Thrivent Financial for Lutherans, et al., 40587-40591 [2018-17497]
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Federal Register / Vol. 83, No. 158 / Wednesday, August 15, 2018 / Notices
levels at a particular venue to be
excessive. In such an environment, the
Exchange must continually adjust its
fees to remain competitive with other
exchanges and to attract order flow. The
Exchange believes that the proposed
rule changes reflect this competitive
environment because they modify the
Exchange’s fees in a manner that
encourages market participants to
provide liquidity and to send order flow
to the Exchange rather than remove
liquidity from the market place.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
Written comments were neither
solicited nor received.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change has become
effective pursuant to Section
19(b)(3)(A)(ii) of the Act,18 and Rule
19b–4(f)(2) 19 thereunder. At any time
within 60 days of the filing of the
proposed rule change, the Commission
summarily may temporarily suspend
such rule change if it appears to the
Commission that such action is
necessary or appropriate in the public
interest, for the protection of investors,
or otherwise in furtherance of the
purposes of the Act. If the Commission
takes such action, the Commission shall
institute proceedings to determine
whether the proposed rule should be
approved or disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
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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–
MIAX–2018–21 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–MIAX–2018–21. This file
18 15
19 17
U.S.C. 78s(b)(3)(A)(ii).
CFR 240.19b–4(f)(2).
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number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
internet website (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 website viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE,
Washington, DC 20549 on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change.
Persons submitting comments are
cautioned that we do not redact or edit
personal identifying information from
comment submissions. You should
submit only information that you wish
to make available publicly. All
submissions should refer to File
Number SR–MIAX–2018–21, and
should be submitted on or before
September 5, 2018.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.20
Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2018–17493 Filed 8–14–18; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Investment Company Act Release No.
33197; File No. 812–14838]
Thrivent Financial for Lutherans, et al.
August 9, 2018.
Securities and Exchange
Commission (‘‘Commission’’).
ACTION: Notice.
AGENCY:
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.
20 17
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CFR 200.30–3(a)(12).
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Applicants
request an order to permit closed-end
management investment companies to
co-invest in portfolio companies with
each other and with certain affiliated
investment funds and accounts.
APPLICANTS: Thrivent Financial for
Lutherans (‘‘Thrivent Financial’’),
Thrivent Asset Management, LLC
(‘‘Thrivent Asset Management’’ and,
together with Thrivent Financial, the
‘‘Existing Advisers’’), and Thrivent
Church Loan and Income Fund
(‘‘Church Loan Fund’’ and, together
with the Existing Advisers, the
‘‘Applicants’’).
FILING DATES: The application was filed
on November 1, 2017, and amended on
March 28, 2018 and June 22, 2018.
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 September 4, 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 St.
NE, Washington, DC 20549–1090.
Applicants: 625 Fourth Avenue South,
Minneapolis, Minnesota 55415.
FOR FURTHER INFORMATION CONTACT: Jill
Ehrlich, Senior Counsel, at (202) 551–
6819, or Andrea Ottomanelli Magovern,
Branch Chief, at (202) 551–6821
(Division of Investment Management,
Chief Counsel’s Office).
SUPPLEMENTARY INFORMATION: The
following is a summary of the
application. The complete application
may be obtained via the Commission’s
website 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.
SUMMARY OF APPLICATION:
Applicants’ Representations
1. The Church Loan Fund is a
Delaware statutory trust that will be
registered as a non-diversified, closedend management investment company.
The Church Loan Fund’s investment
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objective will be to seek to produce
income. The Church Loan Fund expects
to have a policy of investing, under
normal market conditions, at least 80%
of its assets in Church Loans (as defined
below) and other fixed income
securities. The Church Loan Fund
anticipates that its board of trustees
(‘‘Board’’) 1 will have five trustees, four
of whom will not be ‘‘interested
persons’’ as that term is defined in
section 2(a)(19) of the Act.2
2. Thrivent Financial is organized and
operates as a ‘‘fraternal benefit society’’
as defined under the laws of the state of
Wisconsin. Thrivent Financial is an
integrated, not-for-profit, Christian
membership organization that provides
a broad range of financial products and
services. Thrivent Financial is also
registered as an investment adviser
under the Investment Advisers Act of
1940 (the ‘‘Advisers Act’’). Thrivent
Financial, among other investments,
invests in loans to support church longterm financing, which includes
construction and building related
activities (‘‘Church Loans’’). These
Church Loans are made by Thrivent
Financial from a portion of its general
account (‘‘Existing Proprietary
Account’’).3
3. Thrivent Asset Management is a
limited liability company organized
under the laws of Delaware and is
registered as an investment adviser
under the Advisers Act. Thrivent Asset
Management, a wholly owned indirect
subsidiary of Thrivent Financial, will
serve as the investment adviser to the
Church Loan Fund.
4. Applicants seek an order (‘‘Order’’)
to permit one or more Regulated Funds 4
and one or more Affiliated Accounts 5 to
1 The term ‘‘Board’’ refers to the board of directors
or trustees of any Regulated Fund (as defined
below).
