BNP Paribas USA, Inc., et al.; Notice of Application and Temporary Order, 4523-4526 [2018-01905]
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OMB for review entitled, 10 CFR part
50, ‘‘Domestic Licensing of Production
and Utilization Facilities.’’ The NRC
hereby informs potential respondents
that an agency may not conduct or
sponsor, and that a person is not
required to respond to, a collection of
information unless it displays a
currently valid OMB control number.
The NRC published a Federal
Register notice with a 60-day comment
period on this information collection on
October 18, 2017, (82 FR 48539).
1. The title of the information
collection: 10 CFR part 50, ‘‘Domestic
Licensing of Production and Utilization
Facilities.’’
2. OMB approval number: 3150–0011.
3. Type of submission: Extension.
4. The form number if applicable: Not
applicable.
5. How often the collection is required
or requested: As necessary in order for
the NRC to meet its responsibilities to
conduct a detailed review of
applications for licenses and
amendments thereto to construct and
operate nuclear power plants,
preliminary or final design approvals,
design certifications, research and test
facilities, reprocessing plants and other
utilization and production facilities,
licensed pursuant to the Atomic Energy
Act of 1954, as amended (the Act) and
to monitor their activities. Reports are
submitted daily, monthly, quarterly,
annually, semi-annually, and on
occasion.
6. Who will be required or asked to
respond: Licensees and applicants for
nuclear power plants and research and
test facilities.
7. The estimated number of annual
responses: 43,623 (43,473 reporting
responses + 149 recordkeepers + 1 thirdparty disclosure response).
8. The estimated number of annual
respondents: 149.
9. An estimate of the total number of
hours needed annually to comply with
the information collection requirement
or request: 3.7M hours (1.1M hours
reporting + 2.6M hours recordkeeping +
100 hours third-party disclosure).
10. Abstract: Part 50 of title 10 of the
Code of Federal Regulations (10 CFR),
‘‘Domestic Licensing of Production and
Utilization Facilities,’’ specifies
technical information and data to be
provided to the NRC or maintained by
applicants and licensees so that the NRC
may take determinations necessary to
protect the health and safety of the
public, in accordance with the Atomic
Energy Act of 1954, as amended. The
reporting and recordkeeping
requirements contained in 10 CFR part
50 are mandatory for the affected
licensees and applicants.
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Dated at Rockville, Maryland, this 25th day
of January 2017.
For the Nuclear Regulatory Commission.
David Cullison,
NRC Clearance Officer, Office of the Chief
Information Officer.
[FR Doc. 2018–01875 Filed 1–30–18; 8:45 am]
BILLING CODE 7590–01–P
NUCLEAR REGULATORY
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Advisory Committee on Reactor
Safeguards (ACRS); Meeting of the
ACRS Subcommittee on Future Plant
Designs; Notice of Meeting
The ACRS Subcommittee on Future
Plant Designs will hold a meeting on
February 7, 2018 at 11545 Rockville
Pike, Room T–2B1, Rockville, Maryland
20852.
The entire meeting will be open to
public attendance.
The agenda for the subject meeting
shall be as follows:
Wednesday, February 7, 2018—8:30
a.m. Until 12:00 p.m.
The Subcommittee will review Final
Regulatory Guide 1.232, ‘‘Guidance for
Developing Principal Design Criteria for
Non-Light-Water Reactors.’’ The
Subcommittee will hear presentations
by and hold discussions with NRC staff
and other interested persons regarding
this matter. The Subcommittee will
gather information, analyze relevant
issues and facts, and formulate
proposed positions and actions, as
appropriate, for deliberation by the Full
Committee.
Members of the public desiring to
provide oral statements and/or written
comments should notify the Designated
Federal Official (DFO), Derek Widmayer
(Telephone 391–221–1448 or Email
Derek.Widmayer@nrc.gov) five days
prior to the meeting, if possible, so that
appropriate arrangements can be made.
Thirty-five hard copies of each
presentation or handout should be
provided to the DFO thirty minutes
before the meeting. In addition, one
electronic copy of each presentation
should be emailed to the DFO one day
before the meeting. If an electronic copy
cannot be provided within this
timeframe, presenters should provide
the DFO with a CD containing each
presentation at least thirty minutes
before the meeting. Electronic
recordings will be permitted only
during those portions of the meeting
that are open to the public. Detailed
procedures for the conduct of and
participation in ACRS meetings were
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published in the Federal Register on
October 4, 2017 (82 FR 46312).
Detailed meeting agendas and meeting
transcripts are available on the NRC
website at https://www.nrc.gov/readingrm/doc-collections/acrs. Information
regarding topics to be discussed,
changes to the agenda, whether the
meeting has been canceled or
rescheduled, and the time allotted to
present oral statements can be obtained
from the website cited above or by
contacting the identified DFO.
Moreover, in view of the possibility that
the schedule for ACRS meetings may be
adjusted by the Chairman as necessary
to facilitate the conduct of the meeting,
persons planning to attend should check
with these references if such
rescheduling would result in a major
inconvenience.
If attending this meeting, please enter
through the One White Flint North
building, 11555 Rockville Pike,
Rockville, Maryland 20852. After
registering with Security, please contact
Mr. Theron Brown (Telephone 301–
415–6702) to be escorted to the meeting
room.
Dated: January 25, 2018.
Mark L. Banks,
Chief, Technical Support Branch, Advisory
Committee on Reactor Safeguards.
[FR Doc. 2018–01839 Filed 1–30–18; 8:45 am]
BILLING CODE 7590–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. IC–32995; File No. 812–14874]
BNP Paribas USA, Inc., et al.; Notice of
Application and Temporary Order
January 26, 2018.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Temporary order and notice of
application for a permanent order under
section 9(c) of the Investment Company
Act of 1940 (‘‘Act’’).
