Partners Group (USA) Inc., et al., 26554-26559 [2017-11728]
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Federal Register / Vol. 82, No. 108 / Wednesday, June 7, 2017 / Notices
greater transparency regarding
displayed orders in the IEX System
through HIST and the IEX Data Platform
thereby promoting broad price
discovery and market efficiency, and
will not remove or eliminate any data
that is currently available to market
participants, consistent with the
protection of investors and the public
interest. The Commission believes that
waiver of the 30-day operative delay is
consistent with the protection of
investors and the public interest
because it will provide to investors,
without undue delay, public access to,
and thus greater transparency regarding,
displayed orders, including historical
data, free of charge. Therefore, the
Commission hereby waives the 30-day
operative delay and designates the
proposed rule change operative upon
filing.18
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 will institute proceedings
to determine whether the proposed rule
change should be approved or
disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
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Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
IEX–2017–19 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–IEX–2017–19. This file
number should be included in the
subject line if email is used. To help the
Commission process and review your
18 For purposes only of waiving the 30-day
operative delay, the Commission also has
considered the proposed rule’s impact on
efficiency, competition, and capital formation. See
15 U.S.C. 78c(f).
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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 will also be available for
inspection and copying at the IEX’s
principal office and on its Internet Web
site at www.iextrading.com. 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–IEX–2017–19 and should
be submitted on or before June 28, 2017.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.19
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017–11754 Filed 6–6–17; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Release Act No.
32667; 812–14193–01]
Partners Group (USA) Inc., et al.
DATE: June 1, 2017.
AGENCY: Securities and
Exchange
Commission (‘‘Commission’’).
ACTION: Notice.
Notice of application for an order
under section 17(d) of the Investment
Company Act of 1940 (the ‘‘Act’’) and
rule 17d–1 under the Act to permit
certain joint transactions otherwise
prohibited by section 17(d) of the Act
and rule 17d–1 under the Act.
SUMMARY OF APPLICATION: Applicants
request an order to permit certain
closed-end management investment
19 17
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CFR 200.30–3(a)(12).
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companies to co-invest in portfolio
companies with each other and with
affiliated investment funds.
APPLICANTS: Partners Group Private
Equity (Master Fund), LLC (the
‘‘Fund’’); Partners Group Private Income
Opportunities, LLC (‘‘Partners Group
Private Income Opportunities’’);
Partners Group (USA) Inc. (‘‘Partners
Group’’); Partners Group AG (‘‘Partners
Group AG’’); Partners Group (UK)
Limited (‘‘Partners Group UK’’);
Partners Group (Luxembourg) S.A.
(‘‘Partners Group Lux’’); Partners Group
(Guernsey) Limited (‘‘Partners Group
Guernsey’’); Partners Group Cayman
Management I Limited (‘‘PGCM I’’);
Partners Group Cayman Management III
Limited (‘‘PGCM III’’); Partners Group
Management Limited (‘‘PGML’’);
`
Partners Group Management I S.a r.l.
(‘‘PGMS I’’); Partners Group
Management II Limited (‘‘PGML II’’);
`
Partners Group Management III S.a r.l.
(‘‘PGMS III’’); Partners Group
Management IX Limited (‘‘PGML IX’’);
Partners Group Management V Limited
(‘‘PGML V’’); Partners Group
Management VII Limited (‘‘PGML VII’’);
Partners Group Management VIII
Limited (‘‘PGML VIII’’); Partners Group
Management XI Limited (‘‘PGML XI’’);
Partners Group Management XIII
Limited (‘‘PGML XIII’’); Princess
Management Limited (‘‘Princess’’ and
collectively with Partners Group
Guernsey, Partners Group UK, PGCM I,
PGCM III, PGML, PGMS I, PGML II,
PGMS III, PGML IX, PGML V, PGML
VII, PGML VIII, PGML XI and PGML
XIII, the ‘‘General Partner Advisers’’);
and Partners Group (Italy) Global Value
2014; Partners Group Direct Equity 2016
(EUR) G, L.P. Inc.; Partners Group Direct
Equity 2016 (EUR) S.C.A., SICAV–SIF;
Partners Group Direct Equity 2016
(EUR), L.P. Inc.; Partners Group Direct
Equity 2016 (USD) A, L.P.; Partners
Group Direct Equity 2016 (USD) C, L.P.;
Partners Group Direct Equity 2016
(USD) C–G, L.P.; Partners Group Direct
Equity 2016 (USD) C–I, L.P.; Partners
Group Direct Infrastructure 2015 (EUR)
S.C.A., SICAV–SIF; Partners Group
Direct Infrastructure 2015 (USD), L.P.
Inc.; Partners Group Direct
Infrastructure 2016 (USD) A, L.P.;
Partners Group Emerging Markets 2015,
L.P. Inc.; Partners Group Generations
Fund I; Partners Group Global Growth
2014, L.P. Inc.; Partners Group Global
Infrastructure 2012, L.P. Inc.; Partners
Group Global Infrastructure 2015 (EUR)
S.C.A., SICAV–SIF; Partners Group
Global Infrastructure 2015 (EUR), L.P.
Inc.; Partners Group Global
Infrastructure SICAV; Partners Group
Global Multi-Asset Fund; Partners
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Federal Register / Vol. 82, No. 108 / Wednesday, June 7, 2017 / Notices
Group Global Value 2014 (EUR) S.C.A.,
SICAR; Partners Group Global Value
2014, L.P. Inc.; Partners Group Global
Value SICAV; Partners Group Growth
Strategies 2016 S.C.A., SICAV–RAIF;
Partners Group Private Equity
Performance Holding Limited; Partners
Group Secondary 2015 (EUR) S.C.A.,
SICAV–SIF; Partners Group Secondary
2015 (EUR), L.P. Inc.; Partners Group
Secondary 2015 (USD) A, L.P.; Partners
Group Secondary 2015 (USD) C, L.P.;
Partners Group U.S. Private Equity 2015
L.P. S.C.S., SICAV–SIF; Princess Private
Equity Holding Limited; The Partners
Fund SICAV and The Partners Fund
(the ‘‘Existing Affiliated Funds’’).
The application was filed
on August 2, 2013, and amended on
August 11, 2014, January 13, 2016, May
4, 2017, and June 1, 2017.
FILING DATES:
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 26, 2017, 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.
Secretary, U.S. Securities
and Exchange Commission, 100 F St.
NE., Washington, DC 20549–1090.
Applicants: 1114 Avenue of the
Americas, 37th Floor, New York, NY
10036.
ADDRESSES:
FOR FURTHER INFORMATION CONTACT:
Robert Shapiro, Branch Chief, at (202)
551–6821 (Chief Counsel’s Office,
Division of Investment Management).
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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SUPPLEMENTARY INFORMATION:
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Applicants’ Representations
is a Delaware limited
1. The
liability company that is registered as a
closed-end management investment
company under the Act. The Fund’s
investment objective is to seek attractive
long-term capital appreciation by
investing in a globally diversified
portfolio of private equity investments.
The board of directors of the Fund (the
‘‘Fund Board’’) is currently comprised
of three managers, two of whom are not
‘‘interested persons,’’ within the
meaning of Section 2(a)(19) of the Act
(the ‘‘Non-Interested Directors’’), of the
Fund.
2. Partners Group Private Income
Opportunities is a Delaware limited
liability company that is registered as a
closed-end management investment
company under the Act. Partners Group
Private Income Opportunities’
investment objective will be to generate
attractive risk-adjusted returns and
current income by investing in a
diversified portfolio of predominantly
credit-related opportunities. The board
of managers of Partners Group Private
Income Opportunities (the ‘‘PGPIO
Board’’) 2 is currently comprised of five
managers, four of whom are NonInterested Directors of Partners Group
Private Income Opportunities.
3. Each of the Existing Affiliated
Funds would be an investment
company but for section 3(c)(1) or
3(c)(7) of the Act.