2 The term ‘‘Independent Trustees’’ refers to the
directors or trustees of any Regulated Fund who are
not ‘‘interested persons’’ within the meaning of
section 2(a)(19) of the Act.
3 ‘‘Proprietary Account’’ means the Existing
Proprietary Account and any Future Proprietary
Accounts. ‘‘Future Proprietary Account’’ means any
direct or indirect, wholly- or majority-owned
subsidiary of the Advisers that is formed in the
future and, from time to time, may hold various
financial assets in a principal capacity and intends
to invest in the co-investment program. ‘‘Advisers’’
means (a) the Existing Advisers; and (b) any future
investment adviser that controls, is controlled by,
or is under common control with the Existing
Advisers and is registered as an investment adviser
under the Advisers Act.
4 ‘‘Regulated Funds’’ refers to the Church Loan
Fund and any Future Regulated Fund. ‘‘Future
Regulated Fund’’ means any closed-end
management investment company formed in the
future that is registered under the Act and is
advised by an Adviser.
5 ‘‘Affiliated Accounts’’ means any Proprietary
Accounts and Affiliated Funds. ‘‘Affiliated Fund’’
means any investment fund that would be an
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(a) participate in the same investment
opportunities through a proposed coinvestment program where such
participation would otherwise be
prohibited under section 17(d) of the
Act; and (b) make additional
investments in securities of such issuers
(‘‘Follow-On Investments’’), including
through the exercise of warrants,
conversion privileges, and other rights
to purchase securities of the issuers.
‘‘Co-Investment Transaction’’ means any
transaction in which a Regulated Fund
(or its Wholly-Owned Investment
Subsidiary, as defined below)
participate together with one or more
other Regulated Funds and/or Affiliated
Accounts in reliance on the requested
Order. ‘‘Potential Co-Investment
Transaction’’ means any investment
opportunity in which a Regulated Fund
(or its Wholly-Owned Investment
Subsidiaries) could not participate
together with one or more other
Regulated Funds and/or one or more
Affiliated Accounts without obtaining
and relying on the Order.6
5. Applicants state that a Regulated
Fund may, from time to time, form one
or more Wholly-Owned Investment
Subsidiaries.7 Such a subsidiary would
be prohibited from investing in a CoInvestment Transaction with any other
Regulated Fund or Affiliated Account
because it would be a company
controlled by its parent Regulated Fund
for purposes of rule 17d–1. Applicants
request that each Wholly-Owned
Investment Subsidiary be permitted to
participate in Co-Investment
Transactions in lieu of its parent
Regulated Fund and that the WhollyOwned Investment Subsidiary’s
participation in any such transaction be
treated, for purposes of the Order, as
‘‘investment company’’ but for section 3(c)(1) or
3(c)(7) of the Act, is formed in the future, and is
advised by the Advisers. No Affiliated Fund is or
will be a subsidiary of a Regulated Fund.
6 All existing entities that currently intend to rely
upon the requested Order have been named as
applicants. Any other existing or future entity that
subsequently relies on the Order will comply with
the terms and conditions of the application.
7 The term ‘‘Wholly-Owned Investment
Subsidiary’’ means any entity: (i) That is whollyowned by a Regulated Fund (with such Regulated
Fund at all times holding, beneficially and of
record, 100% of the voting and economic interests);
(ii) whose sole business purpose is to hold one or
more investments on behalf of such Regulated
Fund; (iii) with respect to which the board of
trustees of such Regulated Fund has the sole
authority to make all determinations with respect
to the entity’s participation under the conditions of
the application; and (iv) that would be an
investment company but for section 3(c)(1) or
3(c)(7) of the Act. All subsidiaries participating in
Co-Investment Transactions will be Wholly-Owned
Investment Subsidiaries and will have Objectives
and Strategies (as defined below) that are either the
same as, or a subset of, their parent Regulated
Fund’s Objectives and Strategies.
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though the parent 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 the Regulated Fund
and the Wholly-Owned Investment
Subsidiary. The Regulated Fund’s Board
would make all relevant determinations
under the conditions with regard to a
Wholly-Owned Investment Subsidiary’s
participation in a Co-Investment
Transaction, and the Regulated Fund’s
Board would be informed of, and take
into consideration, any proposed use of
a Wholly-Owned Investment Subsidiary
in the Regulated Fund’s place. If the
Regulated Fund proposes to participate
in the same Co-Investment Transaction
with any of its Wholly-Owned
Investment Subsidiaries, the Board will
also be informed of, and take into
consideration, the relative participation
of the Regulated Fund and the WhollyOwned Investment Subsidiary.
