Ramius Archview Credit and Distressed Fund and Ramius Advisors, LLC; Notice of Application, 37654-37656 [2016-13717]
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37654
Federal Register / Vol. 81, No. 112 / Friday, June 10, 2016 / Notices
(1) To provide a source of
information, that will be used for
statistical purposes only, on
demographic characteristics of
individuals who received their first
doctorate or doctorate-equivalent
degrees within the past 10 years,
regardless of the country of degree.
(2) To provide indicators of the state
of science and engineering enterprise in
the U.S., as required by congressional
mandate.
(3) To report biennially on the
participation rates of men, women,
persons with disabilities, and race/
ethnicity groups, in scientific and
technical fields, as required by
congressional mandate.
CATEGORIES OF INDIVIDUALS COVERED BY THE
SYSTEM:
A sample of individuals who earned
their first doctorate within the past 10
years and are working in one of the
following areas of employment: U.S.
academic institutions, federally funded
research and development centers
(FFRDCs), or the National Institutes of
Health intramural research programs
(NIH IRPs).
CATEGORIES OF RECORDS IN THE SYSTEM:
Educational, professional and
demographic characteristics of doctorate
degree holders including name, age,
race, ethnicity, gender, functional
limitations, educational history,
professional activities and
achievements, employer characteristics,
professional and personal life balance,
mentoring training, research
opportunities, and career paths and
plans of early career doctorate holders.
RECORD SOURCE CATEGORIES:
Information is obtained voluntarily
from the individual.
asabaliauskas on DSK3SPTVN1PROD with NOTICES
NSF standard routine uses apply to
the extent that such disclosure is
compatible with the National Science
Foundation Act of 1950, the America
COMPETES Reauthorization Act of
2010, and CIPSEA. In addition,
information may be disclosed to:
(1) License for the Use of Restricted
Data (License) holders. Organizations
(e.g. academic institutions, nonprofit
organizations) and their researcher(s)
granted an NSF/National Center for
Science and Engineering Statistics
(NCSES) License for the purpose of
analyzing data and preparing scientific
reports and articles. These Licensees
receive data without direct personal
identifiers.
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POLICIES AND PRACTICES FOR STORAGE OF
RECORDS:
Records are stored on electronic
digital media.
POLICIES AND PRACTICES FOR RETRIEVABILITY
OF RECORDS:
Records are retrieved by the name of
individual and unique, anonymous data
collection identifier.
POLICIES AND PRACTICES FOR RETENTION AND
DISPOSAL OF RECORDS:
Data are cumulative and are kept
indefinitely.
PHYSICAL, PROCEDURAL, AND ADMINISTRATIVE
SAFEGUARDS:
Records are protected by
administrative, technical, and physical
safeguards administered by NSF.
SYSTEM MANAGER(S):
Division Director, National Center for
Science and Engineering Statistics, NSF
headquarters, Virginia.
RECORD ACCESS PROCEDURES:
ROUTINE USES OF RECORDS MAINTAINED IN THE
SYSTEM, INCLUDING CATEGORIES OF USERS AND
THE PURPOSES OF SUCH USES:
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(2) Federal agency sponsors. Records
without personal identifiers may be
disclosed to federal sponsors, their
contractors and collaborating
researchers and their staff under an
Inter-Agency Agreement for the purpose
of analyzing data, preparing scientific
reports and articles, and for conducting
review and evaluation of their programs.
(3) NCSES contractors. Records may
be disclosed to NCSES contractors for
statistical activities or purposes such as
conducting surveys. Any NSF contractor
who wishes to use restricted-use data
for statistical activities or purposes that
are not part of NCSES-sponsored work
must follow the regular License
procedures as laid out in routine use (1)
above.
This system is exempt from this
requirement pursuant to 5 U.S.C.
552a(k)(4).
CONTESTING RECORD PROCEDURES:
This system is exempt from this
requirement pursuant to 5 U.S.C.
552a(k)(4).
NOTIFICATION PROCEDURE:
This system is exempt from this
requirement pursuant to 5 U.S.C.
552a(k)(4).
