Form TA-1 Filer Information | UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM TA-1/A | OMB APPROVAL |
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TA-1/A : Filer Information
Form Version X0405 |
1(a). Filer CIK: | 0001407656 |
1(b). Filer CCC: | ******** |
1(c). Is this a LIVE or TEST submission? | Live Test |
1(d). Would you like a Return Copy? | Yes |
Submission Contact Information
The registrant may provide a single e-mail address for contact purposes.1(f)(i). Contact Name: | |
1(f)(ii). Contact Phone Number: | |
1(f)(iii). Contact E-Mail Address: |
Notification Information
The registrant may provide additional e-mail addresses for those persons the filer would like to receive notification e-mails regarding the filing.1(g). Notification E-mail Address: |
TA-1/A : Registrant Information
2. Appropriate regulatory agency (check one): | Securities and Exchange Commission Federal Deposit Insurance Corporation Comptroller of the Currency |
3(a). Full Name of Registrant: | INVESCO CANADA LTD. (FORMERLY INVESCO TRIMARK LTD.) |
3(a)(i). Previous name, if being amended: | INVESCO CANADA LTD. (FORMERLY INVESCO TRIMARK LTD) |
3(b). Financial Industry Number (FINS) number: | 331819 |
3(c). Address of principal office where transfer agent activities are, or will be, performed:
3(c)(i). Address 1 | 119 EUSTON STREET |
3(c)(ii). Address 2 | |
3(c)(iii). City | CHARLOTTETOWN |
3(c)(iv). State or Country | PRINCE EDWARD ISLAND, CANADA |
3(c)(v). Postal Code | C1A 1W3 |
3(d). Is Mailing address different from response to Question 3c? If "yes" provide address(es): | Yes No |
3(d)(i). Address 1 | SECRETARY, LEGAL DEPARTMENT |
3(d)(ii). Address 2 | 5140 YONGE STREET, SUITE 800 |
3(d)(iii). City | TORONTO |
3(d)(iv). State or Country | ONTARIO, CANADA |
3(d)(v). Postal Code | M2N 6X7 |
3(e). Telephone Number (Include Area Code) | 1-800-874-6275 |
4. Does Registrant conduct, or will it conduct, transfer agent activities at any location other than that given in Questions 3(c) above? If "Yes" provide address (es): | Yes No |
Other Business Location Record: 1 | |
4(a)(i). Address 1 | 5140 YONGE STREET |
4(a)(ii). Address 2 | SUITE 800 |
4(a)(iii). City | TORONTO |
4(a)(iv). State or Country | ONTARIO, CANADA |
4(a)(v). Postal Code | M2N 6X7 |
5. Does registrant act, or will it act, as a transfer agent solely for its own securities, and/or securities of an affiliate(s)? | Yes No |
6. Has registrant, as a named transfer agent, engaged, or will it engage, a service company to perform any transfer agent functions? | Yes No |
7. Has registrant been engaged, or will it be engaged as a service company by a named transfer agent to perform transfer agent functions? | Yes No |
7(a). Name | INVESCO INVESTMENT SERVICES, INC. |
7(b). File Number | |
7(c)(i). Address 1 | 11 GREENWAY PLAZA STE 1000 |
7(c)(ii). Address 2 | |
7(c)(iii). City | HOUSTON |
7(c)(iv). State or Country | TEXAS |
7(c)(v). Postal Code | 77046 |
TA-1/A : Independent, Non-Issuer Registrant Information
Completion of Question 8 on this form is required by all independent, non-issuer registrants whose appropriate regulatory authority is the Securities and Exchange Commission. Those registrants who are not required to complete Question 8 should select "Not Applicable".
8. Is registrant a: | Corporation |
Section for Initial Registration and for Amendments Reporting Additional Persons.
corporation or partner information Related to item 8 Record: 18(a)(i). Full Name | Harsh Damani |
8(a)(ii). Relationship Start Date | 12/07/2017 |
8(a)(iii). Title or Status | North America Head-Fund Acctg & Fund Exp |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | James Charles Russell |
8(a)(ii). Relationship Start Date | 01/01/2011 |
8(a)(iii). Title or Status | Director, Transfer Agency |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | James Douglas Kingston |
8(a)(ii). Relationship Start Date | 01/01/2011 |
8(a)(iii). Title or Status | Head of Product Management, ETFs and Alt |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | Harsh Damani |
8(a)(ii). Relationship Start Date | 01/01/2013 |
8(a)(iii). Title or Status | CFO Funds |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | Robert Brett Mikalachki |
8(a)(ii). Relationship Start Date | 04/13/2015 |
8(a)(iii). Title or Status | Chief Investment Officer |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date | 10/15/2020 |
8(a)(i). Full Name | Michael Henry Peck |
8(a)(ii). Relationship Start Date | 07/20/2015 |
8(a)(iii). Title or Status | SVP Institutional Investments |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | Invesco, Inc. |
8(a)(ii). Relationship Start Date | 11/30/2017 |
8(a)(iii). Title or Status | Sole Voting Shareholder |
8(a)(iv). Ownership Code | E |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | John Mark Zerr |
8(a)(ii). Relationship Start Date | 03/01/2019 |
8(a)(iii). Title or Status | President |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | John Mark Zerr |
8(a)(ii). Relationship Start Date | 03/01/2019 |
8(a)(iii). Title or Status | Director |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | John Mark Zerr |
8(a)(ii). Relationship Start Date | 03/01/2019 |
8(a)(iii). Title or Status | Chief Executive Officer |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | John Mark Zerr |
8(a)(ii). Relationship Start Date | 03/01/2019 |
8(a)(iii). Title or Status | Chairman |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | Harsh Damani |
8(a)(ii). Relationship Start Date | 06/10/2019 |
8(a)(iii). Title or Status | Director |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | James Charles Russell |
8(a)(ii). Relationship Start Date | 06/10/2019 |
8(a)(iii). Title or Status | Director |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | Jason MacKay |
8(a)(ii). Relationship Start Date | 06/10/2019 |
8(a)(iii). Title or Status | Director |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | Jason MacKay |
8(a)(ii). Relationship Start Date | 02/01/2018 |
8(a)(iii). Title or Status | Head of Wealth Management Intermediaries |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | Jacqueline (Kate) Archibald |
8(a)(ii). Relationship Start Date | 02/01/2020 |
8(a)(iii). Title or Status | SVP, Head of Compliance Canada |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | Shalomi Abraham |