6. When considering Potential CoInvestment Transactions for any
Regulated Fund, the relevant Adviser
will consider only the Objectives and
Strategies,8 investment policies,
investment positions, capital available
for investment, and other pertinent
factors applicable to that Regulated
Fund. The Advisers expect that any
portfolio company that is an appropriate
investment for a Regulated Fund should
also be an appropriate investment for
one or more other Regulated Funds and/
or one or more Affiliated Accounts, with
certain exceptions based on available
capital or diversification.9
7. Other than pro rata dispositions
and Follow-On Investments as provided
in conditions 7 and 8, and after making
the determinations required in
conditions 1 and 2(a), the applicable
Adviser will present each Potential CoInvestment Transaction and the
proposed allocation to the trustees of
the Board eligible to vote on that CoInvestment Transaction (the ‘‘Eligible
Trustees’’) 10 and the majority of such
trustees of the Board who are
Independent Trustees (a ‘‘Required
8 The term ‘‘Objectives and Strategies’’ means a
Regulated Fund’s investment objectives and
strategies as described in the Regulated Fund’s
registration statement on Form N–2, other filings
the Regulated Fund has made with the Commission
under the Securities Act of 1933, the Securities
Exchange Act of 1934 or the Act, and the Regulated
Fund’s reports to investors.
9 The Regulated Funds, however, will not be
obligated to invest, or co-invest, when investment
opportunities are referred to them.
10 Eligible Trustees may not have a financial
interest in such transaction, plan, or arrangement.
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Majority’’) will approve each CoInvestment Transaction prior to any
investment by the participating
Regulated Fund.
8. With respect to the pro rata
dispositions and Follow-On Investments
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 Regulated Fund
and each Affiliated Account in such
disposition is proportionate to its
outstanding investments in the issuer
immediately preceding the disposition
or Follow-On Investment, as the case
may be; and (ii) the Board of the
Regulated Fund has approved that
Regulated Fund’s participation in pro
rata dispositions and Follow-On
Investments as being in the best
interests of the Regulated Fund. If the
Board does not so approve, any such
disposition or Follow-On Investment
will be submitted to the Regulated
Fund’s Eligible Trustees. The Board of
any Regulated Fund may at any time
rescind, suspend or qualify its approval
of pro rata dispositions and Follow-On
Investments with the result that all
dispositions and/or Follow-On
Investments must be submitted to the
Eligible Trustees.
9. No Independent Trustee of a
Regulated Fund will have a direct or
indirect financial interest in any CoInvestment Transaction (other than
indirectly through share ownership in
one of the Regulated Funds), including
any interest in any issuer whose
securities would be acquired in a CoInvestment Transaction.
10. Under condition 16, if an Adviser,
its principals, or any person controlling,
controlled by, or under common control
with the Adviser or its principals, and
the Affiliated Accounts (collectively, the
‘‘Holders’’) own in the aggregate more
than 25 percent of the outstanding
voting shares of a Regulated Fund (the
‘‘Shares’’), then the Holders will vote
such Shares as directed by an
independent third party when voting on
matters specified in the condition.
Applicants believe that this condition
will ensure that the Independent
Trustees will act independently in
evaluating the co-investment program,
because the ability of an Adviser or the
principals to influence the Independent
Trustees by a suggestion, explicit or
implied, that the Independent Trustees
can be removed will be limited
significantly. The Independent Trustees
shall evaluate and approve any such
independent third party, taking into
account its qualifications, reputation for
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independence, cost to the investors, and
other factors that they deem relevant.
Applicants’ Legal Analysis
1. Section 17(d) of the Act and rule
17d–1 under the Act prohibit 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 considers whether the
company’s participation in the joint
transaction is consistent with the
provisions, policies, and purposes of the
Act and the extent to which such
participation is on a basis different from
or less advantageous than that of other
participants.
3. Applicants state that in the absence
of the requested relief, the Regulated
Funds may be, in some circumstances,
limited in their ability to participate in
attractive and appropriate investment
opportunities. Applicants believe that
the proposed terms and conditions will
ensure that the 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 state that the
Regulated Funds’ 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 the Order will
be subject to the following conditions:
1. Each time an Adviser considers a
Potential Co-Investment Transaction for
another Regulated Fund or an Affiliated
Account 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 the 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, the
Adviser 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
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40589
and Affiliated Accounts, 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
Trustees of each participating Regulated
Fund with information concerning each
participating party’s available capital to
assist the Eligible Trustees 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 Regulated Fund and
each Affiliated Account) to the Eligible
Trustees of each participating Regulated
Fund for their consideration. A
Regulated Fund will co-invest with
another Regulated Fund or an Affiliated
Account 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
investors and do not involve
overreaching in respect of the Regulated
Fund or its investors on the part of any
person concerned;
(ii) the Potential Co-Investment
Transaction is consistent with:
(A) The interests of the Regulated
Fund’s investors; and
(B) the Regulated Fund’s then-current
Objectives and Strategies;
(iii) the investment by any other
Regulated Funds or any Affiliated
Accounts 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 any other Regulated Funds
or any Affiliated Accounts; provided
that, if any other Regulated Fund or any
Affiliated Account, but not the
Regulated Fund itself gains the right to
nominate a director for election to a
portfolio company’s board of directors
or the right to have a board observer or
any similar right to participate in the
governance or management of the
portfolio company, such event shall not
be interpreted to prohibit the Required
Majority from reaching the conclusions
required by this condition (2)(c)(iii), if:
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(A) The Eligible Trustees will have
the right to ratify the selection of such
director or board observer, if any; and
(B) the applicable Adviser agrees to,
and does, provide periodic reports to
the Board of the Regulated Fund 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 Regulated Fund or any
Affiliated Account or any affiliated
person of any Regulated Fund or any
Affiliated Account receives in
connection with the right of a Regulated
Fund or an Affiliated Account to
nominate a director or appoint a board
observer or otherwise to participate in
the governance or management of the
portfolio company will be shared
proportionately among the participating
Affiliated Accounts (who may each, 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 any
Adviser, the other Regulated Funds, the
Affiliated Accounts, 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, as applicable, (C) indirectly, as a
result of an interest in the securities
issued by one of the parties to the CoInvestment 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 Accounts
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 Securities
and Exchange Commission and its staff.
