Carey Credit Income Fund, et al.; Notice of Application, 36967-36973 [2016-13514]
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Federal Register / Vol. 81, No. 110 / Wednesday, June 8, 2016 / Notices
proposed rule change should be
disapproved. The Commission is
extending this 45-day time period.
The Commission finds that it is
appropriate to designate a longer period
within which to take action on the
proposed rule change so that it has
sufficient time to consider the proposed
rule change. Accordingly, the
Commission, pursuant to Section
19(b)(2) of the Act,7 designates July 21,
2016, as the date by which the
Commission should approve,
disapprove, or institute proceedings to
determine whether to disapprove the
proposed rule change (File No. SR–
NYSEMKT–2016–15), as modified by
Amendment No. 1.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.8
Brent J. Fields,
Secretary.
[FR Doc. 2016–13476 Filed 6–7–16; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–77977; File No. SR–
NYSEArca–2016–19]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Designation of
Longer Period for Commission Action
on a Proposed Rule Change, as
Modified by Amendment No. 1, To
Establish Certain End User Fees,
Amend the Definition of Affiliate, and
Amend the Co-Location Section of the
Fee Schedule To Reflect the Changes
June 2, 2016.
mstockstill on DSK3G9T082PROD with NOTICES
On April 4, 2016, NYSE Arca, Inc.
(the ‘‘Exchange’’ or ‘‘NYSE Arca’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to establish fees relating to
certain end users, amend the definition
of Affiliate, and amend the co-location
section of the Fee Schedule to reflect the
changes. The Commission published the
proposed rule change for comment in
the Federal Register on April 22, 2016.3
On April 29, 2016, the Exchange filed
Amendment No. 1 to the proposed rule
change.4 The Commission received no
7 Id.
8 17
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See Securities Exchange Act Release No. 34–
77641 (April 18, 2016), 81 FR 23773 (‘‘Notice’’).
4 Amendment No. 1 made technical changes
relating to the General Notes numbering and
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comments on the proposed rule
change.5
Section 19(b)(2) of the Act 6 provides
that, within 45 days of the publication
of the notice of the filing of a proposed
rule change, or within such longer
period up to 90 days as the Commission
may designate if it finds such longer
period to be appropriate and publishes
its reasons for so finding or as to which
the self-regulatory organization
consents, the Commission shall approve
the proposed rule change, disapprove
the proposed rule change, or institute
proceedings to determine whether the
proposed rule change should be
disapproved. The Commission is
extending this 45-day time period.
The Commission finds that it is
appropriate to designate a longer period
within which to take action on the
proposed rule change so that it has
sufficient time to consider the proposed
rule change. Accordingly, the
Commission, pursuant to Section
19(b)(2) of the Act,7 designates July 21,
2016, as the date by which the
Commission should approve,
disapprove, or institute proceedings to
determine whether to disapprove the
proposed rule change (File No. SR–
NYSEArca–2016–19), as modified by
Amendment No. 1.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.8
Brent J. Fields,
Secretary.
[FR Doc. 2016–13475 Filed 6–7–16; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–32138; File No. 812–14426]
Carey Credit Income Fund, et al.;
Notice of Application
June 2, 2016.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of application for an
order under sections 17(d) and 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 sections 17(d)
and 57(a)(4) of the Act and rule 17d–1
under the Act.
AGENCY:
references in the Co-location section of the Fee
Schedule.
5 The Commission notes that it did receive two
comment letters on a related filing, NYSE–2016–11,
which are equally relevant to this filing.
6 15 U.S.C. 78s(b)(2).
7 Id.
8 17 CFR 200.30–3(a)(12).
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36967
Summary of Application: Applicants
request an order to permit certain
business development companies
(‘‘BDC’’) and closed-end management
investment companies to co-invest in
portfolio companies with each other and
with affiliated investment funds.
Applicants: Carey Credit Income
Fund (the ‘‘Fund’’); Carey Credit
Advisors, LLC (‘‘W.P. Carey’’);
Guggenheim Partners Investment
Management, LLC (‘‘Guggenheim’’);
Guggenheim Funds Distributors, LLC,
Guggenheim Funds Investment
Advisors, LLC, Security Investors, LLC
(collectively, together with Guggenheim,
the ‘‘Existing Guggenheim Advisers’’);
Guggenheim European Credit Fund,
Guggenheim Private Debt Fund Note
Issuer, LLC, Guggenheim Private Debt
Fund, LLC, Guggenheim Private Debt
Fund, Ltd., Guggenheim Private Debt
Master Fund, LLC, Guggenheim Private
Debt Fund Note Issuer 2.0, LLC,
Guggenheim Private Debt Fund 2.0,
LLC, Guggenheim Private Debt Fund
2.0, Ltd., Guggenheim Private Debt
Master Fund 2.0, LLC, NZC Guggenheim
Fund LLC, NZC Guggenheim Fund
Limited, NZC Guggenheim Master Fund
Limited, NZCG Funding Ltd., NZCG
Funding 2 Limited, South Dock Funding
Limited, NZCG Feeder I, L.P., NZCG
Funding 2, LLC, NZCG Funding LLC,
Guggenheim U.S. Loan Fund,
Guggenheim U.S. Loan Fund II,
Guggenheim U.S. Loan Fund III,
Guggenheim Opportunistic U.S. Loan
and Bond Fund IV, Guggenheim Loan
and Bond Fund V, Guggenheim Loan
and Bond Fund VI, GFI Fund, and GHY
Fund (collectively, the ‘‘Existing
Affiliated Investors’’).
Filing Dates: The application was
filed on February 23, 2015, and
amended on June 12, 2015, October 20,
2015, February 25, 2016 and April 29,
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 June 27, 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
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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: W.P. Carey and the Fund:
50 Rockefeller Plaza, New York, NY
10020; the Existing Guggenheim
Advisers and the Existing Affiliated
Investors: 100 Wilshire Boulevard, 5th
Floor, Santa Monica, CA 90401.
FOR FURTHER INFORMATION CONTACT:
Robert Shapiro, Senior Counsel, at (202)
551–7758 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.
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Applicants’ Representations
1. The Fund is a Delaware statutory
trust organized as a closed-end
management investment company that
has elected to be regulated as a BDC
under the Act.1 The Fund serves as the
master fund in a master-feeder structure
with two feeder funds and makes
investments with the proceeds it
receives from the sale of shares of the
feeder funds.2 The Fund’s Objectives
and Strategies 3 are to provide
shareholders with current income,
capital preservation and, to a lesser
extent, long-term capital appreciation.
The Fund invests primarily in large,
privately-negotiated loans to private
middle market U.S. companies and in
opportunities that are originated by
various intermediaries where the Fund
is able to play a differentiated role
gaining outsized allocation, influencing
structure, pricing, and fees compared to
the broader market (this could include
1 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
2 The existing feeder funds are Carey Credit
Income Fund—I and Carey Credit Income Fund
2016 T. Any future feeder fund will be created by
W.P. Carey.
3 ‘‘Objectives and Strategies’’ means a Regulated
Entity’s (as defined below) investment objectives
and strategies, as described in the Regulated
Entity’s registration statement on Form N–2, other
filings the Regulated Entity has made with the
Commission under the Securities Act of 1933 (the
‘‘Securities Act’’), or under the Securities Exchange
Act of 1934, and the Regulated Entity’s reports to
shareholders.
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more broadly syndicated assets such as
bank loans and corporate bonds). The
Fund has a five member Board,4 of
which three members are Independent
Trustees.5
2. W.P. Carey is a Delaware limited
liability company and is registered as an
investment adviser under the
Investment Advisers Act of 1940 (the
‘‘Advisers Act’’). W.P. Carey serves as
the investment adviser to the Fund.
W.P. Carey also provides administrative
services to the Fund under an
administrative services agreement.
3. Guggenheim is a Delaware limited
liability company and is registered as an
investment adviser under the Advisers
Act. Guggenheim serves as the subadviser to the Fund. Guggenheim is part
of the investment management business
of Guggenheim Partners LLC, a privately
held, global financial services firm.
4. Each Existing Affiliated Investor is
a privately-offered fund that would be
an investment company but for section
3(c)(1) or 3(c)(7) of the Act. An Existing
Guggenheim Adviser serves as the
investment adviser to each Existing
Affiliated Investor. Each Existing
Guggenheim Adviser is either controlled
by Guggenheim or under common
control with Guggenheim and is
registered as an investment adviser
under the Advisers Act.
5. Applicants seek an order (‘‘Order’’)
to permit one or more Regulated
Entities 6 and/or one or more Affiliated
Investors 7 to participate in the same
investment opportunities through a
proposed co-investment program (the
‘‘Co-Investment Program’’) where such
participation would otherwise be
prohibited under sections 17(d) and
57(a)(4) and the rules under the Act. For
purposes of the application, ‘‘CoInvestment Transaction’’ means any
transaction in which a Regulated Entity
(or its Wholly-Owned Investment
Subsidiary, as defined below)
participated together with one or more
other Regulated Entities and/or one or
more Affiliated Investors in reliance on
the requested Order. ‘‘Potential CoInvestment Transaction’’ means any
investment opportunity in which a
Regulated Entity (or its Wholly-Owned
Investment Subsidiary) could not
participate together with one or more
Affiliated Investors and/or one or more
other Regulated Entities without
obtaining and relying on the Order.8
The term ‘‘Adviser’’ means any W.P.
