Newtek Business Services Corp.; Notice of Application, 23068-23071 [2016-08934]
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III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change is effective
upon filing pursuant to section
19(b)(3)(A) 11 of the Act and
subparagraph (f)(2) of Rule 19b–4 12
thereunder, because it establishes a due,
fee, or other charge imposed by the
Exchange.
At any time within 60 days of the
filing of such proposed rule change, the
Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is necessary or appropriate in the
public interest, for the protection of
investors, or otherwise in furtherance of
the purposes of the Act. If the
Commission takes such action, the
Commission shall institute proceedings
under section 19(b)(2)(B) 13 of the Act to
determine whether the proposed rule
change should be approved or
disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
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Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
NYSEArca–2016–55 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–NYSEArca–2016–55. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
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
11 15
U.S.C. 78s(b)(3)(A).
CFR 240.19b–4(f)(2).
13 15 U.S.C. 78s(b)(2)(B).
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 the
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–
NYSEArca–2016–55, and should be
submitted on or before May 10, 2016.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.14
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016–08946 Filed 4–18–16; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
32070; 812–14450]
Newtek Business Services Corp.;
Notice of Application
April 13, 2016.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application for an
order under section 6(c) of the
Investment Company Act of 1940 (the
‘‘Act’’) for an exemption from sections
23(a), 23(b) and 63 of the Act; under
sections 57(a)(4) and 57(i) of the Act and
rule 17d–1 under the Act permitting
certain joint transactions otherwise
prohibited by section 57(a)(4) of the Act;
and under section 23(c)(3) of the Act for
an exemption from section 23(c) of the
Act.
AGENCY:
Newtek
Business Services Corp. (‘‘Applicant’’ or
‘‘Company’’) requests an order that
would permit Applicant to (a) issue
restricted shares of its common stock
(‘‘Restricted Stock’’) as part of the
compensation package for certain
participants in its 2015 Stock Incentive
Plan (the ‘‘Plan’’), (b) withhold shares of
the Applicant’s common stock or
purchase shares of Applicant’s common
SUMMARY OF THE APPLICATION:
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stock from participants to satisfy tax
withholding obligations relating to the
vesting of Restricted Stock or the
exercise of options to purchase shares of
Applicant’s common stock (‘‘Options’’),
and (c) permit participants to pay the
exercise price of Options with shares of
Applicant’s common stock.
FILING DATES: The application was filed
on April 28, 2015, and amended on
October 28, 2015 and February 9, 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
applicant with a copy of the request,
personally or by mail. Hearing requests
should be received by the Commission
by 5:30 p.m. on May 9, 2016, and
should be accompanied by proof of
service on applicant, in the form of an
affidavit or, for lawyers, a certificate of
service. Pursuant to rule 0–5 under the
Act, hearing requests should state the
nature of the writer’s interest, any facts
bearing upon the desirability of a
hearing on the matter, the reason for the
request, and the issues contested.
Persons who wish to be notified of a
hearing may request notification by
writing to the Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
Applicant, 212 West 35th Street, 2nd
Floor, New York, New York 10001.
FOR FURTHER INFORMATION CONTACT: Jill
Ehrlich, Senior Counsel, at (202) 551–
6819, or Mary Kay Frech, Branch Chief,
at (202) 551–6821 (Chief Counsel’s
Office, Division of Investment
Management).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or for an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
APPLICANT’S REPRESENTATIONS: 1.
Applicant is an internally managed
closed-end investment company that
has elected to be regulated as a business
development company (‘‘BDC’’) under
the Act.1 Applicant represents that it is
1 Applicant was incorporated under the laws of
the state of New York in June 1999 as Whitestone
Holdings, Inc., completed an initial public offering
in September 2000, and changed its name to
Newtek Business Services, Inc. in November 2002.
In November 2014, Newtek Business Services, Inc.
merged with and into Newtek Business Services
Corp. (the ‘‘Reincorporation Transaction’’) for the
purpose of reincorporating in the state of Maryland.
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a leading capital provider to small- and
medium-sized businesses (‘‘SMBs’’).
Applicant originates loans through a
variety of sourcing channels and,
through a rigorous underwriting
process, seeks to achieve attractive riskweighted returns. In addition, Applicant
and its controlled portfolio companies
provide comprehensive lending,
payment processing, managed
technology, personal and commercial
insurance and payroll solutions to over
100,000 SMB accounts, across all
industries. Shares of Applicant’s
common stock are traded on the Nasdaq
Global Market under the symbol
‘‘NEWT.’’ As of December 31, 2015,
there were 14,503,927 shares of
Applicant’s common stock outstanding.
As of that date, Applicant had 146
employees.
2. Applicant currently has a fivemember board of directors (the ‘‘Board’’)
of whom three are not ‘‘interested
persons’’ of Applicant within the
meaning of section 2(a)(19) of the Act,
and two are considered ‘‘interested
persons’’ of Applicant.
3. Applicant believes that, because the
market for superior investment
professionals is highly competitive,
Applicant’s successful performance
depends on its ability to offer fair
compensation packages to its
professionals that are competitive with
those offered by other investment
management businesses. Applicant
states that the ability to offer equitybased compensation to its employees
and non-employee directors (‘‘NonEmployee Directors’’), which both aligns
employee and Board behavior with
stockholder interests and provides a
retention tool, is vital to Applicant’s
future growth and success.
