[Federal Register Volume 59, Number 229 (Wednesday, November 30, 1994)]
[Unknown Section]
[Page 0]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 94-29419]
[[Page Unknown]]
[Federal Register: November 30, 1994]
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SECURITIES AND EXCHANGE COMMISSION
[Rel. No. IC-20727; 812-8906]
Investors Life Insurance Company of North America, et al.
November 22, 1994.
AGENCY: U.S. Securities and Exchange Commission (the ``SEC'' or the
``Commission'').
ACTION: Notice of application for an exemption under the Investment
Company Act of 1940 (the ``1940 Act'').
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APPLICANTS: Investors Life Insurance Company of North America
(``Investors'') and its two separate accounts, Investors Life Insurance
Company of North America--CIGNA Separate Account I (``Account I'') and
Investors Life Insurance Company of North America--INA/Putnam Separate
Account (``INA/Putnam Account''). (Investors, Account I, and INA/Putnam
Account shall be referred to herein collectively as the
``Applicants'').
RELEVANT 1940 ACT SECTIONS: Order requested under Section 26(b) of the
1940 Act approving proposed substitution of portfolio shares; order
requested under Sections 6(c) and 17(b) of the 1940 Act to the extent
that the proposed substitution may involve transactions prohibited by
Section 17(a) of the 1940 Act.
SUMMARY OF APPLICATION: The Applicants seek an order permitting the
substitution (the ``Substitution'') of shares of each of the portfolios
of the CIGNA Annuity Funds Group for shares of corresponding portfolios
of Putnam Capital Manager Trust. The Applicants also seek an order
permitting the purchase and sale of securities between affiliates in
connection with the Substitution.
FILING DATES: The Application was filed initially on March 22, 1994. An
amended and restated application was filed on October 24, 1994.
HEARING OR NOTIFICATION OF HEARING: An order granting the application
will be issued unless the Commission orders a hearing. Interested
persons may request a hearing by writing the Secretary of the
Commission and serving the Applicants with copies of the request,
personally or by mail. Hearing requests should be received by the
Commission by 5:30 p.m. on December 19, 1994, and should be accompanied
by proof of service on the Applicants in the form of an affidavit or,
for lawyers, a certificate of service. Hearing requests should state
the nature of the writer's interest, the reason for the request, and
the issues contested. Persons may request notification of a hearing by
writing to the Secretary of the Commission.
ADDRESSES: Secretary, Securities and Exchange Commission, 450 Fifth
Street, N.W., Washington, D.C. 20549. Applicants, Investors Life
Insurance Company of North America, 701 Brazos Street, Austin, Texas
78701, Attention: Theodore A. Fleron, General Counsel.
FOR FURTHER INFORMATION CONTACT: Patrice M. Pitts, Attorney, at (202)
942-0670, Office of Insurance Products (Division of Investment
Management).
SUPPLEMENTARY INFORMATION: The following is a summary of the
application. The complete application is available for a fee from the
SEC's Public Reference Branch.
Applicants' Representations and Statements
1. Investors is a stock life insurance company which was organized
under the laws of the Commonwealth of Pennsylvania in 1963. Investors
changed its state of domicile to the State of Washington in 1992.
2. In September 1982, Investors established Account I as a separate
investment account to fund certain flexible premium and single premium
variable annuity policies (the ``Account I Policies''). Account I is
organized and registered under the 1940 Act as a unit investment trust.
Account I currently has five divisions, each of which invests
exclusively in shares of a designated portfolio of the CIGNA Annuity
Funds Group (the ``CIGNA Funds'').\1\ Each such division contains two
subdivisions, one for the allocation of tax qualified and one for non-
tax qualified net payments made under variable annuity contracts.
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\1\Before October 1985, the underlying funding vehicle for
Account I was the CIGNA Annuity Fund, Inc. On October 16, 1985, the
CIGNA Funds acquired the assets and liabilities of CIGNA Annuity
Fund, Inc., pursuant to an Agreement and Plan of Reorganization
which had been approved by the shareholders of CIGNA Annuity Fund,
Inc.
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3. The underlying investment vehicle for Account I is the CIGNA
Funds, a Massachusetts business trust organized on April 10, 1985,
which is registered under the 1940 Act as an open-end management
company of the series type. The CIGNA Funds currently consist of five
portfolios, each with its own investment objectives and investment
portfolio. Before November 29, 1993, the investment adviser to the five
portfolios of the CIGNA Funds was CIGNA Investments, Inc. (``CII''), a
subsidiary of CIGNA Corporation.