AGENCY:
Applicants
have received a temporary order
(‘‘Temporary Order’’) exempting them
from section 9(a) of the Act, with
respect to a guilty plea entered on
January 25, 2018 (‘‘Guilty Plea’’), by
BNP Paribas USA, Inc. (the ‘‘Pleading
Entity’’) in the United States District
Court for the Southern District of New
York (the ‘‘District Court’’) in
connection with a plea agreement (‘‘Plea
Agreement’’) between the Pleading
Entity and the United States Department
of Justice (‘‘DOJ’’), until the Commission
takes final action on an application for
a permanent order (the ‘‘Permanent
SUMMARY OF APPLICATION:
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Order,’’ and with the Temporary Order,
the ‘‘Orders’’). Applicants also have
applied for a Permanent Order.
APPLICANTS: BNP Paribas USA, Inc.,
BNP Paribas Asset Management USA,
Inc. (‘‘BNPP AM USA’’), Bishop Street
Capital Management Corp. (‘‘BSCM’’),
and BNP Paribas Asset Management UK
Limited (‘‘BNPP AM UK’’) (each, an
‘‘Applicant’’ and collectively,
‘‘Applicants’’).
FILING DATE: The application was filed
on January 25, 2018.
HEARING OR NOTIFICATION OF HEARING:
An order granting the application 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 February 20, 2018 and
should be accompanied by proof of
service on Applicants, in the form of an
affidavit, or for lawyers, a certificate of
service. Pursuant to rule 0–5 under the
Act, hearing requests should state the
nature of the writer’s interest, any facts
bearing upon the desirability of a
hearing on the matter, the reason for the
request, and the issues contested.
Persons who wish to be notified of a
hearing may request notification by
writing to the Commission’s Secretary.
ADDRESSES: Secretary, U.S. Securities
and Exchange Commission, 100 F Street
NE, Washington, DC 20549–1090;
Applicants: BNP Paribas USA, Inc., 787
Seventh Avenue, New York, NY 10019;
BNPP AM USA: 200 Park Avenue, 11th
Floor, New York, NY 10166; BSCM:
First Hawaiian Center, 999 Bishop
Street, Suite 2806, Honolulu, HI 96813;
BNPP AM UK: 5 Aldermanbury Square,
London EC2V 7BP, United Kingdom.
FOR FURTHER INFORMATION CONTACT:
Jessica Shin, Attorney-Adviser, or
Robert H. Shapiro, Branch Chief, at
(202) 551–6821 (Division of Investment
Management, Chief Counsel’s Office).
SUPPLEMENTARY INFORMATION: The
following is a temporary order and a
summary of the application. The
complete application may be obtained
via the Commission’s website by
searching for the file number, or an
applicant using the Company name box,
at https://www.sec.gov/search/
search.htm, or by calling (202) 551–
8090.
Applicants’ Representations
1. The Pleading Entity is a corporation
organized under the laws of Delaware
and wholly owned subsidiary of BNP
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Paribas S.A. (‘‘BNPP’’).1 The Pleading
Entity serves as BNPP’s U.S.
intermediate holding company.
2. BNPP AM USA, a corporation
formed under the laws of New York, is
registered as an investment adviser
under the Investment Advisers Act of
1940 (the ‘‘Advisers Act’’) and is an
indirect wholly owned subsidiary of
BNPP and of the Pleading Entity. BNPP
AM USA serves as sub-adviser to the
investment companies registered under
the Act or series of such companies
listed in Part 1 of Appendix A to the
application (each a ‘‘Fund’’ and,
collectively, ‘‘Funds’’). Until late April
2017, BNPP AM USA was named
‘‘Fischer Francis Trees & Watts, Inc.’’
3. BSCM, a corporation formed under
the laws of Hawaii in 1999, is registered
as an investment adviser under the
Advisers Act. BSCM is an indirect
wholly owned subsidiary of First
Hawaiian, Inc., which is an
approximately 62% owned indirect
subsidiary of BNPP. BSCM serves as
investment adviser to each Fund listed
in Part 2 of Appendix A to the
application.
4. BNPP AM UK, a corporation
formed under the laws of the United
Kingdom, is registered as an investment
adviser under the Advisers Act. BNPP
AM UK is an indirect wholly owned
subsidiary of BNPP. BNPP AM UK does
not currently advise any Fund, but
expects to be sub-adviser to the newlyorganized Fund listed in Part 1B of
Appendix A to the application.
5. While no existing company of
which the Pleading Entity is an
‘‘affiliated person’’ within the meaning
of section 2(a)(3) of the Act (‘‘Affiliated
Person’’), other than BNPP AM USA,
BSCM and BNPP AM UK (together, the
‘‘Fund Servicing Applicants’’), currently
serves as an investment adviser or
depositor of any Fund, employees’
securities company (‘‘ESC’’) or
investment company that has elected to
be treated as a business development
company under the Act (‘‘BDC’’), or
principal underwriter (as defined in
section 2(a)(29) of the Act) for any openend management investment company
registered under the Act (‘‘Open-End
Fund’’), unit investment trust registered
under the Act (‘‘UIT’’), or face-amount
certificate company registered under the
Act (‘‘FACC’’), Applicants request that
any relief granted by the Commission
pursuant to the application also apply to
any current or future Affiliated person
of the Pleading Entity other than BNPP
1 BNPP, the parent of the Pleading Entity, does
not and will not serve as an investment adviser,
depositor or principal underwriter to any registered
investment company as it is not a Covered Person
(as defined below).