4. Effective October 22, 2014,
Applicant adopted the Newtek Business
Services Corp. 2014 Stock Incentive
Plan (the ‘‘2014 Plan’’), which provides
for the grant of Options. As of February
8, 2016, there were no Options
outstanding. Applicant proposes to
amend and restate the 2014 Plan by
adopting the Plan, which will supersede
the 2014 Plan, subject to the issuance of
the requested order and stockholder
approval. The Plan authorizes the
issuance of Options and Restricted
Stock to the Company’s directors,
including Non-Employee Directors,
Upon completion of the Reincorporation
Transaction, Applicant elected to be regulated as a
BDC. Section 2(a)(48) of the Act 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.
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officers and other employees
(‘‘Participants’’).2
5. The Plan will authorize the
issuance of Options and Restricted
Stock subject to certain forfeiture
restrictions. The restrictions may relate
to continued employment or service on
the Board, the performance of the
Applicant pursuant to performance
goals as set forth in the Plan, or other
restrictions deemed by the Required
Majority,3 the Compensation, Corporate
Governance, and Nominating
Committee 4 or the Board from time to
time to be appropriate and in the best
interests of Applicant and its
stockholders. Unless otherwise
determined by the Board, a Participant
granted Restricted Stock will have all of
the rights of a stockholder including,
without limitation, the right to vote
Restricted Stock and the right to receive
dividends, including deemed dividends,
thereon, although such rights may be
deferred during the restricted period
applicable to these awards. Restricted
Stock may not be transferred, pledged,
hypothecated, margined, or otherwise
encumbered by the Participant during
the restricted period, except for
disposition by will or intestacy. Except
as otherwise determined by the Board
under the Plan, upon termination of a
Participant’s employment or director
relationship with the Company during
the applicable restriction period, the
Participant’s Restricted Stock and any
accrued and unpaid dividends that are
then subject to restrictions shall
generally be forfeited.5
6. A maximum of twenty percent
(20%) of Applicant’s total shares of
common stock issued and outstanding
(as of the Effective Date) 6 will be
available for awards under the Plan.
Under the Plan, no more than fifty
percent (50%) of the shares of stock
reserved for the grant of awards under
2 Options will not be granted to Non-Employee
Directors.
3 Section 57(o) of the Act provides that the term
‘‘required majority,’’ when used with respect to the
approval of a proposed transaction, plan, or
arrangement, means both a majority of a BDC’s
directors or general partners who have no financial
interest in such transaction, plan, or arrangement
and a majority of such directors or general partners
who are not interested persons of such company.
4 The ‘‘Compensation, Corporate Governance, and
Nominating Committee’’ is composed of ‘‘nonemployee directors’’ within the meaning of rule
16b–3, and ‘‘outside directors’’ within the meaning
of section 162(m) of the Internal Revenue Code of
1986, as amended.
5 If any shares subject to an award granted under
the Plan are forfeited, cancelled, exchanged or
surrendered or if an award terminates or expires
without an issuance of shares, those shares will
again be available for awards under the Plan.
6 Effective Date is defined in section 2(p) of the
Plan as the date on which the Plan is approved by
Applicant’s stockholders.
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23069
the Plan may be Restricted Stock awards
at any time during the term of the Plan.
The maximum amount of Restricted
Stock that may be outstanding at any
particular time will be ten percent of the
Applicant’s voting securities.7 Under
the Plan, the aggregate number of shares
of common stock deliverable pursuant
to awards will not exceed 3,000,000.8
7. The Plan will be administered by
the Compensation, Corporate
Governance, and Nominating
Committee with respect to Participants
employed by Applicant and by the
Board with respect to Non-Employee
Directors, and the Board will have the
responsibility to ensure that the Plan is
operated in a manner that best serves
the interests of Applicant and its
stockholders. Restricted Stock will be
awarded to certain employees, officers
and directors, including Non-Employee
Directors, from time to time as part of
the employees’, officers’ or directors’
compensation based on their actual or
expected performance and value to the
Company. All awards of Restricted
Stock to employees and Non-Employee
Directors will be approved by the
Required Majority. Awards of Restricted
Stock to Non-Employee Directors will
be made on the schedule described
below.
8. Under the Plan, Non-Employee
Directors will each receive a grant of up
to 2,000 shares of Restricted Stock at the
beginning of each one-year term of
service on the Board, for which
forfeiture restrictions will lapse as to
one-third of such shares each year for
three years. Each grant of Restricted
Stock to Non-Employee Directors will
be made pursuant to this schedule and
will not be changed without
Commission approval.
9. The Plan provides that the
Company is authorized to withhold
stock (in whole or in part) from any
award of Restricted Stock granted in
satisfaction of a Participant’s tax
obligations. In addition, as discussed
more fully in the application, the
exercise of Options will result in the
recipient being deemed to have received
compensation in the amount by which
the fair market value of the shares of the
Company’s common stock, determined
as of the date of exercise, exceeds the
7 For purposes of calculating compliance with
this limit, the Company will count as Restricted
Stock all shares of its common stock that are issued
under the Plan less any shares that are forfeited
back to the Company and cancelled as a result of
forfeiture restrictions not lapsing.
8 If the Company does not receive the order to
issue Restricted Stock, all shares granted under the
Plan may be subject to Options. All Option awards
will be issued to employees in accordance with the
statutory provisions set forth in section 61 and will
not be granted to Non-Employee Directors.
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exercise price. Accordingly, Applicant
requests relief to withhold shares of its
common stock or purchase shares of its
common stock from Participants to
satisfy tax withholding obligations
related to the exercise of Options
granted under the 2014 Plan or the
vesting of Restricted Stock or exercise of
Options that will be granted pursuant to
the Plan. Applicant also requests an
exemption to permit Participants to pay
the exercise price of Options that were
granted under the 2014 Plan or will be
granted to them pursuant to the Plan
with shares of the Company’s common
stock.