Carey Adviser or any Guggenheim
Adviser.
6. Applicants state that a Regulated
Entity may, from time to time, form a
Wholly-Owned Investment Subsidiary.9
Such a subsidiary would be prohibited
from investing in a Co-Investment
Transaction with any Affiliated Investor
because it would be a company
controlled by its parent Regulated Entity
for purposes of section 57(a)(4) and rule
17d–1. Applicants request that each
Wholly-Owned Investment Subsidiary
be permitted to participate in CoInvestment Transactions in lieu of its
parent Regulated Entity and that the
Wholly-Owned Investment Subsidiary’s
participation in any such transaction be
treated, for purposes of the requested
Order, as though the parent Regulated
4 The term ‘‘Board’’ refers to the board of directors
or trustees of any Regulated Entity.
5 The term ‘‘Independent Trustees’’ refers to the
trustees or directors of any Regulated Entity that are
not ‘‘interested persons’’ of the Regulated Entity
within the meaning of section 2(a)(19) of the Act.
6 ‘‘Regulated Entity’’ means the Fund and any
Future Regulated Entity. ‘‘Future Regulated Entity’’
means a closed-end management investment
company (a) that is registered under the Act or has
elected to be regulated as a BDC under the Act, (b)
whose investment adviser is a W.P. Carey Adviser
and (c) whose investment sub-adviser is a
Guggenheim Adviser. ‘‘W.P. Carey Adviser’’ means
W.P. Carey or any future investment adviser that (i)
controls, is controlled by or is under common
control with W.P. Carey, (ii) is registered as an
investment adviser under the Advisers Act and (iii)
is not a Regulated Entity or a subsidiary of a
Regulated Entity. ‘‘Guggenheim Adviser’’ means
any Existing Guggenheim Adviser or any future
investment adviser that (i) controls, is controlled by
or is under common control with Guggenheim, (ii)
is registered as an investment adviser under the
Advisers Act, and (iii) is not a Regulated Entity or
a subsidiary of a Regulated Entity.
7 ‘‘Affiliated Investors’’ means the Existing
Affiliated Investors and any Future Affiliated
Investor. ‘‘Future Affiliated Investor’’ means an
entity (a) whose investment adviser is a
Guggenheim Adviser and (b) that would be an
investment company but for section 3(c)(1) or
3(c)(7) of the Act.
8 All existing entities that currently intend to rely
upon the requested Order have been named as
applicants. Any other existing or future entity that
subsequently relies on the Order will comply with
the terms and conditions of the application.
9 The term ‘‘Wholly-Owned Investment
Subsidiary’’ means an entity (i) that is whollyowned by a Regulated Entity (with such Regulated
Entity at all times holding, beneficially and of
record, 100% of the voting and economic interests);
(ii) whose sole business purpose is to hold one or
more investments on behalf of the Regulated Entity
(and, in the case of an entity that is licensed by the
Small Business Administration to operate under the
Small Business Investment Act of 1958, as amended
(the ‘‘SBA Act’’), as a small business investment
company (an ‘‘SBIC’’), to maintain a license under
the SBA Act and issue debentures guaranteed by
the Small Business Administration); (iii) with
respect to which the Regulated Entity’s Board has
the sole authority to make all determinations with
respect to the entity’s participation under the
conditions of the application; and (iv) that would
be an investment company but for section 3(c)(1) or
3(c)(7) of the Act. All subsidiaries participating in
the Co-Investment Program will be Wholly-Owned
Investment Subsidiaries and will have Objectives
and Strategies that are either substantially the same
as, or a subset of, their parent Regulated Entity’s
Objectives and Strategies. A subsidiary that is an
SBIC may be a Wholly-Owned Investment
Subsidiary if it satisfies the conditions in this
definition.
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Entity were participating directly.
Applicants represent that this treatment
is justified because a Wholly-Owned
Investment Subsidiary would have no
purpose other than serving as a holding
vehicle for the Regulated Entity’s
investments and, therefore, no conflicts
of interest could arise between the
Regulated Entity and the Wholly-Owned
Investment Subsidiary. The Regulated
Entity’s Board would make all relevant
determinations under the conditions
with regard to a Wholly-Owned
Investment Subsidiary’s participation in
a Co-Investment Transaction, and the
Regulated Entity’s Board would be
informed of, and take into
consideration, any proposed use of a
Wholly-Owned Investment Subsidiary
in the Regulated Entity’s place. If the
Regulated Entity proposes to participate
in the same Co-Investment Transaction
with any of its Wholly-Owned
Investment Subsidiaries, the Board will
also be informed of, and take into
consideration, the relative participation
of the Regulated Entity and the WhollyOwned Investment Subsidiary.
7. It is anticipated that a Guggenheim
Adviser will periodically determine that
certain investments the Guggenheim
Adviser recommends for a Regulated
Entity would also be appropriate
investments for one or more other
Regulated Entities and/or one or more
Affiliated Investors. Such a
determination may result in the
Regulated Entity, one or more other
Regulated Entities and/or one or more
Affiliated Investors co-investing in
certain investment opportunities. For
each such investment opportunity, the
Advisers to each Regulated Entity will
independently analyze and evaluate the
investment opportunity as to its
appropriateness for such Regulated
Entity taking into consideration the
Regulated Entity’s Objectives and
Strategies.
8. Applicants state that W.P. Carey
serves as the Fund’s investment adviser
and administrator and either it or
another W.P. Carey Adviser will serve
in the same capacity to any Future
Regulated Entity, and that Guggenheim
serves as the Fund’s sub-adviser and
either it or another Guggenheim Adviser
will serve in the same capacity to any
Future Regulated Entity. Applicants
represent that although a Guggenheim
Adviser will identify and recommend
investments 10 for each Regulated
Entity, prior to any investment by the
Regulated Entity, the Guggenheim
Adviser will present each proposed
10 Applicants represent that the W.P. Carey
Advisers will not source any Potential CoInvestment Transactions under the requested Order.
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investment to the W.P. Carey Adviser
which has the authority to approve or
reject all investments proposed for the
Regulated Entity by the Guggenheim
Adviser.
9. Applicants state that each
Guggenheim Adviser has (or will have,
in the case of future advisers) an
investment committee through which it
will carry out its obligation under
condition 1 to make a determination as
to the appropriateness of a Potential CoInvestment Transaction for each
Regulated Entity. Applicants represent
that each Guggenheim Adviser, as a
registered investment adviser, has (or
will have, in the case of future advisers)
developed a robust allocation process
that is designed to allocate investment
opportunities fairly and equitably
among its clients over time. Applicants
state that, in the case of a Potential CoInvestment Transaction, the applicable
Guggenheim Adviser would apply its
allocation policies and procedures in
determining the proposed allocation for
the Regulated Entity consistent with the
requirements of condition 2(a).
10. Applicants state that, once the
applicable Guggenheim Adviser
determined a proposed allocation for a
Regulated Entity, such Guggenheim
Adviser would notify the applicable
W.P. Carey Adviser of the Potential CoInvestment Transaction and the
Guggenheim Adviser’s recommended
allocation for such Regulated Entity.
Applicants further state that the
applicable W.P. Carey Adviser would
then present the Potential CoInvestment Transaction and the
Guggenheim Adviser’s proposed
allocation to the W.P. Carey Adviser’s
investment committee for its approval.
Applicants represent that the W.P.
Carey Adviser’s investment committee
would review the Guggenheim
Adviser’s recommendation for the
Regulated Entity and would have the
ability to ask questions of the
Guggenheim Adviser and request
additional information from the
Guggenheim Adviser. Applicants
further submit that if the W.P. Carey
Adviser’s investment committee
approved the investment for the
Regulated Entity, the investment and all
relevant allocation information would
then be presented to the Regulated
Entity’s Board for its approval in
accordance with the conditions to the
application. Applicants state that they
believe the investment process between
the Guggenheim Advisers and the W.P.
Carey Advisers, prior to seeking
approval from the Regulated Entity’s
Board (which is in addition to, rather
than in lieu of, the procedures required
under the conditions of the application),
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36969
is significant and provides for
additional procedures and processes to
ensure that the Regulated Entity is being
treated fairly in respect of Potential CoInvestment Transactions.