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(together with the Fund Servicing
Applicants, the ‘‘Covered Persons’’)
with respect to any activity
contemplated by section 9(a) of the
Act.2
6. On January 25, 2018, the United
States Department of Justice (the
‘‘Department of Justice’’) filed a onecount criminal information (the
‘‘Information’’) in the District Court. The
Information charges that from as early as
September 2011 until at least July 2013,
the Pleading Entity, through a single
Central and Eastern European, Middle
Eastern and African Emerging Markets
currencies (‘‘CEEMEA’’ currencies)
trader employed by BNP Paribas
Securities Corp. (‘‘Sec Corp’’),
participated in a conspiracy to suppress
and eliminate competition in CEEMEA
currencies by various methods (the
‘‘Conduct’’), as further described in the
application, in violation of the Sherman
Antitrust Act (Title 15, United States
Code, section 1).
7. Pursuant to the Plea Agreement, the
Pleading Entity entered the Guilty Plea
on January 25, 2018 in the District Court
to the charge set out in the Information.
According to the Plea Agreement, the
Pleading Entity, among other things,
agreed to a fine of $90 million. The
Applicants expect that the District Court
will enter a judgment against the
Pleading Entity (the ‘‘Judgment’’) that
will require remedies that are materially
the same as set forth in the Plea
Agreement. The individual referenced
in the Information as responsible for the
Conduct is no longer employed by
BNPP or any of its affiliates.
8. BNPP and its affiliates have entered
into settlement agreements with other
U.S. regulatory or enforcement agencies
related to the Conduct. The Board of
Governors of the Federal Reserve
System (‘‘FRB’’) entered a cease and
desist order (the ‘‘FRB Order’’) on July
17, 2017 against BNPP, the Pleading
Entity and Sec Corp concerning unsafe
and unsound banking practices relating
to BNPP’s foreign exchange (‘‘FX’’)
business. The New York State
Department of Financial Services
(‘‘DFS’’) entered into a consent order
(the ‘‘DFS Order’’) on May 24, 2017 with
BNPP and its New York branch (the
‘‘DFS Order Parties’’) to settle DFS’
investigations into alleged violations of
the New York laws and regulations
arising out of conduct in the DFS Order
Parties’ FX business during the period
between 2007 and 2013.
2 Covered Persons may, if the Order is granted, in
the future act in any of the capacities contemplated
by Section 9(a) of the Act subject to the applicable
terms and conditions of the Orders.
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Applicants’ Legal Analysis
1. Section 9(a)(1) of the Act provides,
in pertinent part, that a person may not
serve or act as an investment adviser or
depositor of any registered investment
company or as principal underwriter for
any registered open-end investment
company, UIT, or FACC, if such person
within ten years has been convicted of
any felony or misdemeanor, including
those arising out of such person’s
conduct as a bank. Section 2(a)(10) of
the Act defines the term ‘‘convicted’’ to
include a plea of guilty. Section 9(a)(3)
of the Act extends the prohibitions of
section 9(a)(1) to a company, any
affiliated person of which has been
disqualified under the provisions of
section 9(a)(1). Section 2(a)(3) of the Act
defines ‘‘affiliated person’’ to include,
among others, any person directly or
indirectly controlling, controlled by, or
under common control with, the other
person. The Pleading Entity is an
Affiliated Person of each of the other
Applicants within the meaning of
section 2(a)(3) of the Act. Therefore, the
Applicants state that the Plea
Agreement would result in a
disqualification of the Applicants for
ten years under section 9(a)(3) were they
to act in any of the capacities listed in
section 9(a), by effect of a conviction
described in section 9(a)(1).
2. Section 9(c) of the Act provides
that, upon application, the Commission
shall by order grant an exemption from
the disqualification provisions of
section 9(a) of the Act, either
unconditionally or on an appropriate
temporary or other conditional basis, to
any person if that person establishes
that: (a) The prohibitions of section 9(a),
as applied to the person, are unduly or
disproportionately severe or (b) the
conduct of the person has been such as
not to make it against the public interest
or the protection of investors to grant
the exemption. Applicants have filed an
application pursuant to section 9(c)
seeking a Temporary Order and a
Permanent Order exempting the Fund
Servicing Applicants and other Covered
Persons from the disqualification
provisions of section 9(a) of the Act. The
Covered Persons may, if the Orders are
granted, in the future act in any of the
capacities contemplated by section 9(a)
of the Act subject to the applicable
terms and conditions of the Orders.
3. Applicants believe they meet the
standards for exemption specified in
section 9(c). Applicants assert that (i)
the scope of the misconduct was limited
and did not involve any of the Fund
Servicing Applicants acting as an
‘‘investment adviser’’ (as defined in
section 2(a)(20) of the Act) to Funds
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(such activities, ‘‘Fund Service
Activities’’), or any Fund with respect to
which the Applicants engage in Fund
Service Activities, (ii) application of the
statutory bar would impose significant
hardships on the Funds and their
shareholders, (iii) the prohibitions of
section 9(a), if applied to the BNPP and
other Covered Persons, would be
unduly or disproportionately severe and
(iv) the Conduct did not constitute
conduct that would make it against the
public interest or protection of investors
to grant the exemption from section 9(a).
4. Applicants represent that the
Conduct did not involve any of
Applicants acting in the capacity as an
investment adviser or depositor of any
Fund, ESC or BDC or as principal
underwriter for any Open-End Fund,
UIT or FACC. Applicants represent that
the Conduct similarly did not involve
any Fund with respect to which the
Applicants engage in Fund Service
Activities.3 Instead, the Applicants state
that the Conduct occurred as a result of
the actions of a single employee. The
employee is no longer employed and
will not be employed in the future, by
BNPP, the Applicants or any of the
other Covered Persons. Applicants
assert that, in light of the limited scope
of the Conduct, it would be unduly and
disproportionately severe to impose a
section 9(a) disqualification on the
Applicants. Applicants assert that the
conduct of the Applicants has not been
such to make it against the public
interest or the protection of investors to
grant the exemption from section 9(a).