10. The Plan was approved on April
27, 2015 by the Compensation,
Corporate Governance and Nominating
Committee and the Board, including the
Required Majority. The Plan will be
submitted for approval to the
Company’s stockholders, and will
become effective upon such approval,
subject to and following receipt of the
requested order.
Applicant’s Legal Analysis
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Sections 23(a) and (b), Section 63
1. Under section 63 of the Act, the
provisions of section 23(a) of the Act
generally prohibiting a registered
closed-end investment company from
issuing securities for services or for
property other than cash or securities
are made applicable to BDCs. This
provision would prohibit the issuance
of Restricted Stock as a part of the Plan.
2. Section 23(b) of the Act generally
prohibits a registered closed-end
investment company from selling any
common stock of which it is the issuer
at a price below its current net asset
value. Section 63(2) of the Act makes
section 23(b) applicable to BDCs unless
certain conditions are met. Because
Restricted Stock that would be granted
under the Plan would not meet the
terms of section 63(2), sections 23(b)
and 63 would prevent the issuance of
Restricted Stock.
3. Section 6(c) provides, in part, that
the Commission may, by order upon
application, conditionally or
unconditionally exempt any person,
security, or transaction, or any class or
classes thereof, from any provision of
the Act, if and to the extent that the
exemption is necessary or appropriate
in the public interest and consistent
with the protection of investors and the
purposes fairly intended by the policy
and provisions of the Act.
4. Applicant requests an order
pursuant to section 6(c) of the Act
granting an exemption from the
provisions of sections 23(a), 23(b) and
63 of the Act. Applicant states that the
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Plan would not violate the concerns
underlying these sections, which
include: (a) Preferential treatment of
investment company insiders and the
use of options and other rights by
insiders to obtain control of the
investment company; (b) complication
of the investment company’s structure
that made it difficult to determine the
value of the company’s shares; and (c)
dilution of shareholders’ equity in the
investment company. Applicant asserts
that the Plan does not raise concerns
about preferential treatment of
Applicant’s insiders because the Plan is
a bona fide compensation plan of the
type that is common among
corporations generally. In addition,
section 61(a)(3)(B) of the Act permits a
BDC to issue to its directors, officers,
employees, and general partners
warrants, options, and rights to
purchase the BDC’s voting securities
pursuant to an executive compensation
plan, subject to certain conditions.
Applicant states that, for reasons that
are unclear, section 61 and its legislative
history do not address the issuance by
a BDC of restricted stock as incentive
compensation. Applicant believes,
however, that the issuance of Restricted
Stock is substantially similar, for
purposes of investor protection under
the Act, to the issuance of warrants,
options, and rights as contemplated by
section 61. Applicant also asserts that
the issuance of Restricted Stock would
not become a means for insiders to
obtain control of Applicant because the
maximum amount of Restricted Stock
that may be issued under the Plan at any
one time will be ten percent of the
outstanding shares of common stock of
Applicant. Moreover, no single
Participant will be granted more than
25% of the shares of stock reserved for
issuance under the Plan.
5. Applicant further states that the
Plan will not unduly complicate
Applicant’s capital structure because
equity-based incentive compensation
arrangements are widely used among
corporations and commonly known to
investors. Applicant notes that the Plan
will be submitted for approval to the
Company’s stockholders. Applicant
represents that the proxy materials
submitted to Applicant’s stockholders
will contain a concise ‘‘plain English’’
description of the Plan and its potential
dilutive effect. Applicant also states that
it will comply with the proxy disclosure
requirements in Item 10 of Schedule
14A under the Securities Exchange Act
of 1934. Applicant further notes that the
Plan will be disclosed to investors in
accordance with the requirements of the
Form N–2 registration statement for
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closed-end investment companies and
pursuant to the standards and
guidelines adopted by the Financial
Accounting Standards Board for
operating companies. Applicant also
will comply with the disclosure
requirements for executive
compensation plans applicable to
BDCs.9 Applicant thus concludes that
the Plan will be adequately disclosed to
investors and appropriately reflected in
the market value of Applicant’s shares.
6. Applicant acknowledges that
awards granted under the Plan may
have a dilutive effect on the
stockholders’ equity per share in
Applicant, but believes that effect
would be outweighed by the anticipated
benefits of the Plan to Applicant and its
stockholders. Moreover, based on the
manner in which the issuance of
Restricted Stock pursuant to the Plan
will be administered, the Restricted
Stock will be no more dilutive than if
Applicant were to issue only Options to
Participants who are employees, as is
permitted by section 61(a)(3) of the Act.
Applicant asserts that it needs the
flexibility to provide the requested
equity-based compensation in order to
be able to compete effectively with other
venture capital firms for talented
professionals. These professionals,
Applicant suggests, in turn are likely to
increase Applicant’s performance and
stockholder value. Applicant also
asserts that equity-based compensation
would more closely align the interests of
Applicant’s employees and NonEmployee Directors with those of its
stockholders. In addition, Applicant
states that its stockholders will be
further protected by the conditions to
the requested order that assure
continuing oversight of the operation of
the Plan by the Board.
Section 57(a)(4), Rule 17d–1
7. Section 57(a) proscribes certain
transactions between a BDC and persons
related to the BDC in the manner
described in section 57(b) (‘‘57(b)
persons’’), absent a Commission order.