EXEMPTIONS PROMULGATED FOR THE SYSTEM:
The portions of this system consisting
of statistical records have been
exempted from provisions of 5 U.S.C.
552a(c)(3); (d); (e)(1); (e)(4)(G), (H), (I),
and (f), pursuant to 5 U.S.C. 552a(k)(4).
[FR Doc. 2016–13452 Filed 6–9–16; 8:45 am]
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SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
32139; 812–14501]
Ramius Archview Credit and
Distressed Fund and Ramius Advisors,
LLC; Notice of Application
June 6, 2016.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice of an application under
section 6(c) of the Investment Company
Act of 1940 (the ‘‘Act’’) for an
exemption from sections 18(c) and 18(i)
of the Act and for an order pursuant to
section 17(d) of the Act and rule 17d–
1 under the Act.
AGENCY:
Applicants
request an order to permit certain
registered closed-end management
investment companies to issue multiple
classes of shares of beneficial interest
(‘‘Shares’’) and to impose asset-based
service and/or distribution fees and
contingent deferred sales loads
(‘‘CDSCs’’).
APPLICANTS: Ramius Archview Credit
and Distressed Fund (the ‘‘Fund’’) and
Ramius Advisors, LLC (the ‘‘Adviser’’).
FILING DATES: The application was filed
on June 30, 2015, and amended on
September 3, 2015 and February 4,
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 July 1, 2016, and should
be accompanied by proof of service on
applicants, in the form of an affidavit or,
for lawyers, a certificate of service.
Pursuant to rule 0–5 under the Act,
hearing requests should state the nature
of the writer’s interest, any facts bearing
upon the desirability of a hearing on the
matter, the reason for the request, and
the issues contested. Persons who wish
to be notified of a hearing may request
notification by writing to the
Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090;
Applicants, 1200 Prospect Street, Suite
400, La Jolla, CA 92037.
FOR FURTHER INFORMATION CONTACT:
Kieran G. Brown, Senior Counsel, at
(202) 551–6773 or James M. Curtis,
Branch Chief, at (202) 551–6712
SUMMARY OF APPLICATION:
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Federal Register / Vol. 81, No. 112 / Friday, June 10, 2016 / Notices
asabaliauskas on DSK3SPTVN1PROD with NOTICES
(Division of Investment Management,
Chief Counsel’s Office).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or 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 continuously offered
closed-end management investment
company registered under the Act and
organized as a Delaware statutory trust.
The Fund currently serves as the master
fund in a master-feeder structure with
one feeder fund.1 If the requested relief
is granted, the feeder fund will be
dissolved promptly and the Fund will
no longer operate within a master-feeder
structure.2 The Fund’s investment
objective is to seek to generate
consistent, total returns while
minimizing the risk of loss. The Fund
intends to pursue its investment
objective by investing primarily in debt
and equity securities, loans, trade
claims and derivative instruments of
leveraged or financially distressed
companies. In addition, the Fund will
typically take long and short positions
in securities, loans and derivatives.
2. The Adviser, a Delaware limited
liability company, is registered as an
investment adviser under the
Investment Advisers Act of 1940
(‘‘Advisers Act’’). The Adviser serves as
investment adviser to the Fund.
Foreside Fund Services, LLC, a brokerdealer registered under the Securities
Exchange Act of 1934 (‘‘1934 Act’’), acts
as the distributor of the Fund.
3. The Fund continuously offers its
Shares 3 to investors that represent that
they are ‘‘qualified clients’’ within the
meaning of Rule 205–3 under the
Advisers Act (‘‘Qualified Clients’’).
Shares of the Fund are not listed on any
securities exchange and do not trade on
an over-the-counter system such as
NASDAQ. Applicants do not expect that
any secondary market will develop for
the Shares.
4. The Fund currently offers a single
class of Shares (the ‘‘Initial Class’’) at
net asset value per share without a sales
load and without an annual asset-based
1 The feeder fund is Ramius Archview Credit and
Distressed Feeder Fund.
2 In accordance with the organizational
documents of the feeder fund and Delaware
statutory trust law, no shareholder vote is required
to liquidate and dissolve the feeder fund.