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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 Account, or any affiliated
person of another Regulated Fund or
Affiliated Account 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 the
same for each participating Regulated
Fund and Affiliated Account. The grant
to another Regulated Fund or Affiliated
Account, but not the Regulated Fund, of
the right to nominate a director for
election to a portfolio company’s board
of directors or the right to have a board
observer or any similar right to
participate in the governance or
management of the portfolio company
will not be interpreted so as to violate
this condition 6, if conditions
2(c)(iii)(A), (B) and (C) are met.
7. (a) If any Regulated Fund or an
Affiliated Account 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 Regulated Funds and
Affiliated Accounts.
(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
Account 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 the
application); and (iii) the Board of the
Regulated Fund is provided on a
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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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 Regulated
Fund’s Eligible Trustees, 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 Regulated Fund and each
Affiliated Account will bear its own
expenses in connection with any such
disposition.
8. (a) If a Regulated Fund or an
Affiliated Account 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 Account 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
the application). In all other cases, the
Adviser will provide its written
recommendation as to the Regulated
Fund’s participation to the Eligible
Trustees, 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 a Follow-On
Investment is not based on the
Regulated Funds’ and the Affiliated
Accounts’ 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 Accounts in
the same transaction, exceeds the
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daltland on DSKBBV9HB2PROD with NOTICES
Federal Register / Vol. 83, No. 158 / Wednesday, August 15, 2018 / Notices
amount of the opportunity; then the
amount invested by each such party will
be allocated among them pro rata based
on each party’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. The Independent Trustees 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 and the
Affiliated Accounts that the Regulated
Fund considered but declined to
participate in, so that the Independent
Trustees may determine whether all
investments made during the preceding
quarter, including those investments
which the Regulated Fund considered
but declined to participate in, comply
with the conditions of the Order. In
addition, the Independent Trustees will
consider at least annually the continued
appropriateness for the Regulated Fund
of participating in new and existing CoInvestment Transactions.
10. Each Regulated Fund will
maintain the records required by section
57(f)(3) of the Act as if each of the
Regulated Funds were a business
development company (as defined in
section 2(a)(48) of the Act) and each of
the investments permitted under these
conditions were approved by the
Required Majority under section 57(f) of
the Act.
11. No Independent Trustee of a
Regulated Fund will also be a director,
trustee, general partner, managing
member or principal, or otherwise an
‘‘affiliated person’’ (as defined in the
Act), of an Affiliated Account.
12. The expenses, if any, associated
with acquiring, holding or disposing of
any securities acquired in a CoInvestment Transaction (including,
without limitation, the expenses of the
distribution of any such securities
registered for sale under the Securities
Act of 1933) will, to the extent not
payable by an Adviser under the
investment advisory agreements with
the Regulated Funds and the Affiliated
Accounts be shared by the Affiliated
Accounts and the Regulated Funds in
proportion to the relative amounts of the
securities held or to be acquired or
disposed of, as the case may be.
VerDate Sep<11>2014
18:28 Aug 14, 2018
Jkt 244001
13. Any transaction fee 12 (including
break-up or commitment fees but
excluding broker’s fees contemplated by
section 17(e) of the Act, as applicable),
received in connection with a CoInvestment Transaction will be
distributed to the participating
Regulated Funds and Affiliated
Accounts 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 Accounts based on the
amounts they invest in such CoInvestment Transaction. None of the
Affiliated Accounts, the Advisers, the
other Regulated Funds or any affiliated
person of the Regulated Funds or
Affiliated Accounts 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 Accounts, the pro rata
transaction fees described above and
fees or other compensation described in
condition 2(c)(iii)(C); and (b) in the case
of the Advisers, investment advisory
fees paid in accordance with the
agreements between the Advisers and
the Regulated Funds or the Affiliated
Accounts).
14. The Proprietary Accounts will not
be permitted to invest in a Potential CoInvestment Transaction except to the
extent the demand from the Regulated
Funds and the other Affiliated Accounts
is less than the total investment
opportunity.
