a followon investment in a portfolio company
whose securities were acquired in a CoInvestment Transaction, the applicable
Advisers will:
(i) Notify each Investment Company
that participated in the Co-Investment
Transaction of the proposed transaction
at the earliest practical time; and
(ii) formulate a recommendation as to
the proposed participation, including
the amount of the proposed follow-on
investment, by such Investment
Company.
(b) Such Investment Company may
participate in such follow-on
investment without obtaining prior
approval of the Required Majority if: (i)
The proposed participation of each
Investment Company and each Private
Fund in such investment is
proportionate to its outstanding
investment in the issuer immediately
preceding the follow-on investment; (ii)
the board of directors or board of
trustees, as applicable, of such
Investment Company has approved as
being in the best interests of such
Investment Company the ability to
participate in follow-on investments on
a pro rata basis (as described in greater
detail in the application); and (iii) such
board is provided on a quarterly basis
with a list of all follow on investments
made in accordance with this condition.
In all other cases, the applicable Adviser
will provide its written
recommendation as to such Investment
Company’s participation to the Eligible
Directors, and such Investment
Company will participate in such
follow-on investment solely to the
extent that the Required Majority
determines that it is in such Investment
Company’s best interests.
(c) If with respect to any follow-on
investment:
(i) The amount of the opportunity is
not based on the Investment Companies’
and the Private Funds’ outstanding
investments immediately preceding the
follow-on investment; and
(ii) the aggregate amount
recommended by the applicable Adviser
to be invested by each Investment
Company in the follow-on investment,
together with the amount proposed to be
invested by the participating Private
Funds in the same transaction, exceeds
the amount of the opportunity, then the
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amount to be invested by each such
party will be allocated among them pro
rata based on each participating party’s
capital available for investment in the
asset class being allocated, up to the
amount proposed to be invested by
each.
(d) The acquisition of follow-on
investments as permitted by this
condition will be considered a CoInvestment Transaction for all purposes
and subject to the other conditions set
forth in the application.
9. The Independent Directors or
Independent Trustees, as applicable, of
each Investment Company will be
provided quarterly for review all
information concerning Potential CoInvestment Transactions and CoInvestment Transactions, including
investments made by the other
Investment Companies and the Private
Funds that the applicable Investment
Company considered but declined to
participate in, so that the Independent
Directors or Independent Trustees, as
applicable, may determine whether all
investments made during the preceding
quarter, including those investments
which the applicable Investment
Company considered but declined to
participate in, comply with the
conditions of the Order. In addition, the
Independent Directors or Independent
Trustees, as applicable, will consider at
least annually the continued
appropriateness for such Investment
Company of participating in new and
existing Co-Investment Transactions.
10. The Investment Companies will
maintain the records required by section
57(f)(3) of the Act as if each of the
Investment Companies were a business
development company and as if each of
the investments permitted under these
conditions were approved by the
Required Majority under section 57(f) of
the Act.
11. No Independent Directors or
Independent Trustees, as applicable,
will also be a director, general partner,
managing member or principal, or
otherwise an ‘‘affiliated person’’ (as
defined in the Act) of any Private Fund.
12. The expenses, if any, associated
with acquiring, holding or disposing of
any securities acquired in a CoInvestment Transaction (including,
without limitation, the expenses of the
distribution of any such securities
registered for sale under the 1933 Act)
will, to the extent not payable by the
Advisers under their respective advisory
agreements with the Investment
Companies and the Private Funds, be
shared by the participating Investment
Companies and the participating Private
Funds in proportion to the relative
amounts of the securities held or being
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18:06 Mar 29, 2016
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acquired or disposed of, as the case may
be.
13. Any transaction fee 10 (including
break-up or commitment fees but
excluding broker’s fees contemplated by
section 17(e) or 57(k) of the Act, as
applicable) received in connection with
a Co-Investment Transaction will be
distributed to the participating
Investment Companies and the
participating Private Funds on a pro rata
basis, based on the amount each
invested or committed, as the case may
be, in such Co-Investment Transaction.
If any transaction fee is to be held by an
Adviser pending consummation of the
Co-Investment Transaction, the fee will
be deposited into an account
maintained by such Adviser at a bank or
banks having the qualifications
prescribed in section 26(a)(1) of the Act,
and such account will earn a
competitive rate of interest that will also
be divided pro rata among the
participating Investment Companies and
the participating Private Funds based on
the amount each invests in such CoInvestment Transaction. None of the
Investment Companies, the Private
Funds, the Advisers, nor any affiliated
person of the Investment Companies or
Private Funds will receive additional
compensation or remuneration of any
kind as a result of, or in connection
with, a Co-Investment Transaction
(other than (a) in the case of the
participating Investment Companies and
the participating Private Funds, the pro
rata transaction fees described above
and fees or other compensation
described in condition 2(c)(iii)(C) and
(b) in the case of the Advisers,
investment advisory fees paid in
accordance with the respective
investment advisory agreements).