4. In June 1980, the Investors established INA/Putnam Account as a
separate investment account to fund certain single premium variable
annuity policies (the ``INA/Putnam Policies''). The INA/Putnam Account
is organized and registered under the 1940 Act as a unit investment
trust. The INA/Putnam Account initially had five divisions, each of
which invested exclusively in shares of one of the following mutual
funds (collectively, the ``Putnam Funds''): Putnam Income Fund; Putnam
High Yield Trust; Putnam Equity Income Fund (formerly known as Putnam
Strategic Income Trust and Putnam Option Income Trust); Putnam Daily
Dividend Trust; and Putnam Investors Fund. Each division of the INA/
Putnam Account contained two subdivisions, one for the allocation of
tax qualified and one for the allocation of non-tax qualified net
payments made under variable annuity contracts. Putnam Investment
Management, Inc. (``Putnam'') currently serves as investment adviser to
the Putnam Funds.
5. Following the issuance of Revenue Ruling 81-225 by the Internal
Revenue Service on September 25, 1981, Investors discontinued offering
the INA/Putnam Policies.\2\ For owners of INA/Putnam Policies issued
prior to Revenue Ruling 81-225 who were adversely affected by that
Revenue Ruling, Investors added an additional division to the INA/
Putnam Account, for which the underlying investment vehicle is the
CIGNA Funds. Those INA/Putnam Policy owners were able to transfer
contract values from the Putnam Funds to the CIGNA Funds. The CIGNA
Funds initially offered a money market option (the ``CIGNA Annuity
Money Market Fund''); subsequently, the investment options were
expanded to include the CIGNA Annuity Income Fund and the CIGNA Annuity
Equity Fund as well.\3\ The Putnam Funds have remained available under
INA/Putnam Contracts issued prior to the cut-off dates described in
Revenue Ruling 81-225. Accordingly, there currently are eight divisions
of the INA/Putnam Account.
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\2\Revenue Ruling 81-225 pertains to variable annuity contracts
offered through insurance company separate accounts holding shares
of mutual funds which also offer their shares to the public. Revenue
Ruling 81-225 questioned the tax treatment of variable annuity
contracts when the underlying mutual funds are not managed by the
issuing company or an affiliate, or when the policyholder may
initially allocate, and subsequently reallocate, the contract values
among several underlying funds.
\3\As indicated above, the CIGNA Funds currently consist of five
portfolios. However, shares of two of those five portfolios (the
CIGNA Annuity Growth and Income Fund and the CIGNA Annuity
Aggressive Equity Fund) have not been made available to owners of
the INA/Putnam Policies.
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6. In July 1993, CII advised the Board of Trustees of the CIGNA
Funds that CIGNA Corporation and its subsidiaries intended to redirect
resources away from the active management of equity securities and
concentrate their equity management activities in indexing strategies.
Accordingly, CII indicated to the Board of Trustees of the CIGNA Funds
and to Investors that it would be unwilling to continue to serve as
investment adviser to any of the CIGNA Funds on a long-term basis. CII
also indicated that it would work with Investors to identify and
implement a successor arrangement.
7. Following discussions with several major mutual fund groups,
Investors and CII determined that Putnam Capital Manager Trust (the
``PCM Funds'') and Putnam would provide a means for the orderly
withdrawal of CII's investment advisory services in light of: (i) The
willingness of Putnam to provide interim advisory services to the CIGNA
Equity Funds; (ii) the availability of funds which offer investment
objectives similar to those provided by each series of the CIGNA funds;
and (iii) the availability of a current PCM Funds registration for
funds which could be substituted for the CIGNA Funds as the underlying
investment vehicle for variable annuity contracts sponsored by
Investors.\4\
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\4\Putnam currently serves as investment advisor to the Putnam
Funds (which serve as underlying investment options for the INA/
Putnam Account) as well as the investment advisor to the PCM Funds.
The PCM Funds are structured to satisfy the requirements of Section
817(h) of the Internal Revenue Code. Since the Putnam Funds are not
so structured, they are not appropriate for the purposes of the
Substitution.