3 ‘‘Shares’’ includes any other equivalent
designation of a proportionate ownership interest of
the Fund.
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19:02 Jun 09, 2016
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service and/or distribution fee. The
Fund proposes to issue multiple classes
of Shares and specifically proposes to
offer a new Share class (the ‘‘New
Class’’): (1) Only to Qualified Clients; (2)
at net asset value plus a front-end sales
load of up to 3%; and (3) subject to an
annual distribution/shareholder fee of
0.75%. The front-end sales load and
annual distribution/shareholder
servicing fee to be charged to the New
Class Shares will be the same as those
currently charged to the feeder fund
Shares. The Fund intends to continue to
offer Initial Class Shares, without a sales
load and without a service and/or
distribution fee.
5. In order to provide a limited degree
of liquidity to shareholders, the Fund
may from time to time offer to
repurchase Shares, in an amount not to
exceed 25% of the Fund’s net asset
value, at their then current net asset
value in accordance with rule 13e–4
under the 1934 Act pursuant to written
tenders by shareholders.4 Repurchases
will be made at such times, in such
amounts and on such terms as may be
determined by the Fund’s board of
trustees (‘‘Board’’), in its sole
discretion.5 Repurchases will not
commence for at least six months
following the date of the initial closing
for subscriptions for Shares. Following
such date, the Adviser will recommend
to the Board (subject to its discretion)
that the Fund offer to repurchase Shares
from shareholders on a quarterly basis.
6. Applicants request that the order
also apply to any other continuously
offered registered closed-end
management investment company
existing now or in the future for which
the Adviser or any entity controlling,
controlled by, or under common control
with the Adviser acts as investment
adviser and which provides periodic
liquidity with respect to its Shares
through tender offers conducted in
compliance with rule 13e–4 under the
1934 Act.6
4 Likewise, the feeder fund’s repurchase offers are
conducted pursuant to rule 13e–4 under the 1934
Act.
5 Shares are subject to an Early Repurchase Fee
at a rate of 2% of the net asset value of any Shares
repurchased by the Fund that were held for less
than one year. The Early Repurchase Fee will
equally apply to all shareholders of the Fund,
regardless of class, consistent with section 18 of the
Act and rule 18f–3 under the Act. To the extent the
Fund determines to waive, impose scheduled
variations of, or eliminate the Early Repurchase Fee,
it will do so consistently with the requirements of
rule 22d–1 under the Act as if the Early Repurchase
Fee were a CDSC and as if the Fund were an openend investment company, and the Fund’s waiver of,
scheduled variation in, or elimination of, the Early
Repurchase Fee will apply uniformly to all
shareholders of the Fund.
6 The Fund and any other investment company
relying on the requested relief will do so in a
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37655
7. Applicants represent that any assetbased service and/or distribution fees
will comply with the provisions of rule
2830(d) of the Conduct Rules of the
National Association of Securities
Dealers, Inc. (‘‘NASD Conduct Rule
2830’’) as if that rule applied to the
Fund.7 Applicants also represent that
the Fund will disclose in its prospectus,
the fees, expenses and other
characteristics of each class of Shares
offered for sale by the prospectus as is
required for open-end multiple class
funds under Form N–1A. As is required
for open-end funds, the Fund will
disclose its expenses in shareholder
reports, and disclose any arrangements
that result in breakpoints in or
elimination of sales loads in its
prospectus.8 The Fund will also comply
with any requirements that may be
adopted by the Commission or FINRA
regarding disclosure at the point of sale
and in transaction confirmations about
the costs and conflicts of interest arising
out of the distribution of open-end
investment company shares, and
regarding prospectus disclosure of sales
loads and revenue sharing arrangements
as if those requirements applied to the
Fund and the Distributor.9 The Fund
will contractually require that the
Distributor and any other distributor of
the Fund’s Shares comply with such
requirements in connection with the
distribution of Shares of the Fund.
8. The Fund will allocate all expenses
incurred by it among the various classes
of Shares based on the net assets of the
Fund attributable to each class, except
that the net asset value and expenses of
each class will reflect distribution fees,
service fees, and any other incremental
expenses of that class. Expenses of the
Fund allocated to a particular class of
Shares will be borne on a pro rata basis
manner consistent with the terms and conditions of
the application. Applicants represent that any
person presently intending to rely on the requested
relief is listed as an applicant.