Section 57(a)(4) generally prohibits a
57(b) person from effecting a transaction
in which the BDC is a joint participant
absent such an order. Rule 17d–1, made
applicable to BDCs by section 57(i),
proscribes participation in a ‘‘joint
enterprise or other joint arrangement or
9 See Executive Compensation and Related Party
Disclosure, Securities Act Release No. 8655 (Jan. 27,
2006) (proposed rule); Executive Compensation and
Related Party Disclosure, Securities Act Release No.
8732A (Aug. 29, 2006) (final rule and proposed
rule), as amended by Executive Compensation
Disclosure, Securities Act Release No. 8756 (Dec.
22, 2006) (adopted as interim final rules with
request for comments).
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profit-sharing plan,’’ which includes a
stock option or purchase plan.
Employees and directors of a BDC are
57(b) persons. Thus, the issuance of
shares of Restricted Stock could be
deemed to involve a joint transaction
involving a BDC and a 57(b) person in
contravention of section 57(a)(4). Rule
17d–1(b) provides that, in considering
relief pursuant to the rule, the
Commission will consider (a) whether
the participation of the BDC in a joint
enterprise is consistent with the policies
and purposes of the Act and (b) the
extent to which such participation is on
a basis different from or less
advantageous than that of other
participants.
8. Applicant requests an order
pursuant to sections 57(a)(4) and 57(i) of
the Act and rule 17d–1 under the Act to
permit Applicant to issue Restricted
Stock under the Plan. Applicant
acknowledges that its role is necessarily
different from the other participants
because the other participants are its
directors and employees. It notes,
however, that the Plan is in the interest
of the Company’s stockholders, because
the Plan will help align the interests of
Applicant’s employees with those of its
stockholders, which will encourage
conduct on the part of those employees
designed to produce a better return for
Applicant’s stockholders. Additionally,
section 57(j)(1) of the Act expressly
permits any director, officer or
employee of a BDC to acquire warrants,
options and rights to purchase voting
securities of such BDC, and the
securities issued upon the exercise or
conversion thereof, pursuant to an
executive compensation plan which
meets the requirements of section
61(a)(3)(B) of the Act. Applicant submits
that the issuance of Restricted Stock
pursuant to the Plan poses no greater
risk to stockholders than the issuances
permitted by section 57(j)(1) of the Act.
Section 23(c)
9. Section 23(c) of the Act, which is
made applicable to BDCs by section 63
of the Act, generally prohibits a BDC
from purchasing any securities of which
it is the issuer except in the open market
pursuant to tenders, or under other
circumstances as the Commission may
permit to ensure that the purchases are
made in a manner or on a basis that
does not unfairly discriminate against
any holders of the class or classes of
securities to be purchased. Applicant
states that the withholding or purchase
of shares of Restricted Stock and
common stock in payment of applicable
withholding tax obligations or of
common stock in payment for the
exercise price of a stock option might be
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deemed to be purchases by the
Company of its own securities within
the meaning of section 23(c) and
therefore prohibited by the Act.
10. Section 23(c)(3) of the Act permits
a BDC to purchase securities of which
it is the issuer in circumstances in
which the repurchase is made in a
manner or on a basis that does not
unfairly discriminate against any
holders of the class or classes of
securities to be purchased. Applicant
believes that the requested relief meets
the standards of section 23(c)(3).
11. Applicant submits that these
purchases will be made in a manner that
does not unfairly discriminate against
Applicant’s stockholders because all
purchases of Applicant’s stock will be at
the closing price of the common stock
on the Nasdaq Global Market (or any
primary exchange on which its shares of
common stock may be traded in the
future) on the relevant date (i.e., the
public market price on the date of grant
of Restricted Stock and the date of grant
of Options). Applicant submits that
because all transactions with respect to
the Plan will take place at the public
market price for the Company’s
common stock, these transactions will
not be significantly different than could
be achieved by any stockholder selling
in a market transaction. Applicant
represents that no transactions will be
conducted pursuant to the requested
order on days where there are no
reported market transactions involving
Applicant’s shares.
12. Applicant represents that the
withholding provisions in the Plan do
not raise concerns about preferential
treatment of Applicant’s insiders
because the Plan is a bona fide
compensation plan of the type that is
common among corporations generally.
Furthermore, the vesting schedule is
determined at the time of the initial
grant of the Restricted Stock and the
option exercise price is determined at
the time of the initial grant of the
Options. Applicant represents that all
purchases may be made only as
permitted by the Plan, which will be
approved by the Company’s
stockholders prior to any application of
the relief. Applicant believes that
granting the requested relief would be
consistent with the policies underlying
the provisions of the Act permitting the
use of equity compensation as well as
prior exemptive relief granted by the
Commission under section 23(c) of the
Act.
1. The Plan will be authorized by
Applicant’s stockholders.
2. Each issuance of Restricted Stock to
an officer, employee, or Non-Employee
Director will be approved by the
Required Majority of Applicant’s
directors on the basis that such grant is
in the best interest of Applicant and its
stockholders.
3. The amount of voting securities
that would result from the exercise of all
of Applicant’s outstanding warrants,
options and rights, together with any
Restricted Stock issued and outstanding
pursuant to the Plan, will not at the time
of issuance of any warrant, option, right
or share of Restricted Stock under the
Plan, exceed 20 percent of Applicant’s
outstanding voting securities.
4. The amount of Restricted Stock
issued and outstanding will not at the
time of issuance of any shares of
Restricted Stock exceed ten percent of
Applicant’s outstanding voting
securities.