8(a)(ii). Relationship Start Date | 08/19/2019 |
8(a)(iii). Title or Status | SVP, Head of Legal-Canada |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | Shalomi Abraham |
8(a)(ii). Relationship Start Date | 01/01/2019 |
8(a)(iii). Title or Status | Secretary |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
8(a)(i). Full Name | Jasmin Jabri |
8(a)(ii). Relationship Start Date | 10/08/2019 |
8(a)(iii). Title or Status | Senior Vice President, Compliance |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date | 03/31/2020 |
8(a)(i). Full Name | Jacqueline (Kate) Archibald |
8(a)(ii). Relationship Start Date | 02/24/2020 |
8(a)(iii). Title or Status | Chief Compliance Officer |
8(a)(iv). Ownership Code | NA |
8(a)(v). Control Person | Yes |
8(a)(vi). Relationship End Date |
9. Does any person or entity not named in the answer to Question 8:
9(a). directly or indirectly, through agreement or otherwise exercise or have the power to exercise control over the management or policies of applicant, or;…. | Yes No |
9(b). wholly or partially finance the business of the applicant, directly or indirectly, in any manner other than by a public offering of securities made pursuant to the Securities Act of 1933 or by credit extended in the ordinary course of business by suppliers, banks and others?….. | Yes No |
TA-1/A : 10. Applicant and Control Affiliate Disciplinary History
The following definitions apply for purposes of answering this Question 10
Control Affiliate | - An individual or firm that directly or indirectly controls, is under common control with, or is controlled by applicant. Included are any employees identified in 8(a), 8(b), 8(c) of this form as exercising control. Excluded are any employees who perform solely clerical, administrative support of similar functions, or who, regardless of title, perform no executive duties or have no senior policy making authority. |
Investment or investment related | - Pertaining to securities, commodities, banking, insurance, or real estate (including, but not limited to, acting as or being associated with a broker dealer, investment company, investment adviser, futures sponsor, bank, or savings and loan association). |
Involved | - Doing an act of aiding, abetting, counseling, commanding, inducing, conspiring with or failing reasonably to supervise another in doing an act. |
10(a). In the past ten years has the applicant or a control affiliate been convicted of or plead guilty or nolo contendere ("no contest") to:
10(a)(1). a felony or misdemeanor involving: investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, or bribery, forgery, counterfeiting, or extortion? | Yes No |
10(a)(2). any other felony? | Yes No |
10(b). Has any court in the past ten years: | |
10(b)(1). enjoined the applicant or a control affiliate in connection with any investment-related activity? | Yes No |
10(b)(2). found that the applicant or control affiliate was involved in a violation of investment-related statutes or regulations? | Yes No |
10 (c). Has the U.S. Securities and Exchange Commission or the Commodity Futures Trading Commission ever: | |
10(c)(1). found the applicant or control affiliate to have made a false statement or omission? | Yes No |
Entity information Related to item 10(c)(1) Record: 1
10(c)(1)(i). The individuals named in the Action | INVESCO Funds Group Inc. INVESCO |
10(c)(1)(ii). Title of Action | Docket 03CV2421 |
10(c)(1)(iii). Date of Action | 12/02/2003 |
10(c)(1)(iv). The Court or body taking the Action and its location | United States Securities and Exchange Commission SEC |
10(c)(1)(v). Description of the Action | On October 8, 2004, the U.S. Securities and Exchange Commission ("SEC") settled an administrative proceeding against AIM Advisors, Inc. (n/k/a Invesco Advisers, Inc.) ("AIM"), Invesco Funds Group, Inc. ("IFG") and AIM Distributors, Inc. (n/k/a Invesco Distributors, Inc.) ("ADI") (collectively, "Respondents"). The allegations concerned market timing of and late trading by the proprietary mutual funds and a failure to disclose such arrangements, in violation of Sec. 15(b) of the Securities Exchange Act of 1934, Sections 203(e) and (k) of the Investment Advisers Act of 1940, and Sections 9(b) and (f) of the Investment Company Act of 1940. The Respondents neither admitted nor denied the allegations contained in the order of settlement (In re Invesco Funds Group, Inc., Admin Proc. File No. 3-11701 (Oct. 8, 2004)). Pursuant to the terms of the settlements, AIM was censured. AIM paid $25 million in a civil monetary penalty. ADI paid $5 million in a civil monetary penalty. IFG paid $110 million in a civil monetary penalty and $215 in disgorgement. Two disbursement funds were created to compensate shareholders allegedly prejudiced by market timing and related activity in funds formerly advised by AIM. As of May 2011, the distributions were considered complete. AIM agreed to certain undertakings, including, but not limited to, maintaining a Board of Trustees that is 75% independent, designating an independent chairman of the Board, ensuring that the Board appoints an independent senior officer to monitor compliance and manage the process by which management fees are negotiated. The SEC provided final approval to formally complete and close the disbursement funds on November 6, 2013. |
10(c)(1)(vi). The disposition of the proceeding | This matter has been resolved since October 8, 2004. |
Entity information Related to item 10(c)(1) Record: 2
10(c)(1)(i). The individuals named in the Action | Invesco Aim Advisors, Inc. former name, AIM Advisors, Inc. and Invesco Aim Distributors, Inc. former name, AIM Distributors, |
10(c)(1)(ii). Title of Action | Docket 0311701 |
10(c)(1)(iii). Date of Action | 10/06/2003 |
10(c)(1)(iv). The Court or body taking the Action and its location | United States Securities and Exchange Commission |