4. Partners Group is a Delaware
corporation and an investment adviser
registered with the Commission under
the Investment Advisers Act of 1940, as
amended (the ‘‘Advisers Act’’). Partners
Group serves as investment adviser to
the Fund and Partners Group Private
Income Opportunities. Partners Group is
Fund 1
1 The Fund, Partners Group Private Income
Opportunities, and any Future Regulated Fund are
referred to individually as a ‘‘Regulated Fund,’’ and
collectively as the ‘‘Regulated Funds.’’ ‘‘Future
Regulated Fund’’ means any closed-end
management investment company (a) that is
registered under the Act, (b) whose investment
adviser is an Adviser (defined below) that is
registered as an investment adviser under the
Investment Advisers Act of 1940, as amended (the
‘‘Advisers Act’’), and (c) that intends to participate
in the Co-Investment Program. The term ‘‘Adviser’’
means (a) Partners Group, Partners Group AG,
Partners Group UK, Partners Group Lux and each
General Partner Adviser, and (b) any future
investment adviser that controls, is controlled by or
is under common control with Partners Group,
Partners Group AG, Partners Group UK, Partners
Group Lux or any General Partner Adviser and is
either registered as an investment adviser under the
Advisers Act or is an exempt reporting adviser or
a foreign private adviser.
2 The Fund Board, the PGPIO Board and any
board of managers, board of directors or board of
trustees of a Future Regulated Fund are each
referred to herein as a ‘‘Board’’ and collectively the
‘‘Boards,’’ as applicable.
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a wholly-owned subsidiary of Partners
Group Holding AG, a corporation
organized in Switzerland.
5. Partners Group AG is a corporation
organized in Switzerland and is an
exempt reporting adviser under the
Advisers Act. Partners Group AG is
registered with the Swiss Financial
Markets Authority (FINMA) and
provides investment recommendations
to Partners Group with respect to its
clients’ portfolios. While Partners Group
AG may provide investment
recommendations to Partners Group,
Partners Group maintains ultimate
investment discretion as to whether
such recommendations will translate
into investments made by its clients.
6. Partners Group Guernsey is a
company limited by shares organized in
Guernsey and is an exempt reporting
adviser under the Advisers Act. Partners
Group Guernsey is registered with the
Guernsey Financial Services
Commission (GFSC) and provides
administrative and in particular
investment execution services to
Partners Group with respect to its
clients. Partners Group Guernsey also
serves as General Partner Adviser to
Affiliated Funds.
7. Partners Group UK is a foreign
private adviser under the Advisers Act,
formed as a private limited company in
the United Kingdom. Partners Group UK
is registered with the UK Financial
Conduct Authority (FCA) and provides
investment management or advisory
services to certain Affiliated Funds.
8. Partners Group Lux is an exempt
reporting adviser under the Advisers
´ ´
Act, formed as a societe anonyme in
Luxembourg. Partners Group Lux is
registered with the Luxembourg
Commission de Surveillance du Secteur
Financier (CSSF) and provides
administrative, domiciliary, depositary
and/or investment management or
advisory services to certain Affiliated
Funds.
9. As described more fully in the
application, each General Partner
Adviser serves as the general partner or
fund manager of one or more Affiliated
Funds. Investment decisions are made
by affiliated investment committees and
the respective General Partner signs-off
or otherwise ratifies such decisions.
Other than Partners Group UK, each
General Partner Adviser is an exempt
reporting adviser.
10. Applicants seek an order
(‘‘Order’’) to permit one or more
Regulated Funds and/or one or more
Affiliated Funds 3 to participate in the
3 The term ‘‘Affiliated Fund’’ means any of the
Existing Affiliated Funds and any Future Affiliated
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same investment opportunities through
a proposed co-investment program
where such participation would
otherwise be prohibited under section
17(d) and the rules under the Act (the
‘‘Co-Investment Program’’).4 A ‘‘CoInvestment Transaction’’ means any
transaction in which a Regulated Fund
(or its Wholly-Owned Investment
Subsidiary, as defined below)
participated together with one or more
other Regulated Funds and/or one or
more Affiliated Funds in reliance on the
Order. A ‘‘Potential Co-Investment
Transaction’’ means any investment
opportunity in which a Regulated Fund
(or its Wholly-Owned Investment
Subsidiary, as defined below) could not
participate together with one or more
Regulated Funds and/or one or more
Affiliated Funds without obtaining and
relying on the Order.
11. Applicants state that a Regulated
Fund may, from time to time, form one
or more Wholly-Owned Investment
Subsidiaries.5 A Wholly-Owned
Investment Subsidiary would be
prohibited from investing in a CoInvestment Transaction with another
Regulated Fund or any Affiliated Fund
because it would be a company
controlled by the applicable Regulated
Fund for purposes of sections 17(d) and
rule 17d–1. Applicants request that a
Wholly-Owned Investment Subsidiary
be permitted to participate in CoInvestment Transactions in lieu of the
applicable Regulated Fund, and that
such Wholly-Owned Investment
Subsidiary’s participation in any such
transaction be treated, for purposes of
the requested Order, as though the
Regulated Fund were participating
directly. Applicants represent that this
treatment is justified because a WhollyOwned Investment Subsidiary would
have no purpose other than serving as
a holding vehicle for the Regulated
Fund. ‘‘Future Affiliated Fund’’ means an entity (a)
whose investment adviser is an Adviser and (b) that
would be an investment company but for section
3(c)(1) or 3(c)(7) of the Act, and (iii) that intends
to participate in the Co-Investment Program.
4 All existing entities that currently intend to rely
upon the requested Order have been named as
applicants. Any other existing or future entity that
relies on the Order in the future will comply with
the terms and conditions of the application.
5 The term ‘‘Wholly-Owned Investment
Subsidiary’’ means an entity (a) whose sole
business purpose is to hold one or more
investments on behalf of a Regulated Fund; (b) that
is wholly-owned by a Regulated Fund (with such
Regulated Fund at all times holding, beneficially
and of record, 100% of the voting and economic
interests); (c) with respect to which the Board of the
Regulated Fund has the sole authority to make all
determinations with respect to the Wholly-Owned
Investment Subsidiary’s participation under the
conditions of the application; and (d) that is and
entity that would be an investment company but for
section 3(c)(1) or 3(c)(7) of the Act.
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Fund’s investments and, therefore, no
conflicts of interest could arise between
such Regulated Fund and its respective
Wholly-Owned Investment Subsidiaries.
The Board of the Regulated Fund would
make all relevant determinations under
the conditions with regard to a WhollyOwned Investment Subsidiary’s
participation in a Co-Investment
Transaction, and the Board would be
informed of, and take into
consideration, any proposed use of a
Wholly-Owned Investment Subsidiary
in place of the Regulated Fund. If a
Regulated Fund proposes to participate
in the same Co-Investment Transaction
with any of its Wholly-Owned
Investment Subsidiaries, its Board will
also be informed of, and take into
consideration, the relative participation
of the Regulated Fund and the WhollyOwned Investment Subsidiary.
12. When considering Potential CoInvestment Transactions for any
Regulated Fund, an Adviser will
consider only the Objectives and
Strategies,6 investment policies,
investment positions, capital available
for investment,7 and other pertinent
factors applicable to that Regulated
Fund. Each Adviser, as applicable,
undertakes to perform these duties
consistently for each Regulated Fund, as
applicable, regardless of which of them
serves as investment adviser to these
entities. The participation of a
Regulated Fund in a Potential CoInvestment Transaction may only be
approved by a Required Majority, as
defined in section 57(o) of the Act (a
‘‘Required Majority’’), of the directors of
the Board eligible to vote on that CoInvestment Transaction under section
57(o) (the ‘‘Eligible Directors’’).8 Due to
the similarity in Objectives and
Strategies of certain Regulated Funds
with the investment objectives, policies
and strategies of certain Affiliated
Funds, the Adviser expects that
investments for a Regulated Fund
should also generally be appropriate
6 The term ‘‘Objectives and Strategies’’ means a
Regulated Fund’s investment objectives and
strategies as described in the Regulated Fund’s
registration statement, other filings the Regulated
Fund has made with the Commission under the
Securities Act of 1933 (the ‘‘1933 Act’’) or the
Securities Exchange Act of 1934, and the Regulated
Fund’s reports to shareholders.
