Sierra Total Return Fund, et al., 22592-22595 [2017-09790]
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Federal Register / Vol. 82, No. 93 / Tuesday, May 16, 2017 / Notices
19(b)(3)(A) of the Act 12 and Rule 19b–
4(f)(6) thereunder.13
A proposed rule change filed under
Rule 19(b)–4(f)(6) normally does not
become operative prior to 30 days after
the date of the filing. However, pursuant
to Rule 19b–4(f)(6)(iii), the Commission
may designate a shorter time if such
action is consistent with the protection
of investors and the public interest. The
Exchange has filed the proposed rule
change for immediate effectiveness and
has requested that the Commission
waive the requirement that the proposed
rule change not become operative for 30
days after the date of the filing so that
it may become operative on the date of
filing.
The Exchange notes that the proposed
rule change is intended to mitigate
confidentiality concerns raised in
connection with Section VII(A) of the
Plan, which provides that the data made
publicly available will not identify the
Trading Center that generated the data.
The Exchange states that the additional
time would allow consideration of a
methodology to mitigate concerns
related to the publication of Appendix
B data.14
The Commission believes that
waiving the 30-day operative delay is
consistent with the protection of
investors and the public interest
because it will synchronize the timing
for publication of Appendix B data for
all Participants, which should enhance
the consistency and usefulness of the
data.15 Therefore, the Commission
hereby waives the 30-day operative
delay and designates the proposed rule
change to be operative on the date of
filing.16
12 15
U.S.C. 78s(b)(3)(A).
CFR 240.19b–4(f)(6).
14 The Commission recently approved a FINRA
proposal to implement an aggregated, anonymous
grouped masking methodology for the publication
of Appendix B data related to OTC trading activity.
See Securities Exchange Release No. 80551, (April
28, 2017), 82 FR 20948 (May 4, 2017). See also
Letter from David S. Shillman, Associate Director,
Division of Trading and Markets, Commission, to
Marcia E. Asquith, Executive Vice President FINRA,
dated April 28, 2017.
15 The Commission recently granted exemptive
relief to the Participants delay the publication of
their Appendix B data until August 31, 2017. See
Letter from David S. Shillman, Associate Director,
Division of Trading and Markets, Commission, to
Jennifer Piorko Mitchell, Vice President and Deputy
Corporate Secretary, FINRA, dated April 27, 2017.
The Commission notes that other Participants have
submitted proposed rule changes to delay the
publication of Appendix B data until August 31,
2017. See e.g., SR–BatsBYX–2017–10; SR–
BatsEDGA–2017–10; SR–BatsEDGX–2017–19; SR–
BX–2017–022; SR–CHX–2017–07; SR–FINRA–
2017–010; SR–IEX–2017–12; SR–NASDAQ–2017–
044; SR–Phlx–2017–33; SR–NYSE–2017–19; SR–
NYSEArca–2017–49.
16 For purposes only of waiving the operative
delay for this proposal, the Commission has
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At any time within 60 days of the
filing of the proposed rule change, the
Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is necessary or appropriate in the
public interest, for the protection of
investors, or otherwise in furtherance of
the purposes of the Act. If the
Commission takes such action, the
Commission shall institute proceedings
to determine whether the proposed rule
should be approved or disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
NYSEMKT–2017–24 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Brent J. Fields, Secretary, Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
All submissions should refer to File
Number SR–NYSEMKT–2017–24. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549 on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
considered the proposed rule’s impact on
efficiency, competition, and capital formation. See
15 U.S.C. 78c(f).
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office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–
NYSEMKT–2017–24 and should be
submitted on or before June 6, 2017.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.17
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017–09820 Filed 5–15–17; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
32632; 812–14713]
Sierra Total Return Fund, et al.
May 10, 2017.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice.
AGENCY:
Notice of an application under section
6(c) of the Investment Company Act of
1940 (the ‘‘Act’’) for an exemption from
sections 18(a)(2), 18(c) and 18(i) of the
Act, under sections 6(c) and 23(c)(3) of
the Act for an exemption from rule 23c–
3 under 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 and to impose assetbased distribution and shareholder
service fees and early withdrawal
charges.