10(c)(1)(v). Description of the Action | On October 8, 2004, the U.S. Securities and Exchange Commission ("SEC") settled an administrative proceeding against AIM Advisors, Inc. (n/k/a Invesco Advisers, Inc.) ("AIM"), Invesco Funds Group, Inc. ("IFG") and AIM Distributors, Inc. (n/k/a Invesco Distributors, Inc.) ("ADI") (collectively, "Respondents"). The allegations concerned market timing of and late trading by the proprietary mutual funds and a failure to disclose such arrangements, in violation of Sec. 15(b) of the Securities Exchange Act of 1934, Sections 203(e) and (k) of the Investment Advisers Act of 1940, and Sections 9(b) and (f) of the Investment Company Act of 1940. The Respondents neither admitted nor denied the allegations contained in the order of settlement (In re Invesco Funds Group, Inc., Admin Proc. File No. 3-11701 (Oct. 8, 2004)). Pursuant to the terms of the settlements, AIM was censured. AIM paid $25 million in a civil monetary penalty. ADI paid $5 million in a civil monetary penalty. IFG paid $110 million in a civil monetary penalty and $215 in disgorgement. Two disbursement funds were created to compensate shareholders allegedly prejudiced by market timing and related activity in funds formerly advised by AIM. As of May 2011, the distributions were considered complete. AIM agreed to certain undertakings, including, but not limited to, maintaining a Board of Trustees that is 75% independent, designating an independent chairman of the Board, ensuring that the Board appoints an independent senior officer to monitor compliance and manage the process by which management fees are negotiated. The SEC provided final approval to formally complete and close the disbursement funds on November 6, 2013. |
10(c)(1)(vi). The disposition of the proceeding | This matter has been resolved since Oct. 8, 2004. |
Entity information Related to item 10(c)(1) Record: 3
10(c)(1)(i). The individuals named in the Action | Montagu Investment Management Limited now known as INVESCO Asset Management Limited |
10(c)(1)(ii). Title of Action | Docket 36223 SEC Administrative Proceeding |
10(c)(1)(iii). Date of Action | 03/01/1983 |
10(c)(1)(iv). The Court or body taking the Action and its location | United States Securities and Exchange Commission |
10(c)(1)(v). Description of the Action | Montagu Investment Management Limited allegedly failed to file timely statements containing the information required by Schedule 13D of the Securities Exchange Act of 1934. The exact date of action is not available. The disposition of the proceeding follows. The Securities and Exchange Commission proceeding was settled on March 10, 1983. Findings that Montagu failed to file timely Statements containing the information required by Schedule 13D of the Securities Exchange Act of 1934, and that certain Schedules 13D and amendments thereto filed by Montagu, failed to disclose specific information required by Schedule D. The Commission accepted the Offer of Settlement of Montagu, including undertakings by Montagu to adopt, implement, and maintain internal procedures, policies and controls reasonably designed to assure that it and its affiliates would comply in the future with Section 13D of the Securities Exchange Act of 1934. |
10(c)(1)(vi). The disposition of the proceeding | Settled March 10, 1983. Finding Montagu failed to file timely Statements required by law and failed to make required disclosures. Settlement includes undertakings to implement and maintain internal compliance controls. See Item 10c1v above for details. |
10(c)(2). found the applicant or control affiliate to have been involved in a violation of its regulation or statutes? | Yes No |
Entity information Related to item 10(c)(2) Record: 1
10(c)(2)(i). The individuals named in the Action | INVESCO Funds Group, Inc. |
10(c)(2)(ii). Title of Action | Docket 03CV2421 |
10(c)(2)(iii). Date of Action | 12/02/2003 |
10(c)(2)(iv). The Court or body taking the Action and its location | United States Securities and Exchange Commission |
10(c)(2)(v). Description of the Action | See Item 10(c)(1) Record 1 |
10(c)(2)(vi). The disposition of the proceeding | See Item 10(c)(1) Record 1 |
Entity information Related to item 10(c)(2) Record: 2
10(c)(2)(i). The individuals named in the Action | Invesco Aim Advisors, Inc. former name, A I M Advisors, Inc. and Invesco Aim Distributors, Inc. former name, A I M Distributors, Inc. |
10(c)(2)(ii). Title of Action | Docket 0311701 |
10(c)(2)(iii). Date of Action | 10/06/2003 |
10(c)(2)(iv). The Court or body taking the Action and its location | United States Securities and Exchange Commission |
10(c)(2)(v). Description of the Action | See Item 10(c)(1) Record 2 |
10(c)(2)(vi). The disposition of the proceeding | See Item 10(c)(1) Record 2 |
Entity information Related to item 10(c)(2) Record: 3
10(c)(2)(i). The individuals named in the Action | Montagu Investment Management Limited now known as INVESCO Asset Management Limited |
10(c)(2)(ii). Title of Action | Docket 36223 SEC Administrative Proceeding |
10(c)(2)(iii). Date of Action | 03/01/1983 |
10(c)(2)(iv). The Court or body taking the Action and its location | United States Securities and Exchange Commission |
10(c)(2)(v). Description of the Action | See Item 10(c)(1) Record 3 |
10(c)(2)(vi). The disposition of the proceeding | See Item 10(c)(1) Record 3 |
Entity information Related to item 10(c)(2) Record: 4
10(c)(2)(i). The individuals named in the Action | INVESCO MIM PLC now known as INVESCO Holding Company Limited MIM |
10(c)(2)(ii). Title of Action | Docket 37788 SEC Administrative Proceeding |
10(c)(2)(iii). Date of Action | 06/15/1992 |
10(c)(2)(iv). The Court or body taking the Action and its location | United States Securities and Exchange Commission |
10(c)(2)(v). Description of the Action | Action INVESCO MIM PLC allegedly violated Section 13D of the Securities Exchange Act of 1934 and Rule 13D2 and 13D3 by failing to file timely statements required by Schedule 12D and failed to cause its subsidiary, INVESCO MIM Management Limited, to comply with the Commissions' Order in the Matter of Montagu Investment Management Ltd File No. 36223 March 10, 1983. The disposition of the proceeding follows. The Securities and Exchange Commission ("SEC") proceeding was settled on July 1, 1992. The SEC accepted INVESCO MIM PLCs Offer of Settlement to cease alleged violations of Section 13D of the 1934 Act, to adopt internal policies to assure compliance and fined the company $175,000. The full amount of the fine was paid in July 1992. It was noted in the SEC Order that none of INVESCO MIM PLCs subsidiaries were involved in the violations. Other sanctions ordered by the SEC are the adoption, implementation and maintenance of internal policies, procedures and controls that are reasonably designed to assure compliance with Section 13D of the Securities Exchange act of 1934 and Rule 13D2 and 13D3. |