7 Capital available for investment will be
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
Fund or imposed by applicable laws, rules, or
regulations or interpretations.
8 Although each Regulated Fund will be a
registered closed-end fund, the Board members that
make up the Required Majority will be determined
as if the Regulated Fund were a BDC subject to
Section 57(o) of the Act.
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investments for one or more other
Regulated Funds and/or one or more
Affiliated Funds, with certain
exceptions based on available capital,
diversification, investment objectives,
policies and strategies.9
13. With respect to participation in a
Potential Co-Investment Transaction by
a Regulated Fund, the applicable
Adviser will present each Potential CoInvestment Transaction and the
proposed allocation of each investment
opportunity to the Eligible Directors.
The Required Majority of a Regulated
Fund will approve each Co-Investment
Transaction prior to any investment by
the Regulated Fund.
14. With respect to the pro rata
dispositions and Follow-On
Investments 10 provided in conditions 7
and 8, a Regulated Fund 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 Affiliated Fund
and Regulated Fund in such disposition
or Follow-On Investment is
proportionate to its outstanding
investments in the issuer immediately
preceding the disposition or Follow-On
Investment, as the case may be; and (ii)
the applicable Board has approved such
Regulated Fund’s participation in pro
rata dispositions and Follow-On
Investments as being in the best
interests of such Regulated Fund. If the
Board of the applicable Regulated Fund
does not so approve, any such
disposition or Follow-On Investment
will be submitted to the Eligible
Directors. The Board of any Regulated
Fund may at any time rescind, suspend
or qualify their respective approval of
pro rata dispositions and Follow-On
Investments with the result that all
dispositions and/or Follow-On
Investments must be submitted to the
Eligible Directors.
15. No Non-Interested Director of a
Regulated Fund will have a financial
interest in any Co-Investment
Transaction, other than through an
interest in the securities of a Regulated
Fund.
16. Applicants represent that if an
Adviser or its principal owners (the
‘‘Principals’’), or any person controlling,
controlled by, or under common control
9 A Regulated Fund, however, will not be
obligated to invest, or co-invest, when investment
opportunities are referred to them.
10 ‘‘Follow-On Investment’’ means any additional
investment in an existing portfolio company whose
securities were acquired in a Co-Investment
Transaction, including the exercise of warrants,
conversion privileges or other similar rights to
acquire additional securities of the portfolio
company.
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with an Adviser or the Principals, and
the Affiliated Funds (collectively, the
‘‘Holders’’) own in the aggregate more
than 25% of the outstanding voting
securities of a Regulated Fund
(‘‘Shares’’), then the Holders will vote
such Shares as required under condition
14. Applicants believe that this
condition will ensure that the NonInterested Directors will act
independently in evaluating the CoInvestment Program, because the ability
of an Adviser or the Principals to
influence the Non-Interested Directors
by a suggestion, explicit or implied, that
the Non-Interested Directors can be
removed will be limited significantly.
The Non-Interested Directors shall
evaluate and approve any such
independent third party, taking into
account its qualifications, reputation for
independence, cost to the shareholders,
and other factors they deem relevant.
17. As discussed in more detail in the
application, all of Applicants’
investment activities are conducted
within a global, centralized investment
committee and allocation process and
overseen by a unified, global
compliance program. Applicants
represent that the global processes and
compliance program would ensure that
(a) the Commission and its staff have
complete transparency into the CoInvestment Program and the Advisers
involved with the Co-Investment
Program through its access to Partners
Group and (b) the Co-Investment
Program would be subject to
Commission and staff oversight.
Applicants acknowledge that this global
compliance program will be a key
element in ensuring that the proposed
Co-Investment Transactions are
consistent with the protection of each
Regulated Fund’s shareholders and with
the purposes intended by the policies
and provisions of the Act.
Applicants’ Legal Analysis
1. Section 17(d) of the Act and rule
17d–1 under the Act prohibit affiliated
persons of a registered investment
company from participating in joint
transactions with the company unless
the Commission has granted an order
permitting such transactions. In passing
upon applications under rule 17d–1, the
Commission will consider whether the
participation by the Regulated Fund in
such 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.
2. Applicants state that the CoInvestment Program will increase
favorable investment opportunities for
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the Regulated Funds and allow the
Regulated Funds to participate in
attractive opportunities at levels that are
appropriate. The conditions are
designed to ensure that the Advisors
would not be able to favor any
Regulated Fund or Affiliated Funds over
other Regulated Funds through the
allocation of investment opportunities
among them. Applicants state that the
Regulated Fund’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’ Conditions
Applicants agree that any Order
granting the requested relief will be
subject to the following conditions:
1. Each time an Adviser considers a
Potential Co-Investment Transaction for
an Affiliated Fund or another Regulated
Fund that falls within a Regulated
Fund’s then-current Objectives and
Strategies, the Regulated Fund’s Adviser
will make an independent
determination of the appropriateness of
the investment for such Regulated Fund
in light of the Regulated Fund’s thencurrent circumstances.
2. (a) If the Adviser deems a Regulated
Fund’s participation in any Potential
Co-Investment Transaction to be
appropriate for the Regulated Fund, it
will then determine an appropriate level
of investment for the Regulated Fund.
(b) If the aggregate amount
recommended by the applicable Adviser
to be invested by the applicable
Regulated Fund in the Potential CoInvestment Transaction, together with
the amount proposed to be invested by
the other participating Regulated Funds
and Affiliated Funds, collectively, in the
same transaction, exceeds the amount of
the investment opportunity, the
investment opportunity will be
allocated among them pro rata based on
each participant’s ‘‘capital available for
investment’’ in the asset class being
allocated, up to the amount proposed to
be invested by each. The applicable
Adviser will provide the Eligible
Directors of each participating
Regulated Fund with information
concerning each participating party’s
available capital to assist the Eligible
Directors with their review of the
Regulated Fund’s investments for
compliance with these allocation
procedures.
(c) After making the determinations
required in conditions 1 and 2(a), the
applicable Adviser will distribute
written information concerning the
Potential Co-Investment Transaction
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26557
(including the amount proposed to be
invested by each participating Regulated
Fund and Affiliated Fund) to the
Eligible Directors of each participating
Regulated Fund for their consideration.
A Regulated Fund will co-invest with
one or more other Regulated Funds and/
or one or more Affiliated Funds only if,
prior to the Regulated Fund’s
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 Fund and its
shareholders and do not involve
overreaching in respect of the Regulated
Fund or its shareholders on the part of
any person concerned;
(ii) the Potential Co-Investment
Transaction is consistent with:
(A) the interests of the shareholders of
the Regulated Fund; and
(B) the Regulated Funds then-current
Objectives and Strategies;
(iii) the investment by any other
Regulated Funds or Affiliated Funds
would not disadvantage the Regulated
Fund, and participation by the
Regulated Fund would not be on a basis
different from or less advantageous than
that of other Regulated Funds or
Affiliated Funds; provided that, if any
other Regulated Fund, Affiliated Fund
or Adviser, but not the Regulated Fund
itself, gains the right to nominate a
director for election to a portfolio
company’s board of directors, 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 the Required Majority from
reaching the conclusions required by
this condition (2)(c)(iii), if:
(A) The Eligible Directors will have
the right to ratify the selection of such
director, board observer or participant,
if any;
(B) the applicable Adviser agrees to,
and does, provide periodic reports to
the Regulated Fund’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 Affiliated Fund or any
Regulated Fund or any affiliated person
of any Affiliated Fund or any Regulated
Fund receives in connection with the
right of an Affiliated Fund or a
Regulated Fund to nominate a director
or appoint a board observer or otherwise
to participate in the governance or
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management of the portfolio company
will be shared proportionately among
the participating Affiliated Funds (who
each may, in turn, share its portion with
its affiliated persons) and the
participating Regulated Funds in
accordance with the amount of each
party’s investment; and
(iv) the proposed investment by the
Regulated Fund will not benefit the
Advisers, the Affiliated Funds or the
other Regulated Funds or any affiliated
person of any of them (other than the
parties to the Co-Investment
Transaction), except
(A) to the extent permitted by
condition 13;
(B) to the extent permitted by section
17(e) of the Act;
(C) indirectly, as a result of an interest
in the securities issued by one of the
parties to the Co-Investment
Transaction; or
(D) in the case of fees or other
compensation described in condition
2(c)(iii)(C).