5. The Board will review the Plan at
least annually. In addition, the Board
will review periodically the potential
impact that the issuance of Restricted
Stock under the Plan could have on
Applicant’s earnings and net asset value
per share, such review to take place
prior to any decisions to grant Restricted
Stock under the Plan, but in no event
less frequently than annually. Adequate
procedures and records will be
maintained to permit such review. The
Board will be authorized to take
appropriate steps to ensure that the
issuance of Restricted Stock under the
Plan will be in the best interest of
Applicant and its stockholders. This
authority will include the authority to
prevent or limit the granting of
additional Restricted Stock under the
Plan. All records maintained pursuant
to this condition will be subject to
examination by the Commission and its
staff.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Brent J. Fields,
Secretary.
[FR Doc. 2016–08934 Filed 4–18–16; 8:45 am]
BILLING CODE 8011–01–P
Applicant’s Conditions
Applicant agrees that the order
granting the requested relief will be
subject to the following conditions:
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19APN1
Agencies
[Federal Register Volume 81, Number 75 (Tuesday, April 19, 2016)]
[Notices]
[Pages 23068-23071]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-08934]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 32070; 812-14450]
Newtek Business Services Corp.; Notice of Application
April 13, 2016.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application for an order under section 6(c) of the
Investment Company Act of 1940 (the ``Act'') for an exemption from
sections 23(a), 23(b) and 63 of the Act; under sections 57(a)(4) and
57(i) of the Act and rule 17d-1 under the Act permitting certain joint
transactions otherwise prohibited by section 57(a)(4) of the Act; and
under section 23(c)(3) of the Act for an exemption from section 23(c)
of the Act.
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Summary of the Application: Newtek Business Services Corp.
(``Applicant'' or ``Company'') requests an order that would permit
Applicant to (a) issue restricted shares of its common stock
(``Restricted Stock'') as part of the compensation package for certain
participants in its 2015 Stock Incentive Plan (the ``Plan''), (b)
withhold shares of the Applicant's common stock or purchase shares of
Applicant's common stock from participants to satisfy tax withholding
obligations relating to the vesting of Restricted Stock or the exercise
of options to purchase shares of Applicant's common stock
(``Options''), and (c) permit participants to pay the exercise price of
Options with shares of Applicant's common stock.
Filing Dates: The application was filed on April 28, 2015, and amended
on October 28, 2015 and February 9, 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 applicant with a copy of the request, personally
or by mail. Hearing requests should be received by the Commission by
5:30 p.m. on May 9, 2016, and should be accompanied by proof of service
on applicant, in the form of an affidavit or, for lawyers, a
certificate of service. Pursuant to rule 0-5 under the Act, hearing
requests should state the nature of the writer's interest, any facts
bearing upon the desirability of a hearing on the matter, the reason
for the request, and the issues contested. Persons who wish to be
notified of a hearing may request notification by writing to the
Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street NE., Washington, DC 20549-1090. Applicant, 212 West 35th Street,
2nd Floor, New York, New York 10001.
FOR FURTHER INFORMATION CONTACT: Jill Ehrlich, Senior Counsel, at (202)
551-6819, or Mary Kay Frech, Branch Chief, at (202) 551-6821 (Chief
Counsel's Office, Division of Investment Management).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or for an
applicant using the Company name box, at https://www.sec.gov/search/search.htm or by calling (202) 551-8090.
Applicant's Representations: 1. Applicant is an internally managed
closed-end investment company that has elected to be regulated as a
business development company (``BDC'') under the Act.\1\ Applicant
represents that it is
[[Page 23069]]
a leading capital provider to small- and medium-sized businesses
(``SMBs''). Applicant originates loans through a variety of sourcing
channels and, through a rigorous underwriting process, seeks to achieve
attractive risk-weighted returns. In addition, Applicant and its
controlled portfolio companies provide comprehensive lending, payment
processing, managed technology, personal and commercial insurance and
payroll solutions to over 100,000 SMB accounts, across all industries.
Shares of Applicant's common stock are traded on the Nasdaq Global
Market under the symbol ``NEWT.'' As of December 31, 2015, there were
14,503,927 shares of Applicant's common stock outstanding. As of that
date, Applicant had 146 employees.
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\1\ Applicant was incorporated under the laws of the state of
New York in June 1999 as Whitestone Holdings, Inc., completed an
initial public offering in September 2000, and changed its name to
Newtek Business Services, Inc. in November 2002. In November 2014,
Newtek Business Services, Inc. merged with and into Newtek Business
Services Corp. (the ``Reincorporation Transaction'') for the purpose
of reincorporating in the state of Maryland. Upon completion of the
Reincorporation Transaction, Applicant elected to be regulated as a
BDC. Section 2(a)(48) of the Act 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.
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2. Applicant currently has a five-member board of directors (the
``Board'') of whom three are not ``interested persons'' of Applicant
within the meaning of section 2(a)(19) of the Act, and two are
considered ``interested persons'' of Applicant.
3. Applicant believes that, because the market for superior
investment professionals is highly competitive, Applicant's successful
performance depends on its ability to offer fair compensation packages
to its professionals that are competitive with those offered by other
investment management businesses. Applicant states that the ability to
offer equity-based compensation to its employees and non-employee
directors (``Non-Employee Directors''), which both aligns employee and
Board behavior with stockholder interests and provides a retention
tool, is vital to Applicant's future growth and success.
4. Effective October 22, 2014, Applicant adopted the Newtek
Business Services Corp. 2014 Stock Incentive Plan (the ``2014 Plan''),
which provides for the grant of Options. As of February 8, 2016, there
were no Options outstanding. Applicant proposes to amend and restate
the 2014 Plan by adopting the Plan, which will supersede the 2014 Plan,
subject to the issuance of the requested order and stockholder
approval. The Plan authorizes the issuance of Options and Restricted
Stock to the Company's directors, including Non-Employee Directors,
officers and other employees (``Participants'').\2\
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\2\ Options will not be granted to Non-Employee Directors.