15. The Advisers will each maintain
policies and procedures reasonably
designed to ensure compliance with the
foregoing conditions. These policies and
procedures will require, among other
things, that the applicable Adviser will
be notified of all Potential CoInvestment Transactions that fall within
a Regulated Fund’s then-current
Objectives and Strategies and will be
given sufficient information to make its
independent determination and
recommendations under conditions 1,
2(a), 7 and 8.
12 Applicants are not requesting and the staff is
not providing any relief for transaction fees
received in connection with any Co-Investment
Transaction.
PO 00000
Frm 00093
Fmt 4703
Sfmt 4703
40591
16. If the Holders own in the aggregate
more than 25 percent of the Shares of
a Regulated Fund, then the Holders will
vote such Shares as directed by an
independent third party when voting on
(1) the election of trustees; (2) the
removal of one or more trustees; or (3)
all other matters under either the Act or
applicable State law affecting the
Board’s composition, size or manner of
election.
17. Each Regulated Fund’s chief
compliance officer, as defined in Rule
38a–1(a)(4) under 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. 2018–17497 Filed 8–14–18; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–83810; File No. SR–BX–
2018–036]
Self-Regulatory Organizations; Nasdaq
BX, Inc.; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change To Incorporate BX Rule
7039 Into the Market Data Enterprise
License Proposed by the Nasdaq
Stock Market LLC
August 9, 2018.
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 July 27,
2018, Nasdaq BX, Inc. (‘‘BX’’ or
‘‘Exchange’’) filed with the Securities
and Exchange Commission (‘‘SEC’’ or
‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III, below, which Items have been
prepared by the Exchange. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
This amendment is immediately
effective upon filing.3
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 This proposed change was initially filed on July
3, 2018, and became immediately effective on that
date. See SR–BX–2018–031, available at https://
nasdaq.cchwallstreet.com/. It was subsequently
refiled on July 17, 2018. See SR–BX–2018–034,
available at https://nasdaq.cchwallstreet.com/. A
2 17
E:\FR\FM\15AUN1.SGM
Continued
15AUN1
Agencies
[Federal Register Volume 83, Number 158 (Wednesday, August 15, 2018)]
[Notices]
[Pages 40587-40591]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-17497]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Investment Company Act Release No. 33197; File No. 812-14838]
Thrivent Financial for Lutherans, et al.
August 9, 2018.
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 closed-
end management investment companies to co-invest in portfolio companies
with each other and with certain affiliated investment funds and
accounts.
Applicants: Thrivent Financial for Lutherans (``Thrivent Financial''),
Thrivent Asset Management, LLC (``Thrivent Asset Management'' and,
together with Thrivent Financial, the ``Existing Advisers''), and
Thrivent Church Loan and Income Fund (``Church Loan Fund'' and,
together with the Existing Advisers, the ``Applicants'').
Filing Dates: The application was filed on November 1, 2017, and
amended on March 28, 2018 and June 22, 2018.
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 September 4, 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
St. NE, Washington, DC 20549-1090. Applicants: 625 Fourth Avenue South,
Minneapolis, Minnesota 55415.
FOR FURTHER INFORMATION CONTACT: Jill Ehrlich, Senior Counsel, at (202)
551-6819, or Andrea Ottomanelli Magovern, Branch Chief, at (202) 551-
6821 (Division of Investment Management, Chief Counsel's Office).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application may be obtained via the
Commission's website 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 Church Loan Fund is a Delaware statutory trust that will be
registered as a non-diversified, closed-end management investment
company. The Church Loan Fund's investment
[[Page 40588]]
objective will be to seek to produce income. The Church Loan Fund
expects to have a policy of investing, under normal market conditions,
at least 80% of its assets in Church Loans (as defined below) and other
fixed income securities. The Church Loan Fund anticipates that its
board of trustees (``Board'') \1\ will have five trustees, four of whom
will not be ``interested persons'' as that term is defined in section
2(a)(19) of the Act.\2\
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\1\ The term ``Board'' refers to the board of directors or
trustees of any Regulated Fund (as defined below).
\2\ The term ``Independent Trustees'' refers to the directors or
trustees of any Regulated Fund who are not ``interested persons''
within the meaning of section 2(a)(19) of the Act.
---------------------------------------------------------------------------
2. Thrivent Financial is organized and operates as a ``fraternal
benefit society'' as defined under the laws of the state of Wisconsin.
Thrivent Financial is an integrated, not-for-profit, Christian
membership organization that provides a broad range of financial
products and services. Thrivent Financial is also registered as an
investment adviser under the Investment Advisers Act of 1940 (the
``Advisers Act''). Thrivent Financial, among other investments, invests
in loans to support church long-term financing, which includes
construction and building related activities (``Church Loans''). These
Church Loans are made by Thrivent Financial from a portion of its
general account (``Existing Proprietary Account'').\3\
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\3\ ``Proprietary Account'' means the Existing Proprietary
Account and any Future Proprietary Accounts. ``Future Proprietary
Account'' means any direct or indirect, wholly- or majority-owned
subsidiary of the Advisers that is formed in the future and, from
time to time, may hold various financial assets in a principal
capacity and intends to invest in the co-investment program.