Applicants: Sierra Total Return Fund
(‘‘STRF’’), STRF Advisors LLC (‘‘STRF
Advisors’’), Sierra Opportunity Fund
(‘‘SOF’’), and SOF Advisors LLC (‘‘SOF
Advisors’’).
Filing Dates: The application was
filed on October 31, 2016 and amended
on March 8, 2017 and April 18, 2017.
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 5, 2017, and
should be accompanied by proof of
17 17
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CFR 200.30–3(a)(12).
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service on the 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: 280 Park Ave., 6th
Floor East, New York, NY 10017.
FOR FURTHER INFORMATION CONTACT: HaeSung Lee, Attorney-Adviser, at (202)
551–7345, or Robert H. Shapiro, Branch
Chief, at (202) 551–6821 (Division of
Investment Management, Chief
Counsel’s Office).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
Web site by searching for the file
number, or for an applicant using the
Company name box, at https://
www.sec.gov/search/search.htm or by
calling (202) 551–8090.
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Applicants’ Representations
1. STRF is a Delaware statutory trust
that is registered under the Act as a
continuously offered, non-diversified,
closed-end management investment
company. STRF’s primary investment
objective is to seek total return through
a combination of current income and
long-term capital appreciation by
investing in a portfolio of debt securities
and equities.
2. STRF Advisors is a Delaware
limited liability company and is
registered as an investment adviser
under the Investment Advisers Act of
1940 (‘‘Advisers Act’’). STRF Advisors
serves as investment adviser to STRF.
3. SOF is a Delaware statutory trust
that is registered under the Act as a
continuously offered, non-diversified,
closed-end management investment
company. SOF’s primary investment
objective is to generate current income
and, as a secondary objective, long-term
capital appreciation.
4. SOF Advisors is a Delaware limited
liability company and is registered as an
investment adviser under the Advisers
Act. SOF Advisors serves as investment
adviser to SOF.
5. The applicants seek an order to
permit the Funds (as defined below) to
issue multiple classes of shares, each
having its own fee and expense
structure and to impose early
withdrawal charges and asset-based
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distribution and shareholder service
fees with respect to certain classes.
6. Applicants request that the order
also apply to any continuously-offered
registered closed-end management
investment company that has been
previously organized or that may be
organized in the future for which STRF
Advisors, SOF Advisors or any entity
controlling, controlled by, or under
common control with STRF Advisors
and SOF Advisors, or any successor in
interest to any such entity,1 acts as
investment adviser and which operates
as an interval fund pursuant to rule
23c–3 under the Act or provides
periodic liquidity with respect to its
shares pursuant to rule 13e–4 under the
Securities Exchange Act of 1934
(‘‘Exchange Act’’) (each, a ‘‘Future
Fund’’ and together with STRF and
SOF, the ‘‘Funds’’).2
7. Each Fund intends to engage in a
continuous offering of its shares of
beneficial interest. Applicants state that
additional offerings by any Fund relying
on the order may be on a private
placement or public offering basis.
Shares of the Funds will not be listed on
any securities exchange nor publicly
traded. There is currently no secondary
market for the Funds’ shares and the
Funds expect that no secondary market
will develop.
8. If the requested relief is granted,
STRF and SOF will offer Class A, Class
T, Class I, Class S, and Class L shares,
with each class having its own fee and
expense structure, and may also offer
additional classes of shares in the
future. Because of the different
distribution and/or shareholder services
fees, services and any other class
expenses that may be attributable to
each of STRF’s and SOF’s Class A, Class
T, Class I, Class S, and Class L shares,
the net income attributable to, and the
dividends payable on, each class of
shares may differ from each other.
9. Applicants state that, from time to
time, the Funds may create additional
classes of shares, the terms of which
may differ from Class A, Class T, Class
I, Class S, and Class L shares in the
following respects: (i) The amount of
fees permitted by different distribution
plans or different shareholder services
fee arrangements; (ii) voting rights with
respect to a distribution and/or
shareholder services plan of a class; (iii)
1 A successor in interest is limited to an entity
that results from a reorganization into another
jurisdiction or a change in the type of business
organization.