5. Applicants assert that neither the
protection of investors nor the public
interest would be served by permitting
the section 9(a) disqualifications to
apply to the Fund Servicing Applicants
because those disqualifications would
deprive the Fund of the advisory or subadvisory services that shareholders
expected the Funds would receive when
they decided to invest in the Funds.
Applicants also assert that the
prohibitions of section 9(a) could
operate to the financial detriment of the
Funds and their shareholders, which
would be an unduly and
disproportionately severe consequence
given that the Conduct did not involve
any of the Fund Service Activities.
6. Applicants further represent that
the inability of the Fund Servicing
Applicants to continue providing
investment advisory services to Funds
would result in the Funds and their
shareholders facing potential hardship,
as described in the application.
3 The Pleading Entity does not engage, has not
engaged, and will not engage in in any of the
capacities contemplated by Section 9(a) of the Act.
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Applicants assert that if the Fund
Servicing Applicants were barred under
section 9(a) from providing investment
advisory services to the Funds and were
unable to obtain the requested
exemption, the effect on their
businesses and employees would be
severe. Applicants state that the Fund
Servicing Applicants have committed
substantial capital and other resources
to establishing expertise in advising and
sub-advising Funds with a view to
continuing and expanding this business,
which Applicants consider strategically
important. Applicants further state that
prohibiting the Fund Servicing
Applicants from engaging in Fund
Service Activities would not only
adversely affect their business, but
would also adversely affect their
employees who are involved in these
activities. In addition, Applicants assert
that if the Fund Servicing Applicants or
Covered Persons are unable to expand
their businesses in the future because of
the imposition of the section 9(a)
disqualification, it could also have an
adverse impact on their businesses.
7. Applicants represent that: (1) None
of the current or former directors,
officers or employees of Applicants had
any involvement in the Conduct; (2) no
current or former employee of the
Pleading Entity or of any other Covered
Person who previously has been or who
subsequently may be identified by the
Pleading Entity or any U.S. or non-U.S.
regulatory or enforcement agencies as
having been responsible for the Conduct
will be an officer, director, or employee
of any Covered Person; (3) the identified
employee has had no, and will not have
any future, involvement in the Covered
Persons’ activities in any capacity
described in section 9(a) of the Act; and
(4) because the personnel of Applicants
did not have any involvement in the
Conduct, shareholders of the Fund were
not affected any differently than if the
Fund had received services from any
other non-affiliated investment adviser.
8. Applicants have agreed that none of
BNPP, the Applicants or any of the
other Covered Persons will employ the
former employee of an affiliate of the
Pleading Entity or any other person who
subsequently may be identified by the
Pleading Entity or any U.S. or non-U.S.
regulatory or enforcement agencies as
having been responsible for the Conduct
in any capacity without first making a
further application to the Commission
pursuant to section 9(c).
9. Applicants have also agreed that
BNPP and each Applicant and Covered
Person will adopt and implement
policies and procedures reasonably
designed to ensure compliance with the
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terms and conditions of the Orders
granted under section 9(c).
10. In addition, BNPP and each
Applicant and Covered Person will
comply in all material respects with the
material terms and conditions of the
Plea Agreement and with the materials
terms of the FRB Order, the DFS Order
any other orders issued by regulatory or
enforcement agencies addressing the
Conduct. Applicants further state that
BNPP and its affiliates have undertaken
certain remedial measures, as described
in greater detail in the application.
These include certain remedial
measures as required by the Plea
Agreement, the FRB Order, and the DFS
Order, including improvements to the
oversight, internal controls and
compliance program, compliance risk
management program, and internal
audit program for FX trading.
Applicants state that BNPP and its
affiliates have taken a number of steps
to enhance its internal controls, policies
and procedures relating to its FX
activities. Specifically, Applicants
represent BNPP has devised and
implemented new global detailed FXspecific policies and procedures and a
comprehensive program to change the
culture of the business with the aim that
each individual within the business
understands their responsibility for
proper conduct and compliance.
Applicants also represent that BNPP has
globally rolled out culture and conduct
workshops and training on BNPP’s
Foreign Exchange Local Markets
remediation program. Additionally,
Applicants represent that supervisors
have been given increased tools to
directly oversee their staff and identify
conduct issues more effectively,
permanent cross-bank chat rooms have
been prohibited, and reverse trades are
monitored through software designed to
detect transactions (proprietary and
customer) that were not exposed to the
risk of the market and did not result in
a change of beneficial ownership.
11. As a result of the foregoing, the
Applicants submit that granting the
exemption as requested in the
application is consistent with the public
interest and the protection of investors.
12. To provide further assurance that
the exemptive relief being requested
herein would be consistent with the
public interest and the protection of the
investors, the Applicants agree that they
will, as soon as reasonably practical,
distribute to the boards of directors or
trustees of the Funds (‘‘Board’’) written
materials describing the circumstances
that led to the Plea Agreement, as well
as any effects on the Funds and the
application. The written materials will
include an offer to discuss the materials
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at an in-person meeting with the Board,
including the directors who are not
‘‘interested persons’’ of the Funds as
defined in section 2(a)(19) of the Act
and their ‘‘independent legal counsel’’
as defined in rule 0–1(a)(6) under the
Act, if any. The Applicants undertake to
provide the Boards with all information
concerning the Plea Agreement and the
application as necessary for those Funds
to fulfill their disclosure and other
obligations under the U.S. federal
securities laws and will provide them a
copy of the Judgment as entered by the
District Court.