3. Each Regulated Fund has the right
to decline to participate in any Potential
Co-Investment Transaction or to invest
less than the amount proposed.
4. The applicable Adviser will present
to the Board of each Regulated Fund, on
a quarterly basis, a record of all
investments in Potential Co-Investment
Transactions made by any of the other
Regulated Funds or Affiliated Funds
during the preceding quarter that fell
within the Regulated Fund’s thencurrent Objectives and Strategies that
were not made available to the
Regulated Fund, and an explanation of
why the investment opportunities were
not offered to the Regulated Fund. All
information presented to the Board
pursuant to this condition will be kept
for the life of the Regulated Fund 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 8,11
a Regulated Fund will not invest in
reliance on the Order in any issuer in
which another Regulated Fund,
Affiliated Fund or any affiliated person
of another Regulated Fund or Affiliated
Fund is an existing investor.
6. A Regulated Fund 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
identical for each participating
11 This exception applies only to Follow-On
Investments by a Regulated Fund in issuers in
which that Regulated Fund already holds
investments.
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16:37 Jun 06, 2017
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Regulated Fund and Affiliated Fund.
The grant to an Affiliated Fund or
another Regulated Fund, but not the
Regulated Fund, 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 a
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 Affiliated Fund or any
Regulated Fund elects to sell, exchange
or otherwise dispose of an interest in a
security that was acquired in a CoInvestment Transaction, the applicable
Adviser will:
(i) Notify each Regulated Fund 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 Fund in
the disposition.
(b) Each Regulated Fund 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
participating Affiliated Funds and
Regulated Funds.
(c) A Regulated Fund may participate
in such disposition without obtaining
prior approval of the Required Majority
if: (i) The proposed participation of each
Regulated Fund and each Affiliated
Fund in such disposition is
proportionate to its outstanding
investments in the issuer immediately
preceding the disposition; (ii) the Board
of the Regulated Fund has approved as
being in the best interests of the
Regulated Fund the ability to participate
in such dispositions on a pro rata basis
(as described in greater detail in this
Application); and (iii) the Board of the
Regulated Fund is provided on a
quarterly basis with a list of all
dispositions made in accordance with
this condition. In all other cases, the
Adviser will provide its written
recommendation as to the Regulated
Fund’s participation to the Eligible
Directors, and the Regulated Fund will
participate in such disposition solely to
the extent that a Required Majority
determines that it is in the Regulated
Fund’s best interests.
(d) Each Affiliated Fund and each
Regulated Fund will bear its own
expenses in connection with any such
disposition.
8. (a) If any Affiliated Fund or any
Regulated Fund desires to make a
Follow-On Investment in a portfolio
company whose securities were
acquired in a Co-Investment
PO 00000
Frm 00136
Fmt 4703
Sfmt 4703
Transaction, the applicable Adviser
will:
(i) Notify each Regulated Fund that
participated in the Co-Investment
Transaction of the proposed transaction
at the earliest practical time; and
(ii) formulate a recommendation as to
the proposed participation, including
the amount of the proposed Follow-On
Investment, by each Regulated Fund.
(b) A Regulated Fund may participate
in such Follow-On Investment without
obtaining prior approval of the Required
Majority if: (i) The proposed
participation of each Regulated Fund
and each Affiliated Fund in such
investment is proportionate to its
outstanding investments in the issuer
immediately preceding the Follow-On
Investment; and (ii) the Board of the
Regulated Fund has approved as being
in the best interests of the Regulated
Fund the ability to participate in
Follow-On Investments on a pro rata
basis (as described in greater detail in
this application). In all other cases, the
Adviser will provide its written
recommendation as to the Regulated
Fund’s participation to the Eligible
Directors, and the Regulated Fund will
participate in such Follow-On
Investment solely to the extent that a
Required Majority determines that it is
in the Regulated Fund’s best interests.
(c) If, with respect to any Follow-On
Investment:
(i) The amount of the opportunity is
not based on the Regulated Funds’ and
the Affiliated Funds’ outstanding
investments immediately preceding the
Follow-On Investment; and
(ii) the aggregate amount
recommended by the Adviser to be
invested by each Regulated Fund in the
Follow-On Investment, together with
the amount proposed to be invested by
the participating Affiliated Funds 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 ‘‘capital available for
investment’’ in the asset class being
allocated, up to the amount proposed to
be invested by each.
(d) The acquisition of Follow-On
Investments as permitted by this
condition will be considered a CoInvestment Transaction for all purposes
and subject to the other conditions set
forth in the application.
9. Each Regulated Fund will maintain
the records required by Section 57(f)(3)
of the Act as if each of the Regulated
Funds was a business development
company and each of the investments
permitted under these conditions was
approved by the Required Majority
under Section 57(f).
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10. The Non-Interested Directors of
each Regulated Fund will be provided
quarterly for review all information
concerning Potential Co-Investment
Transactions and Co-Investment
Transactions, including investments
made by other Regulated Funds or
Affiliated Funds that the Regulated
Fund considered but declined to
participate in, so that the Non-Interested
Directors may determine whether all
investments made during the preceding
quarter, including those investments
that the Regulated Fund considered but
declined to participate in, comply with
the conditions of the Order. In addition,
the Non-Interested Directors will
consider at least annually the continued
appropriateness for the Regulated Fund
of participating in new and existing CoInvestment Transactions.
11. No Non-Interested Director of a
Regulated Fund will also be a director,
general partner, managing member or
principal, or otherwise an ‘‘affiliated
person’’ (as defined in the Act) of any
of the Affiliated Funds.
12. The expenses, if any, associated
with acquiring, holding or disposing of
any securities acquired in a CoInvestment Transaction (including,
without limitation, the expenses of the
distribution of any such securities
registered for sale under the 1933 Act)
will, to the extent not payable by the
Adviser under its respective investment
advisory agreements with Affiliated
Funds and the Regulated Funds, be
shared by the Regulated Funds and the
Affiliated Funds 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,
without limitation, break-up or
commitment fees but excluding broker’s
fees contemplated by Section 17(e) of
the Act) received in connection with a
Co-Investment Transaction will be
distributed to the participating
Regulated Funds and Affiliated Funds
(who may, in turn, share their portion
with affiliated persons) on a pro rata
basis based on the amounts they
invested or committed, as the case may
be, in such Co-Investment Transaction.
If any transaction fee is to be held by the
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 Funds and
Affiliated Funds based on the amounts
they invest in such Co-Investment
Transaction. None of the Affiliated
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26559
Funds, the Adviser, the other Regulated
Funds or any affiliated person of the
Regulated Funds or Affiliated Funds
will receive additional compensation or
remuneration of any kind as a result of
or in connection with a Co-Investment
Transaction (other than (a) in the case
of the Regulated Funds and the
Affiliated Funds, the pro rata
transaction fees described above and
fees or other compensation described in
condition 2(c)(iii)(C); and (b) in the case
of the Adviser, investment advisory fees
paid in accordance with the agreement
between the Adviser and the Regulated
Fund or Affiliated Fund).
14. If the Holders own in the aggregate
more than 25% of the Shares, then the
Holders will vote such Shares as
directed by an independent third party
when voting on (1) the election of
directors; (2) the removal of one or more
directors; or (3) all other matters under
either the Act or applicable state law
affecting the Board’s composition, size
or manner of election.