2 Any Fund relying on this relief in the future will
do so in a manner consistent with the terms and
conditions of the application. Applicants represent
that each entity presently intending to rely on the
requested relief is listed as an applicant.
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different class designations; (iv) the
impact of any class expenses directly
attributable to a particular class of
shares allocated on a class basis as
described in the application; (v) any
differences in dividends and net asset
value resulting from differences in fees
under a distribution and/or shareholder
services plan or in class expenses; (vi)
any early withdrawal charge or other
sales load structure; and (vii) exchange
or conversion privileges of the classes as
permitted under the Act.
10. Applicants state that each of STRF
and SOF has adopted a fundamental
policy to repurchase a specified
percentage of its shares (no less than 5%
and not more than 25%) at net asset
value on a quarterly basis and on an
annual basis, respectively. Such
repurchase offers will be conducted
pursuant to rule 23c–3 under the Act.
Each of the other Funds will likewise
adopt fundamental investment policies
in compliance with rule 23c–3 and
make repurchase offers to its
shareholders at periodic intervals and/
or provide periodic liquidity with
respect to its shares pursuant to rule
13e–4 under the Exchange Act.3 Any
repurchase offers made by the Funds
will be made to all holders of shares of
each such Fund.
11. Applicants represent that any
asset-based shareholder services and
distribution fees for each class of shares
will comply with the provisions of
FINRA Rule 2341(d) (‘‘FINRA Sales
Charge Rule’’).4 Applicants also
represent that each 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.5 As is
required for open-end funds, each Fund
will disclose its expenses in shareholder
reports, and describe any arrangements
that result in breakpoints in or
elimination of sales loads in its
prospectus.6 In addition, applicants will
3 Applicants submit that rule 23c–3 and
Regulation M under the Exchange Act permit an
interval fund to make repurchase offers to
repurchase its shares while engaging in a
continuous offering of its shares pursuant to Rule
415 under the Securities Act of 1933, as amended.
4 All references in the application to the FINRA
Sales Charge Rule include any Financial Industry
Regulatory Authority successor or replacement rule
to the FINRA Sales Charge Rule.
5 In all respects other than class-by-class
disclosure, each Fund will comply with the
requirements of Form N–2.
6 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
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comply with applicable enhanced fee
disclosure requirements for fund of
funds, including registered funds of
hedge funds.7
12. Each of the Funds will comply
with any requirements that the
Commission or FINRA may adopt
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. In addition, each
Fund will contractually require that any
distributor of the Fund’s shares comply
with such requirements in connection
with the distribution of such Fund’s
shares.
13. Each 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, shareholder
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
by each outstanding share of that class.
Applicants state that each Fund will
comply with the provisions of rule 18f–
3 under the Act as if it were an openend investment company.
14. Applicants state that each Fund
may impose an early withdrawal charge
on shares submitted for repurchase that
have been held less than a specified
period and may waive the early
withdrawal charge for certain categories
of shareholders or transactions to be
established from time to time.
Applicants state that each of the Funds
will apply the early withdrawal charge
(and any waivers or scheduled
variations of the early withdrawal
charge) uniformly to all shareholders in
a given class and consistently with the
requirements of rule 22d–1 under the
Act as if the Funds were open-end
investment companies.
15. Each Fund operating as an interval
fund pursuant to rule 23c–3 under the
Act may offer its shareholders an
exchange feature under which the
shareholders of the Fund may, in
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).
7 Fund of Funds Investments, Investment
Company Act Rel. Nos. 26198 (Oct. 1, 2003)
(proposing release) and 27399 (Jun. 20, 2006)
(adopting release). See also Rules 12d1–1, et seq. of
the Act.