14. If the Holders own in the aggregate
more than 25 percent of the Shares of
an Investment Company, then the
Holders will vote such Shares as
directed by an independent third party
when voting on (1) the election of
directors; (2) the removal of one or more
directors; or (3) any other matter under
either the Act or applicable state law
affecting the Board’s composition, size,
or manner of election.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Brent J. Fields,
Secretary.
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–77440; File No. SR–
NYSEArca–2016–50]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change To Amend Rule 6.2 To
Create a Reserve Market Maker
Options Trading Permit
March 24, 2016.
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that, on March
22, 2016, NYSE Arca, Inc. (the
‘‘Exchange’’ or ‘‘NYSE Arca’’) filed with
the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the self-regulatory
organization. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend
Rule 6.2 to create a Reserve Market
Maker Options Trading Permit
(‘‘Reserve OTP’’). 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.
[FR Doc. 2016–07101 Filed 3–29–16; 8:45 am]
BILLING CODE 8011–01–P
10 Applicants are not requesting and the staff is
not providing any relief for transaction fees
received in connection with any Co-Investment
Transaction.
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1 15
U.S.C. 78s(b)(1).
U.S.C. 78a.
3 17 CFR 240.19b–4.
2 15
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Agencies
[Federal Register Volume 81, Number 61 (Wednesday, March 30, 2016)]
[Notices]
[Pages 17741-17746]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-07101]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-32048; File No. 812-14430]
NexPoint Capital, Inc., et al.; Notice of Application
March 24, 2016.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application for an order under section 17(d) and
section 57(i) of the Investment Company Act of 1940 (the ``Act'') and
rule 17d-1 under the Act to permit certain joint transactions otherwise
prohibited by section 17(d) and section 57(a)(4) of the Act and rule
17d-1 under the Act.
-----------------------------------------------------------------------
Summary of Application: Applicants request an order to permit a
business development company (``BDC'') and a closed-end management
investment company to co-invest in portfolio companies with each other
and with certain affiliated investment funds.
Applicants: NexPoint Capital, Inc. (``NexPoint Capital''), NexPoint
Credit Strategies Fund (``NHF'') (each of NexPoint Capital and NHF, an
``Existing Investment Company'' and collectively, the ``Existing
Investment Companies''), NexPoint Advisors, L.P. (``NexPoint
Advisors''), Highland Multi Strategy Credit Fund, L.P. (``HMSCF'') and
Highland Capital Healthcare Partners (Master), L.P. (``HCHP'' and,
collectively with HMSCF, the ``Existing Private Funds''), Highland
Capital Management, L.P., Highland Capital Healthcare Advisors, L.P.
and Acis Capital Management, L.P. (each, a ``Current Adviser to Private
Funds'' and, collectively, the ``Current Advisers to Private Funds,''
and, the Current Advisers to Private Funds collectively with the
Existing Investment Companies, NexPoint Advisors and the Existing
Private Funds, the ``Applicants'').
[[Page 17742]]
Filing Dates: The application was filed on March 6, 2015 and amended on
August 28, 2015, December 21, 2015, March 11, 2016, and March 18, 2016.
Hearing or Notification of Hearing: An order granting the requested
relief will be issued unless the Commission orders a hearing.
Interested persons may request a hearing by writing to the Commission's
Secretary and serving applicants with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 p.m. on April 18, 2016, 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
St. NE., Washington, DC 20549-1090. Applicants: 300 Crescent Court,
Suite 700, Dallas, Texas 75201.
FOR FURTHER INFORMATION CONTACT: Jill Ehrlich, Senior Counsel, at (202)
551-6819, or Mary Kay Frech, Branch Chief, at (202) 551-6821 (Division
of Investment Management, Chief Counsel's Office).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or for an
applicant using the Company name box, at https://www.sec.gov/search/search.htm or by calling (202) 551-8090.