13. Applicants state that certain of the
Applicants and their affiliates have
previously received an order under
section 9(c) of the Act, as the result of
conduct that triggered section 9(a), as
described in greater detail in the
application.
Applicants’ Conditions
Applicants agree that any order
granted by the Commission pursuant to
the application will be subject to the
following conditions:
1. Any temporary exemption granted
pursuant to the application will be
without prejudice to, and will not limit
the Commission’s rights in any manner
with respect to, any Commission
investigation of, or administrative
proceedings involving or against,
Covered Persons, including, without
limitation, the consideration by the
Commission of a permanent exemption
from section 9(a) of the Act requested
pursuant to the application or the
revocation or removal of any temporary
exemptions granted under the Act in
connection with the application.
2. None of BNPP, the Applicants or
any of the other Covered Persons will
employ the former employee of an
affiliate of the Pleading Entity or any
other person who subsequently may be
identified by the Pleading Entity or any
U.S. or non-U.S. regulatory or
enforcement agencies as having been
responsible for the Conduct in any
capacity without first making a further
application to the Commission pursuant
to section 9(c).
3. BNPP and each Applicant and
Covered Person will adopt and
implement policies and procedures
reasonably designed to ensure that it
will comply with the terms and
conditions of the Orders within 60 days
of the date of the Permanent Order or,
with respect to condition four, such
later date or dates as may be
contemplated by the FRB Order, the
DFS Order or any other orders issued by
regulatory or enforcement agencies
addressing the Conduct.
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4. BNPP and each Applicant and
Covered Person will comply in all
material respects with the material
terms and conditions of the Plea
Agreement and with the material terms
of the FRB Order, the DFS Order and
any other orders issued by regulatory or
enforcement agencies addressing the
Conduct.
5. Applicants will provide written
notification to the Chief Counsel of the
Commission’s Division of Investment
Management with a copy to the Chief
Counsel of the Commission’s Division of
Enforcement of a material violation of
the terms and conditions of any of the
Orders within 30 days of discovery of
the material violation.
Temporary Order
The Commission has considered the
matter and finds that Applicants have
made the necessary showing to justify
granting a temporary exemption.
Accordingly,
It is hereby ordered, pursuant to
section 9(c) of the Act, that the
Applicants and any other Covered
Persons are granted a temporary
exemption from the provisions of
section 9(a), effective as the date of the
Guilty Plea, solely with respect to the
Guilty Plea entered into pursuant to the
Plea Agreement, subject to the
representations and conditions in the
application, until the Commission takes
final action on their application for a
permanent order.
By the Commission.
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2018–01905 Filed 1–30–18; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–82585; File No. SR–OCC–
2017–020]
Self-Regulatory Organizations; The
Options Clearing Corporation; Notice
of Designation of Longer Period for
Commission Action on Proposed Rule
Change Concerning Enhanced and
New Tools for Recovery Scenarios
January 25, 2018.
On December 18, 2017, The Options
Clearing Corporation (‘‘OCC’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) proposed
rule change SR–OCC–2017–020
(‘‘Proposed Rule Change’’) pursuant to
Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’),1 and
1 15
E:\FR\FM\31JAN1.SGM
U.S.C. 78s(b)(1).
31JAN1
Agencies
[Federal Register Volume 83, Number 21 (Wednesday, January 31, 2018)]
[Notices]
[Pages 4523-4526]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-01905]
=======================================================================
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SECURITIES AND EXCHANGE COMMISSION
[Release No. IC-32995; File No. 812-14874]
BNP Paribas USA, Inc., et al.; Notice of Application and
Temporary Order
January 26, 2018.
AGENCY: Securities and Exchange Commission (``Commission'').
ACTION: Temporary order and notice of application for a permanent
order under section 9(c) of the Investment Company Act of 1940
(``Act'').
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Summary of Application: Applicants have received a temporary order
(``Temporary Order'') exempting them from section 9(a) of the Act, with
respect to a guilty plea entered on January 25, 2018 (``Guilty Plea''),
by BNP Paribas USA, Inc. (the ``Pleading Entity'') in the United States
District Court for the Southern District of New York (the ``District
Court'') in connection with a plea agreement (``Plea Agreement'')
between the Pleading Entity and the United States Department of Justice
(``DOJ''), until the Commission takes final action on an application
for a permanent order (the ``Permanent
[[Page 4524]]
Order,'' and with the Temporary Order, the ``Orders''). Applicants also
have applied for a Permanent Order.
Applicants: BNP Paribas USA, Inc., BNP Paribas Asset Management USA,
Inc. (``BNPP AM USA''), Bishop Street Capital Management Corp.
(``BSCM''), and BNP Paribas Asset Management UK Limited (``BNPP AM
UK'') (each, an ``Applicant'' and collectively, ``Applicants'').
Filing Date: The application was filed on January 25, 2018.
Hearing or Notification of Hearing: An order granting the application
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 February 20, 2018 and should be accompanied by proof of service
on Applicants, in the form of an affidavit, or for lawyers, a
certificate of service. Pursuant to rule 0-5 under the Act, hearing
requests should state the nature of the writer's interest, any facts
bearing upon the desirability of a hearing on the matter, the reason
for the request, and the issues contested. Persons who wish to be
notified of a hearing may request notification by writing to the
Commission's Secretary.