10(c)(2)(vi). The disposition of the proceeding | Settled July 1, 1992. MIM agreed to cease violations of the Act; adopt internal compliance controls and pay a fine of $175,000. See Item 10c2v above for details. |
10(c)(3). found the applicant or control affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted? | Yes No |
10(c)(4). entered an order denying, suspending or revoking the applicant’s or control affiliate’s registration or otherwise disciplined it by restricting its activities? | Yes No |
10(d). Has any other Federal regulatory agency or any state regulatory agency : | |
10(d)(1). ever found the applicant or control affiliate to have made a false statement or omission or to have been dishonest, unfair, or unethical? | Yes No |
Entity information Related to item 10(d)(1) Record: 1
10(d)(1)(i). The individuals named in the Action | INVESCO Funds Group, Inc. INVESCO |
10(d)(1)(ii). Title of Action | Docket 03403885 |
10(d)(1)(iii). Date of Action | 12/02/2003 |
10(d)(1)(iv). The Court or body taking the Action and its location | Attorney General of the State of New York |
10(d)(1)(v). Description of the Action | On October 7, 2004, the Attorney General of the State of New York settled investigations concerning AIM Advisors, Inc. (n/k/a Invesco Advisers, Inc.) ("AIM") and Invesco Funds Group, Inc. ("IFG"). The allegations concerned market timing of and late trading by the proprietary mutual funds and a failure to disclose such arrangements, in violation of the Martin Act, general business law section 349 and/or Executive Law Section 63(12) (Act). AIM and IFG neither admitted nor denied the allegations contained in the assurances of discontinuance (In re AIM Advisors, Inc., Assurance of Discontinuance, Attorney General of the State of New York, Bureau of Investment Protection (Oct. 7, 2004) and In re Invesco Funds Group, Inc., Assurance of Discontinuance, Attorney General of the State of New York, Bureau of Investment Protection (Oct. 7, 2004)). IFG agreed to cease and desist from engaging in any acts in violations of the Act. Additionally, IFG and AIM, in accordance with the SEC Order of Settlement dated October 8, 2004, paid $325 million in disgorgement and civil money penalty. AIM paid $20 million in disgorgement and $30 million in civil monetary penalty. AIM agreed to cease and desist from engaging in acts violating the Act. In addition, AIM agreed to certain undertakings, including a reduction in net management fee rates for funds including former Invesco Funds by $75 million over 5 years (which ceased in 2009) and implementation of certain corporate governance reforms for certain funds, including, but not limited to, maintaining a Board of Trustees that is 75% independent, designating an independent chairman of the Board, and recommending that the funds appoint an independent Senior officer to monitor compliance and manage the process by which management fees are negotiated. AIM agreed to additional undertakings as well, such as disclosing the fees and returns of a hypothetical investment with a 5% return. |
10(d)(1)(vi). The disposition of the proceeding | This matter has been resolved since Oct. 7, 2004. |
Entity information Related to item 10(d)(1) Record: 2
10(d)(1)(i). The individuals named in the Action | INVESCO Funds Group, Inc. INVESCO |
10(d)(1)(ii). Title of Action | Case No. EN 19703 |
10(d)(1)(iii). Date of Action | 01/05/2004 |
10(d)(1)(iv). The Court or body taking the Action and its location | Secretary of State of the State of Georgia |
10(d)(1)(v). Description of the Action | As of October 7, 2004, the Secretary of State of Georgia settled investigations (case numbers EN-19703 and EN-19704) concerning Invesco Funds Group, Inc. ("IFG") and AIM Advisors, Inc. (n/k/a Invesco Advisers, Inc.) ("AIM"). The allegations concerned market timing of and late trading by the proprietary mutual funds and a failure to disclosure such arrangements, in violation of certain provisions of the Georgia Securities Act of 1973. AIM and IFG neither admitted nor denied the allegations contained in the letter of undertaking. IFG and AIM paid $100,000 to an investor protection trust to support programs in the State of Georgia designed for the purpose of investor education, and $75,000 to reimburse investigative and administrative costs incurred in connection with the investigations. |
10(d)(1)(vi). The disposition of the proceeding | This matter has been resolved since October 7, 2004. |
Entity information Related to item 10(d)(1) Record: 3
10(d)(1)(i). The individuals named in the Action | INVESCO Funds Group, Inc. INVESCO |
10(d)(1)(ii). Title of Action | Order No. 05 L 07 |
10(d)(1)(iii). Date of Action | 12/02/2003 |
10(d)(1)(iv). The Court or body taking the Action and its location | Securities Commissioner for the State of Colorado |
10(d)(1)(v). Description of the Action | On October 8, 2004, the Staff of the Colorado Division of Securities settled an investigation concerning Invesco Funds Group, Inc. ("IFG"). The allegations concerned market timing of and late trading by the proprietary mutual funds from 2001 to 2003 and a failure to disclosure such arrangements, in violation of Sec. 11-51-501(5) C.R.S. IFG neither admitted nor denied the allegations contained in the stipulation for consent order (In re Invesco Funds Group, Inc., Stipulation for Consent Order No. 05-L-07, Colorado Securities Commission (Oct. 8, 2004)). AIM Advisors, Inc. (n/k/a Invesco Advisers, Inc.) ("AIM"), as successor adviser to the funds, agreed to certain undertakings, including, but not limited to, implement commercially reasonable policies and procedures to detect and prevent market timing and excessive trading practices generally and with respect to omnibus accounts and disclose the fees and returns of a hypothetical investment with a 5% return. Additionally, IFG and AIM, in accordance with the SEC Order of settlement dated October 8, 2004, paid $325 million in disgorgement and civil money penalty. |
10(d)(1)(vi). The disposition of the proceeding | This matter has been resolved since October 8, 2004. |
Entity information Related to item 10(d)(1) Record: 4
10(d)(1)(i). The individuals named in the Action | INVESCO Funds Group, Inc. INVESCO |