11. If the Advisers to a Regulated
Entity determine that a Potential CoInvestment Transaction is appropriate
for the Regulated Entity (and the
applicable W.P. Carey Adviser approves
the investment for such Regulated
Entity), and one or more other Regulated
Entities and/or one or more Affiliated
Investors may also participate, the
Advisers will present the investment
opportunity to the Eligible Trustees 11 of
the Regulated Entity prior to the actual
investment by the Regulated Entity. As
to any Regulated Entity, a CoInvestment Transaction will be
consummated only upon approval by a
required majority of the Eligible
Trustees of such Regulated Entity
within the meaning of section 57(o) of
the Act (‘‘Required Majority’’).12
12. With respect to the pro rata
dispositions and follow-on Investments
provided in conditions 7 and 8, a
Regulated Entity 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 each Regulated Entity
and Affiliated Investor in such
disposition is proportionate to its
outstanding investments in the issuer
immediately preceding the disposition
or follow-on investment, as the case
may be; and (ii) each Regulated Entity’s
Board has approved that Regulated
Entity’s participation in pro rata
dispositions and follow-on investments
as being in the best interests of the
Regulated Entity. If the Board does not
so approve, any such disposition or
follow-on investment will be submitted
to the Regulated Entity’s Eligible
Trustees. The Board of any Regulated
Entity 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 Trustees.
11 ‘‘Eligible Trustees’’ means the trustees or
directors of a Regulated Entity that are eligible to
vote under section 57(o) of the Act.
12 In the case of a Regulated Entity that is a
registered closed-end fund, the trustees or directors
that make up the Required Majority will be
determined as if the Regulated Entity were a BDC
subject to section 57(o). As defined in section 57(o),
‘‘required majority’’ means ‘‘both a majority of a
business development company’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.’’
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13. No Independent Trustee of a
Regulated Entity will have a financial
interest in any Co-Investment
Transaction.
14. Under condition 15, if an Adviser
or its principals, or any person
controlling, controlled by, or under
common control with the Adviser or its
the principals, and any Affiliated
Investors (collectively, the ‘‘Holders’’)
own in the aggregate more than 25% of
the outstanding voting securities of a
Regulated Entity (‘‘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 Trustees will act
independently in evaluating the CoInvestment Program, because the ability
of the Adviser or its principals to
influence the Independent Trustees by a
suggestion, explicit or implied, that the
Independent Trustees can be removed
will be limited significantly. Applicants
represent that the Independent Trustees
shall evaluate and approve any such
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
participation by a registered investment
company and an affiliated person in any
‘‘joint enterprise or other joint
arrangement or profit-sharing plan,’’ as
defined in the rule, without prior
approval by the Commission by order
upon application. Section 17(d) of the
Act and rule 17d–1 under the Act are
applicable to Regulated Entities that are
registered closed-end investment
companies. Similarly, with regard to
BDCs, section 57(a)(4) of the Act makes
it unlawful for any person who is
related to a BDC in a manner described
in section 57(b), acting as principal,
knowingly to effect any transaction in
which the BDC (or a company
controlled by such BDC) is a joint or a
joint and several participant with that
person in contravention of rules as
prescribed by the Commission. Because
the Commission has not adopted any
rules expressly under section 57(a)(4),
section 57(i) provides that the rules
under section 17(d) applicable to
registered closed-end investment
companies (e.g., rule 17d–1) are, in the
interim, deemed to apply to transactions
subject to section 57(a). 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
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in section 57(b), as modified by rule
57b–1, from 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 (or a company
controlled by such BDC) is a participant,
unless an application regarding the joint
enterprise, arrangement, or profitsharing plan has been filed with the
Commission and has been granted by an
order entered prior to the submission of
the plan or any modification thereof, to
security holders for approval, or prior to
its adoption or modification if not so
submitted.
2. 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 submit that each
Regulated Entity may be deemed to be
an ‘‘affiliated person’’ of each other
Regulated Entity within the meaning of
section 2(a)(3) of the Act. Applicants
state that the Regulated Entities, by
virtue of each having a W.P. Carey
Adviser, may be deemed to be under
common control, and thus affiliated
persons of each other under section
2(a)(3)(C) of the Act. Section 17(d) and
section 57(b) apply to any investment
adviser to a closed-end fund or a BDC,
respectively, including the sub-adviser.
Thus, a Guggenheim Adviser and any
Affiliated Investors that it advises could
be deemed to be persons related to
Regulated Entities in a manner
described by sections 17(d) and 57(b)
and therefore prohibited by sections
17(d) and 57(a)(4) and rule 17d–1 from
participating in the Co-Investment
Program. Applicants further submit that,
because the Guggenheim Advisers are
‘‘affiliated persons’’ of other
Guggenheim Advisers, Affiliated
Investors advised by any of them could
be deemed to be persons related to
Regulated Entities (or a company
controlled by a Regulated Entity) in a
manner described by sections 17(d) and
57(b) and also prohibited from
participating in the Co-Investment
Program.
4. Applicants state that they expect
that that co-investment in portfolio
companies by a Regulated Entity, one or
more other Regulated Entities and/or
one or more Affiliated Investors will
increase favorable investment
opportunities for each Regulated Entity.
5. Applicants submit that the fact that
the Required Majority will approve each
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Co-Investment Transaction before
investment (except for certain
dispositions or follow-on investments,
as described in the conditions), and
other protective conditions set forth in
the application, will ensure that each
Regulated Entity will be treated fairly.
Applicants state that each Regulated
Entity’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 other
participants. Applicants further state
that the terms and conditions proposed
herein will ensure that all such
transactions are reasonable and fair to
each Regulated Entity and the Affiliated
Investors and do not involve
overreaching by any person concerned,
including W.P. Carey or Guggenheim.
Applicants’ Conditions
Applicants agree that the Order will
be subject to the following conditions:
1. Each time a Guggenheim Adviser
considers a Potential Co-Investment
Transaction for an Affiliated Investor or
another Regulated Entity that falls
within a Regulated Entity’s then-current
Objectives and Strategies, the Advisers
to the Regulated Entity will make an
independent determination of the
appropriateness of the investment for
the Regulated Entity in light of the
Regulated Entity’s then-current
circumstances.
2. a. If the Advisers to a Regulated
Entity deem participation in any
Potential Co-Investment Transaction to
be appropriate for the Regulated Entity,
the Advisers will then determine an
appropriate level of investment for such
Regulated Entity.
b. If the aggregate amount
recommended by the Advisers to a
Regulated Entity to be invested by the
Regulated Entity in the Potential CoInvestment Transaction, together with
the amount proposed to be invested by
the other participating Regulated
Entities and Affiliated Investors,
collectively, in the same transaction,
exceeds the amount of the investment
opportunity, the amount of the
investment opportunity will be
allocated among the Regulated Entities
and such Affiliated Investors, pro rata
based on each participant’s Available
Capital 13 for investment in the asset
13 ‘‘Available Capital’’ means (a) for each
Regulated Entity, the amount of capital available for
investment determined based on the amount of cash
on hand, existing commitments and reserves, if any,
the targeted leverage level, targeted asset mix and
other investment policies and restrictions set from
time to time by the Board of the applicable
Regulated Entity or imposed by applicable laws,
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class being allocated, up to the amount
proposed to be invested by each. The
Advisers to each participating Regulated
Entity will provide the Eligible Trustees
of each participating Regulated Entity
with information concerning each
participating party’s Available Capital to
assist the Eligible Trustees with their
review of the Regulated Entity’s
investments for compliance with these
allocation procedures.
c. After making the determinations
required in conditions 1 and 2(a) above,
the Advisers to the Regulated Entity will
distribute written information
concerning the Potential Co-Investment
Transaction, including the amount
proposed to be invested by each
Regulated Entity and any Affiliated
Investor, to the Eligible Trustees of each
participating Regulated Entity for their
consideration. A Regulated Entity will
co-invest with one or more other
Regulated Entities and/or an Affiliated
Investor only if, prior to the Regulated
Entities’ and the Affiliated Investors’
participation in the Potential CoInvestment Transaction, a Required
Majority concludes that:
(i) The terms of the Potential CoInvestment Transaction, including the
consideration to be paid, are reasonable
and fair to the Regulated Entity and its
shareholders and do not involve
overreaching in respect of the Regulated
Entity or its shareholders on the part of
any person concerned;
(ii) the Potential Co-Investment
Transaction is consistent with:
(a) The interests of the Regulated
Entity’s shareholders; and
(b) the Regulated Entity’s then-current
Objectives and Strategies;
(iii) the investment by any other
Regulated Entity or an Affiliated
Investor would not disadvantage the
Regulated Entity, and participation by
the Regulated Entity would not be on a
basis different from or less advantageous
than that of any other Regulated Entity
or Affiliated Investor; provided, that if
another Regulated Entity or Affiliated
Investor, but not the Regulated Entity
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 shall not
rules, regulations or interpretations and (b) for each
Affiliated Investor, the amount of capital available
for investment determined based on the amount of
cash on hand, existing commitments and reserves,
if any, the targeted leverage level, targeted asset mix
and other investment policies and restrictions set
by the Affiliated Investor’s directors, general
partners or adviser or imposed by applicable laws,
rules, regulations or interpretations.