7 All references to NASD Conduct Rule 2830
include any successor or replacement rule that may
be adopted by the Financial Industry Regulatory
Authority (‘‘FINRA’’).
8 See Shareholder Reports and Quarterly Portfolio
Disclosure of Registered Management Investment
Companies, Investment Company Act Release No.
26372 (Feb. 27, 2004) (adopting release) (requiring
open-end investment companies to disclose fund
expenses in shareholder reports); and Disclosure of
Breakpoint Discounts by Mutual Funds, Investment
Company Act Release No. 26464 (June 7, 2004)
(adopting release) (requiring open-end investment
companies to provide prospectus disclosure of
certain sales load information).
9 See, e.g., Confirmation Requirements and Point
of Sale Disclosure Requirements for Transactions
and Certain Mutual Funds and Other Securities,
and Other Confirmation Requirement Amendments,
and Amendments to the Registration Form for
Mutual Funds, Investment Company Act Release
No. 26341 (Jan. 29, 2004) (proposing release).
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Federal Register / Vol. 81, No. 112 / Friday, June 10, 2016 / Notices
by each outstanding Share of that class.
Applicants state that the Fund will
comply with the provisions of rule 18f–
3 under the Act as if it were an openend investment company.
9. In the event the Fund imposes a
CDSC, the applicants will comply with
the provisions of rule 6c-10 under the
Act, as if that rule applied to closed-end
management investment companies.
With respect to any waiver of,
scheduled variation in, or elimination of
the CDSC, the Fund will comply with
rule 22d–1 under the Act as if the Fund
were an open-end investment company.
Applicants’ Legal Analysis
asabaliauskas on DSK3SPTVN1PROD with NOTICES
Multiple Classes of Shares
1. Section 18(c) of the Act provides,
in relevant part, that a closed-end
investment company may not issue or
sell any senior security if, immediately
thereafter, the company has outstanding
more than one class of senior security.
Applicants state that the creation of
multiple classes of Shares of the Fund
may be prohibited by section 18(c).
2. Section 18(i) of the Act provides
that each share of stock issued by a
registered management investment
company will be a voting stock and
have equal voting rights with every
other outstanding voting stock.
Applicants state that permitting
multiple classes of Shares of the Fund
may violate section 18(i) of the Act
because each class would be entitled to
exclusive voting rights with respect to
matters solely related to that class.
3. Section 6(c) of the Act provides that
the Commission may exempt any
person, security or transaction or any
class or classes of persons, securities or
transactions from any provision of the
Act, or from any rule under the Act, if
and to the extent such exemption is
necessary or appropriate in the public
interest and consistent with the
protection of investors and the purposes
fairly intended by the policy and
provisions of the Act. Applicants
request an exemption under section 6(c)
from sections 18(c) and 18(i) to permit
the Fund to issue multiple classes of
Shares.
4. Applicants submit that the
proposed allocation of expenses and
voting rights among multiple classes is
equitable and will not discriminate
against any group or class of
shareholders. Applicants submit that
the proposed arrangements would
permit the Fund to facilitate the
distribution of its Shares and provide
investors with a broader choice of
shareholder options. Applicants assert
that the proposed closed-end
investment company multiple class
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19:02 Jun 09, 2016
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structure does not raise the concerns
underlying section 18 of the Act to any
greater degree than open-end
investment companies’ multiple class
structures that are permitted by rule
18f–3 under the Act. Applicants state
that the Fund will comply with the
provisions of rule 18f–3 as if it were an
open-end investment company.
CDSCs
Applicants believe that the requested
relief meets the standards of section 6(c)
of the Act. Rule 6c–10 under the Act
permits open-end investment
companies to impose CDSCs, subject to
certain conditions. Applicants state that
any CDSC imposed by the Fund will
comply with rule 6c–10 under the Act
as if the rule were applicable to closedend investment companies. The Fund
also will disclose CDSCs in accordance
with the requirements of Form N–1A
concerning CDSCs as if the Fund were
an open-end investment company.