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5. The Plan will authorize the issuance of Options and Restricted
Stock subject to certain forfeiture restrictions. The restrictions may
relate to continued employment or service on the Board, the performance
of the Applicant pursuant to performance goals as set forth in the
Plan, or other restrictions deemed by the Required Majority,\3\ the
Compensation, Corporate Governance, and Nominating Committee \4\ or the
Board from time to time to be appropriate and in the best interests of
Applicant and its stockholders. Unless otherwise determined by the
Board, a Participant granted Restricted Stock will have all of the
rights of a stockholder including, without limitation, the right to
vote Restricted Stock and the right to receive dividends, including
deemed dividends, thereon, although such rights may be deferred during
the restricted period applicable to these awards. Restricted Stock may
not be transferred, pledged, hypothecated, margined, or otherwise
encumbered by the Participant during the restricted period, except for
disposition by will or intestacy. Except as otherwise determined by the
Board under the Plan, upon termination of a Participant's employment or
director relationship with the Company during the applicable
restriction period, the Participant's Restricted Stock and any accrued
and unpaid dividends that are then subject to restrictions shall
generally be forfeited.\5\
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\3\ Section 57(o) of the Act provides that the term ``required
majority,'' when used with respect to the approval of a proposed
transaction, plan, or arrangement, means both a majority of a BDC's
directors or general partners who have no financial interest in such
transaction, plan, or arrangement and a majority of such directors
or general partners who are not interested persons of such company.
\4\ The ``Compensation, Corporate Governance, and Nominating
Committee'' is composed of ``non-employee directors'' within the
meaning of rule 16b-3, and ``outside directors'' within the meaning
of section 162(m) of the Internal Revenue Code of 1986, as amended.
\5\ If any shares subject to an award granted under the Plan are
forfeited, cancelled, exchanged or surrendered or if an award
terminates or expires without an issuance of shares, those shares
will again be available for awards under the Plan.
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6. A maximum of twenty percent (20%) of Applicant's total shares of
common stock issued and outstanding (as of the Effective Date) \6\ will
be available for awards under the Plan. Under the Plan, no more than
fifty percent (50%) of the shares of stock reserved for the grant of
awards under the Plan may be Restricted Stock awards at any time during
the term of the Plan. The maximum amount of Restricted Stock that may
be outstanding at any particular time will be ten percent of the
Applicant's voting securities.\7\ Under the Plan, the aggregate number
of shares of common stock deliverable pursuant to awards will not
exceed 3,000,000.\8\
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\6\ Effective Date is defined in section 2(p) of the Plan as the
date on which the Plan is approved by Applicant's stockholders.
\7\ For purposes of calculating compliance with this limit, the
Company will count as Restricted Stock all shares of its common
stock that are issued under the Plan less any shares that are
forfeited back to the Company and cancelled as a result of
forfeiture restrictions not lapsing.
\8\ If the Company does not receive the order to issue
Restricted Stock, all shares granted under the Plan may be subject
to Options. All Option awards will be issued to employees in
accordance with the statutory provisions set forth in section 61 and
will not be granted to Non-Employee Directors.
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7. The Plan will be administered by the Compensation, Corporate
Governance, and Nominating Committee with respect to Participants
employed by Applicant and by the Board with respect to Non-Employee
Directors, and the Board will have the responsibility to ensure that
the Plan is operated in a manner that best serves the interests of
Applicant and its stockholders. Restricted Stock will be awarded to
certain employees, officers and directors, including Non-Employee
Directors, from time to time as part of the employees', officers' or
directors' compensation based on their actual or expected performance
and value to the Company. All awards of Restricted Stock to employees
and Non-Employee Directors will be approved by the Required Majority.
Awards of Restricted Stock to Non-Employee Directors will be made on
the schedule described below.
8. Under the Plan, Non-Employee Directors will each receive a grant
of up to 2,000 shares of Restricted Stock at the beginning of each one-
year term of service on the Board, for which forfeiture restrictions
will lapse as to one-third of such shares each year for three years.
Each grant of Restricted Stock to Non-Employee Directors will be made
pursuant to this schedule and will not be changed without Commission
approval.
9. The Plan provides that the Company is authorized to withhold
stock (in whole or in part) from any award of Restricted Stock granted
in satisfaction of a Participant's tax obligations. In addition, as
discussed more fully in the application, the exercise of Options will
result in the recipient being deemed to have received compensation in
the amount by which the fair market value of the shares of the
Company's common stock, determined as of the date of exercise, exceeds
the
[[Page 23070]]
exercise price. Accordingly, Applicant requests relief to withhold
shares of its common stock or purchase shares of its common stock from
Participants to satisfy tax withholding obligations related to the
exercise of Options granted under the 2014 Plan or the vesting of
Restricted Stock or exercise of Options that will be granted pursuant
to the Plan. Applicant also requests an exemption to permit
Participants to pay the exercise price of Options that were granted
under the 2014 Plan or will be granted to them pursuant to the Plan
with shares of the Company's common stock.
10. The Plan was approved on April 27, 2015 by the Compensation,
Corporate Governance and Nominating Committee and the Board, including
the Required Majority. The Plan will be submitted for approval to the
Company's stockholders, and will become effective upon such approval,
subject to and following receipt of the requested order.