``Advisers'' means (a) the Existing Advisers; and (b) any future
investment adviser that controls, is controlled by, or is under
common control with the Existing Advisers and is registered as an
investment adviser under the Advisers Act.
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3. Thrivent Asset Management is a limited liability company
organized under the laws of Delaware and is registered as an investment
adviser under the Advisers Act. Thrivent Asset Management, a wholly
owned indirect subsidiary of Thrivent Financial, will serve as the
investment adviser to the Church Loan Fund.
4. Applicants seek an order (``Order'') to permit one or more
Regulated Funds \4\ and one or more Affiliated Accounts \5\ to (a)
participate in the same investment opportunities through a proposed co-
investment program where such participation would otherwise be
prohibited under section 17(d) of the Act; and (b) make additional
investments in securities of such issuers (``Follow-On Investments''),
including through the exercise of warrants, conversion privileges, and
other rights to purchase securities of the issuers. ``Co-Investment
Transaction'' means any transaction in which a Regulated Fund (or its
Wholly-Owned Investment Subsidiary, as defined below) participate
together with one or more other Regulated Funds and/or Affiliated
Accounts in reliance on the requested Order. ``Potential Co-Investment
Transaction'' means any investment opportunity in which a Regulated
Fund (or its Wholly-Owned Investment Subsidiaries) could not
participate together with one or more other Regulated Funds and/or one
or more Affiliated Accounts without obtaining and relying on the
Order.\6\
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\4\ ``Regulated Funds'' refers to the Church Loan Fund and any
Future Regulated Fund. ``Future Regulated Fund'' means any closed-
end management investment company formed in the future that is
registered under the Act and is advised by an Adviser.
\5\ ``Affiliated Accounts'' means any Proprietary Accounts and
Affiliated Funds. ``Affiliated Fund'' means any investment fund that
would be an ``investment company'' but for section 3(c)(1) or
3(c)(7) of the Act, is formed in the future, and is advised by the
Advisers. No Affiliated Fund is or will be a subsidiary of a
Regulated Fund.
\6\ All existing entities that currently intend to rely upon the
requested Order have been named as applicants. Any other existing or
future entity that subsequently relies on the Order will comply with
the terms and conditions of the application.
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5. Applicants state that a Regulated Fund may, from time to time,
form one or more Wholly-Owned Investment Subsidiaries.\7\ Such a
subsidiary would be prohibited from investing in a Co-Investment
Transaction with any other Regulated Fund or Affiliated Account because
it would be a company controlled by its parent Regulated Fund for
purposes of rule 17d-1. Applicants request that each Wholly-Owned
Investment Subsidiary be permitted to participate in Co-Investment
Transactions in lieu of its parent Regulated Fund and that the Wholly-
Owned Investment Subsidiary's participation in any such transaction be
treated, for purposes of the Order, as though the parent 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 the Regulated Fund and the Wholly-Owned Investment Subsidiary.
The Regulated Fund's Board would make all relevant determinations under
the conditions with regard to a Wholly-Owned Investment Subsidiary's
participation in a Co-Investment Transaction, and the Regulated Fund's
Board would be informed of, and take into consideration, any proposed
use of a Wholly-Owned Investment Subsidiary in the Regulated Fund's
place. If the Regulated Fund proposes to participate in the same Co-
Investment Transaction with any of its Wholly-Owned Investment
Subsidiaries, the Board will also be informed of, and take into
consideration, the relative participation of the Regulated Fund and the
Wholly-Owned Investment Subsidiary.
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\7\ The term ``Wholly-Owned Investment Subsidiary'' means any
entity: (i) 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); (ii) whose sole business
purpose is to hold one or more investments on behalf of such
Regulated Fund; (iii) with respect to which the board of trustees of
such Regulated Fund has the sole authority to make all
determinations with respect to the entity's participation under the
conditions of the application; and (iv) that would be an investment
company but for section 3(c)(1) or 3(c)(7) of the Act. All
subsidiaries participating in Co-Investment Transactions will be
Wholly-Owned Investment Subsidiaries and will have Objectives and
Strategies (as defined below) that are either the same as, or a
subset of, their parent Regulated Fund's Objectives and Strategies.
---------------------------------------------------------------------------
6. When considering Potential Co-Investment Transactions for any
Regulated Fund, the relevant Adviser will consider only the Objectives
and Strategies,\8\ investment policies, investment positions, capital
available for investment, and other pertinent factors applicable to
that Regulated Fund. The Advisers expect that any portfolio company
that is an appropriate investment for a Regulated Fund should also be
an appropriate investment for one or more other Regulated Funds and/or
one or more Affiliated Accounts, with certain exceptions based on
available capital or diversification.\9\
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\8\ The term ``Objectives and Strategies'' means a Regulated
Fund's investment objectives and strategies as described in the
Regulated Fund's registration statement on Form N-2, other filings
the Regulated Fund has made with the Commission under the Securities
Act of 1933, the Securities Exchange Act of 1934 or the Act, and the
Regulated Fund's reports to investors.