Applicants further state that the Fund
will apply the CDSC (and any waivers,
scheduled variations or eliminations of
the CDSC) uniformly to all shareholders
in a given class and consistently with
the requirements of rule 22d–1 under
the Act.
Asset-Based Service and/or Distribution
Fees
1. Section 17(d) of the Act and rule
17d–1 under the Act prohibit an
affiliated person of a registered
investment company or an affiliated
person of such person, acting as
principal, from participating in or
effecting any transaction in connection
with any joint enterprise or joint
arrangement in which the investment
company participates unless the
Commission issues an order permitting
the transaction. In reviewing
applications submitted under section
17(d) and rule 17d–1, the Commission
considers whether the participation of
the investment company in a joint
enterprise or joint arrangement is
consistent with the provisions, policies
and purposes of the Act, and the extent
to which the participation is on a basis
different from or less advantageous than
that of other participants.
2. Rule 17d–3 under the Act provides
an exemption from section 17(d) and
rule 17d–1 to permit open-end
investment companies to enter into
distribution arrangements pursuant to
rule 12b–1 under the Act. Applicants
request an order under section 17(d) and
rule 17d–1 under the Act to permit the
Fund to impose asset-based service and/
or distribution fees. Applicants have
agreed to comply with rules 12b–1 and
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17d–3 as if those rules applied to
closed-end investment companies.
Applicants’ Condition
The applicants agree that any order
granting the requested relief will be
subject to the following condition:
Applicants will comply with the
provisions of rules 6c–10, 12b–1, 17d–
3, 18f–3 and 22d–1 under the Act, as
amended from time to time or replaced,
as if those rules applied to closed-end
management investment companies,
and will comply with NASD Conduct
Rule 2830, as amended from time to
time, as if that rule applied to all closedend management investment
companies.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016–13717 Filed 6–9–16; 8:45 am]
BILLING CODE P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–77995; File No. SR–CHX–
2016–07]
Self-Regulatory Organizations;
Chicago Stock Exchange, Inc.; Notice
of Filing and Immediate Effectiveness
of Proposed Rule Change To Adopt
Business Continuity Plan
Requirements for Participants
June 6, 2016.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 2 thereunder,
notice is hereby given that on May 24,
2016, the Chicago Stock Exchange, Inc.
(‘‘CHX’’ or the ‘‘Exchange’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
Items I, II and III below, which Items
have been prepared by the Exchange.
The Commission is publishing this
notice to solicit comments on the
proposed rule change from interested
persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
CHX proposes to amend the Rules of
the Exchange (‘‘CHX Rules’’) to adopt
Article 7, Rule 14, which corresponds to
a similar rule of the Financial Industry
Regulatory Authority, Inc. (‘‘FINRA’’)
regarding Business Continuity Plans
(‘‘BCPs’’).
1 15
2 17
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U.S.C. 78s(b)(1).
CFR 240.19b–4.
10JNN1
Agencies
[Federal Register Volume 81, Number 112 (Friday, June 10, 2016)]
[Notices]
[Pages 37654-37656]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-13717]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 32139; 812-14501]
Ramius Archview Credit and Distressed Fund and Ramius Advisors,
LLC; Notice of Application
June 6, 2016.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice of an application under section 6(c) of the Investment
Company Act of 1940 (the ``Act'') for an exemption from sections 18(c)
and 18(i) of the Act and for an order pursuant to section 17(d) of the
Act and rule 17d-1 under the Act.
-----------------------------------------------------------------------
Summary of Application: Applicants request an order to permit certain
registered closed-end management investment companies to issue multiple
classes of shares of beneficial interest (``Shares'') and to impose
asset-based service and/or distribution fees and contingent deferred
sales loads (``CDSCs'').
Applicants: Ramius Archview Credit and Distressed Fund (the ``Fund'')
and Ramius Advisors, LLC (the ``Adviser'').