Applicants' Representations
1. NexPoint Capital, a Delaware corporation, is an externally
managed, non-diversified, closed-end management investment company that
has elected to be regulated as a BDC under the Act.\1\ NexPoint
Capital's investment objective is to generate current income and
capital appreciation primarily through investments in middle-market
healthcare companies, middle-market companies in non-healthcare
sectors, syndicated floating rate debt of large nonpublic and public
companies and collateralized loan obligations. NexPoint Capital's board
of directors currently consists of six members, five of whom are not
``interested persons'' of NexPoint Capital within the meaning of
section 2(a)(19) of the Act (the ``Independent Directors'').
---------------------------------------------------------------------------
\1\ Section 2(a)(48) defines a BDC to be any closed-end
investment company that operates for the purpose of making
investments in securities described in sections 55(a)(1) through
55(a)(3) of the Act and makes available significant managerial
assistance with respect to the issuers of such securities.
---------------------------------------------------------------------------
2. NHF, a Delaware statutory trust, is an externally managed, non-
diversified, closed-end management investment company registered under
the Act. NHF's investment objective is to generate current income and
capital appreciation primarily through investments in: (i) Secured and
unsecured floating and fixed rate loans; (ii) bonds and other debt
obligations; (iii) debt obligations of stressed, distressed and
bankrupt issuers; (iv) structured products, including but not limited
to, mortgage-backed and other asset-backed securities and
collateralized debt obligations; and (v) equities. NHF's board of
trustees currently consists of six members, five of whom are not
``interested persons'' of NHF within the meaning of section 2(a)(19) of
the Act (the ``Independent Trustees'').
3. NexPoint Advisors, a Delaware limited partnership, is registered
under the Investment Advisers Act of 1940 (``Advisers Act'') and is the
investment adviser of NexPoint Capital and NHF.
4. The Existing Private Funds are entities formed under the laws of
Delaware or under the laws of the Cayman Islands. In reliance on the
exclusion from the definition of ``investment company'' provided by
section 3(c)(1) or 3(c)(7) of the Act, neither of the Existing Private
Funds will be registered under the Act. Highland Capital Management,
L.P., registered as an investment adviser under the Advisers Act,
serves as the investment adviser to HMSCF, and Acis Capital Management,
L.P., registered as an investment adviser under the Advisers Act,
serves as the investment sub-adviser to HMSCF. Highland Capital
Healthcare Advisors, L.P., registered as an investment adviser under
the Advisers Act, serves as the investment adviser to HCHP. NexPoint
Advisors expects that certain portfolio companies that are appropriate
investments for a Private Fund \2\ may also be appropriate for one or
more Investment Companies,\3\ with certain exceptions based on
available capital or diversification.
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\2\ ``Private Fund'' means any Existing Private Fund or any
entity (a) whose investment adviser is an Adviser, (b) that would be
an investment company but for section 3(c)(1) or 3(c)(7) of the Act,
and (c) that intends to participate in the Co-Investment Program (as
defined below). ``Adviser'' means (a) NexPoint Advisors, (b) the
Current Advisers to Private Funds, and (c) any future investment
adviser that controls, is controlled by or is under common control
with any of NexPoint Advisors or the Current Advisers to Private
Funds and is registered as an investment adviser under the Advisers
Act.
\3\ The term ``Investment Company'' means any Existing
Investment Company and any future closed-end investment company that
(a) is registered under the Act or has elected to be regulated as a
BDC under the Act, (b) will be advised by an Adviser, and (c) that
intends to participate in the Co-Investment Program.
---------------------------------------------------------------------------
5. Applicants seek an order (``Order'') \4\ to allow an Investment
Company to co-invest in the same issuers of securities with one or more
other Investment Companies or Private Funds (the ``Co-Investment
Program'') with which it may be prohibited from co-investing by reason
of section 17(d) or section 57 of the Act. For purposes of the
application, a ``Co-Investment Transaction'' means any transaction in
which an Investment Company (or one of its Wholly Owned Investment
Subsidiaries, as defined below) participates together with one or more
other Investment Companies and/or Private Funds in reliance on the
requested Order. ``Potential Co-Investment Transaction'' means any
investment opportunity in which an Investment Company (or a Wholly
Owned Investment Subsidiary) could not participate together with one or
more other Investment Companies and/or Private Funds without obtaining
and relying on the Order.
---------------------------------------------------------------------------
\4\ All existing entities that currently intend to rely on the
Order have been named as Applicants and any entities that may rely
on the Order in the future will comply with the terms and conditions
of the application.