15. Each Regulated Fund’s chief
compliance officer, as defined in rule
38a–1(a)(4) of the Act, will prepare an
annual report for its Board each year
that evaluates (and documents the basis
of that evaluation) the Regulated Fund’s
compliance with the terms and
conditions of the application and the
procedures established to achieve such
compliance.
change as described in Items I and II
below, which Items have been prepared
by the Exchange. The Exchange has
designated this proposal as a ‘‘noncontroversial’’ proposed rule change
pursuant to Section 19(b)(3)(A) of the
Act 3 and Rule 19b–4(f)(6) thereunder,4
which renders it effective upon filing
with the Commission. The Commission
is publishing this notice to solicit
comments on the proposed rule change
from interested persons.
For the Commission, by the Division of
Investment Management, under delegated
authority.
Eduardo A. Aleman,
Assistant Secretary.
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 parts of such
statements.
[FR Doc. 2017–11728 Filed 6–6–17; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–80841; File No. SR–
BatsEDGX–2017–25]
Self-Regulatory Organizations; Bats
EDGX Exchange, Inc.; Notice of Filing
and Immediate Effectiveness of a
Proposed Rule Change To Add a New
Optional Order Instruction Known as
Non-Displayed Swap
June 1, 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 May 26,
2017, Bats EDGX Exchange, Inc.
(‘‘Exchange’’ or ‘‘EDGX’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
1 15
2 17
PO 00000
U.S.C. 78s(b)(1).
CFR 240.19b–4.
Frm 00137
Fmt 4703
I. Self-Regulatory Organization’s
Statement of the Terms of the Substance
of the Proposed Rule Change
The Exchange filed a proposal to: (i)
Amend paragraph (n) of Exchange Rule
11.6, Routing/Posting Instructions to
add a new optional order instruction to
be known as Non-Displayed Swap; and
(ii) make a related change to description
of Limit Orders and MidPoint Peg
Orders under Exchange Rule 11.8.
The text of the proposed rule change
is available at the Exchange’s Web site
at www.bats.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
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to: (i) Amend
paragraph (n) of Exchange Rule 11.6,
Routing/Posting Instructions to add a
new optional order instruction to be
known as Non-Displayed Swap; and (ii)
make a related change to description of
Limit Orders and MidPoint Peg Orders
under Exchange Rule 11.8. The
proposed amendments are substantially
similar to the rules of the Nasdaq Stock
3 15
4 17
Sfmt 4703
E:\FR\FM\07JNN1.SGM
U.S.C. 78s(b)(3)(A).
CFR 240.19b–4(f)(6).
07JNN1
Agencies
[Federal Register Volume 82, Number 108 (Wednesday, June 7, 2017)]
[Notices]
[Pages 26554-26559]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-11728]
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SECURITIES AND EXCHANGE COMMISSION
[Investment Company Release Act No. 32667; 812-14193-01]
Partners Group (USA) Inc., et al.
DATE: June 1, 2017.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Notice.
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Notice of application for an order under section 17(d) of the
Investment Company Act of 1940 (the ``Act'') and rule 17d-1 under the
Act to permit certain joint transactions otherwise prohibited by
section 17(d) of the Act and rule 17d-1 under the Act.
SUMMARY OF APPLICATION: Applicants request an order to permit certain
closed-end management investment companies to co-invest in portfolio
companies with each other and with affiliated investment funds.
APPLICANTS: Partners Group Private Equity (Master Fund), LLC (the
``Fund''); Partners Group Private Income Opportunities, LLC (``Partners
Group Private Income Opportunities''); Partners Group (USA) Inc.
(``Partners Group''); Partners Group AG (``Partners Group AG'');
Partners Group (UK) Limited (``Partners Group UK''); Partners Group
(Luxembourg) S.A. (``Partners Group Lux''); Partners Group (Guernsey)
Limited (``Partners Group Guernsey''); Partners Group Cayman Management
I Limited (``PGCM I''); Partners Group Cayman Management III Limited
(``PGCM III''); Partners Group Management Limited (``PGML''); Partners
Group Management I S.[agrave] r.l. (``PGMS I''); Partners Group
Management II Limited (``PGML II''); Partners Group Management III
S.[agrave] r.l. (``PGMS III''); Partners Group Management IX Limited
(``PGML IX''); Partners Group Management V Limited (``PGML V'');
Partners Group Management VII Limited (``PGML VII''); Partners Group
Management VIII Limited (``PGML VIII''); Partners Group Management XI
Limited (``PGML XI''); Partners Group Management XIII Limited (``PGML
XIII''); Princess Management Limited (``Princess'' and collectively
with Partners Group Guernsey, Partners Group UK, PGCM I, PGCM III,
PGML, PGMS I, PGML II, PGMS III, PGML IX, PGML V, PGML VII, PGML VIII,
PGML XI and PGML XIII, the ``General Partner Advisers''); and Partners
Group (Italy) Global Value 2014; Partners Group Direct Equity 2016
(EUR) G, L.P. Inc.; Partners Group Direct Equity 2016 (EUR) S.C.A.,
SICAV-SIF; Partners Group Direct Equity 2016 (EUR), L.P. Inc.; Partners
Group Direct Equity 2016 (USD) A, L.P.; Partners Group Direct Equity
2016 (USD) C, L.P.; Partners Group Direct Equity 2016 (USD) C-G, L.P.;
Partners Group Direct Equity 2016 (USD) C-I, L.P.; Partners Group
Direct Infrastructure 2015 (EUR) S.C.A., SICAV-SIF; Partners Group
Direct Infrastructure 2015 (USD), L.P. Inc.; Partners Group Direct
Infrastructure 2016 (USD) A, L.P.; Partners Group Emerging Markets
2015, L.P. Inc.; Partners Group Generations Fund I; Partners Group
Global Growth 2014, L.P. Inc.; Partners Group Global Infrastructure
2012, L.P. Inc.; Partners Group Global Infrastructure 2015 (EUR)
S.C.A., SICAV-SIF; Partners Group Global Infrastructure 2015 (EUR),
L.P. Inc.; Partners Group Global Infrastructure SICAV; Partners Group
Global Multi-Asset Fund; Partners
[[Page 26555]]
Group Global Value 2014 (EUR) S.C.A., SICAR; Partners Group Global
Value 2014, L.P. Inc.; Partners Group Global Value SICAV; Partners
Group Growth Strategies 2016 S.C.A., SICAV-RAIF; Partners Group Private
Equity Performance Holding Limited; Partners Group Secondary 2015 (EUR)
S.C.A., SICAV-SIF; Partners Group Secondary 2015 (EUR), L.P. Inc.;
Partners Group Secondary 2015 (USD) A, L.P.; Partners Group Secondary
2015 (USD) C, L.P.; Partners Group U.S. Private Equity 2015 L.P.
S.C.S., SICAV-SIF; Princess Private Equity Holding Limited; The
Partners Fund SICAV and The Partners Fund (the ``Existing Affiliated
Funds'').
FILING DATES: The application was filed on August 2, 2013, and amended
on August 11, 2014, January 13, 2016, May 4, 2017, and June 1, 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 26, 2017, and should be accompanied by proof of
service on applicants, in the form of an affidavit or, for lawyers, a
certificate of service. Pursuant to rule 0-5 under the Act, hearing
requests should state the nature of the writer's interest, any facts
bearing upon the desirability of a hearing on the matter, the reason
for the request, and the issues contested. Persons who wish to be
notified of a hearing may request notification by writing to the
Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
St. NE., Washington, DC 20549-1090. Applicants: 1114 Avenue of the
Americas, 37th Floor, New York, NY 10036.
FOR FURTHER INFORMATION CONTACT: Robert Shapiro, 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 \1\ is a Delaware limited liability company that is
registered as a closed-end management investment company under the Act.
The Fund's investment objective is to seek attractive long-term capital
appreciation by investing in a globally diversified portfolio of
private equity investments. The board of directors of the Fund (the
``Fund Board'') is currently comprised of three managers, two of whom
are not ``interested persons,'' within the meaning of Section 2(a)(19)
of the Act (the ``Non-Interested Directors''), of the Fund.