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be interpreted to prohibit a Required
Majority from reaching the conclusions
required by this condition 2(c)(iii), if:
(a) The Eligible Trustees will have the
right to ratify the selection of such
director or board observer, if any; and
(b) the Advisers to the Regulated
Entity agree to, and do, provide periodic
reports to the Regulated Entity’s Board
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
(c) any fees or other compensation
that any other Regulated Entity or any
Affiliated Investor or any affiliated
person of any other Regulated Entity or
an Affiliated Investor receives in
connection with the right of one or more
Regulated Entities or Affiliated Investors
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 Affiliated Investors
(who may, in turn, share their portion
with their affiliated persons) and any
participating Regulated Entity in
accordance with the amount of each
party’s investment; and
(iv) the proposed investment by the
Regulated Entity will not benefit the
Advisers, any other Regulated Entity or
the Affiliated Investors 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 under sections 17(e)
and 57(k) of the Act, as applicable, (C)
in the case of fees or other
compensation described in condition
2(c)(iii)(c), or (D) indirectly, as a result
of an interest in the securities issued by
one of the parties to the Co-Investment
Transaction.
3. Each Regulated Entity will have the
right to decline to participate in any
Potential Co-Investment Transaction or
to invest less than the amount proposed.
4. The Advisers will present to the
Board of each Regulated Entity, on a
quarterly basis, a record of all
investments in Potential Co-Investment
Transactions made by any of the other
Regulated Entities or any of the
Affiliated Investors during the
preceding quarter that fell within the
Regulated Entity’s then-current
Objectives and Strategies that were not
made available to the Regulated Entity,
and an explanation of why the
investment opportunities were not
offered to the Regulated Entity. All
information presented to the Board
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36971
pursuant to this condition will be kept
for the life of the Regulated Entity 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 8,14
a Regulated Entity will not invest in
reliance on the Order in any issuer in
which another Regulated Entity or an
Affiliated Investor or any affiliated
person of another Regulated Entity or an
Affiliated Investor is an existing
investor.
6. A Regulated Entity 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 Regulated
Entity and Affiliated Investor. The grant
to one or more Regulated Entities or
Affiliated Investors, but not the
Regulated Entity itself, 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 Regulated Entity or
Affiliated Investor elects to sell,
exchange or otherwise dispose of an
interest in a security that was acquired
by one or more Regulated Entities and/
or Affiliated Investors in a CoInvestment Transaction, the Advisers
will:
(i) Notify each Regulated Entity 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 each Regulated Entity
in the disposition.
b. Each Regulated Entity 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 the
Affiliated Investors and any other
Regulated Entity.
c. A Regulated Entity may participate
in such disposition without obtaining
prior approval of the Required Majority
if: (i) The proposed participation of each
Regulated Entity and each Affiliated
Investor in such disposition is
proportionate to its outstanding
investments in the issuer immediately
14 This exception applies only to follow-on
investments by a Regulated Entity in issuers in
which that Regulated Entity already holds
investments.
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preceding the disposition; (ii) the
Regulated Entity’s Board has approved
as being in the best interests of the
Regulated Entity the ability to
participate in such dispositions on a pro
rata basis (as described in greater detail
in the application); and (iii) the
Regulated Entity’s Board is provided on
a quarterly basis with a list of all
dispositions made in accordance with
this condition. In all other cases, the
Advisers will provide their written
recommendation as to the Regulated
Entity’s participation to the Eligible
Trustees, and the Regulated Entity will
participate in such disposition solely to
the extent that a Required Majority
determines that it is in the Regulated
Entity’s best interests.
d. Each Regulated Entity and each
Affiliated Investor will bear its own
expenses in connection with the
disposition.
8. a. If any Regulated Entity or
Affiliated Investor desires to make a
‘‘follow-on investment’’ (i.e., an
additional investment in the same
entity, including through the exercise of
warrants or other rights to purchase
securities of the issuer) in a portfolio
company whose securities were
acquired by the Regulated Entity and
the Affiliated Investor in a CoInvestment Transaction, the Advisers
will:
(i) Notify each Regulated Entity 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 each Regulated Entity.
b. A Regulated Entity may participate
in such follow-on investment without
obtaining prior approval of the Required
Majority if: (i) The proposed
participation of each Regulated Entity
and each Affiliated Investor in such
investment is proportionate to its
outstanding investments in the issuer
immediately preceding the follow-on
investment; and (ii) the Regulated
Entity’s Board has approved as being in
the best interests of such Regulated
Entity the ability to participate in
follow-on investments on a pro rata
basis (as described in greater detail in
the application). In all other cases, the
Advisers will provide their written
recommendation as to such Regulated
Entity’s participation to the Eligible
Trustees, and the Regulated Entity will
participate in such follow-on
investment solely to the extent that the
Required Majority determines that it is
in such Regulated Entity’s best interests.
c. If, with respect to any follow-on
investment:
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(i) The amount of a follow-on
investment is not based on the
Regulated Entities’ and the Affiliated
Investors’ outstanding investments
immediately preceding the follow-on
investment; and
(ii) the aggregate amount
recommended by the Advisers to be
invested by the Regulated Entity in the
follow-on investment, together with the
amount proposed to be invested by the
other participating Regulated Entities
and the Affiliated Investors in the same
transaction, exceeds the amount of the
opportunity; then the amount invested
by each such party will be allocated
among them pro rata based on each
participant’s Available Capital 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 be subject to the other conditions
set forth in the application.
9. The Independent Trustees of each
Regulated Entity will be provided
quarterly for review all information
concerning Potential Co-Investment
Transactions and Co-Investment
Transactions, including investments
made by other Regulated Entities or
Affiliated Investors that a Regulated
Entity considered but declined to
participate in, so that the Independent
Trustees may determine whether all
investments made during the preceding
quarter, including those investments
which the Regulated Entity considered
but declined to participate in, comply
with the conditions of the Order. In
addition, the Independent Trustees will
consider at least annually the continued
appropriateness for such Regulated
Entity of participating in new and
existing Co-Investment Transactions.
10. Each Regulated Entity will
maintain the records required by section
57(f)(3) of the Act as if each of the
Regulated Entities were a BDC and each
of the investments permitted under
these conditions were approved by a
Required Majority under section 57(f).
11. No Independent Trustee of a
Regulated Entity will also be a trustee,
director, general partner, managing
member or principal, or otherwise an
‘‘affiliated person’’ (as defined in the
Act) of any Affiliated Investor.
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 Securities
Act) shall, to the extent not payable by
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the Advisers under their respective
advisory agreements with the Regulated
Entities and the Affiliated Investors, be
shared by the Regulated Entities and the
Affiliated Investors in proportion to the
relative amounts of the securities held
or to be acquired or disposed of, as the
case may be.
13. Any transaction fee (including
break-up or commitment fees but
excluding brokers’ fees contemplated by
section 17(e) or 57(k) of the Act, as
applicable) 15 received in connection
with a Co-Investment Transaction will
be distributed to the participating
Regulated Entities and Affiliated
Investors on a pro rata basis based on
the amount they invested or committed,
as the case may be, in such CoInvestment Transaction. If any
transaction fee is to be held by an
Adviser pending consummation of the
transaction, the fee will be deposited
into an account maintained by the
Adviser at a bank or banks having the
qualifications prescribed in section
26(a)(1) of the Act, and the account will
earn a competitive rate of interest that
will also be divided pro rata among the
participating Regulated Entities and
Affiliated Investors based on the amount
they invest in the Co-Investment
Transaction. None of the other
Regulated Entities, Affiliated Investors,
the Advisers nor any affiliated person of
the Regulated Entities or the Affiliated
Investors 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 Regulated Entities
and the Affiliated Investors, 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
Regulated Entities’ and the Affiliated
Investors’ investment advisory
agreements).
14. The Advisers to the Regulated
Entities and Affiliated Investors will
maintain written policies and
procedures reasonably designed to
ensure compliance with the foregoing
conditions. These policies and
procedures will require, among other
things, that each of the Advisers to each
Regulated Entity will be notified of all
Potential Co-Investment Transactions
that fall within a Regulated Entity’s
then-current Objectives and Strategies
and will be given sufficient information
to make its independent determination
15 Applicants are not requesting and the
Commission is not providing any relief for
transaction fees received in connection with any
Co-Investment Transaction.
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Federal Register / Vol. 81, No. 110 / Wednesday, June 8, 2016 / Notices
and recommendations under conditions
1, 2(a), 7 and 8.
15. If the Holders own in the aggregate
more than 25 percent of the shares of a
Regulated Entity, then the Holders will
vote such shares as directed by an
independent third party when voting on
(1) the election of directors or trustees;
(2) the removal of one or more directors
or trustees; or (3) any matters requiring
approval by the vote of a majority of the
outstanding voting securities, as defined
in section 2(a)(42) of the Act.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Brent J. Fields,
Secretary.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
[FR Doc. 2016–13514 Filed 6–7–16; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–77975; File No. SR–NYSE–
2016–39]
Self-Regulatory Organizations; New
York Stock Exchange LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change Amending the
Exchange’s Price List To Eliminate
Certain Services That Are No Longer
Utilized by Users and To Remove
Obsolete Text
June 2, 2016.
mstockstill on DSK3G9T082PROD with NOTICES
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 May 23,
2016, New York Stock Exchange LLC
(‘‘NYSE’’ or the ‘‘Exchange’’) filed with
the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I, II, and III below, which Items
have been prepared by the selfregulatory organization. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of the Substance
of the Proposed Rule Change
The Exchange proposes to amend the
Exchange’s Price List to eliminate
certain services that are no longer
utilized by Users and to remove obsolete
text. 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.