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connection with the Fund’s periodic
repurchase offers, exchange their shares
of the Fund for shares of the same class
of (i) registered open-end investment
companies or (ii) other registered
closed-end investment companies that
comply with rule 23c–3 under the Act
and continuously offer their shares at
net asset value, that are in the Fund’s
group of investment companies
(collectively, ‘‘Other Funds’’). Shares of
a Fund operating pursuant to rule 23c–
3 that are exchanged for shares of Other
Funds will be included as part of the
amount of the repurchase offer amount
for such Fund as specified in rule 23c–
3 under the Act. Any exchange option
will comply with rule 11a–3 under the
Act, as if the Fund were an open-end
investment company subject to rule
11a–3. In complying with rule 11a–3,
each Fund will treat an early
withdrawal charge as if it were a
contingent deferred sales load.
Applicants’ Legal Analysis
Multiple Classes of Shares
1. Section 18(a)(2) of the Act provides
that a closed-end investment company
may not issue or sell a senior security
that is a stock unless certain
requirements are met. Applicants state
that the creation of multiple classes of
shares of the Funds may violate section
18(a)(2) because the Funds may not
meet such requirements with respect to
a class of shares that may be a senior
security.
2. 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 Funds
may be prohibited by section 18(c), as
a class may have priority over another
class as to payment of dividends
because shareholders of different classes
would pay different fees and expenses.
3. 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 multiple classes of
shares of the Funds 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.
4. 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
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Act, or from any rule or regulation
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(a)(2), 18(c) and 18(i) to
permit the Funds to issue multiple
classes of shares.
5. Applicants submit that the
proposed allocation of expenses relating
to distribution 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 a Fund to facilitate the
distribution of its shares and provide
investors with a broader choice of
shareholder services. 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 each Fund will comply with the
provisions of rule 18f–3 as if it were an
open-end investment company.
Early Withdrawal Charges
1. Section 23(c) of the Act provides,
in relevant part, that no registered
closed-end investment company shall
purchase securities of which it is the
issuer, except: (a) On a securities
exchange or other open market; (b)
pursuant to tenders, after reasonable
opportunity to submit tenders given to
all holders of securities of the class to
be purchased; or (c) under other
circumstances as the Commission may
permit by rules and regulations or
orders for the protection of investors.
2. Rule 23c–3 under the Act permits
a registered closed-end investment
company (an ‘‘interval fund’’) to make
repurchase offers of between five and
twenty-five percent of its outstanding
shares at net asset value at periodic
intervals pursuant to a fundamental
policy of the interval fund. Rule 23c–
3(b)(1) under the Act permits an interval
fund to deduct from repurchase
proceeds only a repurchase fee, not to
exceed two percent of the proceeds, that
is paid to the interval fund and is
reasonably intended to compensate the
fund for expenses directly related to the
repurchase.
3. Section 23(c)(3) provides that the
Commission may issue an order that
would permit a closed-end investment
company to repurchase its shares in
circumstances in which the repurchase
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is made in a manner or on a basis that
does not unfairly discriminate against
any holders of the class or classes of
securities to be purchased.
4. Applicants request relief under
section 6(c), discussed above, and
section 23(c)(3) from rule 23c–3 to the
extent necessary for the Funds to
impose early withdrawal charges on
shares of the Funds submitted for
repurchase that have been held for less
than a specified period.
5. Applicants state that the early
withdrawal charges they intend to
impose are functionally similar to
contingent deferred sales loads imposed
by open-end investment companies
under rule 6c–10 under the Act. Rule
6c–10 permits open-end investment
companies to impose contingent
deferred sales loads, subject to certain
conditions. Applicants note that rule
6c–10 is grounded in policy
considerations supporting the
employment of contingent deferred
sales loads where there are adequate
safeguards for the investor and state that
the same policy considerations support
imposition of early withdrawal charges
in the interval fund context. In addition,
applicants state that early withdrawal
charges may be necessary for the
distributor to recover distribution costs.
Applicants represent that any early
withdrawal charge imposed by the
Funds will comply with rule 6c–10
under the Act as if the rule were
applicable to closed-end investment
companies. The Funds will disclose
early withdrawal charges in accordance
with the requirements of Form N–1A
concerning contingent deferred sales
loads.
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Asset-Based Distribution and
Shareholder Service 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.