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\1\ The Fund, Partners Group Private Income Opportunities, and
any Future Regulated Fund are referred to individually as a
``Regulated Fund,'' and collectively as the ``Regulated Funds.''
``Future Regulated Fund'' means any closed-end management investment
company (a) that is registered under the Act, (b) whose investment
adviser is an Adviser (defined below) that is registered as an
investment adviser under the Investment Advisers Act of 1940, as
amended (the ``Advisers Act''), and (c) that intends to participate
in the Co-Investment Program. The term ``Adviser'' means (a)
Partners Group, Partners Group AG, Partners Group UK, Partners Group
Lux and each General Partner Adviser, and (b) any future investment
adviser that controls, is controlled by or is under common control
with Partners Group, Partners Group AG, Partners Group UK, Partners
Group Lux or any General Partner Adviser and is either registered as
an investment adviser under the Advisers Act or is an exempt
reporting adviser or a foreign private adviser.
---------------------------------------------------------------------------
2. Partners Group Private Income Opportunities is a Delaware
limited liability company that is registered as a closed-end management
investment company under the Act. Partners Group Private Income
Opportunities' investment objective will be to generate attractive
risk-adjusted returns and current income by investing in a diversified
portfolio of predominantly credit-related opportunities. The board of
managers of Partners Group Private Income Opportunities (the ``PGPIO
Board'') \2\ is currently comprised of five managers, four of whom are
Non-Interested Directors of Partners Group Private Income
Opportunities.
---------------------------------------------------------------------------
\2\ The Fund Board, the PGPIO Board and any board of managers,
board of directors or board of trustees of a Future Regulated Fund
are each referred to herein as a ``Board'' and collectively the
``Boards,'' as applicable.
---------------------------------------------------------------------------
3. Each of the Existing Affiliated Funds would be an investment
company but for section 3(c)(1) or 3(c)(7) of the Act.
4. Partners Group is a Delaware corporation and an investment
adviser registered with the Commission under the Investment Advisers
Act of 1940, as amended (the ``Advisers Act''). Partners Group serves
as investment adviser to the Fund and Partners Group Private Income
Opportunities. Partners Group is a wholly-owned subsidiary of Partners
Group Holding AG, a corporation organized in Switzerland.
5. Partners Group AG is a corporation organized in Switzerland and
is an exempt reporting adviser under the Advisers Act. Partners Group
AG is registered with the Swiss Financial Markets Authority (FINMA) and
provides investment recommendations to Partners Group with respect to
its clients' portfolios. While Partners Group AG may provide investment
recommendations to Partners Group, Partners Group maintains ultimate
investment discretion as to whether such recommendations will translate
into investments made by its clients.
6. Partners Group Guernsey is a company limited by shares organized
in Guernsey and is an exempt reporting adviser under the Advisers Act.
Partners Group Guernsey is registered with the Guernsey Financial
Services Commission (GFSC) and provides administrative and in
particular investment execution services to Partners Group with respect
to its clients. Partners Group Guernsey also serves as General Partner
Adviser to Affiliated Funds.
7. Partners Group UK is a foreign private adviser under the
Advisers Act, formed as a private limited company in the United
Kingdom. Partners Group UK is registered with the UK Financial Conduct
Authority (FCA) and provides investment management or advisory services
to certain Affiliated Funds.
8. Partners Group Lux is an exempt reporting adviser under the
Advisers Act, formed as a soci[eacute]t[eacute] anonyme in Luxembourg.
Partners Group Lux is registered with the Luxembourg Commission de
Surveillance du Secteur Financier (CSSF) and provides administrative,
domiciliary, depositary and/or investment management or advisory
services to certain Affiliated Funds.
9. As described more fully in the application, each General Partner
Adviser serves as the general partner or fund manager of one or more
Affiliated Funds. Investment decisions are made by affiliated
investment committees and the respective General Partner signs-off or
otherwise ratifies such decisions. Other than Partners Group UK, each
General Partner Adviser is an exempt reporting adviser.
10. Applicants seek an order (``Order'') to permit one or more
Regulated Funds and/or one or more Affiliated Funds \3\ to participate
in the
[[Page 26556]]
same investment opportunities through a proposed co-investment program
where such participation would otherwise be prohibited under section
17(d) and the rules under the Act (the ``Co-Investment Program'').\4\ A
``Co-Investment Transaction'' means any transaction in which a
Regulated Fund (or its Wholly-Owned Investment Subsidiary, as defined
below) participated together with one or more other Regulated Funds
and/or one or more Affiliated Funds in reliance on the Order. A
``Potential Co-Investment Transaction'' means any investment
opportunity in which a Regulated Fund (or its Wholly-Owned Investment
Subsidiary, as defined below) could not participate together with one
or more Regulated Funds and/or one or more Affiliated Funds without
obtaining and relying on the Order.
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\3\ The term ``Affiliated Fund'' means any of the Existing
Affiliated Funds and any Future Affiliated Fund. ``Future Affiliated
Fund'' means an entity (a) whose investment adviser is an Adviser
and (b) that would be an investment company but for section 3(c)(1)
or 3(c)(7) of the Act, and (iii) that intends to participate in the
Co-Investment Program.
\4\ All existing entities that currently intend to rely upon the
requested Order have been named as applicants. Any other existing or
future entity that relies on the Order in the future will comply
with the terms and conditions of the application.
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11. Applicants state that a Regulated Fund may, from time to time,
form one or more Wholly-Owned Investment Subsidiaries.\5\ A Wholly-
Owned Investment Subsidiary would be prohibited from investing in a Co-
Investment Transaction with another Regulated Fund or any Affiliated
Fund because it would be a company controlled by the applicable
Regulated Fund for purposes of sections 17(d) and rule 17d-1.
Applicants request that a Wholly-Owned Investment Subsidiary be
permitted to participate in Co-Investment Transactions in lieu of the
applicable Regulated Fund, and that such Wholly-Owned Investment
Subsidiary's participation in any such transaction be treated, for
purposes of the requested Order, as though the Regulated Fund 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
Fund's investments and, therefore, no conflicts of interest could arise
between such Regulated Fund and its respective Wholly-Owned Investment
Subsidiaries. The Board of the Regulated Fund 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 Board would be informed of, and take into consideration, any
proposed use of a Wholly-Owned Investment Subsidiary in place of the
Regulated Fund. If a Regulated Fund proposes to participate in the same
Co-Investment Transaction with any of its Wholly-Owned Investment
Subsidiaries, its Board will also be informed of, and take into
consideration, the relative participation of the Regulated Fund and the
Wholly-Owned Investment Subsidiary.
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\5\ The term ``Wholly-Owned Investment Subsidiary'' means an
entity (a) whose sole business purpose is to hold one or more
investments on behalf of a Regulated Fund; (b) that is wholly-owned
by a Regulated Fund (with such Regulated Fund at all times holding,
beneficially and of record, 100% of the voting and economic
interests); (c) with respect to which the Board of the Regulated
Fund has the sole authority to make all determinations with respect
to the Wholly-Owned Investment Subsidiary's participation under the
conditions of the application; and (d) that is and entity that would
be an investment company but for section 3(c)(1) or 3(c)(7) of the
Act.
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12. When considering Potential Co-Investment Transactions for any
Regulated Fund, an Adviser will consider only the Objectives and
Strategies,\6\ investment policies, investment positions, capital
available for investment,\7\ and other pertinent factors applicable to
that Regulated Fund. Each Adviser, as applicable, undertakes to perform
these duties consistently for each Regulated Fund, as applicable,
regardless of which of them serves as investment adviser to these
entities. The participation of a Regulated Fund in a Potential Co-
Investment Transaction may only be approved by a Required Majority, as
defined in section 57(o) of the Act (a ``Required Majority''), of the
directors of the Board eligible to vote on that Co-Investment
Transaction under section 57(o) (the ``Eligible Directors'').\8\ Due to
the similarity in Objectives and Strategies of certain Regulated Funds
with the investment objectives, policies and strategies of certain
Affiliated Funds, the Adviser expects that investments for a Regulated
Fund should also generally be appropriate investments for one or more
other Regulated Funds and/or one or more Affiliated Funds, with certain
exceptions based on available capital, diversification, investment
objectives, policies and strategies.\9\
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\6\ The term ``Objectives and Strategies'' means a Regulated
Fund's investment objectives and strategies as described in the
Regulated Fund's registration statement, other filings the Regulated
Fund has made with the Commission under the Securities Act of 1933
(the ``1933 Act'') or the Securities Exchange Act of 1934, and the
Regulated Fund's reports to shareholders.