---------------------------------------------------------------------------
6. Each of the Investment Companies may, from time to time and as
applicable, form a special purpose subsidiary (a ``Wholly-Owned
Investment Subsidiary'').\5\ Wholly-Owned Investment Subsidiaries would
be prohibited from investing in a Co-
[[Page 17743]]
Investment Transaction with any other Investment Company or Private
Fund because the Wholly-Owned Investment Subsidiary would be a company
controlled by the applicable Investment Company for purposes of section
17(d) and section 57(a)(4) and rule 17d-1. Applicants request that any
Wholly Owned Investment Subsidiary be permitted to participate in Co-
Investment Transactions in lieu of the Investment Company of which it
is a subsidiary and that the participation in any such transaction by
any Wholly Owned Investment Subsidiary be treated, for purposes of the
Order, as though the Investment Company of which it is a subsidiary
were participating directly. Applicants represent that this treatment
is justified because any Wholly Owned Investment Subsidiary would have
no purpose other than serving as a holding and financing vehicle for
the applicable Investment Company's investments and, therefore, no
conflicts of interest could arise between an Investment Company and its
Wholly Owned Investment Subsidiary. The board of directors or board of
trustees, as applicable, of an Investment Company would make all
relevant determinations under the conditions with regard to the
participation of such Investment Company's Wholly Owned Investment
Subsidiary in a Co-Investment Transaction, and the board of directors
or the board of trustees, as applicable, of an Investment Company would
be informed of, and take into consideration, any proposed use of any
Wholly Owned Investment Subsidiary in such Investment Company's place.
If an Investment Company proposes to participate in the same Co-
Investment Transaction with any of its Wholly Owned Investment
Subsidiaries, the board of directors or the board of trustees, as
applicable, of such Investment Company will also be informed of, and
take into consideration, the relative participation of the Investment
Company and the Wholly Owned Investment Subsidiary.
---------------------------------------------------------------------------
\5\ The term ``Wholly-Owned Investment Subsidiary'' means an
entity (a) whose sole business purpose is to hold one or more
investments and issue debt on behalf of such Investment Company, to
obtain debt financing for those investments and, in the case of a
Wholly Owned Investment Subsidiary organized as a small business
investment company under the Small Business Investment Act of 1958
(``SBA Act''), to maintain a license under the SBA Act and issue
debentures guaranteed by the Small Business Administration; (b) that
is wholly owned by such Investment Company (with the applicable
Investment Company at all times holding directly or indirectly,
beneficially and of record, 100% of the voting and economic
interests); (c) with respect to which the board of directors or
board of trustees, as applicable, of such Investment Company has the
sole authority to make all determinations with respect to the Wholly
Owned Investment Subsidiary's participation under the conditions to
the application; and (d) that is an entity that would be an
investment company but for section 3(c)(1) or 3(c)(7) of the Act.
---------------------------------------------------------------------------
7. Applicants represent that the Adviser of another Investment
Company or a Private Fund will refer to the Adviser of an Investment
Company all Potential Co-Investment Transactions within such Investment
Company's Objectives and Strategies \6\ that are considered for such
other Investment Company or Private Fund, and such investment
opportunities may result in a Co-Investment Transaction. For each such
referral, the applicable Adviser will consider the investment
objective, investment policies, investment position, investment
strategies, investment restrictions, regulatory and tax requirements,
capital available for investment and other pertinent factors applicable
to such Investment Company. Likewise, when selecting investments for a
Private Fund, the applicable Adviser to the Private Fund will select
investments separately for the Private Fund, considering the investment
objective, investment policies, investment position, investment
strategies, investment restrictions, regulatory and tax requirements,
capital available for investment and other pertinent factors applicable
to such Private Fund. Each Co-Investment Transaction and the proposed
allocation of such Co-Investment Transaction would be approved prior to
the actual investment by the required majority (within the meaning of
section 57(o) of the Act) (the ``Required Majority'') \7\ of the
Investment Company's board of directors or board of trustees, as
applicable.
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\6\ ``Objectives and Strategies'' means the Investment Company's
investment objectives and strategies, as described in its
registration statement on Form N-2 and other filings made with the
Commission by such Investment Company under the Securities Act of
1933, as amended (``1933 Act''), or the Act, any reports filed by
such Investment Company with the Commission under the Securities
Exchange Act of 1934, as amended, or the Act and such Investment
Company's reports to stockholders.
\7\ In the case of an Investment Company that is a registered
closed-end fund, the directors or trustees that make up the Required
Majority will be determined as if the Investment Company were a BDC
subject to section 57(o).