1 15
U.S.C.78s(b)(1).
U.S.C. 78a.
3 17 CFR 240.19b–4.
2 15
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II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
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.
1. Purpose
The Exchange proposes to change the
Price List for the co-location 4 services
offered by the Exchange to eliminate
certain services that are no longer
utilized by Users 5 and to remove
obsolete text.
LCN CSP Access
The ‘‘Liquidity Center Network’’
(‘‘LCN’’) is a local area network
available in the data center. A User is
currently able to act as a content service
provider (a ‘‘CSP’’ User) and deliver
services to another User in the data
center (a ‘‘Subscribing’’ User).6 These
services could include, for example,
order routing/brokerage services and/or
data delivery services.
Currently, the Exchange offers CSP
Users specific, dedicated 10 gigabyte
(‘‘Gb’’) LCN connections (‘‘LCN CSP’’)
that would allow CSP Users to send data
to, and communicate with, all their
properly authorized Subscribing Users
4 The Exchange initially filed rule changes
relating to its co-location services with the
Securities and Exchange Commission
(‘‘Commission’’) in 2010. See Securities Exchange
Act Release No. 62960 (September 21, 2010), 75 FR
59310 (September 27, 2010) (SR–NYSE–2010–56).
The Exchange operates a data center in Mahwah,
New Jersey (the ‘‘data center’’) from which it
provides co-location services to Users.
5 For purposes of the Exchange’s co-location
services, a ‘‘User’’ means any market participant
that requests to receive co-location services directly
from the Exchange. See Securities Exchange Act
Release No. 76008 (September 29, 2015), 80 FR
60190 (October 5, 2015) (SR–NYSE–2015–40). As
specified in the Price List, a User that incurs colocation fees for a particular co-location service
pursuant thereto would not be subject to co-location
fees for the same co-location service charged by the
Exchange’s affiliates NYSE MKT LLC and NYSE
Arca, Inc. See Securities Exchange Act Release No.
70206 (August 15, 2013), 78 FR 51765 (August 21,
2013) (SR–NYSE–2013–59).
6 See Securities Exchange Act Release No. 67666
(August 15, 2012), 77 FR 50742 (August 22, 2012)
(SR–NYSE–2012–18).
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36973
at once. In such a case, a Subscribing
User would receive the services via its
standard LCN connection and would be
charged an initial and monthly fee
(‘‘CSP Subscriber fee’’) reflecting the
benefit of receiving services from the
CSP User in this manner.7
However, Users no longer utilize the
LCN CSP connection offering.
Accordingly, the Exchange proposes to
discontinue LCN CSP connections, and
to remove references to LCN CSP access
and CSP Subscriber fees from the Price
List. A CSP User would remain able to
deliver services to a Subscribing User
via direct cross connect, as is currently
the case and as was the case prior to the
introduction of the LCN CSP connection
offering.
Bundled Network Access
A User is currently able to select from
two ‘‘bundled’’ connectivity options
when connecting to the data center:
‘‘Bundled Network Access Option 1’’
and ‘‘Bundled Network Access Option
2’’.8 The Exchange proposes to
discontinue Bundled Network Access
Option 2, as Users no longer utilize it,
and to remove references to related
pricing from the Price List. In addition,
the Exchange proposes to rename
‘‘Bundled Network Access Option 1’’ as
‘‘Bundled Network Access,’’ as it would
be the sole remaining option.
IP Network Access
The Internet protocol (‘‘IP’’) network
is a local area network available in the
data center.9 IP network access is
offered in 1, 10 and 40 Gb capacities.
The Exchange proposes to delete a
statement in the Price List that the 40
Gb circuit of the IP network is expected
to be available no later than April 15,
2016,10 as such statement is obsolete.
This proposed change would have no
impact on pricing.
7 Id. Previously, the Exchange also offered a one
Gb LCN CSP connection, but it was discontinued
as it was no longer utilized by Users. See Securities
Exchange Act Release No. 72721 (July 30, 2014), 79
FR 45562 (August 5, 2014) (SR–NYSE–2014–37).
8 Previously, the Exchange offered other
‘‘bundled’’ connectivity options, but they were
discontinued as they were no longer utilized by
Users. See id., at 45562.
9 See Securities Exchange Act Release No. 74222
(February 6, 2015), 80 FR 7888 (February 12, 2015)
(SR–NYSE–2015–05) (notice of filing and
immediate effectiveness of proposed rule change to
include IP network connections and fiber cross
connects between a User’s cabinet and a non-User’s
equipment).
10 See Securities Exchange Act Release No. 76368
(November 5, 2015), 80 FR 70027 (November 12,
2015) (SR–NYSE–2015–54) (notice of filing and
immediate effectiveness of proposed rule change to
include IP 40 Gb network connections).
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Agencies
[Federal Register Volume 81, Number 110 (Wednesday, June 8, 2016)]
[Notices]
[Pages 36967-36973]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-13514]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-32138; File No. 812-14426]
Carey Credit Income Fund, et al.; Notice of Application
June 2, 2016.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of application for an order under sections 17(d) and
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 sections 17(d) and 57(a)(4) of the Act and rule 17d-1
under the Act.
-----------------------------------------------------------------------
Summary of Application: Applicants request an order to permit
certain business development companies (``BDC'') and closed-end
management investment companies to co-invest in portfolio companies
with each other and with affiliated investment funds.
Applicants: Carey Credit Income Fund (the ``Fund''); Carey Credit
Advisors, LLC (``W.P. Carey''); Guggenheim Partners Investment
Management, LLC (``Guggenheim''); Guggenheim Funds Distributors, LLC,
Guggenheim Funds Investment Advisors, LLC, Security Investors, LLC
(collectively, together with Guggenheim, the ``Existing Guggenheim
Advisers''); Guggenheim European Credit Fund, Guggenheim Private Debt
Fund Note Issuer, LLC, Guggenheim Private Debt Fund, LLC, Guggenheim
Private Debt Fund, Ltd., Guggenheim Private Debt Master Fund, LLC,
Guggenheim Private Debt Fund Note Issuer 2.0, LLC, Guggenheim Private
Debt Fund 2.0, LLC, Guggenheim Private Debt Fund 2.0, Ltd., Guggenheim
Private Debt Master Fund 2.0, LLC, NZC Guggenheim Fund LLC, NZC
Guggenheim Fund Limited, NZC Guggenheim Master Fund Limited, NZCG
Funding Ltd., NZCG Funding 2 Limited, South Dock Funding Limited, NZCG
Feeder I, L.P., NZCG Funding 2, LLC, NZCG Funding LLC, Guggenheim U.S.
Loan Fund, Guggenheim U.S. Loan Fund II, Guggenheim U.S. Loan Fund III,
Guggenheim Opportunistic U.S. Loan and Bond Fund IV, Guggenheim Loan
and Bond Fund V, Guggenheim Loan and Bond Fund VI, GFI Fund, and GHY
Fund (collectively, the ``Existing Affiliated Investors'').
Filing Dates: The application was filed on February 23, 2015, and
amended on June 12, 2015, October 20, 2015, February 25, 2016 and April
29, 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 June 27, 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
[[Page 36968]]
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: W.P. Carey and the
Fund: 50 Rockefeller Plaza, New York, NY 10020; the Existing Guggenheim
Advisers and the Existing Affiliated Investors: 100 Wilshire Boulevard,
5th Floor, Santa Monica, CA 90401.
FOR FURTHER INFORMATION CONTACT: Robert Shapiro, Senior Counsel, at
(202) 551-7758 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.
Applicants' Representations
1. The Fund is a Delaware statutory trust organized as a closed-end
management investment company that has elected to be regulated as a BDC
under the Act.\1\ The Fund serves as the master fund in a master-feeder
structure with two feeder funds and makes investments with the proceeds
it receives from the sale of shares of the feeder funds.\2\ The Fund's
Objectives and Strategies \3\ are to provide shareholders with current
income, capital preservation and, to a lesser extent, long-term capital
appreciation. The Fund invests primarily in large, privately-negotiated
loans to private middle market U.S. companies and in opportunities that
are originated by various intermediaries where the Fund is able to play
a differentiated role gaining outsized allocation, influencing
structure, pricing, and fees compared to the broader market (this could
include more broadly syndicated assets such as bank loans and corporate
bonds). The Fund has a five member Board,\4\ of which three members are
Independent Trustees.\5\
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\1\ 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
\2\ The existing feeder funds are Carey Credit Income Fund--I
and Carey Credit Income Fund 2016 T. Any future feeder fund will be
created by W.P. Carey.
\3\ ``Objectives and Strategies'' means a Regulated Entity's (as
defined below) investment objectives and strategies, as described in
the Regulated Entity's registration statement on Form N-2, other
filings the Regulated Entity has made with the Commission under the
Securities Act of 1933 (the ``Securities Act''), or under the
Securities Exchange Act of 1934, and the Regulated Entity's reports
to shareholders.