\7\ Capital available for investment will be 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 Fund or imposed by applicable
laws, rules, or regulations or interpretations.
\8\ Although each Regulated Fund will be a registered closed-end
fund, the Board members that make up the Required Majority will be
determined as if the Regulated Fund were a BDC subject to Section
57(o) of the Act.
\9\ A Regulated Fund, however, will not be obligated to invest,
or co-invest, when investment opportunities are referred to them.
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13. With respect to participation in a Potential Co-Investment
Transaction by a Regulated Fund, the applicable Adviser will present
each Potential Co-Investment Transaction and the proposed allocation of
each investment opportunity to the Eligible Directors. The Required
Majority of a Regulated Fund will approve each Co-Investment
Transaction prior to any investment by the Regulated Fund.
14. With respect to the pro rata dispositions and Follow-On
Investments \10\ provided in conditions 7 and 8, a Regulated Fund 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 Affiliated Fund and
Regulated Fund in such disposition or Follow-On Investment is
proportionate to its outstanding investments in the issuer immediately
preceding the disposition or Follow-On Investment, as the case may be;
and (ii) the applicable Board has approved such Regulated Fund's
participation in pro rata dispositions and Follow-On Investments as
being in the best interests of such Regulated Fund. If the Board of the
applicable Regulated Fund does not so approve, any such disposition or
Follow-On Investment will be submitted to the Eligible Directors. The
Board of any Regulated Fund may at any time rescind, suspend or qualify
their respective approval of pro rata dispositions and Follow-On
Investments with the result that all dispositions and/or Follow-On
Investments must be submitted to the Eligible Directors.
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\10\ ``Follow-On Investment'' means any additional investment in
an existing portfolio company whose securities were acquired in a
Co-Investment Transaction, including the exercise of warrants,
conversion privileges or other similar rights to acquire additional
securities of the portfolio company.
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15. No Non-Interested Director of a Regulated Fund will have a
financial interest in any Co-Investment Transaction, other than through
an interest in the securities of a Regulated Fund.
16. Applicants represent that if an Adviser or its principal owners
(the ``Principals''), or any person controlling, controlled by, or
under common control
[[Page 26557]]
with an Adviser or the Principals, and the Affiliated Funds
(collectively, the ``Holders'') own in the aggregate more than 25% of
the outstanding voting securities of a Regulated Fund (``Shares''),
then the Holders will vote such Shares as required under condition 14.
Applicants believe that this condition will ensure that the Non-
Interested Directors will act independently in evaluating the Co-
Investment Program, because the ability of an Adviser or the Principals
to influence the Non-Interested Directors by a suggestion, explicit or
implied, that the Non-Interested Directors can be removed will be
limited significantly. The Non-Interested Directors shall evaluate and
approve any such independent third party, taking into account its
qualifications, reputation for independence, cost to the shareholders,
and other factors they deem relevant.
17. As discussed in more detail in the application, all of
Applicants' investment activities are conducted within a global,
centralized investment committee and allocation process and overseen by
a unified, global compliance program. Applicants represent that the
global processes and compliance program would ensure that (a) the
Commission and its staff have complete transparency into the Co-
Investment Program and the Advisers involved with the Co-Investment
Program through its access to Partners Group and (b) the Co-Investment
Program would be subject to Commission and staff oversight. Applicants
acknowledge that this global compliance program will be a key element
in ensuring that the proposed Co-Investment Transactions are consistent
with the protection of each Regulated Fund's shareholders and with the
purposes intended by the policies and provisions of the Act.
Applicants' Legal Analysis
1. Section 17(d) of the Act and rule 17d-1 under the Act prohibit
affiliated persons of a registered investment company from
participating in joint transactions with the company unless the
Commission has granted an order permitting such transactions. In
passing upon applications under rule 17d-1, the Commission will
consider whether the participation by the Regulated Fund in such 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.
2. Applicants state that the Co-Investment Program will increase
favorable investment opportunities for the Regulated Funds and allow
the Regulated Funds to participate in attractive opportunities at
levels that are appropriate. The conditions are designed to ensure that
the Advisors would not be able to favor any Regulated Fund or
Affiliated Funds over other Regulated Funds through the allocation of
investment opportunities among them. Applicants state that the
Regulated Fund'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' Conditions
Applicants agree that any Order granting the requested relief will
be subject to the following conditions:
1. Each time an Adviser considers a Potential Co-Investment
Transaction for an Affiliated Fund or another Regulated Fund that falls
within a Regulated Fund's then-current Objectives and Strategies, the
Regulated Fund's Adviser will make an independent determination of the
appropriateness of the investment for such Regulated Fund in light of
the Regulated Fund's then-current circumstances.
2. (a) If the Adviser deems a Regulated Fund's participation in any
Potential Co-Investment Transaction to be appropriate for the Regulated
Fund, it will then determine an appropriate level of investment for the
Regulated Fund.
(b) If the aggregate amount recommended by the applicable Adviser
to be invested by the applicable Regulated Fund in the Potential Co-
Investment Transaction, together with the amount proposed to be
invested by the other participating Regulated Funds and Affiliated
Funds, collectively, in the same transaction, exceeds the amount of the
investment opportunity, the investment opportunity will be allocated
among them pro rata based on each participant's ``capital available for
investment'' in the asset class being allocated, up to the amount
proposed to be invested by each. The applicable Adviser will provide
the Eligible Directors of each participating Regulated Fund with
information concerning each participating party's available capital to
assist the Eligible Directors with their review of the Regulated Fund's
investments for compliance with these allocation procedures.
(c) After making the determinations required in conditions 1 and
2(a), the applicable Adviser will distribute written information
concerning the Potential Co-Investment Transaction (including the
amount proposed to be invested by each participating Regulated Fund and
Affiliated Fund) to the Eligible Directors of each participating
Regulated Fund for their consideration. A Regulated Fund will co-invest
with one or more other Regulated Funds and/or one or more Affiliated
Funds only if, prior to the Regulated Fund's 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
Fund and its shareholders and do not involve overreaching in respect of
the Regulated Fund or its shareholders on the part of any person
concerned;
(ii) the Potential Co-Investment Transaction is consistent with:
(A) the interests of the shareholders of the Regulated Fund; and
(B) the Regulated Funds then-current Objectives and Strategies;
(iii) the investment by any other Regulated Funds or Affiliated
Funds would not disadvantage the Regulated Fund, and participation by
the Regulated Fund would not be on a basis different from or less
advantageous than that of other Regulated Funds or Affiliated Funds;
provided that, if any other Regulated Fund, Affiliated Fund or Adviser,
but not the Regulated Fund itself, gains the right to nominate a
director for election to a portfolio company's board of directors, 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 the Required Majority from reaching the
conclusions required by this condition (2)(c)(iii), if:
(A) The Eligible Directors will have the right to ratify the
selection of such director, board observer or participant, if any;
(B) the applicable Adviser agrees to, and does, provide periodic
reports to the Regulated Fund'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 Affiliated Fund or any
Regulated Fund or any affiliated person of any Affiliated Fund or any
Regulated Fund receives in connection with the right of an Affiliated
Fund or a Regulated Fund to nominate a director or appoint a board
observer or otherwise to participate in the governance or
[[Page 26558]]
management of the portfolio company will be shared proportionately
among the participating Affiliated Funds (who each may, in turn, share
its portion with its affiliated persons) and the participating
Regulated Funds in accordance with the amount of each party's
investment; and
(iv) the proposed investment by the Regulated Fund will not benefit
the Advisers, the Affiliated Funds or the other Regulated Funds or any
affiliated person of any of them (other than the parties to the Co-
Investment Transaction), except
(A) to the extent permitted by condition 13;
(B) to the extent permitted by section 17(e) of the Act;
(C) indirectly, as a result of an interest in the securities issued
by one of the parties to the Co-Investment Transaction; or
(D) in the case of fees or other compensation described in
condition 2(c)(iii)(C).