---------------------------------------------------------------------------
8. Other than pro rata dispositions and follow-on investments \8\
as provided in conditions 7 and 8, and after making the determinations
required in conditions 1 and 2(a), the applicable Adviser will present
each Potential Co-Investment Transaction and the proposed allocation to
the directors or trustees of the applicable Investment Company who are
eligible to vote under section 57(o) of the Act (``Eligible
Directors''), and the Required Majority will approve each Co-Investment
Transaction prior to any investment by such Investment Company.
---------------------------------------------------------------------------
\8\ ``Follow-on investment'' means an additional investment in
an existing portfolio company, including through the exercise of
warrants, conversion privileges or other rights to acquire
securities of the portfolio company.
---------------------------------------------------------------------------
9. With respect to the pro rata dispositions and follow-on
investments provided in conditions 7 and 8, the Investment Companies
may participate in a pro rata disposition or follow-on investment
without obtaining prior approval of the Required Majority if, among
other things: (i) The proposed participation of such Investment Company
and each other Investment Company or Private Fund in such disposition
or follow-on investment is proportionate to its outstanding investments
in the issuer immediately preceding the disposition or follow-on
investment, as the case may be; and (ii) the board of directors or
board of trustees, as applicable, of the Investment Company has
approved such Investment Company's participation in pro rata
dispositions and follow-on investments as being in the best interests
of the Investment Company. If such board does not so approve, any such
disposition or follow-on investment will be submitted to the Investment
Company's Eligible Directors. The board of directors or board of
trustees, as applicable, of an Investment Company may at any time
rescind, suspend or qualify its approval of pro rata dispositions and
follow-on investments, with the result that all dispositions and/or
follow-on investments must be submitted to the Eligible Directors of
such Investment Company.
10. No Independent Director or Independent Trustee of an Investment
Company will have a financial interest in any Co-Investment
Transaction, other than indirectly through share ownership in the
Investment Company.
11. Under condition 14, if NexPoint Advisors or its principals, or
any person controlling, controlled by, or under common control with
NexPoint Advisors or its principals, and the Private Funds
(collectively, the ``Holders'') own in the aggregate more than 25
percent of the outstanding voting shares of an Investment Company (the
``Shares''), then the Holders will vote such Shares as directed by an
independent third party when voting on matters specified in the
condition. Applicants believe that this condition will ensure that the
Independent Directors or Independent Trustees will act independently in
evaluating the Co-Investment Program, because the ability of NexPoint
Advisors or its principals to influence the Independent Directors or
Independent Trustees by a suggestion, explicit or implied, that the
Independent Directors or Independent Trustees can be removed will be
limited significantly. Applicants represent that the Independent
Directors or Independent Trustees shall evaluate and approve any
independent third party, taking into account its qualifications,
reputation for independence, cost to the shareholders, and other
factors that they deem relevant.
Applicants' Legal Analysis
1. Section 17(d) of the Act and rule 17d-1 under the Act prohibit
affiliated
[[Page 17744]]
persons of a registered investment company from participating in joint
transactions with the company or a company controlled by such company
unless the Commission has granted an order permitting such
transactions. Section 57(a)(4) of the Act prohibits certain affiliated
persons of a BDC from participating in joint transactions with the BDC
(or a company controlled by such company) in contravention of rules as
prescribed by the Commission. Section 57(i) of the Act provides that,
until the Commission prescribes rules under section 57(a)(4), the
Commission's rules under section 17(d) of the Act applicable to
registered closed-end investment companies will be deemed to apply to
BDCs. Because the Commission has not adopted any rules under section
57(a)(4), rule 17d-1 applies to BDCs. NexPoint Advisors and any other
Investment Company or Private Fund that it advises could be deemed to
be persons related to an Investment Company in a manner described by
section 2(a)(3) or section 57(b), as applicable, and, therefore,
prohibited by section 17(d) or section 57(a)(4), as applicable, and
rule 17d-1 from participating in the Co-Investment Program. In
addition, because the other Advisers are ``affiliated persons'' of
NexPoint Advisors, such Advisers and the Investment Companies and
Private Funds advised by any of them could be deemed to be persons
related to such Investment Company in a manner described by section
2(a)(3) or section 57(b), as applicable, and also prohibited from
participating in the Co-Investment Program. Finally, because any Wholly
Owned Investment Subsidiary will be controlled by an Investment
Company, it will subject to section 17(d) or section 57(a)(4), and thus
also subject to the provisions of rule 17d-1.