\4\ The term ``Board'' refers to the board of directors or
trustees of any Regulated Entity.
\5\ The term ``Independent Trustees'' refers to the trustees or
directors of any Regulated Entity that are not ``interested
persons'' of the Regulated Entity within the meaning of section
2(a)(19) of the Act.
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2. W.P. Carey is a Delaware limited liability company and is
registered as an investment adviser under the Investment Advisers Act
of 1940 (the ``Advisers Act''). W.P. Carey serves as the investment
adviser to the Fund. W.P. Carey also provides administrative services
to the Fund under an administrative services agreement.
3. Guggenheim is a Delaware limited liability company and is
registered as an investment adviser under the Advisers Act. Guggenheim
serves as the sub-adviser to the Fund. Guggenheim is part of the
investment management business of Guggenheim Partners LLC, a privately
held, global financial services firm.
4. Each Existing Affiliated Investor is a privately-offered fund
that would be an investment company but for section 3(c)(1) or 3(c)(7)
of the Act. An Existing Guggenheim Adviser serves as the investment
adviser to each Existing Affiliated Investor. Each Existing Guggenheim
Adviser is either controlled by Guggenheim or under common control with
Guggenheim and is registered as an investment adviser under the
Advisers Act.
5. Applicants seek an order (``Order'') to permit one or more
Regulated Entities \6\ and/or one or more Affiliated Investors \7\ to
participate in the same investment opportunities through a proposed co-
investment program (the ``Co-Investment Program'') where such
participation would otherwise be prohibited under sections 17(d) and
57(a)(4) and the rules under the Act. For purposes of the application,
``Co-Investment Transaction'' means any transaction in which a
Regulated Entity (or its Wholly-Owned Investment Subsidiary, as defined
below) participated together with one or more other Regulated Entities
and/or one or more Affiliated Investors in reliance on the requested
Order. ``Potential Co-Investment Transaction'' means any investment
opportunity in which a Regulated Entity (or its Wholly-Owned Investment
Subsidiary) could not participate together with one or more Affiliated
Investors and/or one or more other Regulated Entities without obtaining
and relying on the Order.\8\ The term ``Adviser'' means any W.P. Carey
Adviser or any Guggenheim Adviser.
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\6\ ``Regulated Entity'' means the Fund and any Future Regulated
Entity. ``Future Regulated Entity'' means a closed-end management
investment company (a) that is registered under the Act or has
elected to be regulated as a BDC under the Act, (b) whose investment
adviser is a W.P. Carey Adviser and (c) whose investment sub-adviser
is a Guggenheim Adviser. ``W.P. Carey Adviser'' means W.P. Carey or
any future investment adviser that (i) controls, is controlled by or
is under common control with W.P. Carey, (ii) is registered as an
investment adviser under the Advisers Act and (iii) is not a
Regulated Entity or a subsidiary of a Regulated Entity. ``Guggenheim
Adviser'' means any Existing Guggenheim Adviser or any future
investment adviser that (i) controls, is controlled by or is under
common control with Guggenheim, (ii) is registered as an investment
adviser under the Advisers Act, and (iii) is not a Regulated Entity
or a subsidiary of a Regulated Entity.
\7\ ``Affiliated Investors'' means the Existing Affiliated
Investors and any Future Affiliated Investor. ``Future Affiliated
Investor'' means an entity (a) whose investment adviser is a
Guggenheim Adviser and (b) that would be an investment company but
for section 3(c)(1) or 3(c)(7) of the Act.
\8\ All existing entities that currently intend to rely upon the
requested Order have been named as applicants. Any other existing or
future entity that subsequently relies on the Order will comply with
the terms and conditions of the application.
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6. Applicants state that a Regulated Entity may, from time to time,
form a Wholly-Owned Investment Subsidiary.\9\ Such a subsidiary would
be prohibited from investing in a Co-Investment Transaction with any
Affiliated Investor because it would be a company controlled by its
parent Regulated Entity for purposes of section 57(a)(4) and rule 17d-
1. Applicants request that each Wholly-Owned Investment Subsidiary be
permitted to participate in Co-Investment Transactions in lieu of its
parent Regulated Entity and that the Wholly-Owned Investment
Subsidiary's participation in any such transaction be treated, for
purposes of the requested Order, as though the parent Regulated
[[Page 36969]]
Entity were participating directly. Applicants represent that this
treatment is justified because a Wholly-Owned Investment Subsidiary
would have no purpose other than serving as a holding vehicle for the
Regulated Entity's investments and, therefore, no conflicts of interest
could arise between the Regulated Entity and the Wholly-Owned
Investment Subsidiary. The Regulated Entity's Board would make all
relevant determinations under the conditions with regard to a Wholly-
Owned Investment Subsidiary's participation in a Co-Investment
Transaction, and the Regulated Entity's Board would be informed of, and
take into consideration, any proposed use of a Wholly-Owned Investment
Subsidiary in the Regulated Entity's place. If the Regulated Entity
proposes to participate in the same Co-Investment Transaction with any
of its Wholly-Owned Investment Subsidiaries, the Board will also be
informed of, and take into consideration, the relative participation of
the Regulated Entity and the Wholly-Owned Investment Subsidiary.
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\9\ The term ``Wholly-Owned Investment Subsidiary'' means an
entity (i) that is wholly-owned by a Regulated Entity (with such
Regulated Entity at all times holding, beneficially and of record,
100% of the voting and economic interests); (ii) whose sole business
purpose is to hold one or more investments on behalf of the
Regulated Entity (and, in the case of an entity that is licensed by
the Small Business Administration to operate under the Small
Business Investment Act of 1958, as amended (the ``SBA Act''), as a
small business investment company (an ``SBIC''), to maintain a
license under the SBA Act and issue debentures guaranteed by the
Small Business Administration); (iii) with respect to which the
Regulated Entity's Board has the sole authority to make all
determinations with respect to the entity's participation under the
conditions of the application; and (iv) that would be an investment
company but for section 3(c)(1) or 3(c)(7) of the Act. All
subsidiaries participating in the Co-Investment Program will be
Wholly-Owned Investment Subsidiaries and will have Objectives and
Strategies that are either substantially the same as, or a subset
of, their parent Regulated Entity's Objectives and Strategies. A
subsidiary that is an SBIC may be a Wholly-Owned Investment
Subsidiary if it satisfies the conditions in this definition.
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7. It is anticipated that a Guggenheim Adviser will periodically
determine that certain investments the Guggenheim Adviser recommends
for a Regulated Entity would also be appropriate investments for one or
more other Regulated Entities and/or one or more Affiliated Investors.
Such a determination may result in the Regulated Entity, one or more
other Regulated Entities and/or one or more Affiliated Investors co-
investing in certain investment opportunities. For each such investment
opportunity, the Advisers to each Regulated Entity will independently
analyze and evaluate the investment opportunity as to its
appropriateness for such Regulated Entity taking into consideration the
Regulated Entity's Objectives and Strategies.
8. Applicants state that W.P. Carey serves as the Fund's investment
adviser and administrator and either it or another W.P. Carey Adviser
will serve in the same capacity to any Future Regulated Entity, and
that Guggenheim serves as the Fund's sub-adviser and either it or
another Guggenheim Adviser will serve in the same capacity to any
Future Regulated Entity. Applicants represent that although a
Guggenheim Adviser will identify and recommend investments \10\ for
each Regulated Entity, prior to any investment by the Regulated Entity,
the Guggenheim Adviser will present each proposed investment to the
W.P. Carey Adviser which has the authority to approve or reject all
investments proposed for the Regulated Entity by the Guggenheim
Adviser.
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\10\ Applicants represent that the W.P. Carey Advisers will not
source any Potential Co-Investment Transactions under the requested
Order.
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9. Applicants state that each Guggenheim Adviser has (or will have,
in the case of future advisers) an investment committee through which
it will carry out its obligation under condition 1 to make a
determination as to the appropriateness of a Potential Co-Investment
Transaction for each Regulated Entity. Applicants represent that each
Guggenheim Adviser, as a registered investment adviser, has (or will
have, in the case of future advisers) developed a robust allocation
process that is designed to allocate investment opportunities fairly
and equitably among its clients over time. Applicants state that, in
the case of a Potential Co-Investment Transaction, the applicable
Guggenheim Adviser would apply its allocation policies and procedures
in determining the proposed allocation for the Regulated Entity
consistent with the requirements of condition 2(a).