\9\ The Regulated Funds, however, will not be obligated to
invest, or co-invest, when investment opportunities are referred to
them.
---------------------------------------------------------------------------
7. Other than pro rata dispositions and Follow-On Investments as
provided in conditions 7 and 8, and after making the determinations
required in conditions 1 and 2(a), the applicable Adviser will present
each Potential Co-Investment Transaction and the proposed allocation to
the trustees of the Board eligible to vote on that Co-Investment
Transaction (the ``Eligible Trustees'') \10\ and the majority of such
trustees of the Board who are Independent Trustees (a ``Required
[[Page 40589]]
Majority'') will approve each Co-Investment Transaction prior to any
investment by the participating Regulated Fund.
---------------------------------------------------------------------------
\10\ Eligible Trustees may not have a financial interest in such
transaction, plan, or arrangement.
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8. With respect to the pro rata dispositions and Follow-On
Investments 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 Regulated Fund and each
Affiliated Account in such disposition is proportionate to its
outstanding investments in the issuer immediately preceding the
disposition or Follow-On Investment, as the case may be; and (ii) the
Board of the Regulated Fund has approved that Regulated Fund's
participation in pro rata dispositions and Follow-On Investments as
being in the best interests of the Regulated Fund. If the Board does
not so approve, any such disposition or Follow-On Investment will be
submitted to the Regulated Fund's Eligible Trustees. The Board of any
Regulated Fund may at any time rescind, suspend or qualify its approval
of pro rata dispositions and Follow-On Investments with the result that
all dispositions and/or Follow-On Investments must be submitted to the
Eligible Trustees.
9. No Independent Trustee of a Regulated Fund will have a direct or
indirect financial interest in any Co-Investment Transaction (other
than indirectly through share ownership in one of the Regulated Funds),
including any interest in any issuer whose securities would be acquired
in a Co-Investment Transaction.
10. Under condition 16, if an Adviser, its principals, or any
person controlling, controlled by, or under common control with the
Adviser or its principals, and the Affiliated Accounts (collectively,
the ``Holders'') own in the aggregate more than 25 percent of the
outstanding voting shares of a Regulated Fund (the ``Shares''), then
the Holders will vote such Shares as directed by an independent third
party when voting on matters specified in the condition. Applicants
believe that this condition will ensure that the Independent Trustees
will act independently in evaluating the co-investment program, because
the ability of an Adviser or the principals to influence the
Independent Trustees by a suggestion, explicit or implied, that the
Independent Trustees can be removed will be limited significantly. The
Independent Trustees shall evaluate and approve any such independent
third party, taking into account its qualifications, reputation for
independence, cost to the investors, and other factors that they deem
relevant.
Applicants' Legal Analysis
1. Section 17(d) of the Act and rule 17d-1 under the Act prohibit
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 considers
whether the company's participation in the joint transaction is
consistent with the provisions, policies, and purposes of the Act and
the extent to which such participation is on a basis different from or
less advantageous than that of other participants.
3. Applicants state that in the absence of the requested relief,
the Regulated Funds may be, in some circumstances, limited in their
ability to participate in attractive and appropriate investment
opportunities. Applicants believe that the proposed terms and
conditions will ensure that the 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 state that the Regulated Funds' 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 the Order will be subject to the following
conditions:
1. Each time an Adviser considers a Potential Co-Investment
Transaction for another Regulated Fund or an Affiliated Account 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 the 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, the Adviser 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 Accounts,
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 Trustees of each participating Regulated Fund with
information concerning each participating party's available capital to
assist the Eligible Trustees 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 Regulated Fund and each
Affiliated Account) to the Eligible Trustees of each participating
Regulated Fund for their consideration. A Regulated Fund will co-invest
with another Regulated Fund or an Affiliated Account 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 investors and do not involve overreaching in respect of
the Regulated Fund or its investors on the part of any person
concerned;
(ii) the Potential Co-Investment Transaction is consistent with:
(A) The interests of the Regulated Fund's investors; and
(B) the Regulated Fund's then-current Objectives and Strategies;
(iii) the investment by any other Regulated Funds or any Affiliated
Accounts 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 any other Regulated Funds or any Affiliated
Accounts; provided that, if any other Regulated Fund or any Affiliated
Account, but not the Regulated Fund itself gains the right to nominate
a director for election to a portfolio company's board of directors or
the right to have a board observer or any similar right to participate
in the governance or management of the portfolio company, such event
shall not be interpreted to prohibit the Required Majority from
reaching the conclusions required by this condition (2)(c)(iii), if:
[[Page 40590]]
(A) The Eligible Trustees will have the right to ratify the
selection of such director or board observer, if any; and
(B) the applicable Adviser agrees to, and does, provide periodic
reports to the Board of the Regulated Fund 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 Regulated Fund or any
Affiliated Account or any affiliated person of any Regulated Fund or
any Affiliated Account receives in connection with the right of a
Regulated Fund or an Affiliated Account to nominate a director or
appoint a board observer or otherwise to participate in the governance
or management of the portfolio company will be shared proportionately
among the participating Affiliated Accounts (who may each, 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
any Adviser, the other Regulated Funds, the Affiliated Accounts, 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,
as applicable, (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 Accounts 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 Securities and
Exchange 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
Account, or any affiliated person of another Regulated Fund or
Affiliated Account 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 the same for each participating Regulated Fund and Affiliated
Account. The grant to another Regulated Fund or Affiliated Account, but
not the Regulated Fund, of the right to nominate a director for
election to a portfolio company's board of directors or the right to
have a board observer or any similar right to participate in the
governance or management of the portfolio company will not be
interpreted so as to violate this condition 6, if conditions
2(c)(iii)(A), (B) and (C) are met.