2. Rule 17d-1, as made applicable to BDCs by section 57(i),
prohibits any person who is related to a BDC in a manner described in
section 57(b), acting as principal, from participating in, or effecting
any transaction in connection with, any joint enterprise or other joint
arrangement or profit-sharing plan in which the BDC is a participant,
absent an order from the Commission. In passing upon applications under
rule 17d-1, the Commission considers whether the company's
participation in the joint transaction is consistent with the
provisions, policies, and purposes of the Act and the extent to which
such participation is on a basis different from or less advantageous
than that of other participants.
3. Applicants state that they expect that co-investment in
portfolio companies by the Investment Companies and the Private Funds
will increase favorable investment opportunities for each participant.
4. Applicants submit that the fact that the Required Majority will
approve each Co-Investment Transaction before investment, and other
protective conditions set forth in the application, will ensure that
each Investment Company will be treated fairly. Applicants state that
each Investment Company's participation in the Co-Investment
Transactions will be consistent with the provisions, policies, and
purposes of the Act and on a basis that is not different from, or less
advantageous than, that of the other Investment Companies or the
Private Funds.
Applicants' Conditions
Applicants agree that any order granting the requested relief will
be subject to the following conditions:
1. Each time an Adviser considers a Potential Co-Investment
Transaction for a Private Fund or another Investment Company that falls
within an Investment Company's then-current Objectives and Strategies,
the Investment Company's Adviser will make an independent determination
of the appropriateness of such investment for such Investment Company
in light of such Investment Company's then-current circumstances.
2. (a) If the applicable Adviser deems an Investment Company's
participation in any Potential Co-Investment Transaction to be
appropriate for such Investment Company, it will then determine an
appropriate level of investment for such Investment Company;
(b) If the aggregate amount recommended by the applicable Adviser
to be invested in such Potential Co-Investment Transaction by an
Investment Company, together with the amount proposed to be invested by
the other participating Investment Companies and Private Funds,
collectively, in the same transaction, exceeds the amount of the
investment opportunity, then the investment opportunity will be
allocated among them pro rata based on each participating party's
capital available for investment in the asset class being allocated, up
to the amount proposed to be invested by each party. The applicable
Adviser will provide the Eligible Directors of each participating
Investment Company with information concerning each participating
party's available capital to assist the Eligible Directors with their
review of such Investment Company's investments for compliance with
these allocation procedures; and
(c) After making the determinations required in conditions 1 and
2(a), the applicable Adviser will distribute written information
concerning the Potential Co-Investment Transaction, including the
amount proposed to be invested by each Investment Company and each
Private Fund, to the Eligible Directors of each participating
Investment Company for their consideration. An Investment Company will
co-invest with one or more other Investment Companies and/or Private
Funds only if, prior to the Investment Company's participation in the
Potential Co-Investment Transaction, the Required Majority concludes
that:
(i) The terms of the Potential Co-Investment Transaction, including
the consideration to be paid, are reasonable and fair to such
Investment Company and its stockholders and do not involve overreaching
in respect of such Investment Company or its stockholders on the part
of any person concerned;
(ii) the Potential Co-Investment Transaction is consistent with:
(A) The interests of the stockholders of such Investment Company;
and
(B) such Investment Company's then-current Objectives and
Strategies;
(iii) the investment by another Investment Company or any Private
Fund would not disadvantage such Investment Company, and participation
by such Investment Company would not be on a basis different from, or
less advantageous than, that of any other Investment Company or Private
Fund; provided, that if any other Investment Company or Private Fund,
but not such Investment Company itself, gains the right to nominate a
director for election to a portfolio company's board of directors or
the right to have a board observer or any similar right to participate
in the governance or management of the portfolio company, such event
will not be interpreted to prohibit the Required Majority from reaching
the conclusions required by this condition (2)(c)(iii), if
(A) The Eligible Directors will have the right to ratify the
selection of such director or board observer, if any;
(B) the Advisers agree to, and do, provide periodic reports to each
Investment Company's board of directors or board of trustees, as
applicable, with respect to the actions of such director or the
information received by such board observer or obtained through the
exercise of any similar right to participate in the governance or
management of the portfolio company; and
[[Page 17745]]
(C) any fees or other compensation that any other Investment
Company, Private Fund or any affiliated person of another Investment
Company or Private Fund receives in connection with the right of such
other Investment Company or Private Fund to nominate a director or
appoint a board observer or otherwise to participate in the governance
or management of the portfolio company will be shared proportionately
among the participating Private Funds (which each may, in turn, share
their portion with their affiliated persons) and the participating
Investment Companies in accordance with the amount of each party's
investment; and
(iv) the proposed investment by the Investment Company will not
benefit the other Investment Companies, the Advisers, the Private Funds
or any affiliated person of any of them (other than the parties to the
Co-Investment Transaction), except (A) to the extent permitted by
condition 13; (B) to the extent permitted by sections 17(e) or 57(k) of
the Act, as applicable; (C) indirectly, as a result of an interest in
the securities issued by one of the parties to the Co-Investment
Transaction; or (D) in the case of fees or other compensation described
in condition 2(c)(iii)(C).