Filing Dates: The application was filed on June 30, 2015, and amended
on September 3, 2015 and February 4, 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 July 1, 2016, and should be accompanied by proof of
service on applicants, in the form of an affidavit or, for lawyers, a
certificate of service. Pursuant to rule 0-5 under the Act, hearing
requests should state the nature of the writer's interest, any facts
bearing upon the desirability of a hearing on the matter, the reason
for the request, and the issues contested. Persons who wish to be
notified of a hearing may request notification by writing to the
Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street NE., Washington, DC 20549-1090; Applicants, 1200 Prospect
Street, Suite 400, La Jolla, CA 92037.
FOR FURTHER INFORMATION CONTACT: Kieran G. Brown, Senior Counsel, at
(202) 551-6773 or James M. Curtis, Branch Chief, at (202) 551-6712
[[Page 37655]]
(Division of Investment Management, Chief Counsel's Office).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or 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 continuously offered closed-end management
investment company registered under the Act and organized as a Delaware
statutory trust. The Fund currently serves as the master fund in a
master-feeder structure with one feeder fund.\1\ If the requested
relief is granted, the feeder fund will be dissolved promptly and the
Fund will no longer operate within a master-feeder structure.\2\ The
Fund's investment objective is to seek to generate consistent, total
returns while minimizing the risk of loss. The Fund intends to pursue
its investment objective by investing primarily in debt and equity
securities, loans, trade claims and derivative instruments of leveraged
or financially distressed companies. In addition, the Fund will
typically take long and short positions in securities, loans and
derivatives.
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\1\ The feeder fund is Ramius Archview Credit and Distressed
Feeder Fund.
\2\ In accordance with the organizational documents of the
feeder fund and Delaware statutory trust law, no shareholder vote is
required to liquidate and dissolve the feeder fund.
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2. The Adviser, a Delaware limited liability company, is registered
as an investment adviser under the Investment Advisers Act of 1940
(``Advisers Act''). The Adviser serves as investment adviser to the
Fund. Foreside Fund Services, LLC, a broker-dealer registered under the
Securities Exchange Act of 1934 (``1934 Act''), acts as the distributor
of the Fund.
3. The Fund continuously offers its Shares \3\ to investors that
represent that they are ``qualified clients'' within the meaning of
Rule 205-3 under the Advisers Act (``Qualified Clients''). Shares of
the Fund are not listed on any securities exchange and do not trade on
an over-the-counter system such as NASDAQ. Applicants do not expect
that any secondary market will develop for the Shares.
---------------------------------------------------------------------------
\3\ ``Shares'' includes any other equivalent designation of a
proportionate ownership interest of the Fund.
---------------------------------------------------------------------------
4. The Fund currently offers a single class of Shares (the
``Initial Class'') at net asset value per share without a sales load
and without an annual asset-based service and/or distribution fee. The
Fund proposes to issue multiple classes of Shares and specifically
proposes to offer a new Share class (the ``New Class''): (1) Only to
Qualified Clients; (2) at net asset value plus a front-end sales load
of up to 3%; and (3) subject to an annual distribution/shareholder fee
of 0.75%. The front-end sales load and annual distribution/shareholder
servicing fee to be charged to the New Class Shares will be the same as
those currently charged to the feeder fund Shares. The Fund intends to
continue to offer Initial Class Shares, without a sales load and
without a service and/or distribution fee.
5. In order to provide a limited degree of liquidity to
shareholders, the Fund may from time to time offer to repurchase
Shares, in an amount not to exceed 25% of the Fund's net asset value,
at their then current net asset value in accordance with rule 13e-4
under the 1934 Act pursuant to written tenders by shareholders.\4\
Repurchases will be made at such times, in such amounts and on such
terms as may be determined by the Fund's board of trustees (``Board''),
in its sole discretion.\5\ Repurchases will not commence for at least
six months following the date of the initial closing for subscriptions
for Shares. Following such date, the Adviser will recommend to the
Board (subject to its discretion) that the Fund offer to repurchase
Shares from shareholders on a quarterly basis.
---------------------------------------------------------------------------
\4\ Likewise, the feeder fund's repurchase offers are conducted
pursuant to rule 13e-4 under the 1934 Act.