7. (a) If any Regulated Fund or an Affiliated Account 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 Regulated
Funds and Affiliated Accounts.
(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 Account 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 the 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 Regulated Fund's
Eligible Trustees, 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 Regulated Fund and each Affiliated Account will bear its
own expenses in connection with any such disposition.
8. (a) If a Regulated Fund or an Affiliated Account 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
Account 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 the application). In all other cases, the Adviser
will provide its written recommendation as to the Regulated Fund's
participation to the Eligible Trustees, 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 a Follow-On Investment is not based on the
Regulated Funds' and the Affiliated Accounts' 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 Accounts
in the same transaction, exceeds the
[[Page 40591]]
amount of the opportunity; then the amount invested by each such party
will be allocated among them pro rata based on each party'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. The Independent Trustees 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 and the Affiliated Accounts that the Regulated
Fund considered but declined to participate in, so that the Independent
Trustees may determine whether all investments made during the
preceding quarter, including those investments which the Regulated Fund
considered but declined to participate in, comply with the conditions
of the Order. In addition, the Independent Trustees will consider at
least annually the continued appropriateness for the Regulated Fund of
participating in new and existing Co-Investment Transactions.
10. Each Regulated Fund will maintain the records required by
section 57(f)(3) of the Act as if each of the Regulated Funds were a
business development company (as defined in section 2(a)(48) of the
Act) and each of the investments permitted under these conditions were
approved by the Required Majority under section 57(f) of the Act.
11. No Independent Trustee of a Regulated Fund will also be a
director, trustee, general partner, managing member or principal, or
otherwise an ``affiliated person'' (as defined in the Act), of an
Affiliated Account.
12. The expenses, if any, associated with acquiring, holding or
disposing of any securities acquired in a Co-Investment Transaction
(including, without limitation, the expenses of the distribution of any
such securities registered for sale under the Securities Act of 1933)
will, to the extent not payable by an Adviser under the investment
advisory agreements with the Regulated Funds and the Affiliated
Accounts be shared by the Affiliated Accounts and the Regulated 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 \12\ (including break-up or commitment fees
but excluding broker's fees contemplated by section 17(e) of the Act,
as applicable), received in connection with a Co-Investment Transaction
will be distributed to the participating Regulated Funds and Affiliated
Accounts 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 Accounts based on the
amounts they invest in such Co-Investment Transaction. None of the
Affiliated Accounts, the Advisers, the other Regulated Funds or any
affiliated person of the Regulated Funds or Affiliated Accounts 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 Accounts, the pro
rata transaction fees described above and fees or other compensation
described in condition 2(c)(iii)(C); and (b) in the case of the
Advisers, investment advisory fees paid in accordance with the
agreements between the Advisers and the Regulated Funds or the
Affiliated Accounts).
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\12\ Applicants are not requesting and the staff is not
providing any relief for transaction fees received in connection
with any Co-Investment Transaction.
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14. The Proprietary Accounts will not be permitted to invest in a
Potential Co-Investment Transaction except to the extent the demand
from the Regulated Funds and the other Affiliated Accounts is less than
the total investment opportunity.
15. The Advisers will each maintain policies and procedures
reasonably designed to ensure compliance with the foregoing conditions.
These policies and procedures will require, among other things, that
the applicable Adviser will be notified of all Potential Co-Investment
Transactions that fall within a Regulated Fund's then-current
Objectives and Strategies and will be given sufficient information to
make its independent determination and recommendations under conditions
1, 2(a), 7 and 8.
16. If the Holders own in the aggregate more than 25 percent of the
Shares of a Regulated Fund, then the Holders will vote such Shares as
directed by an independent third party when voting on (1) the election
of trustees; (2) the removal of one or more trustees; or (3) all other
matters under either the Act or applicable State law affecting the
Board's composition, size or manner of election.
17. Each Regulated Fund's chief compliance officer, as defined in
Rule 38a-1(a)(4) under 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. 2018-17497 Filed 8-14-18; 8:45 am]
BILLING CODE 8011-01-P