3. Each Investment Company has the right to decline to participate
in any Potential Co-Investment Transaction or to invest less than the
amount proposed.
4. The applicable Adviser will present to the board of directors or
the board of trustees, as applicable, of each Investment Company, on a
quarterly basis, a record of all investments in Potential Co-Investment
Transactions made by any of the other Investment Companies and the
Private Funds during the preceding quarter that fell within such
Investment Company's then-current Objectives and Strategies that were
not made available to such Investment Company and an explanation of why
the investment opportunities were not offered to such Investment
Company. All information presented to a board pursuant to this
condition will be kept for the life of such Investment Company and at
least two years thereafter, and will be subject to examination by the
Commission and its staff.
5. Except for follow-on investments made in accordance with
condition 8,\9\ an Investment Company will not invest in reliance on
the Order in any issuer in which any other Investment Company, Private
Fund or any affiliated person of another Investment Company or Private
Fund is an existing investor.
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\9\ This exception applies only to follow-on investments by an
Investment Company in issuers in which that Investment Company
already holds investments.
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6. An Investment Company will not participate in any Potential Co-
Investment Transaction unless the terms, conditions, price, class of
securities to be purchased, settlement date and registration rights
will be the same for each participating Investment Company and Private
Fund. The grant to another participant, but not such Investment
Company, of the right to nominate a director for election to a
portfolio company's board of directors, the right to have an observer
on the board of directors or similar rights to participate in the
governance or management of the portfolio company will not be
interpreted so as to violate this condition 6, if conditions
2(c)(iii)(A), (B) and (C) are met.
7. (a) If any Investment Company or Private Fund elects to sell,
exchange or otherwise dispose of an interest in a security that was
acquired in a Co-Investment Transaction, the applicable Advisers will:
(i) Notify each Investment Company that participated in the Co-
Investment Transaction of the proposed disposition at the earliest
practical time; and
(ii) formulate a recommendation as to participation by such
Investment Company in any such disposition.
(b) Each Investment Company will have the right to participate in
such disposition on a proportionate basis, at the same price and on the
same terms and conditions as those applicable to any participating
Private Funds and other participating Investment Companies.
(c) An Investment Company may participate in such disposition
without obtaining prior approval of the Required Majority if: (i) The
proposed participation of such Investment Company and of each other
participant in such disposition is proportionate to its outstanding
investment in the issuer immediately preceding the disposition; (ii)
the board of directors or board of trustees, as applicable, of such
Investment Company has approved as being in the best interests of such
Investment Company the ability to participate in such dispositions on a
pro rata basis (as described in greater detail in the application); and
(iii) such board is provided on a quarterly basis with a list of all
dispositions made in accordance with this condition. In all other
cases, the applicable Adviser will provide its written recommendation
as to an Investment Company's participation to the Eligible Directors
of such Investment Company, and the Investment Company will participate
in such disposition solely to the extent that the Required Majority
determines that it is in the Investment Company's best interests.
(d) Each Investment Company and each other participant will bear
its own expenses in connection with any such disposition.
8. (a) If any Investment Company or Private Fund desires to make a
follow-on investment in a portfolio company whose securities were
acquired in a Co-Investment Transaction, the applicable Advisers will:
(i) Notify each Investment Company that participated in the Co-
Investment Transaction of the proposed transaction at the earliest
practical time; and
(ii) formulate a recommendation as to the proposed participation,
including the amount of the proposed follow-on investment, by such
Investment Company.
(b) Such Investment Company may participate in such follow-on
investment without obtaining prior approval of the Required Majority
if: (i) The proposed participation of each Investment Company and each
Private Fund in such investment is proportionate to its outstanding
investment in the issuer immediately preceding the follow-on
investment; (ii) the board of directors or board of trustees, as
applicable, of such Investment Company has approved as being in the
best interests of such Investment Company the ability to participate in
follow-on investments on a pro rata basis (as described in greater
detail in the application); and (iii) such board is provided on a
quarterly basis with a list of all follow on investments made in
accordance with this condition. In all other cases, the applicable
Adviser will provide its written recommendation as to such Investment
Company's participation to the Eligible Directors, and such Investment
Company will participate in such follow-on investment solely to the
extent that the Required Majority determines that it is in such
Investment Company's best interests.