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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 the extent
necessary to permit the Fund to impose
asset-based distribution and shareholder
service fees. Applicants have agreed to
comply with rules 12b–1 and 17d–3 as
if those rules applied to closed-end
investment companies, which they
believe will resolve any concerns that
might arise in connection with a Fund
financing the distribution of its shares
through asset-based distribution fees.
For the reasons stated above,
applicants submit that the exemptions
requested under section 6(c) are
necessary and appropriate in the public
interest and are consistent with the
protection of investors and the purposes
fairly intended by the policy and
provisions of the Act. Applicants further
submit that the relief requested
pursuant to section 23(c)(3) will be
consistent with the protection of
investors and will insure that applicants
do not unfairly discriminate against any
holders of the class of securities to be
purchased. Finally, applicants state that
the Funds’ imposition of asset-based
distribution and shareholder service
fees is consistent with the provisions,
policies and purposes of the Act and
does not involve participation on a basis
different from or less advantageous than
that of other participants.
Applicants’ Condition
Applicants agree that any order
granting the requested relief will be
subject to the following condition:
Each Fund relying on the order will
comply with the provisions of rules 6c–
10, 12b–1, 17d–3, 18f–3, 22d–1, and,
where applicable, 11a–3 under the Act,
as amended from time to time, as if
those rules applied to closed-end
management investment companies,
and will comply with the FINRA Sales
Charge Rule, 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.
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017–09790 Filed 5–15–17; 8:45 am]
BILLING CODE 8011–01–P
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–80649; File No. SR–GEMX–
2017–07]
Self-Regulatory Organizations; Nasdaq
GEMX, LLC; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change To Establish INET Ports
May 10, 2017.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on April 27,
2017, Nasdaq GEMX, LLC (‘‘GEMX’’ or
‘‘Exchange’’) filed with the Securities
and Exchange Commission (‘‘SEC’’ or
‘‘Commission’’) the proposed rule
change as described in Items I and II,
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
The Exchange proposes to establish
ports that members use to connect to the
Exchange with the migration of the
Exchange’s trading system to the Nasdaq
INET architecture.
The text of the proposed rule change
is available on the Exchange’s Web site
at www.ise.com, at the principal office
of the Exchange, and at the
Commission’s Public Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in sections A, B, and C below, of
the most significant aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The purpose of the proposed rule
change is to establish ports that
members use to connect to the Exchange
with the migration of the Exchange’s
1 15
2 17
Sfmt 4703
22595
U.S.C. 78s(b)(1).
CFR 240.19b–4.
E:\FR\FM\16MYN1.SGM
16MYN1
Agencies
[Federal Register Volume 82, Number 93 (Tuesday, May 16, 2017)]
[Notices]
[Pages 22592-22595]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-09790]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 32632; 812-14713]
Sierra Total Return Fund, et al.
May 10, 2017.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice.
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Notice of an application under section 6(c) of the Investment
Company Act of 1940 (the ``Act'') for an exemption from sections
18(a)(2), 18(c) and 18(i) of the Act, under sections 6(c) and 23(c)(3)
of the Act for an exemption from rule 23c-3 under 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 and to impose asset-based distribution and
shareholder service fees and early withdrawal charges.
Applicants: Sierra Total Return Fund (``STRF''), STRF Advisors LLC
(``STRF Advisors''), Sierra Opportunity Fund (``SOF''), and SOF
Advisors LLC (``SOF Advisors'').
Filing Dates: The application was filed on October 31, 2016 and
amended on March 8, 2017 and April 18, 2017.
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 5, 2017, and should be accompanied by proof of
[[Page 22593]]
service on the 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: 280 Park Ave., 6th
Floor East, New York, NY 10017.
FOR FURTHER INFORMATION CONTACT: Hae-Sung Lee, Attorney-Adviser, at
(202) 551-7345, or Robert H. Shapiro, Branch Chief, at (202) 551-6821
(Division of Investment Management, Chief Counsel's Office).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's Web site by searching for the file number, or for an
applicant using the Company name box, at https://www.sec.gov/search/search.htm or by calling (202) 551-8090.