ADDRESSES: Secretary, U.S. Securities and Exchange Commission, 100 F
Street NE, Washington, DC 20549-1090; Applicants: BNP Paribas USA,
Inc., 787 Seventh Avenue, New York, NY 10019; BNPP AM USA: 200 Park
Avenue, 11th Floor, New York, NY 10166; BSCM: First Hawaiian Center,
999 Bishop Street, Suite 2806, Honolulu, HI 96813; BNPP AM UK: 5
Aldermanbury Square, London EC2V 7BP, United Kingdom.
FOR FURTHER INFORMATION CONTACT: Jessica Shin, Attorney-Adviser, or
Robert H. Shapiro, Branch Chief, at (202) 551-6821 (Division of
Investment Management, Chief Counsel's Office).
SUPPLEMENTARY INFORMATION: The following is a temporary order and a
summary of the application. The complete application may be obtained
via the Commission's website by searching for the file number, or an
applicant using the Company name box, at https://www.sec.gov/search/search.htm, or by calling (202) 551-8090.
Applicants' Representations
1. The Pleading Entity is a corporation organized under the laws of
Delaware and wholly owned subsidiary of BNP Paribas S.A. (``BNPP'').\1\
The Pleading Entity serves as BNPP's U.S. intermediate holding company.
---------------------------------------------------------------------------
\1\ BNPP, the parent of the Pleading Entity, does not and will
not serve as an investment adviser, depositor or principal
underwriter to any registered investment company as it is not a
Covered Person (as defined below).
---------------------------------------------------------------------------
2. BNPP AM USA, a corporation formed under the laws of New York, is
registered as an investment adviser under the Investment Advisers Act
of 1940 (the ``Advisers Act'') and is an indirect wholly owned
subsidiary of BNPP and of the Pleading Entity. BNPP AM USA serves as
sub-adviser to the investment companies registered under the Act or
series of such companies listed in Part 1 of Appendix A to the
application (each a ``Fund'' and, collectively, ``Funds''). Until late
April 2017, BNPP AM USA was named ``Fischer Francis Trees & Watts,
Inc.''
3. BSCM, a corporation formed under the laws of Hawaii in 1999, is
registered as an investment adviser under the Advisers Act. BSCM is an
indirect wholly owned subsidiary of First Hawaiian, Inc., which is an
approximately 62% owned indirect subsidiary of BNPP. BSCM serves as
investment adviser to each Fund listed in Part 2 of Appendix A to the
application.
4. BNPP AM UK, a corporation formed under the laws of the United
Kingdom, is registered as an investment adviser under the Advisers Act.
BNPP AM UK is an indirect wholly owned subsidiary of BNPP. BNPP AM UK
does not currently advise any Fund, but expects to be sub-adviser to
the newly-organized Fund listed in Part 1B of Appendix A to the
application.
5. While no existing company of which the Pleading Entity is an
``affiliated person'' within the meaning of section 2(a)(3) of the Act
(``Affiliated Person''), other than BNPP AM USA, BSCM and BNPP AM UK
(together, the ``Fund Servicing Applicants''), currently serves as an
investment adviser or depositor of any Fund, employees' securities
company (``ESC'') or investment company that has elected to be treated
as a business development company under the Act (``BDC''), or principal
underwriter (as defined in section 2(a)(29) of the Act) for any open-
end management investment company registered under the Act (``Open-End
Fund''), unit investment trust registered under the Act (``UIT''), or
face-amount certificate company registered under the Act (``FACC''),
Applicants request that any relief granted by the Commission pursuant
to the application also apply to any current or future Affiliated
person of the Pleading Entity other than BNPP (together with the Fund
Servicing Applicants, the ``Covered Persons'') with respect to any
activity contemplated by section 9(a) of the Act.\2\
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\2\ Covered Persons may, if the Order is granted, in the future
act in any of the capacities contemplated by Section 9(a) of the Act
subject to the applicable terms and conditions of the Orders.
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6. On January 25, 2018, the United States Department of Justice
(the ``Department of Justice'') filed a one-count criminal information
(the ``Information'') in the District Court. The Information charges
that from as early as September 2011 until at least July 2013, the
Pleading Entity, through a single Central and Eastern European, Middle
Eastern and African Emerging Markets currencies (``CEEMEA'' currencies)
trader employed by BNP Paribas Securities Corp. (``Sec Corp''),
participated in a conspiracy to suppress and eliminate competition in
CEEMEA currencies by various methods (the ``Conduct''), as further
described in the application, in violation of the Sherman Antitrust Act
(Title 15, United States Code, section 1).
7. Pursuant to the Plea Agreement, the Pleading Entity entered the
Guilty Plea on January 25, 2018 in the District Court to the charge set
out in the Information. According to the Plea Agreement, the Pleading
Entity, among other things, agreed to a fine of $90 million. The
Applicants expect that the District Court will enter a judgment against
the Pleading Entity (the ``Judgment'') that will require remedies that
are materially the same as set forth in the Plea Agreement. The
individual referenced in the Information as responsible for the Conduct
is no longer employed by BNPP or any of its affiliates.
8. BNPP and its affiliates have entered into settlement agreements
with other U.S. regulatory or enforcement agencies related to the
Conduct. The Board of Governors of the Federal Reserve System (``FRB'')
entered a cease and desist order (the ``FRB Order'') on July 17, 2017
against BNPP, the Pleading Entity and Sec Corp concerning unsafe and
unsound banking practices relating to BNPP's foreign exchange (``FX'')
business. The New York State Department of Financial Services (``DFS'')
entered into a consent order (the ``DFS Order'') on May 24, 2017 with
BNPP and its New York branch (the ``DFS Order Parties'') to settle DFS'
investigations into alleged violations of the New York laws and
regulations arising out of conduct in the DFS Order Parties' FX
business during the period between 2007 and 2013.