10. Applicants state that, once the applicable Guggenheim Adviser
determined a proposed allocation for a Regulated Entity, such
Guggenheim Adviser would notify the applicable W.P. Carey Adviser of
the Potential Co-Investment Transaction and the Guggenheim Adviser's
recommended allocation for such Regulated Entity. Applicants further
state that the applicable W.P. Carey Adviser would then present the
Potential Co-Investment Transaction and the Guggenheim Adviser's
proposed allocation to the W.P. Carey Adviser's investment committee
for its approval. Applicants represent that the W.P. Carey Adviser's
investment committee would review the Guggenheim Adviser's
recommendation for the Regulated Entity and would have the ability to
ask questions of the Guggenheim Adviser and request additional
information from the Guggenheim Adviser. Applicants further submit that
if the W.P. Carey Adviser's investment committee approved the
investment for the Regulated Entity, the investment and all relevant
allocation information would then be presented to the Regulated
Entity's Board for its approval in accordance with the conditions to
the application. Applicants state that they believe the investment
process between the Guggenheim Advisers and the W.P. Carey Advisers,
prior to seeking approval from the Regulated Entity's Board (which is
in addition to, rather than in lieu of, the procedures required under
the conditions of the application), is significant and provides for
additional procedures and processes to ensure that the Regulated Entity
is being treated fairly in respect of Potential Co-Investment
Transactions.
11. If the Advisers to a Regulated Entity determine that a
Potential Co-Investment Transaction is appropriate for the Regulated
Entity (and the applicable W.P. Carey Adviser approves the investment
for such Regulated Entity), and one or more other Regulated Entities
and/or one or more Affiliated Investors may also participate, the
Advisers will present the investment opportunity to the Eligible
Trustees \11\ of the Regulated Entity prior to the actual investment by
the Regulated Entity. As to any Regulated Entity, a Co-Investment
Transaction will be consummated only upon approval by a required
majority of the Eligible Trustees of such Regulated Entity within the
meaning of section 57(o) of the Act (``Required Majority'').\12\
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\11\ ``Eligible Trustees'' means the trustees or directors of a
Regulated Entity that are eligible to vote under section 57(o) of
the Act.
\12\ In the case of a Regulated Entity that is a registered
closed-end fund, the trustees or directors that make up the Required
Majority will be determined as if the Regulated Entity were a BDC
subject to section 57(o). As defined in section 57(o), ``required
majority'' means ``both a majority of a business development
company'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.''
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12. With respect to the pro rata dispositions and follow-on
Investments provided in conditions 7 and 8, a Regulated Entity 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 each Regulated Entity and
Affiliated Investor in such disposition is proportionate to its
outstanding investments in the issuer immediately preceding the
disposition or follow-on investment, as the case may be; and (ii) each
Regulated Entity's Board has approved that Regulated Entity's
participation in pro rata dispositions and follow-on investments as
being in the best interests of the Regulated Entity. If the Board does
not so approve, any such disposition or follow-on investment will be
submitted to the Regulated Entity's Eligible Trustees. The Board of any
Regulated Entity 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 Trustees.
[[Page 36970]]
13. No Independent Trustee of a Regulated Entity will have a
financial interest in any Co-Investment Transaction.
14. Under condition 15, if an Adviser or its principals, or any
person controlling, controlled by, or under common control with the
Adviser or its the principals, and any Affiliated Investors
(collectively, the ``Holders'') own in the aggregate more than 25% of
the outstanding voting securities of a Regulated Entity (``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
Trustees will act independently in evaluating the Co-Investment
Program, because the ability of the Adviser or its principals to
influence the Independent Trustees by a suggestion, explicit or
implied, that the Independent Trustees can be removed will be limited
significantly. Applicants represent that the Independent Trustees shall
evaluate and approve any such 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
participation by a registered investment company and an affiliated
person in any ``joint enterprise or other joint arrangement or profit-
sharing plan,'' as defined in the rule, without prior approval by the
Commission by order upon application. Section 17(d) of the Act and rule
17d-1 under the Act are applicable to Regulated Entities that are
registered closed-end investment companies. Similarly, with regard to
BDCs, section 57(a)(4) of the Act makes it unlawful for any person who
is related to a BDC in a manner described in section 57(b), acting as
principal, knowingly to effect any transaction in which the BDC (or a
company controlled by such BDC) is a joint or a joint and several
participant with that person in contravention of rules as prescribed by
the Commission. Because the Commission has not adopted any rules
expressly under section 57(a)(4), section 57(i) provides that the rules
under section 17(d) applicable to registered closed-end investment
companies (e.g., rule 17d-1) are, in the interim, deemed to apply to
transactions subject to section 57(a). 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), as modified by rule 57b-1, from
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 (or a company
controlled by such BDC) is a participant, unless an application
regarding the joint enterprise, arrangement, or profit-sharing plan has
been filed with the Commission and has been granted by an order entered
prior to the submission of the plan or any modification thereof, to
security holders for approval, or prior to its adoption or modification
if not so submitted.
2. 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 submit that each Regulated Entity may be deemed to be
an ``affiliated person'' of each other Regulated Entity within the
meaning of section 2(a)(3) of the Act. Applicants state that the
Regulated Entities, by virtue of each having a W.P. Carey Adviser, may
be deemed to be under common control, and thus affiliated persons of
each other under section 2(a)(3)(C) of the Act. Section 17(d) and
section 57(b) apply to any investment adviser to a closed-end fund or a
BDC, respectively, including the sub-adviser. Thus, a Guggenheim
Adviser and any Affiliated Investors that it advises could be deemed to
be persons related to Regulated Entities in a manner described by
sections 17(d) and 57(b) and therefore prohibited by sections 17(d) and
57(a)(4) and rule 17d-1 from participating in the Co-Investment
Program. Applicants further submit that, because the Guggenheim
Advisers are ``affiliated persons'' of other Guggenheim Advisers,
Affiliated Investors advised by any of them could be deemed to be
persons related to Regulated Entities (or a company controlled by a
Regulated Entity) in a manner described by sections 17(d) and 57(b) and
also prohibited from participating in the Co-Investment Program.
4. Applicants state that they expect that that co-investment in
portfolio companies by a Regulated Entity, one or more other Regulated
Entities and/or one or more Affiliated Investors will increase
favorable investment opportunities for each Regulated Entity.
5. Applicants submit that the fact that the Required Majority will
approve each Co-Investment Transaction before investment (except for
certain dispositions or follow-on investments, as described in the
conditions), and other protective conditions set forth in the
application, will ensure that each Regulated Entity will be treated
fairly. Applicants state that each Regulated Entity'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 other participants. Applicants
further state that the terms and conditions proposed herein will ensure
that all such transactions are reasonable and fair to each Regulated
Entity and the Affiliated Investors and do not involve overreaching by
any person concerned, including W.P. Carey or Guggenheim.
Applicants' Conditions
Applicants agree that the Order will be subject to the following
conditions:
1. Each time a Guggenheim Adviser considers a Potential Co-
Investment Transaction for an Affiliated Investor or another Regulated
Entity that falls within a Regulated Entity's then-current Objectives
and Strategies, the Advisers to the Regulated Entity will make an
independent determination of the appropriateness of the investment for
the Regulated Entity in light of the Regulated Entity's then-current
circumstances.
2. a. If the Advisers to a Regulated Entity deem participation in
any Potential Co-Investment Transaction to be appropriate for the
Regulated Entity, the Advisers will then determine an appropriate level
of investment for such Regulated Entity.
b. If the aggregate amount recommended by the Advisers to a
Regulated Entity to be invested by the Regulated Entity in the
Potential Co-Investment Transaction, together with the amount proposed
to be invested by the other participating Regulated Entities and
Affiliated Investors, collectively, in the same transaction, exceeds
the amount of the investment opportunity, the amount of the investment
opportunity will be allocated among the Regulated Entities and such
Affiliated Investors, pro rata based on each participant's Available
Capital \13\ for investment in the asset
[[Page 36971]]
class being allocated, up to the amount proposed to be invested by
each. The Advisers to each participating Regulated Entity will provide
the Eligible Trustees of each participating Regulated Entity with
information concerning each participating party's Available Capital to
assist the Eligible Trustees with their review of the Regulated
Entity's investments for compliance with these allocation procedures.
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\13\ ``Available Capital'' means (a) for each Regulated Entity,
the amount of capital available for investment determined based on
the amount of cash on hand, existing commitments and reserves, if
any, the targeted leverage level, targeted asset mix and other
investment policies and restrictions set from time to time by the
Board of the applicable Regulated Entity or imposed by applicable
laws, rules, regulations or interpretations and (b) for each
Affiliated Investor, the amount of capital available for investment
determined based on the amount of cash on hand, existing commitments
and reserves, if any, the targeted leverage level, targeted asset
mix and other investment policies and restrictions set by the
Affiliated Investor's directors, general partners or adviser or
imposed by applicable laws, rules, regulations or interpretations.