3. Each Regulated Fund has the right to decline to participate in
any Potential Co-Investment Transaction or to invest less than the
amount proposed.
4. The applicable Adviser will present to the Board of each
Regulated Fund, on a quarterly basis, a record of all investments in
Potential Co-Investment Transactions made by any of the other Regulated
Funds or Affiliated Funds during the preceding quarter that fell within
the Regulated Fund's then-current Objectives and Strategies that were
not made available to the Regulated Fund, and an explanation of why the
investment opportunities were not offered to the Regulated Fund. All
information presented to the Board pursuant to this condition will be
kept for the life of the Regulated Fund 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,\11\ a Regulated Fund will not invest in reliance on the
Order in any issuer in which another Regulated Fund, Affiliated Fund or
any affiliated person of another Regulated Fund or Affiliated Fund is
an existing investor.
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\11\ This exception applies only to Follow-On Investments by a
Regulated Fund in issuers in which that Regulated Fund already holds
investments.
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6. A Regulated Fund 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 identical for each participating Regulated Fund and Affiliated
Fund. The grant to an Affiliated Fund or another Regulated Fund, but
not the Regulated Fund, 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 a 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 Affiliated Fund or any Regulated Fund elects to sell,
exchange or otherwise dispose of an interest in a security that was
acquired in a Co-Investment Transaction, the applicable Adviser will:
(i) Notify each Regulated Fund 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 Fund in the disposition.
(b) Each Regulated Fund 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 participating
Affiliated Funds and Regulated Funds.
(c) A Regulated Fund may participate in such disposition without
obtaining prior approval of the Required Majority if: (i) The proposed
participation of each Regulated Fund and each Affiliated Fund in such
disposition is proportionate to its outstanding investments in the
issuer immediately preceding the disposition; (ii) the Board of the
Regulated Fund has approved as being in the best interests of the
Regulated Fund the ability to participate in such dispositions on a pro
rata basis (as described in greater detail in this Application); and
(iii) the Board of the Regulated Fund is provided on a quarterly basis
with a list of all dispositions made in accordance with this condition.
In all other cases, the Adviser will provide its written recommendation
as to the Regulated Fund's participation to the Eligible Directors, and
the Regulated Fund will participate in such disposition solely to the
extent that a Required Majority determines that it is in the Regulated
Fund's best interests.
(d) Each Affiliated Fund and each Regulated Fund will bear its own
expenses in connection with any such disposition.
8. (a) If any Affiliated Fund or any Regulated Fund desires to make
a Follow-On Investment in a portfolio company whose securities were
acquired in a Co-Investment Transaction, the applicable Adviser will:
(i) Notify each Regulated Fund that participated in the Co-
Investment Transaction of the proposed transaction at the earliest
practical time; and
(ii) formulate a recommendation as to the proposed participation,
including the amount of the proposed Follow-On Investment, by each
Regulated Fund.
(b) A Regulated Fund may participate in such Follow-On Investment
without obtaining prior approval of the Required Majority if: (i) The
proposed participation of each Regulated Fund and each Affiliated Fund
in such investment is proportionate to its outstanding investments in
the issuer immediately preceding the Follow-On Investment; and (ii) the
Board of the Regulated Fund has approved as being in the best interests
of the Regulated Fund the ability to participate in Follow-On
Investments on a pro rata basis (as described in greater detail in this
application). In all other cases, the Adviser will provide its written
recommendation as to the Regulated Fund's participation to the Eligible
Directors, and the Regulated Fund will participate in such Follow-On
Investment solely to the extent that a Required Majority determines
that it is in the Regulated Fund's best interests.
(c) If, with respect to any Follow-On Investment:
(i) The amount of the opportunity is not based on the Regulated
Funds' and the Affiliated Funds' outstanding investments immediately
preceding the Follow-On Investment; and
(ii) the aggregate amount recommended by the Adviser to be invested
by each Regulated Fund in the Follow-On Investment, together with the
amount proposed to be invested by the participating Affiliated Funds 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 ``capital available for investment''
in the asset class being allocated, up to the amount proposed to be
invested by each.
(d) The acquisition of Follow-On Investments as permitted by this
condition will be considered a Co-Investment Transaction for all
purposes and subject to the other conditions set forth in the
application.
9. Each Regulated Fund will maintain the records required by
Section 57(f)(3) of the Act as if each of the Regulated Funds was a
business development company and each of the investments permitted
under these conditions was approved by the Required Majority under
Section 57(f).
[[Page 26559]]
10. The Non-Interested Directors of each Regulated Fund will be
provided quarterly for review all information concerning Potential Co-
Investment Transactions and Co-Investment Transactions, including
investments made by other Regulated Funds or Affiliated Funds that the
Regulated Fund considered but declined to participate in, so that the
Non-Interested Directors may determine whether all investments made
during the preceding quarter, including those investments that the
Regulated Fund considered but declined to participate in, comply with
the conditions of the Order. In addition, the Non-Interested Directors
will consider at least annually the continued appropriateness for the
Regulated Fund of participating in new and existing Co-Investment
Transactions.
11. No Non-Interested Director of a Regulated Fund will also be a
director, general partner, managing member or principal, or otherwise
an ``affiliated person'' (as defined in the Act) of any of the
Affiliated Funds.
12. The expenses, if any, associated with acquiring, holding or
disposing of any securities acquired in a Co-Investment Transaction
(including, without limitation, the expenses of the distribution of any
such securities registered for sale under the 1933 Act) will, to the
extent not payable by the Adviser under its respective investment
advisory agreements with Affiliated Funds and the Regulated Funds, be
shared by the Regulated Funds and the Affiliated Funds 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, without limitation, break-up or
commitment fees but excluding broker's fees contemplated by Section
17(e) of the Act) received in connection with a Co-Investment
Transaction will be distributed to the participating Regulated Funds
and Affiliated Funds (who may, in turn, share their portion with
affiliated persons) on a pro rata basis based on the amounts they
invested or committed, as the case may be, in such Co-Investment
Transaction. If any transaction fee is to be held by the 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 Funds and Affiliated
Funds based on the amounts they invest in such Co-Investment
Transaction. None of the Affiliated Funds, the Adviser, the other
Regulated Funds or any affiliated person of the Regulated Funds or
Affiliated Funds will receive additional compensation or remuneration
of any kind as a result of or in connection with a Co-Investment
Transaction (other than (a) in the case of the Regulated Funds and the
Affiliated Funds, the pro rata transaction fees described above and
fees or other compensation described in condition 2(c)(iii)(C); and (b)
in the case of the Adviser, investment advisory fees paid in accordance
with the agreement between the Adviser and the Regulated Fund or
Affiliated Fund).
14. If the Holders own in the aggregate more than 25% of the
Shares, then the Holders will vote such Shares as directed by an
independent third party when voting on (1) the election of directors;
(2) the removal of one or more directors; or (3) all other matters
under either the Act or applicable state law affecting the Board's
composition, size or manner of election.
15. Each Regulated Fund's chief compliance officer, as defined in
rule 38a-1(a)(4) of the Act, will prepare an annual report for its
Board each year that evaluates (and documents the basis of that
evaluation) the Regulated Fund's compliance with the terms and
conditions of the application and the procedures established to achieve
such compliance.
For the Commission, by the Division of Investment Management,
under delegated authority.
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017-11728 Filed 6-6-17; 8:45 am]
BILLING CODE 8011-01-P