[[Page 4525]]
Applicants' Legal Analysis
1. Section 9(a)(1) of the Act provides, in pertinent part, that a
person may not serve or act as an investment adviser or depositor of
any registered investment company or as principal underwriter for any
registered open-end investment company, UIT, or FACC, if such person
within ten years has been convicted of any felony or misdemeanor,
including those arising out of such person's conduct as a bank. Section
2(a)(10) of the Act defines the term ``convicted'' to include a plea of
guilty. Section 9(a)(3) of the Act extends the prohibitions of section
9(a)(1) to a company, any affiliated person of which has been
disqualified under the provisions of section 9(a)(1). Section 2(a)(3)
of the Act defines ``affiliated person'' to include, among others, any
person directly or indirectly controlling, controlled by, or under
common control with, the other person. The Pleading Entity is an
Affiliated Person of each of the other Applicants within the meaning of
section 2(a)(3) of the Act. Therefore, the Applicants state that the
Plea Agreement would result in a disqualification of the Applicants for
ten years under section 9(a)(3) were they to act in any of the
capacities listed in section 9(a), by effect of a conviction described
in section 9(a)(1).
2. Section 9(c) of the Act provides that, upon application, the
Commission shall by order grant an exemption from the disqualification
provisions of section 9(a) of the Act, either unconditionally or on an
appropriate temporary or other conditional basis, to any person if that
person establishes that: (a) The prohibitions of section 9(a), as
applied to the person, are unduly or disproportionately severe or (b)
the conduct of the person has been such as not to make it against the
public interest or the protection of investors to grant the exemption.
Applicants have filed an application pursuant to section 9(c) seeking a
Temporary Order and a Permanent Order exempting the Fund Servicing
Applicants and other Covered Persons from the disqualification
provisions of section 9(a) of the Act. The Covered Persons may, if the
Orders are granted, in the future act in any of the capacities
contemplated by section 9(a) of the Act subject to the applicable terms
and conditions of the Orders.
3. Applicants believe they meet the standards for exemption
specified in section 9(c). Applicants assert that (i) the scope of the
misconduct was limited and did not involve any of the Fund Servicing
Applicants acting as an ``investment adviser'' (as defined in section
2(a)(20) of the Act) to Funds (such activities, ``Fund Service
Activities''), or any Fund with respect to which the Applicants engage
in Fund Service Activities, (ii) application of the statutory bar would
impose significant hardships on the Funds and their shareholders, (iii)
the prohibitions of section 9(a), if applied to the BNPP and other
Covered Persons, would be unduly or disproportionately severe and (iv)
the Conduct did not constitute conduct that would make it against the
public interest or protection of investors to grant the exemption from
section 9(a).
4. Applicants represent that the Conduct did not involve any of
Applicants acting in the capacity as an investment adviser or depositor
of any Fund, ESC or BDC or as principal underwriter for any Open-End
Fund, UIT or FACC. Applicants represent that the Conduct similarly did
not involve any Fund with respect to which the Applicants engage in
Fund Service Activities.\3\ Instead, the Applicants state that the
Conduct occurred as a result of the actions of a single employee. The
employee is no longer employed and will not be employed in the future,
by BNPP, the Applicants or any of the other Covered Persons. Applicants
assert that, in light of the limited scope of the Conduct, it would be
unduly and disproportionately severe to impose a section 9(a)
disqualification on the Applicants. Applicants assert that the conduct
of the Applicants has not been such to make it against the public
interest or the protection of investors to grant the exemption from
section 9(a).
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\3\ The Pleading Entity does not engage, has not engaged, and
will not engage in in any of the capacities contemplated by Section
9(a) of the Act.
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5. Applicants assert that neither the protection of investors nor
the public interest would be served by permitting the section 9(a)
disqualifications to apply to the Fund Servicing Applicants because
those disqualifications would deprive the Fund of the advisory or sub-
advisory services that shareholders expected the Funds would receive
when they decided to invest in the Funds. Applicants also assert that
the prohibitions of section 9(a) could operate to the financial
detriment of the Funds and their shareholders, which would be an unduly
and disproportionately severe consequence given that the Conduct did
not involve any of the Fund Service Activities.
6. Applicants further represent that the inability of the Fund
Servicing Applicants to continue providing investment advisory services
to Funds would result in the Funds and their shareholders facing
potential hardship, as described in the application. Applicants assert
that if the Fund Servicing Applicants were barred under section 9(a)
from providing investment advisory services to the Funds and were
unable to obtain the requested exemption, the effect on their
businesses and employees would be severe. Applicants state that the
Fund Servicing Applicants have committed substantial capital and other
resources to establishing expertise in advising and sub-advising Funds
with a view to continuing and expanding this business, which Applicants
consider strategically important. Applicants further state that
prohibiting the Fund Servicing Applicants from engaging in Fund Service
Activities would not only adversely affect their business, but would
also adversely affect their employees who are involved in these
activities. In addition, Applicants assert that if the Fund Servicing
Applicants or Covered Persons are unable to expand their businesses in
the future because of the imposition of the section 9(a)
disqualification, it could also have an adverse impact on their
businesses.
7. Applicants represent that: (1) None of the current or former
directors, officers or employees of Applicants had any involvement in
the Conduct; (2) no current or former employee of the Pleading Entity
or of any other Covered Person who previously has been or who
subsequently may be identified by the Pleading Entity or any U.S. or
non-U.S. regulatory or enforcement agencies as having been responsible
for the Conduct will be an officer, director, or employee of any
Covered Person; (3) the identified employee has had no, and will not
have any future, involvement in the Covered Persons' activities in any
capacity described in section 9(a) of the Act; and (4) because the
personnel of Applicants did not have any involvement in the Conduct,
shareholders of the Fund were not affected any differently than if the
Fund had received services from any other non-affiliated investment
adviser.