Applicants' Representations
1. STRF is a Delaware statutory trust that is registered under the
Act as a continuously offered, non-diversified, closed-end management
investment company. STRF's primary investment objective is to seek
total return through a combination of current income and long-term
capital appreciation by investing in a portfolio of debt securities and
equities.
2. STRF Advisors is a Delaware limited liability company and is
registered as an investment adviser under the Investment Advisers Act
of 1940 (``Advisers Act''). STRF Advisors serves as investment adviser
to STRF.
3. SOF is a Delaware statutory trust that is registered under the
Act as a continuously offered, non-diversified, closed-end management
investment company. SOF's primary investment objective is to generate
current income and, as a secondary objective, long-term capital
appreciation.
4. SOF Advisors is a Delaware limited liability company and is
registered as an investment adviser under the Advisers Act. SOF
Advisors serves as investment adviser to SOF.
5. The applicants seek an order to permit the Funds (as defined
below) to issue multiple classes of shares, each having its own fee and
expense structure and to impose early withdrawal charges and asset-
based distribution and shareholder service fees with respect to certain
classes.
6. Applicants request that the order also apply to any
continuously-offered registered closed-end management investment
company that has been previously organized or that may be organized in
the future for which STRF Advisors, SOF Advisors or any entity
controlling, controlled by, or under common control with STRF Advisors
and SOF Advisors, or any successor in interest to any such entity,\1\
acts as investment adviser and which operates as an interval fund
pursuant to rule 23c-3 under the Act or provides periodic liquidity
with respect to its shares pursuant to rule 13e-4 under the Securities
Exchange Act of 1934 (``Exchange Act'') (each, a ``Future Fund'' and
together with STRF and SOF, the ``Funds'').\2\
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\1\ A successor in interest is limited to an entity that results
from a reorganization into another jurisdiction or a change in the
type of business organization.
\2\ Any Fund relying on this relief in the future will do so in
a manner consistent with the terms and conditions of the
application. Applicants represent that each entity presently
intending to rely on the requested relief is listed as an applicant.
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7. Each Fund intends to engage in a continuous offering of its
shares of beneficial interest. Applicants state that additional
offerings by any Fund relying on the order may be on a private
placement or public offering basis. Shares of the Funds will not be
listed on any securities exchange nor publicly traded. There is
currently no secondary market for the Funds' shares and the Funds
expect that no secondary market will develop.
8. If the requested relief is granted, STRF and SOF will offer
Class A, Class T, Class I, Class S, and Class L shares, with each class
having its own fee and expense structure, and may also offer additional
classes of shares in the future. Because of the different distribution
and/or shareholder services fees, services and any other class expenses
that may be attributable to each of STRF's and SOF's Class A, Class T,
Class I, Class S, and Class L shares, the net income attributable to,
and the dividends payable on, each class of shares may differ from each
other.
9. Applicants state that, from time to time, the Funds may create
additional classes of shares, the terms of which may differ from Class
A, Class T, Class I, Class S, and Class L shares in the following
respects: (i) The amount of fees permitted by different distribution
plans or different shareholder services fee arrangements; (ii) voting
rights with respect to a distribution and/or shareholder services plan
of a class; (iii) different class designations; (iv) the impact of any
class expenses directly attributable to a particular class of shares
allocated on a class basis as described in the application; (v) any
differences in dividends and net asset value resulting from differences
in fees under a distribution and/or shareholder services plan or in
class expenses; (vi) any early withdrawal charge or other sales load
structure; and (vii) exchange or conversion privileges of the classes
as permitted under the Act.
10. Applicants state that each of STRF and SOF has adopted a
fundamental policy to repurchase a specified percentage of its shares
(no less than 5% and not more than 25%) at net asset value on a
quarterly basis and on an annual basis, respectively. Such repurchase
offers will be conducted pursuant to rule 23c-3 under the Act. Each of
the other Funds will likewise adopt fundamental investment policies in
compliance with rule 23c-3 and make repurchase offers to its
shareholders at periodic intervals and/or provide periodic liquidity
with respect to its shares pursuant to rule 13e-4 under the Exchange
Act.\3\ Any repurchase offers made by the Funds will be made to all
holders of shares of each such Fund.