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c. After making the determinations required in conditions 1 and
2(a) above, the Advisers to the Regulated Entity will distribute
written information concerning the Potential Co-Investment Transaction,
including the amount proposed to be invested by each Regulated Entity
and any Affiliated Investor, to the Eligible Trustees of each
participating Regulated Entity for their consideration. A Regulated
Entity will co-invest with one or more other Regulated Entities and/or
an Affiliated Investor only if, prior to the Regulated Entities' and
the Affiliated Investors' participation in the Potential Co-Investment
Transaction, a Required Majority concludes that:
(i) The terms of the Potential Co-Investment Transaction, including
the consideration to be paid, are reasonable and fair to the Regulated
Entity and its shareholders and do not involve overreaching in respect
of the Regulated Entity or its shareholders on the part of any person
concerned;
(ii) the Potential Co-Investment Transaction is consistent with:
(a) The interests of the Regulated Entity's shareholders; and
(b) the Regulated Entity's then-current Objectives and Strategies;
(iii) the investment by any other Regulated Entity or an Affiliated
Investor would not disadvantage the Regulated Entity, and participation
by the Regulated Entity would not be on a basis different from or less
advantageous than that of any other Regulated Entity or Affiliated
Investor; provided, that if another Regulated Entity or Affiliated
Investor, but not the Regulated Entity 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 shall not be interpreted to prohibit a Required
Majority from reaching the conclusions required by this condition
2(c)(iii), if:
(a) The Eligible Trustees will have the right to ratify the
selection of such director or board observer, if any; and
(b) the Advisers to the Regulated Entity agree to, and do, provide
periodic reports to the Regulated Entity's Board 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
(c) any fees or other compensation that any other Regulated Entity
or any Affiliated Investor or any affiliated person of any other
Regulated Entity or an Affiliated Investor receives in connection with
the right of one or more Regulated Entities or Affiliated Investors 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 Affiliated
Investors (who may, in turn, share their portion with their affiliated
persons) and any participating Regulated Entity in accordance with the
amount of each party's investment; and
(iv) the proposed investment by the Regulated Entity will not
benefit the Advisers, any other Regulated Entity or the Affiliated
Investors 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 under sections
17(e) and 57(k) of the Act, as applicable, (C) in the case of fees or
other compensation described in condition 2(c)(iii)(c), or (D)
indirectly, as a result of an interest in the securities issued by one
of the parties to the Co-Investment Transaction.
3. Each Regulated Entity will have the right to decline to
participate in any Potential Co-Investment Transaction or to invest
less than the amount proposed.
4. The Advisers will present to the Board of each Regulated Entity,
on a quarterly basis, a record of all investments in Potential Co-
Investment Transactions made by any of the other Regulated Entities or
any of the Affiliated Investors during the preceding quarter that fell
within the Regulated Entity's then-current Objectives and Strategies
that were not made available to the Regulated Entity, and an
explanation of why the investment opportunities were not offered to the
Regulated Entity. All information presented to the Board pursuant to
this condition will be kept for the life of the Regulated Entity 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,\14\ a Regulated Entity will not invest in reliance on the
Order in any issuer in which another Regulated Entity or an Affiliated
Investor or any affiliated person of another Regulated Entity or an
Affiliated Investor is an existing investor.
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\14\ This exception applies only to follow-on investments by a
Regulated Entity in issuers in which that Regulated Entity already
holds investments.
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6. A Regulated Entity 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 Regulated Entity and Affiliated
Investor. The grant to one or more Regulated Entities or Affiliated
Investors, but not the Regulated Entity itself, 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 Regulated Entity or Affiliated Investor elects to
sell, exchange or otherwise dispose of an interest in a security that
was acquired by one or more Regulated Entities and/or Affiliated
Investors in a Co-Investment Transaction, the Advisers will:
(i) Notify each Regulated Entity 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 each
Regulated Entity in the disposition.
b. Each Regulated Entity 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 the Affiliated Investors
and any other Regulated Entity.
c. A Regulated Entity may participate in such disposition without
obtaining prior approval of the Required Majority if: (i) The proposed
participation of each Regulated Entity and each Affiliated Investor in
such disposition is proportionate to its outstanding investments in the
issuer immediately
[[Page 36972]]
preceding the disposition; (ii) the Regulated Entity's Board has
approved as being in the best interests of the Regulated Entity the
ability to participate in such dispositions on a pro rata basis (as
described in greater detail in the application); and (iii) the
Regulated Entity's Board is provided on a quarterly basis with a list
of all dispositions made in accordance with this condition. In all
other cases, the Advisers will provide their written recommendation as
to the Regulated Entity's participation to the Eligible Trustees, and
the Regulated Entity will participate in such disposition solely to the
extent that a Required Majority determines that it is in the Regulated
Entity's best interests.
d. Each Regulated Entity and each Affiliated Investor will bear its
own expenses in connection with the disposition.
8. a. If any Regulated Entity or Affiliated Investor desires to
make a ``follow-on investment'' (i.e., an additional investment in the
same entity, including through the exercise of warrants or other rights
to purchase securities of the issuer) in a portfolio company whose
securities were acquired by the Regulated Entity and the Affiliated
Investor in a Co-Investment Transaction, the Advisers will:
(i) Notify each Regulated Entity 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 each
Regulated Entity.
b. A Regulated Entity may participate in such follow-on investment
without obtaining prior approval of the Required Majority if: (i) The
proposed participation of each Regulated Entity and each Affiliated
Investor in such investment is proportionate to its outstanding
investments in the issuer immediately preceding the follow-on
investment; and (ii) the Regulated Entity's Board has approved as being
in the best interests of such Regulated Entity the ability to
participate in follow-on investments on a pro rata basis (as described
in greater detail in the application). In all other cases, the Advisers
will provide their written recommendation as to such Regulated Entity's
participation to the Eligible Trustees, and the Regulated Entity will
participate in such follow-on investment solely to the extent that the
Required Majority determines that it is in such Regulated Entity's best
interests.
c. If, with respect to any follow-on investment:
(i) The amount of a follow-on investment is not based on the
Regulated Entities' and the Affiliated Investors' outstanding
investments immediately preceding the follow-on investment; and
(ii) the aggregate amount recommended by the Advisers to be
invested by the Regulated Entity in the follow-on investment, together
with the amount proposed to be invested by the other participating
Regulated Entities and the Affiliated Investors in the same
transaction, exceeds the amount of the opportunity; then the amount
invested by each such party will be allocated among them pro rata based
on each participant's Available Capital 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 be subject to the other conditions set forth in the
application.
9. The Independent Trustees of each Regulated Entity will be
provided quarterly for review all information concerning Potential Co-
Investment Transactions and Co-Investment Transactions, including
investments made by other Regulated Entities or Affiliated Investors
that a Regulated Entity considered but declined to participate in, so
that the Independent Trustees may determine whether all investments
made during the preceding quarter, including those investments which
the Regulated Entity considered but declined to participate in, comply
with the conditions of the Order. In addition, the Independent Trustees
will consider at least annually the continued appropriateness for such
Regulated Entity of participating in new and existing Co-Investment
Transactions.
10. Each Regulated Entity will maintain the records required by
section 57(f)(3) of the Act as if each of the Regulated Entities were a
BDC and each of the investments permitted under these conditions were
approved by a Required Majority under section 57(f).
11. No Independent Trustee of a Regulated Entity will also be a
trustee, director, general partner, managing member or principal, or
otherwise an ``affiliated person'' (as defined in the Act) of any
Affiliated Investor.
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 Securities Act) shall, to
the extent not payable by the Advisers under their respective advisory
agreements with the Regulated Entities and the Affiliated Investors, be
shared by the Regulated Entities and the Affiliated Investors in
proportion to the relative amounts of the securities held or to be
acquired or disposed of, as the case may be.
13. Any transaction fee (including break-up or commitment fees but
excluding brokers' fees contemplated by section 17(e) or 57(k) of the
Act, as applicable) \15\ received in connection with a Co-Investment
Transaction will be distributed to the participating Regulated Entities
and Affiliated Investors on a pro rata basis based on the amount they
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 transaction, the fee will be deposited into an
account maintained by the Adviser at a bank or banks having the
qualifications prescribed in section 26(a)(1) of the Act, and the
account will earn a competitive rate of interest that will also be
divided pro rata among the participating Regulated Entities and
Affiliated Investors based on the amount they invest in the Co-
Investment Transaction. None of the other Regulated Entities,
Affiliated Investors, the Advisers nor any affiliated person of the
Regulated Entities or the Affiliated Investors 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 Regulated Entities and the Affiliated Investors, 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
Regulated Entities' and the Affiliated Investors' investment advisory
agreements).
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\15\ Applicants are not requesting and the Commission is not
providing any relief for transaction fees received in connection
with any Co-Investment Transaction.
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14. The Advisers to the Regulated Entities and Affiliated Investors
will maintain written policies and procedures reasonably designed to
ensure compliance with the foregoing conditions. These policies and
procedures will require, among other things, that each of the Advisers
to each Regulated Entity will be notified of all Potential Co-
Investment Transactions that fall within a Regulated Entity's then-
current Objectives and Strategies and will be given sufficient
information to make its independent determination
[[Page 36973]]
and recommendations under conditions 1, 2(a), 7 and 8.
15. If the Holders own in the aggregate more than 25 percent of the
shares of a Regulated Entity, then the Holders will vote such shares as
directed by an independent third party when voting on (1) the election
of directors or trustees; (2) the removal of one or more directors or
trustees; or (3) any matters requiring approval by the vote of a
majority of the outstanding voting securities, as defined in section
2(a)(42) of the Act.
For the Commission, by the Division of Investment Management,
under delegated authority.
Brent J. Fields,
Secretary.
[FR Doc. 2016-13514 Filed 6-7-16; 8:45 am]
BILLING CODE 8011-01-P