Applicant's Legal Analysis
Sections 23(a) and (b), Section 63
1. Under section 63 of the Act, the provisions of section 23(a) of
the Act generally prohibiting a registered closed-end investment
company from issuing securities for services or for property other than
cash or securities are made applicable to BDCs. This provision would
prohibit the issuance of Restricted Stock as a part of the Plan.
2. Section 23(b) of the Act generally prohibits a registered
closed-end investment company from selling any common stock of which it
is the issuer at a price below its current net asset value. Section
63(2) of the Act makes section 23(b) applicable to BDCs unless certain
conditions are met. Because Restricted Stock that would be granted
under the Plan would not meet the terms of section 63(2), sections
23(b) and 63 would prevent the issuance of Restricted Stock.
3. Section 6(c) provides, in part, that the Commission may, by
order upon application, conditionally or unconditionally exempt any
person, security, or transaction, or any class or classes thereof, from
any provision of the Act, if and to the extent that the exemption is
necessary or appropriate in the public interest and consistent with the
protection of investors and the purposes fairly intended by the policy
and provisions of the Act.
4. Applicant requests an order pursuant to section 6(c) of the Act
granting an exemption from the provisions of sections 23(a), 23(b) and
63 of the Act. Applicant states that the Plan would not violate the
concerns underlying these sections, which include: (a) Preferential
treatment of investment company insiders and the use of options and
other rights by insiders to obtain control of the investment company;
(b) complication of the investment company's structure that made it
difficult to determine the value of the company's shares; and (c)
dilution of shareholders' equity in the investment company. Applicant
asserts that the Plan does not raise concerns about preferential
treatment of Applicant's insiders because the Plan is a bona fide
compensation plan of the type that is common among corporations
generally. In addition, section 61(a)(3)(B) of the Act permits a BDC to
issue to its directors, officers, employees, and general partners
warrants, options, and rights to purchase the BDC's voting securities
pursuant to an executive compensation plan, subject to certain
conditions. Applicant states that, for reasons that are unclear,
section 61 and its legislative history do not address the issuance by a
BDC of restricted stock as incentive compensation. Applicant believes,
however, that the issuance of Restricted Stock is substantially
similar, for purposes of investor protection under the Act, to the
issuance of warrants, options, and rights as contemplated by section
61. Applicant also asserts that the issuance of Restricted Stock would
not become a means for insiders to obtain control of Applicant because
the maximum amount of Restricted Stock that may be issued under the
Plan at any one time will be ten percent of the outstanding shares of
common stock of Applicant. Moreover, no single Participant will be
granted more than 25% of the shares of stock reserved for issuance
under the Plan.
5. Applicant further states that the Plan will not unduly
complicate Applicant's capital structure because equity-based incentive
compensation arrangements are widely used among corporations and
commonly known to investors. Applicant notes that the Plan will be
submitted for approval to the Company's stockholders. Applicant
represents that the proxy materials submitted to Applicant's
stockholders will contain a concise ``plain English'' description of
the Plan and its potential dilutive effect. Applicant also states that
it will comply with the proxy disclosure requirements in Item 10 of
Schedule 14A under the Securities Exchange Act of 1934. Applicant
further notes that the Plan will be disclosed to investors in
accordance with the requirements of the Form N-2 registration statement
for closed-end investment companies and pursuant to the standards and
guidelines adopted by the Financial Accounting Standards Board for
operating companies. Applicant also will comply with the disclosure
requirements for executive compensation plans applicable to BDCs.\9\
Applicant thus concludes that the Plan will be adequately disclosed to
investors and appropriately reflected in the market value of
Applicant's shares.
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\9\ See Executive Compensation and Related Party Disclosure,
Securities Act Release No. 8655 (Jan. 27, 2006) (proposed rule);
Executive Compensation and Related Party Disclosure, Securities Act
Release No. 8732A (Aug. 29, 2006) (final rule and proposed rule), as
amended by Executive Compensation Disclosure, Securities Act Release
No. 8756 (Dec. 22, 2006) (adopted as interim final rules with
request for comments).
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6. Applicant acknowledges that awards granted under the Plan may
have a dilutive effect on the stockholders' equity per share in
Applicant, but believes that effect would be outweighed by the
anticipated benefits of the Plan to Applicant and its stockholders.
Moreover, based on the manner in which the issuance of Restricted Stock
pursuant to the Plan will be administered, the Restricted Stock will be
no more dilutive than if Applicant were to issue only Options to
Participants who are employees, as is permitted by section 61(a)(3) of
the Act. Applicant asserts that it needs the flexibility to provide the
requested equity-based compensation in order to be able to compete
effectively with other venture capital firms for talented
professionals. These professionals, Applicant suggests, in turn are
likely to increase Applicant's performance and stockholder value.
Applicant also asserts that equity-based compensation would more
closely align the interests of Applicant's employees and Non-Employee
Directors with those of its stockholders. In addition, Applicant states
that its stockholders will be further protected by the conditions to
the requested order that assure continuing oversight of the operation
of the Plan by the Board.
Section 57(a)(4), Rule 17d-1
7. Section 57(a) proscribes certain transactions between a BDC and
persons related to the BDC in the manner described in section 57(b)
(``57(b) persons''), absent a Commission order. Section 57(a)(4)
generally prohibits a 57(b) person from effecting a transaction in
which the BDC is a joint participant absent such an order. Rule 17d-1,
made applicable to BDCs by section 57(i), proscribes participation in a
``joint enterprise or other joint arrangement or
[[Page 23071]]
profit-sharing plan,'' which includes a stock option or purchase plan.