\5\ Shares are subject to an Early Repurchase Fee at a rate of
2% of the net asset value of any Shares repurchased by the Fund that
were held for less than one year. The Early Repurchase Fee will
equally apply to all shareholders of the Fund, regardless of class,
consistent with section 18 of the Act and rule 18f-3 under the Act.
To the extent the Fund determines to waive, impose scheduled
variations of, or eliminate the Early Repurchase Fee, it will do so
consistently with the requirements of rule 22d-1 under the Act as if
the Early Repurchase Fee were a CDSC and as if the Fund were an
open-end investment company, and the Fund's waiver of, scheduled
variation in, or elimination of, the Early Repurchase Fee will apply
uniformly to all shareholders of the Fund.
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6. Applicants request that the order also apply to any other
continuously offered registered closed-end management investment
company existing now or in the future for which the Adviser or any
entity controlling, controlled by, or under common control with the
Adviser acts as investment adviser and which provides periodic
liquidity with respect to its Shares through tender offers conducted in
compliance with rule 13e-4 under the 1934 Act.\6\
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\6\ The Fund and any other investment company relying on the
requested relief will do so in a manner consistent with the terms
and conditions of the application. Applicants represent that any
person presently intending to rely on the requested relief is listed
as an applicant.
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7. Applicants represent that any asset-based service and/or
distribution fees will comply with the provisions of rule 2830(d) of
the Conduct Rules of the National Association of Securities Dealers,
Inc. (``NASD Conduct Rule 2830'') as if that rule applied to the
Fund.\7\ Applicants also represent that the Fund will disclose in its
prospectus, the fees, expenses and other characteristics of each class
of Shares offered for sale by the prospectus as is required for open-
end multiple class funds under Form N-1A. As is required for open-end
funds, the Fund will disclose its expenses in shareholder reports, and
disclose any arrangements that result in breakpoints in or elimination
of sales loads in its prospectus.\8\ The Fund will also comply with any
requirements that may be adopted by the Commission or FINRA regarding
disclosure at the point of sale and in transaction confirmations about
the costs and conflicts of interest arising out of the distribution of
open-end investment company shares, and regarding prospectus disclosure
of sales loads and revenue sharing arrangements as if those
requirements applied to the Fund and the Distributor.\9\ The Fund will
contractually require that the Distributor and any other distributor of
the Fund's Shares comply with such requirements in connection with the
distribution of Shares of the Fund.
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\7\ All references to NASD Conduct Rule 2830 include any
successor or replacement rule that may be adopted by the Financial
Industry Regulatory Authority (``FINRA'').
\8\ See Shareholder Reports and Quarterly Portfolio Disclosure
of Registered Management Investment Companies, Investment Company
Act Release No. 26372 (Feb. 27, 2004) (adopting release) (requiring
open-end investment companies to disclose fund expenses in
shareholder reports); and Disclosure of Breakpoint Discounts by
Mutual Funds, Investment Company Act Release No. 26464 (June 7,
2004) (adopting release) (requiring open-end investment companies to
provide prospectus disclosure of certain sales load information).
\9\ See, e.g., Confirmation Requirements and Point of Sale
Disclosure Requirements for Transactions and Certain Mutual Funds
and Other Securities, and Other Confirmation Requirement Amendments,
and Amendments to the Registration Form for Mutual Funds, Investment
Company Act Release No. 26341 (Jan. 29, 2004) (proposing release).
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8. The Fund will allocate all expenses incurred by it among the
various classes of Shares based on the net assets of the Fund
attributable to each class, except that the net asset value and
expenses of each class will reflect distribution fees, service fees,
and any other incremental expenses of that class. Expenses of the Fund
allocated to a particular class of Shares will be borne on a pro rata
basis
[[Page 37656]]
by each outstanding Share of that class. Applicants state that the Fund
will comply with the provisions of rule 18f-3 under the Act as if it
were an open-end investment company.
9. In the event the Fund imposes a CDSC, the applicants will comply
with the provisions of rule 6c-10 under the Act, as if that rule
applied to closed-end management investment companies. With respect to
any waiver of, scheduled variation in, or elimination of the CDSC, the
Fund will comply with rule 22d-1 under the Act as if the Fund were an
open-end investment company.