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\3\ Applicants submit that rule 23c-3 and Regulation M under the
Exchange Act permit an interval fund to make repurchase offers to
repurchase its shares while engaging in a continuous offering of its
shares pursuant to Rule 415 under the Securities Act of 1933, as
amended.
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11. Applicants represent that any asset-based shareholder services
and distribution fees for each class of shares will comply with the
provisions of FINRA Rule 2341(d) (``FINRA Sales Charge Rule'').\4\
Applicants also represent that each 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.\5\ As is required for open-
end funds, each Fund will disclose its expenses in shareholder reports,
and describe any arrangements that result in breakpoints in or
elimination of sales loads in its prospectus.\6\ In addition,
applicants will
[[Page 22594]]
comply with applicable enhanced fee disclosure requirements for fund of
funds, including registered funds of hedge funds.\7\
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\4\ All references in the application to the FINRA Sales Charge
Rule include any Financial Industry Regulatory Authority successor
or replacement rule to the FINRA Sales Charge Rule.
\5\ In all respects other than class-by-class disclosure, each
Fund will comply with the requirements of Form N-2.
\6\ 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).
\7\ Fund of Funds Investments, Investment Company Act Rel. Nos.
26198 (Oct. 1, 2003) (proposing release) and 27399 (Jun. 20, 2006)
(adopting release). See also Rules 12d1-1, et seq. of the Act.
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12. Each of the Funds will comply with any requirements that the
Commission or FINRA may adopt 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. In
addition, each Fund will contractually require that any distributor of
the Fund's shares comply with such requirements in connection with the
distribution of such Fund's shares.
13. Each 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, shareholder
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 by each outstanding share of that class.
Applicants state that each Fund will comply with the provisions of rule
18f-3 under the Act as if it were an open-end investment company.
14. Applicants state that each Fund may impose an early withdrawal
charge on shares submitted for repurchase that have been held less than
a specified period and may waive the early withdrawal charge for
certain categories of shareholders or transactions to be established
from time to time. Applicants state that each of the Funds will apply
the early withdrawal charge (and any waivers or scheduled variations of
the early withdrawal charge) uniformly to all shareholders in a given
class and consistently with the requirements of rule 22d-1 under the
Act as if the Funds were open-end investment companies.
15. Each Fund operating as an interval fund pursuant to rule 23c-3
under the Act may offer its shareholders an exchange feature under
which the shareholders of the Fund may, in connection with the Fund's
periodic repurchase offers, exchange their shares of the Fund for
shares of the same class of (i) registered open-end investment
companies or (ii) other registered closed-end investment companies that
comply with rule 23c-3 under the Act and continuously offer their
shares at net asset value, that are in the Fund's group of investment
companies (collectively, ``Other Funds''). Shares of a Fund operating
pursuant to rule 23c-3 that are exchanged for shares of Other Funds
will be included as part of the amount of the repurchase offer amount
for such Fund as specified in rule 23c-3 under the Act. Any exchange
option will comply with rule 11a-3 under the Act, as if the Fund were
an open-end investment company subject to rule 11a-3. In complying with
rule 11a-3, each Fund will treat an early withdrawal charge as if it
were a contingent deferred sales load.
Applicants' Legal Analysis
Multiple Classes of Shares
1. Section 18(a)(2) of the Act provides that a closed-end
investment company may not issue or sell a senior security that is a
stock unless certain requirements are met. Applicants state that the
creation of multiple classes of shares of the Funds may violate section
18(a)(2) because the Funds may not meet such requirements with respect
to a class of shares that may be a senior security.
2. 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 Funds may be prohibited by section
18(c), as a class may have priority over another class as to payment of
dividends because shareholders of different classes would pay different
fees and expenses.
3. 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 multiple classes of shares of the Funds
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.
4. 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 or regulation 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(a)(2), 18(c) and 18(i) to permit the
Funds to issue multiple classes of shares.