10(d)(1)(ii). Title of Action | Case No. 2003CV9199 |
10(d)(1)(iii). Date of Action | 12/02/2003 |
10(d)(1)(iv). The Court or body taking the Action and its location | Attorney General of the State of Colorado |
10(d)(1)(v). Description of the Action | On October 7, 2004, the Attorney General of the Colorado Department of Law settled a case against Invesco Funds Group, Inc. ("IFG"), State of Colorado v. Invesco Funds Group, Inc., Case No. 2003CV9199 (D. Denver) (complaint filed December 2, 2003). The allegations concerned market timing of and late trading by the proprietary mutual funds and a failure to disclosure such arrangements, in violation of fiduciary duties. IFG neither admitted nor denied the allegations contained in the assurance of discontinuance (In re Invesco Funds Group, Inc., Assurance of Discontinuance, Colo. Dept. of Law (Oct. 7, 2004)) as successor adviser to the funds, agreed to certain undertakings. The undertakings include implementing certain corporate governance reforms for funds, including but not limited to, maintaining a Board of Trustees that is 75% independent, designating an independent chairman of the Board, ensure that the Board appoint an independent individual or firm to monitor compliance. AIM agreed to additional undertakings as well, such as implementing commercially reasonable policies and procedures to detect and prevent market timing and late trading in omnibus accounts. IFG also paid $1.5 million for reimbursement of expenses incurred, for investor education, and Colorado's general consumer fraud and antitrust enforcement efforts. Additionally, IFG and AIM, in accordance with the SEC Order of Settlement dated October 8, 2004, paid $325 million in disgorgement and civil money penalty. |
10(d)(1)(vi). The disposition of the proceeding | This matter has been resolved since October 7, 2004. |
Entity information Related to item 10(d)(1) Record: 5
10(d)(1)(i). The individuals named in the Action | Invesco Aim Advisors, Inc. former name, A I M Advisors, Inc. |
10(d)(1)(ii). Title of Action | No Docket Case Number |
10(d)(1)(iii). Date of Action | 12/03/2003 |
10(d)(1)(iv). The Court or body taking the Action and its location | Attorney General of the State of New York |
10(d)(1)(v). Description of the Action | On October 7, 2004, the Attorney General of the State of New York settled investigations concerning AIM Advisors, Inc. (n/k/a Invesco Advisers, Inc.) ("AIM") and Invesco Funds Group, Inc. ("IFG"). The allegations concerned market timing of and late trading by the proprietary mutual funds from 1997 to 2003 and a failure to disclosure such arrangements, in violation of the Martin Act, general business law section 349 and/or Executive Law Section 63(12) ("Act"). AIM and IFG neither admitted nor denied the allegations contained in the assurances of discontinuance (In re AIM Advisors, Inc., Assurance of Discontinuance, Attorney General of the State of New York, Bureau of Investment Protection (Oct. 7, 2004) and In re Invesco Funds Group, Inc., Assurance of Discontinuance, Attorney General of the State of New York, Bureau of Investment Protection (Oct. 7, 2004)). IFG agreed to cease and desist from engaging in any acts in violations of the Act. Additionally, IFG and AIM, in accordance with the SEC Order of Settlement dated October 8, 2004, paid $325 million in disgorgement and civil money penalty. AIM paid $20 million in disgorgement and $30 civil monetary penalties. AIM agreed to cease and desist from engaging in acts violating the Act. In addition, AIM agreed to certain undertakings including a reduction in net management fee rates for funds including former Invesco Funds by $75 million over five years (which ceased in 2009) and implementation of certain corporate governance reforms for certain funds, including, but not limited to, maintaining a Board of Trustees that is 75% independent, designating an independent chairman of the Board, and recommending that the funds appoint an independent Senior officer to monitor compliance and manage the process by which management fees are negotiated. AIM agreed to additional undertakings as well, such as disclosing the fees and returns of a hypothetical investment with a 5% return. |
10(d)(1)(vi). The disposition of the proceeding | This matter has been resolved since Oct. 7, 2004. |
Entity information Related to item 10(d)(1) Record: 6
10(d)(1)(i). The individuals named in the Action | Invesco Aim Advisors, Inc. former name, A I M Advisors, Inc. |
10(d)(1)(ii). Title of Action | Case No. EN 19704 |
10(d)(1)(iii). Date of Action | 01/05/2004 |
10(d)(1)(iv). The Court or body taking the Action and its location | Secretary of State of the State of Georgia |
10(d)(1)(v). Description of the Action | As of October 7, 2004, the Secretary of State of Georgia settled investigations (case numbers EN-19703 and EN-19704) concerning Invesco Funds Group, Inc. ("IFG") and AIM Advisors, Inc. (n/k/a Invesco Advisers, Inc.) ("AIM"). The allegations concerned market timing of and late trading by the proprietary mutual funds and a failure to disclosure such arrangements, in violation of certain provisions of the Georgia Securities Act of 1973. AIM and IFG neither admitted nor denied the allegations contained in the letter of undertaking. IFG and AIM paid $100,000 to an investor protection trust to support programs in the State of Georgia designed for the purpose of investor education, and $75,000 to reimburse investigative and administrative costs incurred in connection with the investigations. |
10(d)(1)(vi). The disposition of the proceeding | This matter has been resolved since October 7, 2004. |
10(d)(2). ever found the applicant or control affiliate to have been involved in a violation of investment-related regulations or statutes? | Yes No |
Entity information Related to item 10(d)(2) Record: 1
10(d)(2)(i). The individuals named in the Action | INVESCO Funds Group, Inc. |
10(d)(2)(ii). Title of Action | Docket 03 403885 |
10(d)(2)(iii). Date of Action | 12/02/2003 |
10(d)(2)(iv). The Court or body taking the Action and its location | Attorney General of the State of New York |
10(d)(2)(v). Description of the Action | See Item 10(d)(1) Record 1 |
10(d)(2)(vi). The disposition of the proceeding | See Item 10(d)(1) Record 1 |
Entity information Related to item 10(d)(2) Record: 2