Applicants' Legal Analysis
Multiple Classes of Shares
1. Section 18(c) of the Act provides, in relevant part, that a
closed-end investment company may not issue or sell any senior security
if, immediately thereafter, the company has outstanding more than one
class of senior security. Applicants state that the creation of
multiple classes of Shares of the Fund may be prohibited by section
18(c).
2. Section 18(i) of the Act provides that each share of stock
issued by a registered management investment company will be a voting
stock and have equal voting rights with every other outstanding voting
stock. Applicants state that permitting multiple classes of Shares of
the Fund may violate section 18(i) of the Act because each class would
be entitled to exclusive voting rights with respect to matters solely
related to that class.
3. Section 6(c) of the Act provides that the Commission may exempt
any person, security or transaction or any class or classes of persons,
securities or transactions from any provision of the Act, or from any
rule under the Act, if and to the extent such exemption is necessary or
appropriate in the public interest and consistent with the protection
of investors and the purposes fairly intended by the policy and
provisions of the Act. Applicants request an exemption under section
6(c) from sections 18(c) and 18(i) to permit the Fund to issue multiple
classes of Shares.
4. Applicants submit that the proposed allocation of expenses and
voting rights among multiple classes is equitable and will not
discriminate against any group or class of shareholders. Applicants
submit that the proposed arrangements would permit the Fund to
facilitate the distribution of its Shares and provide investors with a
broader choice of shareholder options. Applicants assert that the
proposed closed-end investment company multiple class structure does
not raise the concerns underlying section 18 of the Act to any greater
degree than open-end investment companies' multiple class structures
that are permitted by rule 18f-3 under the Act. Applicants state that
the Fund will comply with the provisions of rule 18f-3 as if it were an
open-end investment company.
CDSCs
Applicants believe that the requested relief meets the standards of
section 6(c) of the Act. Rule 6c-10 under the Act permits open-end
investment companies to impose CDSCs, subject to certain conditions.
Applicants state that any CDSC imposed by the Fund will comply with
rule 6c-10 under the Act as if the rule were applicable to closed-end
investment companies. The Fund also will disclose CDSCs in accordance
with the requirements of Form N-1A concerning CDSCs as if the Fund were
an open-end investment company. Applicants further state that the Fund
will apply the CDSC (and any waivers, scheduled variations or
eliminations of the CDSC) uniformly to all shareholders in a given
class and consistently with the requirements of rule 22d-1 under the
Act.
Asset-Based Service and/or Distribution Fees
1. Section 17(d) of the Act and rule 17d-1 under the Act prohibit
an affiliated person of a registered investment company or an
affiliated person of such person, acting as principal, from
participating in or effecting any transaction in connection with any
joint enterprise or joint arrangement in which the investment company
participates unless the Commission issues an order permitting the
transaction. In reviewing applications submitted under section 17(d)
and rule 17d-1, the Commission considers whether the participation of
the investment company in a joint enterprise or joint arrangement is
consistent with the provisions, policies and purposes of the Act, and
the extent to which the participation is on a basis different from or
less advantageous than that of other participants.
2. Rule 17d-3 under the Act provides an exemption from section
17(d) and rule 17d-1 to permit open-end investment companies to enter
into distribution arrangements pursuant to rule 12b-1 under the Act.
Applicants request an order under section 17(d) and rule 17d-1 under
the Act to permit the Fund to impose asset-based service and/or
distribution fees. Applicants have agreed to comply with rules 12b-1
and 17d-3 as if those rules applied to closed-end investment companies.
Applicants' Condition
The applicants agree that any order granting the requested relief
will be subject to the following condition:
Applicants will comply with the provisions of rules 6c-10, 12b-1,
17d-3, 18f-3 and 22d-1 under the Act, as amended from time to time or
replaced, as if those rules applied to closed-end management investment
companies, and will comply with NASD Conduct Rule 2830, as amended from
time to time, as if that rule applied to all closed-end management
investment companies.
For the Commission, by the Division of Investment Management,
under delegated authority.
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016-13717 Filed 6-9-16; 8:45 am]
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