(c) If with respect to any follow-on investment:
(i) The amount of the opportunity is not based on the Investment
Companies' and the Private Funds' outstanding investments immediately
preceding the follow-on investment; and
(ii) the aggregate amount recommended by the applicable Adviser to
be invested by each Investment Company in the follow-on investment,
together with the amount proposed to be invested by the participating
Private Funds in the same transaction, exceeds the amount of the
opportunity, then the
[[Page 17746]]
amount to be invested by each such party will be allocated among them
pro rata based on each participating party's capital available for
investment in the asset class being allocated, up to the amount
proposed to be invested by each.
(d) The acquisition of follow-on investments as permitted by this
condition will be considered a Co-Investment Transaction for all
purposes and subject to the other conditions set forth in the
application.
9. The Independent Directors or Independent Trustees, as
applicable, of each Investment Company will be provided quarterly for
review all information concerning Potential Co-Investment Transactions
and Co-Investment Transactions, including investments made by the other
Investment Companies and the Private Funds that the applicable
Investment Company considered but declined to participate in, so that
the Independent Directors or Independent Trustees, as applicable, may
determine whether all investments made during the preceding quarter,
including those investments which the applicable Investment Company
considered but declined to participate in, comply with the conditions
of the Order. In addition, the Independent Directors or Independent
Trustees, as applicable, will consider at least annually the continued
appropriateness for such Investment Company of participating in new and
existing Co-Investment Transactions.
10. The Investment Companies will maintain the records required by
section 57(f)(3) of the Act as if each of the Investment Companies were
a business development company and as if each of the investments
permitted under these conditions were approved by the Required Majority
under section 57(f) of the Act.
11. No Independent Directors or Independent Trustees, as
applicable, will also be a director, general partner, managing member
or principal, or otherwise an ``affiliated person'' (as defined in the
Act) of any Private Fund.
12. The expenses, if any, associated with acquiring, holding or
disposing of any securities acquired in a Co-Investment Transaction
(including, without limitation, the expenses of the distribution of any
such securities registered for sale under the 1933 Act) will, to the
extent not payable by the Advisers under their respective advisory
agreements with the Investment Companies and the Private Funds, be
shared by the participating Investment Companies and the participating
Private Funds in proportion to the relative amounts of the securities
held or being acquired or disposed of, as the case may be.
13. Any transaction fee \10\ (including break-up or commitment fees
but excluding broker's fees contemplated by section 17(e) or 57(k) of
the Act, as applicable) received in connection with a Co-Investment
Transaction will be distributed to the participating Investment
Companies and the participating Private Funds on a pro rata basis,
based on the amount each invested or committed, as the case may be, in
such Co-Investment Transaction. If any transaction fee is to be held by
an Adviser pending consummation of the Co-Investment Transaction, the
fee will be deposited into an account maintained by such Adviser at a
bank or banks having the qualifications prescribed in section 26(a)(1)
of the Act, and such account will earn a competitive rate of interest
that will also be divided pro rata among the participating Investment
Companies and the participating Private Funds based on the amount each
invests in such Co-Investment Transaction. None of the Investment
Companies, the Private Funds, the Advisers, nor any affiliated person
of the Investment Companies or Private Funds will receive additional
compensation or remuneration of any kind as a result of, or in
connection with, a Co-Investment Transaction (other than (a) in the
case of the participating Investment Companies and the participating
Private Funds, the pro rata transaction fees described above and fees
or other compensation described in condition 2(c)(iii)(C) and (b) in
the case of the Advisers, investment advisory fees paid in accordance
with the respective investment advisory agreements).
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\10\ Applicants are not requesting and the staff is not
providing any relief for transaction fees received in connection
with any Co-Investment Transaction.
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14. If the Holders own in the aggregate more than 25 percent of the
Shares of an Investment Company, then the Holders will vote such Shares
as directed by an independent third party when voting on (1) the
election of directors; (2) the removal of one or more directors; or (3)
any other matter under either the Act or applicable state law affecting
the Board's composition, size, or manner of election.
For the Commission, by the Division of Investment Management,
under delegated authority.
Brent J. Fields,
Secretary.
[FR Doc. 2016-07101 Filed 3-29-16; 8:45 am]
BILLING CODE 8011-01-P