10(d)(2)(i). The individuals named in the Action | INVESCO Funds Group, Inc. |
10(d)(2)(ii). Title of Action | Case No. EN 19703 |
10(d)(2)(iii). Date of Action | 01/05/2004 |
10(d)(2)(iv). The Court or body taking the Action and its location | Secretary of State of the State of Georgia |
10(d)(2)(v). Description of the Action | See Item 10(d)(1) Record 2 |
10(d)(2)(vi). The disposition of the proceeding | See Item 10(d)(1) Record 2 |
Entity information Related to item 10(d)(2) Record: 3
10(d)(2)(i). The individuals named in the Action | INVESCO Funds Group, Inc. |
10(d)(2)(ii). Title of Action | Order No. 05 L 07 |
10(d)(2)(iii). Date of Action | 12/02/2003 |
10(d)(2)(iv). The Court or body taking the Action and its location | Securities Commissioner for the State of Colorado |
10(d)(2)(v). Description of the Action | See Item 10(d)(1) Record 3 |
10(d)(2)(vi). The disposition of the proceeding | See Item 10(d)(1) Record 3 |
Entity information Related to item 10(d)(2) Record: 4
10(d)(2)(i). The individuals named in the Action | INVESCO Funds Group, Inc. |
10(d)(2)(ii). Title of Action | Case No. 2003CV9199 |
10(d)(2)(iii). Date of Action | 12/02/2003 |
10(d)(2)(iv). The Court or body taking the Action and its location | Attorney General of the State of Colorado |
10(d)(2)(v). Description of the Action | See Item 10(d)(1) Record 4 |
10(d)(2)(vi). The disposition of the proceeding | See Item 10(d)(1) Record 4 |
Entity information Related to item 10(d)(2) Record: 5
10(d)(2)(i). The individuals named in the Action | Invesco Aim Advisors, Inc. former name, A I M Advisors, Inc. |
10(d)(2)(ii). Title of Action | No Docket Case Number |
10(d)(2)(iii). Date of Action | 12/02/2003 |
10(d)(2)(iv). The Court or body taking the Action and its location | Attorney General of the State of New York |
10(d)(2)(v). Description of the Action | See Item 10(d)(1) Record 5 |
10(d)(2)(vi). The disposition of the proceeding | See Item 10(d)(1) Record 5 |
Entity information Related to item 10(d)(2) Record: 6
10(d)(2)(i). The individuals named in the Action | Invesco Aim Advisors, Inc. former name, A I M Advisors, Inc. |
10(d)(2)(ii). Title of Action | Case No. EN 19704 |
10(d)(2)(iii). Date of Action | 01/05/2004 |
10(d)(2)(iv). The Court or body taking the Action and its location | Secretary of State of the State of Georgia |
10(d)(2)(v). Description of the Action | See Item 10(d)(1) Record 6 |
10(d)(2)(vi). The disposition of the proceeding | See Item 10(d)(1) Record 6 |
10(d)(3). ever found the applicant or control affiliate to have been a cause of an investment-related business having its authorization to do business Denied, suspended, revoked or restricted? | Yes No |
10(d)(4). in the past ten years entered an order against the applicant or control affiliate in connection with investment-related activity? | Yes No |
10(d)(5). ever denied, suspended, or revoked applicant’s or control affiliate’s registration or license, or prevented it from associating with an investment-related business, or otherwise disciplined it by restricting its activities? | Yes No |
10(d)(6). ever revoked or suspended the applicant’s or a control affiliate’s license as an attorney or accountant? | Yes No |
10(e)(1). found the applicant or a control affiliate to have made a false statement or omission? | Yes No |
10(e)(2). found the applicant or a control affiliate to have been involved in a violation of its rules? | Yes No |
Entity information Related to item 10(e)(2) Record: 1
10(e)(2)(i). The individuals named in the Action | Invesco Capital Markets, Inc. |
10(e)(2)(ii). Title of Action | No Docket Case Number |
10(e)(2)(iii). Date of Action | 07/01/1980 |
10(e)(2)(iv). The Court or body taking the Action and its location | National Association of Securities Dealers |
10(e)(2)(v). Description of the Action | Invesco Capital Markets, Inc. (formerly known as Van Kampen Merritt, Inc.) executed a Letter of Admission, Waiver and Consent and paid the National Association of Securities Dealers a fine of $1,000 for violation of Securities and Exchange Commission rules 15C2-1, 15C3-3 and 17A-3 and MSRB Rules A-13, G-8 and G-10. Van Kampen Merritt, Inc., Van Kampen Funds, Inc. and Carl Ferwerda were named. |
10(e)(2)(vi). The disposition of the proceeding | Exact date of resolution is not known. Van Kampen Merritt, Inc. executed a Letter of Admission, Waiver and Consent and paid the NASD a fine of $1,000. |
Entity information Related to item 10(e)(2) Record: 2
10(e)(2)(i). The individuals named in the Action | Invesco Capital Markets, Inc. |
10(e)(2)(ii). Title of Action | CHI 834 AWC |
10(e)(2)(iii). Date of Action | 10/01/1985 |
10(e)(2)(iv). The Court or body taking the Action and its location | National Association of Securities Dealers |
10(e)(2)(v). Description of the Action | Invesco Capital Markets, Inc. ("ICM") (formerly known as Van Kampen Merritt, Inc.) failed to comply with certain provisions of the Securities Exchange Act of 1934, Article III, Sections 1 and 21 of the rules of fair practice and MSRB rules G-15 and G-27. The company prepared an inaccurate computation of the amount required to be on deposit in the special reserve bank account for the exclusive benefit of customers; failed to buy in two short security count differences over forty five calendar days; failed to obtain possession or control of customers' fully-paid securities in two of twenty-two instances; prepared an inaccurate computation of net capital; filed an inaccurate focus part 1 report for October 31, 1984; failed to maintain accurate books and records; failed to maintain a ledger reflecting securities in transfer; failed to have quarterly box counts; failed to record on books and records unresolved securities differences; failed to indicate on onfirmations of municipal securities transactions all required information; and, failed to provide evidence in writing of the supervision of municipal transactions. On October 18, 1985, the Letter of Acceptance, Waiver and Consent submitted by respondents ICM and an individual was accepted. Therefore, they were censured and the respondent member was required to amend, revise and update its supervisory procedures within six months of the date of the letter and will submit copy of same to the association. |