5. Applicants submit that the proposed allocation of expenses
relating to distribution 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 a Fund to facilitate the distribution of its shares and provide
investors with a broader choice of shareholder services. 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 each Fund will comply with the provisions of rule
18f-3 as if it were an open-end investment company.
Early Withdrawal Charges
1. Section 23(c) of the Act provides, in relevant part, that no
registered closed-end investment company shall purchase securities of
which it is the issuer, except: (a) On a securities exchange or other
open market; (b) pursuant to tenders, after reasonable opportunity to
submit tenders given to all holders of securities of the class to be
purchased; or (c) under other circumstances as the Commission may
permit by rules and regulations or orders for the protection of
investors.
2. Rule 23c-3 under the Act permits a registered closed-end
investment company (an ``interval fund'') to make repurchase offers of
between five and twenty-five percent of its outstanding shares at net
asset value at periodic intervals pursuant to a fundamental policy of
the interval fund. Rule 23c-3(b)(1) under the Act permits an interval
fund to deduct from repurchase proceeds only a repurchase fee, not to
exceed two percent of the proceeds, that is paid to the interval fund
and is reasonably intended to compensate the fund for expenses directly
related to the repurchase.
3. Section 23(c)(3) provides that the Commission may issue an order
that would permit a closed-end investment company to repurchase its
shares in circumstances in which the repurchase
[[Page 22595]]
is made in a manner or on a basis that does not unfairly discriminate
against any holders of the class or classes of securities to be
purchased.
4. Applicants request relief under section 6(c), discussed above,
and section 23(c)(3) from rule 23c-3 to the extent necessary for the
Funds to impose early withdrawal charges on shares of the Funds
submitted for repurchase that have been held for less than a specified
period.
5. Applicants state that the early withdrawal charges they intend
to impose are functionally similar to contingent deferred sales loads
imposed by open-end investment companies under rule 6c-10 under the
Act. Rule 6c-10 permits open-end investment companies to impose
contingent deferred sales loads, subject to certain conditions.
Applicants note that rule 6c-10 is grounded in policy considerations
supporting the employment of contingent deferred sales loads where
there are adequate safeguards for the investor and state that the same
policy considerations support imposition of early withdrawal charges in
the interval fund context. In addition, applicants state that early
withdrawal charges may be necessary for the distributor to recover
distribution costs. Applicants represent that any early withdrawal
charge imposed by the Funds will comply with rule 6c-10 under the Act
as if the rule were applicable to closed-end investment companies. The
Funds will disclose early withdrawal charges in accordance with the
requirements of Form N-1A concerning contingent deferred sales loads.
Asset-Based Distribution and Shareholder Service 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 the extent necessary to permit the Fund to impose asset-
based distribution and shareholder service fees. Applicants have agreed
to comply with rules 12b-1 and 17d-3 as if those rules applied to
closed-end investment companies, which they believe will resolve any
concerns that might arise in connection with a Fund financing the
distribution of its shares through asset-based distribution fees.
For the reasons stated above, applicants submit that the exemptions
requested under section 6(c) are necessary and appropriate in the
public interest and are consistent with the protection of investors and
the purposes fairly intended by the policy and provisions of the Act.
Applicants further submit that the relief requested pursuant to section
23(c)(3) will be consistent with the protection of investors and will
insure that applicants do not unfairly discriminate against any holders
of the class of securities to be purchased. Finally, applicants state
that the Funds' imposition of asset-based distribution and shareholder
service fees is consistent with the provisions, policies and purposes
of the Act and does not involve participation on a basis different from
or less advantageous than that of other participants.
Applicants' Condition
Applicants agree that any order granting the requested relief will
be subject to the following condition:
Each Fund relying on the order will comply with the provisions of
rules 6c-10, 12b-1, 17d-3, 18f-3, 22d-1, and, where applicable, 11a-3
under the Act, as amended from time to time, as if those rules applied
to closed-end management investment companies, and will comply with the
FINRA Sales Charge Rule, 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.
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017-09790 Filed 5-15-17; 8:45 am]
BILLING CODE 8011-01-P