8. Applicants have agreed that none of BNPP, the Applicants or any
of the other Covered Persons will employ the former employee of an
affiliate of the Pleading Entity or any other person who subsequently
may be identified by the Pleading Entity or any U.S. or non-U.S.
regulatory or enforcement agencies as having been responsible for the
Conduct in any capacity without first making a further application to
the Commission pursuant to section 9(c).
9. Applicants have also agreed that BNPP and each Applicant and
Covered Person will adopt and implement policies and procedures
reasonably designed to ensure compliance with the
[[Page 4526]]
terms and conditions of the Orders granted under section 9(c).
10. In addition, BNPP and each Applicant and Covered Person will
comply in all material respects with the material terms and conditions
of the Plea Agreement and with the materials terms of the FRB Order,
the DFS Order any other orders issued by regulatory or enforcement
agencies addressing the Conduct. Applicants further state that BNPP and
its affiliates have undertaken certain remedial measures, as described
in greater detail in the application. These include certain remedial
measures as required by the Plea Agreement, the FRB Order, and the DFS
Order, including improvements to the oversight, internal controls and
compliance program, compliance risk management program, and internal
audit program for FX trading. Applicants state that BNPP and its
affiliates have taken a number of steps to enhance its internal
controls, policies and procedures relating to its FX activities.
Specifically, Applicants represent BNPP has devised and implemented new
global detailed FX-specific policies and procedures and a comprehensive
program to change the culture of the business with the aim that each
individual within the business understands their responsibility for
proper conduct and compliance. Applicants also represent that BNPP has
globally rolled out culture and conduct workshops and training on
BNPP's Foreign Exchange Local Markets remediation program.
Additionally, Applicants represent that supervisors have been given
increased tools to directly oversee their staff and identify conduct
issues more effectively, permanent cross-bank chat rooms have been
prohibited, and reverse trades are monitored through software designed
to detect transactions (proprietary and customer) that were not exposed
to the risk of the market and did not result in a change of beneficial
ownership.
11. As a result of the foregoing, the Applicants submit that
granting the exemption as requested in the application is consistent
with the public interest and the protection of investors.
12. To provide further assurance that the exemptive relief being
requested herein would be consistent with the public interest and the
protection of the investors, the Applicants agree that they will, as
soon as reasonably practical, distribute to the boards of directors or
trustees of the Funds (``Board'') written materials describing the
circumstances that led to the Plea Agreement, as well as any effects on
the Funds and the application. The written materials will include an
offer to discuss the materials at an in-person meeting with the Board,
including the directors who are not ``interested persons'' of the Funds
as defined in section 2(a)(19) of the Act and their ``independent legal
counsel'' as defined in rule 0-1(a)(6) under the Act, if any. The
Applicants undertake to provide the Boards with all information
concerning the Plea Agreement and the application as necessary for
those Funds to fulfill their disclosure and other obligations under the
U.S. federal securities laws and will provide them a copy of the
Judgment as entered by the District Court.
13. Applicants state that certain of the Applicants and their
affiliates have previously received an order under section 9(c) of the
Act, as the result of conduct that triggered section 9(a), as described
in greater detail in the application.
Applicants' Conditions
Applicants agree that any order granted by the Commission pursuant
to the application will be subject to the following conditions:
1. Any temporary exemption granted pursuant to the application will
be without prejudice to, and will not limit the Commission's rights in
any manner with respect to, any Commission investigation of, or
administrative proceedings involving or against, Covered Persons,
including, without limitation, the consideration by the Commission of a
permanent exemption from section 9(a) of the Act requested pursuant to
the application or the revocation or removal of any temporary
exemptions granted under the Act in connection with the application.
2. None of BNPP, the Applicants or any of the other Covered Persons
will employ the former employee of an affiliate of the Pleading Entity
or any other person who subsequently may be identified by the Pleading
Entity or any U.S. or non-U.S. regulatory or enforcement agencies as
having been responsible for the Conduct in any capacity without first
making a further application to the Commission pursuant to section
9(c).
3. BNPP and each Applicant and Covered Person will adopt and
implement policies and procedures reasonably designed to ensure that it
will comply with the terms and conditions of the Orders within 60 days
of the date of the Permanent Order or, with respect to condition four,
such later date or dates as may be contemplated by the FRB Order, the
DFS Order or any other orders issued by regulatory or enforcement
agencies addressing the Conduct.
4. BNPP and each Applicant and Covered Person will comply in all
material respects with the material terms and conditions of the Plea
Agreement and with the material terms of the FRB Order, the DFS Order
and any other orders issued by regulatory or enforcement agencies
addressing the Conduct.
5. Applicants will provide written notification to the Chief
Counsel of the Commission's Division of Investment Management with a
copy to the Chief Counsel of the Commission's Division of Enforcement
of a material violation of the terms and conditions of any of the
Orders within 30 days of discovery of the material violation.
Temporary Order
The Commission has considered the matter and finds that Applicants
have made the necessary showing to justify granting a temporary
exemption.
Accordingly,
It is hereby ordered, pursuant to section 9(c) of the Act, that the
Applicants and any other Covered Persons are granted a temporary
exemption from the provisions of section 9(a), effective as the date of
the Guilty Plea, solely with respect to the Guilty Plea entered into
pursuant to the Plea Agreement, subject to the representations and
conditions in the application, until the Commission takes final action
on their application for a permanent order.
By the Commission.
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2018-01905 Filed 1-30-18; 8:45 am]
BILLING CODE 8011-01-P