10(e)(2)(vi). The disposition of the proceeding | This proceeding was resolved on October 18, 1985. Van Kampen Merritt, Inc. entered into a letter of acceptance, waiver and consent with NASD. |
Entity information Related to item 10(e)(2) Record: 3
10(e)(2)(i). The individuals named in the Action | Van Kampen Funds Inc. |
10(e)(2)(ii). Title of Action | E1020040470 01 |
10(e)(2)(iii). Date of Action | 08/25/2005 |
10(e)(2)(iv). The Court or body taking the Action and its location | National Association of Securities Dealers |
10(e)(2)(v). Description of the Action | For the period March 1, 2004, through May 31, 2004, the firm allegedly failed to timely report 50 transactions eligible for trace reporting, reporting 2 transactions with an inaccurate time of order execution, 1 transaction was reported twice, and 1 transaction was reported with an incorrect quantity. |
10(e)(2)(vi). The disposition of the proceeding | This proceeding was resolved on August 25 2005, by a Letter of Acceptance, Waiver and Consent with NASD, and payment to the NASD of a fine of $5,000. |
Entity information Related to item 10(e)(2) Record: 4
10(e)(2)(i). The individuals named in the Action | Invesco Capital Markets, Inc. |
10(e)(2)(ii). Title of Action | 2009020770801 |
10(e)(2)(iii). Date of Action | 01/24/2011 |
10(e)(2)(iv). The Court or body taking the Action and its location | Financial Industry National Regulatory Authority |
10(e)(2)(v). Description of the Action | On January 24, 2011, Invesco Capital Markets, Inc. ("ICM") (formerly known as Van Kampen Funds, Inc.) entered into a Letter of Acceptance, Waiver and Consent ("Settlement ") with Financial Industry National Regulatory Authority ("FINRA"). ICM accepted and consented, without admitting to or denying the FINRA finding of a violation of NASD Rule 2110. The findings state ICM did not inform investors purchasing Unit Investment Trusts (UITs") through its In-Kind Exchange programs the manner in which a discounted sales charge would be assessed, and investors could have concluded from the disclosures made that they were eligible to receive certain sales charge discounts when, in fact, such discounts did not apply to the In- Kind Exchange programs. The firm has remediated approximately 4,600 customers who paid more than the exchange discount described in the prospectus approximately $200,000 including interest, and prospectuses were updated to disclose the In-Kind Exchange discount fully and accurately. ICM also consented to the imposition of a censure and a $150,000 fine as settlement with FINRA. |
10(e)(2)(vi). The disposition of the proceeding | On January 24, 2011, ICM entered into a Letter of Acceptance, Waiver and Consent settlement with FINRA and consented to the imposition of a censure and a $150,000 fine as settlement with FINRA. |
Entity information Related to item 10(e)(2) Record: 5
10(e)(2)(i). The individuals named in the Action | Invesco Capital Markets, Inc. |
10(e)(2)(ii). Title of Action | 2008013163301 |
10(e)(2)(iii). Date of Action | 07/14/2011 |
10(e)(2)(iv). The Court or body taking the Action and its location | Financial Industry National Regulatory Authority |
10(e)(2)(v). Description of the Action | During the review period, the firm failed to transmit 1,539 reportable order events ("ROEs"), to the Order Audit Trail System (OATS) on 381 business days. These 1,539 ROES represented 100% of all ROES that the firm was required to transmit to OATS during the review period. The conduct described in this paragraph constitutes separate and distinct violations of NASD rule 6955(a). The firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of NASD, concerning OATS. Specifically, the firms supervisory system did not include written supervisory procedures providing for: (1) The identification of the person(s) responsible for supervision with respect to applicable rules; (s) A statement of the supervisor step(s) to be taken by the identified person(s); (3) A statement as to how often such person(s) should take such step(s); and (4) A statement as to how the completion of the step(s) included in the written supervisory procedures should be documented. The conduct described in this paragraph constitutes violation of NASD Rules 2210 and 3010. |
10(e)(2)(vi). The disposition of the proceeding | The firm must pay a fine of $17,500 to FINRA (consisting of $12,500 for violations of NASD rule 6955 and $5,000 for violations of NASD rules 2110 and 3010). The AWC was accepted by FINRA on July 14, 2011, and the fine was paid on July 21, 2011. |
Entity information Related to item 10(e)(2) Record: 6
10(e)(2)(i). The individuals named in the Action | Invesco Capital Markets, Inc. |
10(e)(2)(ii). Title of Action | Docket/Case 2010024499901 |
10(e)(2)(iii). Date of Action | 05/24/2012 |
10(e)(2)(iv). The Court or body taking the Action and its location | Financial Industry National Regulatory Authority |
10(e)(2)(v). Description of the Action | MSRB Rules G-8, G-14 - Invesco Capital Markets, Inc. ("ICM") (formerly known as Van Kampen Funds, Inc.) allegedly failed to report information regarding purchase and sale transactions effected in municipal securities to the real-time transaction reporting system (RTRS), in the manner prescribed by Rule G-14 RTRS procedures and the RTRS users manual. The firm allegedly failed to report information about such transactions within 15 minutes of trade time to an RTRS portal. The firm allegedly failed to report the trade time to the RTRS in municipal securities transaction reports. The firm allegedly failed to record the correct trade time on the trade memorandum for the trades in municipal securities. |
10(e)(2)(vi). The disposition of the proceeding | Without admitting or denying the findings, the firm entered into a Letter of Acceptance, Waiver and Consent with FINRA. The firm consented to the censure and a monetary fine of $10,000 for MSRB rule violations. |
10(e)(3). found the applicant or a control affiliate to have been the cause of an investment-related business losing its authorization to do business? | Yes No |
10(e)(4). disciplined the applicant or a control affiliate by expelling or suspending it from membership, by barring or suspending its association with other members, or by otherwise restricting its activities? | Yes No |
10(f). Has any foreign government, court, regulatory agency or exchange ever entered an order against the applicant or a control affiliate related to investments or fraud? | Yes No |