Employees and directors of a BDC are 57(b) persons. Thus, the issuance
of shares of Restricted Stock could be deemed to involve a joint
transaction involving a BDC and a 57(b) person in contravention of
section 57(a)(4). Rule 17d-1(b) provides that, in considering relief
pursuant to the rule, the Commission will consider (a) whether the
participation of the BDC in a joint enterprise is consistent with the
policies and purposes of the Act and (b) the extent to which such
participation is on a basis different from or less advantageous than
that of other participants.
8. Applicant requests an order pursuant to sections 57(a)(4) and
57(i) of the Act and rule 17d-1 under the Act to permit Applicant to
issue Restricted Stock under the Plan. Applicant acknowledges that its
role is necessarily different from the other participants because the
other participants are its directors and employees. It notes, however,
that the Plan is in the interest of the Company's stockholders, because
the Plan will help align the interests of Applicant's employees with
those of its stockholders, which will encourage conduct on the part of
those employees designed to produce a better return for Applicant's
stockholders. Additionally, section 57(j)(1) of the Act expressly
permits any director, officer or employee of a BDC to acquire warrants,
options and rights to purchase voting securities of such BDC, and the
securities issued upon the exercise or conversion thereof, pursuant to
an executive compensation plan which meets the requirements of section
61(a)(3)(B) of the Act. Applicant submits that the issuance of
Restricted Stock pursuant to the Plan poses no greater risk to
stockholders than the issuances permitted by section 57(j)(1) of the
Act.
Section 23(c)
9. Section 23(c) of the Act, which is made applicable to BDCs by
section 63 of the Act, generally prohibits a BDC from purchasing any
securities of which it is the issuer except in the open market pursuant
to tenders, or under other circumstances as the Commission may permit
to ensure that the purchases are made in a manner or on a basis that
does not unfairly discriminate against any holders of the class or
classes of securities to be purchased. Applicant states that the
withholding or purchase of shares of Restricted Stock and common stock
in payment of applicable withholding tax obligations or of common stock
in payment for the exercise price of a stock option might be deemed to
be purchases by the Company of its own securities within the meaning of
section 23(c) and therefore prohibited by the Act.
10. Section 23(c)(3) of the Act permits a BDC to purchase
securities of which it is the issuer in circumstances in which the
repurchase is made in a manner or on a basis that does not unfairly
discriminate against any holders of the class or classes of securities
to be purchased. Applicant believes that the requested relief meets the
standards of section 23(c)(3).
11. Applicant submits that these purchases will be made in a manner
that does not unfairly discriminate against Applicant's stockholders
because all purchases of Applicant's stock will be at the closing price
of the common stock on the Nasdaq Global Market (or any primary
exchange on which its shares of common stock may be traded in the
future) on the relevant date (i.e., the public market price on the date
of grant of Restricted Stock and the date of grant of Options).
Applicant submits that because all transactions with respect to the
Plan will take place at the public market price for the Company's
common stock, these transactions will not be significantly different
than could be achieved by any stockholder selling in a market
transaction. Applicant represents that no transactions will be
conducted pursuant to the requested order on days where there are no
reported market transactions involving Applicant's shares.
12. Applicant represents that the withholding provisions in the
Plan do not raise concerns about preferential treatment of Applicant's
insiders because the Plan is a bona fide compensation plan of the type
that is common among corporations generally. Furthermore, the vesting
schedule is determined at the time of the initial grant of the
Restricted Stock and the option exercise price is determined at the
time of the initial grant of the Options. Applicant represents that all
purchases may be made only as permitted by the Plan, which will be
approved by the Company's stockholders prior to any application of the
relief. Applicant believes that granting the requested relief would be
consistent with the policies underlying the provisions of the Act
permitting the use of equity compensation as well as prior exemptive
relief granted by the Commission under section 23(c) of the Act.
Applicant's Conditions
Applicant agrees that the order granting the requested relief will
be subject to the following conditions:
1. The Plan will be authorized by Applicant's stockholders.
2. Each issuance of Restricted Stock to an officer, employee, or
Non-Employee Director will be approved by the Required Majority of
Applicant's directors on the basis that such grant is in the best
interest of Applicant and its stockholders.
3. The amount of voting securities that would result from the
exercise of all of Applicant's outstanding warrants, options and
rights, together with any Restricted Stock issued and outstanding
pursuant to the Plan, will not at the time of issuance of any warrant,
option, right or share of Restricted Stock under the Plan, exceed 20
percent of Applicant's outstanding voting securities.
4. The amount of Restricted Stock issued and outstanding will not
at the time of issuance of any shares of Restricted Stock exceed ten
percent of Applicant's outstanding voting securities.
5. The Board will review the Plan at least annually. In addition,
the Board will review periodically the potential impact that the
issuance of Restricted Stock under the Plan could have on Applicant's
earnings and net asset value per share, such review to take place prior
to any decisions to grant Restricted Stock under the Plan, but in no
event less frequently than annually. Adequate procedures and records
will be maintained to permit such review. The Board will be authorized
to take appropriate steps to ensure that the issuance of Restricted
Stock under the Plan will be in the best interest of Applicant and its
stockholders. This authority will include the authority to prevent or
limit the granting of additional Restricted Stock under the Plan. All
records maintained pursuant to this condition will be subject to
examination by the Commission and its staff.
For the Commission, by the Division of Investment Management,
under delegated authority.
Brent J. Fields,
Secretary.
[FR Doc. 2016-08934 Filed 4-18-16; 8:45 am]
BILLING CODE 8011-01-P