Entity information Related to item 10(f) Record: 1
10(f)(i). The individuals named in the Action | Invesco Taiwan Limited |
10(f)(ii). Title of Action | Not Applicable |
10(f)(iii). Date of Action | 03/15/2011 |
10(f)(iv). The Court or body taking the Action and its location | Financial Supervisory Commission, Executive Yuan, R.O.C. |
10(f)(v). Description of the Action | Invesco Taiwan Limited, Invesco Taiwan, was fined by the Financial Supervisory Commission, Executive Yuan, R.O.C., the Regulator, on the ground that it violated a Taiwan regulation requiring a fund manager to carry out adequate research before buying and selling the investment on behalf of the portfolio and that such research be documented. The Regulator has penalized Invesco Taiwan because its investment on a particular stock was without reasonable grounds and justifications to support the decision. Invesco Taiwan bought and sold this stock with a small profit, and documented the rationale of the buying and selling. However, the Regulator believed that the rationale behind the decision to sell the security was not based upon reasonable grounds and justifications. |
10(f)(vi). The disposition of the proceeding | The Regulator imposed a fine on Invesco Taiwan of NT 120,000 dollars which is approximately $4,000. |
Entity information Related to item 10(f) Record: 2
10(f)(i). The individuals named in the Action | Invesco Asset Management Ltd. and Invesco Fund Managers Limited |
10(f)(ii). Title of Action | Not Applicable |
10(f)(iii). Date of Action | 04/28/2014 |
10(f)(iv). The Court or body taking the Action and its location | Financial Conduct Authority (UK) |
10(f)(v). Description of the Action | On April 28, 2014, the Financial Conduct Authority ("FCA"), the UK financial services regulator, announced the settlement of an investigation of Invesco Asset Management Limited and Invesco Fund Managers Limited (together Invesco Perpetual) that included the imposition of a financial penalty of GBP 18.6 million. The issues identified by the FCA related to the period May 2008 to November 2012 and included the following: 1) Investment restriction breaches in UK-domiciled retail funds managed by Invesco Perpetual. Such breaches had been identified by Invesco Perpetual and reported to FCA, and the Funds were promptly reimbursed where necessary. 2) Disclosures regarding the use of, and risks associated with, derivatives were not made or inadequately made in disclosure documents for two UK-domiciled retail funds managed by Invesco Perpetual. These disclosure failings were corrected in August 2012. 3) Invesco Perpetual failed to adequately document allocations of fixed income securities when aggregating client orders. A review by Invesco Perpetual determined there was no evidence that this impacted investors. 4) Certain fixed income transactions were not posted on a timely basis. This did not result in any need to re-price funds. |
10(f)(vi). The disposition of the proceeding | The Financial Conduct Authority imposed a financial penalty of GBP 18.6 million which is approximately $31.1 million. |
10(g). Is the applicant or a control affiliate now the subject of a proceeding that could result in a yes answer for questions 10(a) – 10(f) ? | Yes No |
Entity information Related to item 10(g) Record: 1
10(g)(i). The individuals named in the Action | Invesco Aim Distributors, Inc. former name, AIM Distributors, Inc. and Invesco Aim Advisors, Inc. former name, AIM Advisors, |
10(g)(ii). Title of Action | Order No. 05 1318 |
10(g)(iii). Date of Action | 08/30/2005 |
10(g)(iv). The Court or body taking the Action and its location | West Virginia Office of the State Auditor Securities Commission |
10(g)(v). Description of the Action | On August 30, 2005, the West Virginia Office of the State Auditor - Securities Commission ("WVASC") issued a Summary Order to Cease and Desist and Notice of Right to Hearing to AIM Advisors, Inc. (n/k/a Invesco Advisers, Inc.) ("AIM") and AIM Distributors, Inc. ("ADI") (Order No. 05-1318). The WVASC alleges that AIM and ADI failed to disclose market timing arrangements. The WVASC purports to order AIM and ADI to cease any further violations and seeks to impose monetary sanctions, including restitution to affected investors, disgorgement of fees, reimbursement of investigatory, administrative and legal costs and an "administrative assessment" to be determined by the commissioner. |
10(g)(vi). The disposition of the proceeding | We believe this matter has been indefinitely suspended. |
Entity information Related to item 10(g) Record: 2
10(g)(i). The individuals named in the Action | Van Kampen Series Fund, Inc. and Van Kampen Investment Advisory Corp. now Van Kampen Asset Management |
10(g)(ii). Title of Action | Case Number 03 L 2036 |
10(g)(iii). Date of Action | 12/18/2003 |
10(g)(iv). The Court or body taking the Action and its location | Third Judicial Circuit of Illinois Madison County |
10(g)(v). Description of the Action | On December 18 2003 a class action suit was filed by Avery Jackson individually and on behalf of other similarly situated alleging defendants failed to make daily adjustments for fluctuations between U.S. and foreign markets in calculating net asset values in the VK International Magnum Fund thereby exposing long term shareholders to market timing trades. |
10(g)(vi). The disposition of the proceeding | Stayed pending an appeal in a companion case Kircher v. Putnam. |
10(h). Has a bonding company denied, paid out on, or revoked a bond for the applicant or a control affiliate? | Yes No |
10(i). Does the applicant or a control affiliate have any unsatisfied judgments or liens against it? | Yes No |
TA-1/A : Signature
ATTENTION: INTENTIONAL MISSTATEMENTS OR OMISSIONS OF FACT CONSTITUTE FEDERAL CRIMINAL VIOLATIONS. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a) SIGNATURE: The registrant submitting this form, and as required, the SEC supplement and Schedules A-D, And the executing official hereby represent that all the information contained herein is true, correct and complete.11(a). Signature of Official responsible for Form: | Kate Archibald |
11(b). Telephone Number: | 416-228-8330 |
11(c). Title of Signing Officer: | Chief Compliance Officer |
11(d). Date Signed (Month/Day/Year): | 12/04/2020 |