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8. On November 29, 1993, the board of trustees of the CIGNA Funds,
acting on the advice of CII, terminated the appointment of CII as
investment adviser to the CIGNA Annuity Equity Fund, the CIGNA Annuity
Growth and Income Fund and the CIGNA Annuity Aggressive Equity Fund
(the ``CIGNA Equity Funds''). Concurrently, the board of trustees
appointed Putnam as the investment adviser to the CIGNA Equity Funds,
effective as of November 30, 1993. The investment advisory agreement
between the CIGNA Funds and Putnam is substantially the same as the
agreement between the CIGNA funds and CII, except with respect to the
provisions of certain administrative services.\5\ On March 8, 1994, the
shareholders of the CIGNA Equity Funds approved the investment advisory
agreement between Putnam and the CIGNA Equity Funds.
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\5\CII was retained to provide administrative services to the
CIGNA Equity Funds, pending the effectiveness of the proposed
substitution. CII continues to act as investment advisor to the
CIGNA Annuity Money Market Fund and the CIGNA Annuity Income Fund.
Putnam receives an investment advisory fee calculated at the same
annual rate as the fee previously paid to CII for the CIGNA Equity
Funds. CII continues to receive reimbursement for a portion of its
expenses associated with the administration of the CIGNA Equity
Funds. These fees remain subject to reduction under expense waiver
or reimbursement arrangements.
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9. The PCM Funds are registered under the 1940 Act as an open-end
management company of the series type. The PCM Funds currently consist
of nine portfolios, each with its own investment objectives and
investment portfolio. The proposed substitution would utilize four of
the portfolios of the PCM Funds with respect to Account I Policies and
three of the portfolios with respect to the INA/Putnam Policies.
10. Investors proposes to substitute shares of the CIGNA Funds for
shares of the PCM Funds on the following basis.
As of the effective date of the Substitution, shares of
CIGNA Annuity Money Market Fund would be redeemed by Investors. On the
same day, Investors would use the proceeds to purchase the appropriate
number of shares of the PCM Money Market Fund.
As of the effective date of the Substitution, shares of
CIGNA Annuity Income Fund would be redeemed by Investors. On the same
day, Investors would use the proceeds to purchase the appropriate
number of shares of PCM U.S. Government and High Quality Bond Fund.
As of the effective date of the Substitution, shares of
CIGNA Annuity Equity Fund would be redeemed by Investors. On the same
day, Investors would use the proceeds to purchase the appropriate
number of shares of the PCM Growth and Income Fund.
As of the effective date of the Substitution, shares of
CIGNA Annuity Growth and Income Fund would be redeemed by Investors. On
the same day, Investors would use the proceeds to purchase the
appropriate number of shares of PCM Growth and Income Fund.
As of the effective date of the Substitution, shares of
CIGNA Annuity Aggressive Equity Fund would be redeemed by Investors. On
the same day, Investors would use the proceeds to purchase the
appropriate number of shares of PCM Voyager Fund.
11. The Substitution would take place at relative net asset values
of the CIGNA Funds and the PCM Funds, with no change in the amount of
any policyholder's account value under either the Account I or the INA/
Putnam Policies.
12. It is expected that the CIGNA Funds will incur brokerage fees
and expenses in connection with the redemption by Investors of the
shares of the CIGNA Funds. These expenses would be charged to the
applicable portfolio of the CIGNA Funds. To alleviate the potential
impact of such brokerage fees and expenses upon the CIGNA Funds, CII
and the CIGNA Funds have proposed to Investors that the redemption of
the shares of the CIGNA Funds be accomplished, in part, by ``in kind''
payments. Under the proposal, the CIGNA Funds would transfer to
Investors cash and/or securities held by the CIGNA Funds at the
effective date of the Substitution, and Investors would use such cash
and/or securities to purchase shares of the applicable portfolio of the
PCM Funds. Investors has indicated that it would be agreeable to the
``in kind'' aspect of the proposal, on the conditions that: (i) The
CIGNA Funds identify prior to the effective date of the Substitution
the securities to be included in the ``in kind'' transfer; and (ii) the
PCM Funds and Putnam, in its capacity as investment adviser to the PCM
Funds, agree to accept the securities so identified in payment for the
purchase by Investors of shares of PCM Funds to effectuate the
Substitution. The valuation of any ``in kind'' transfers will be on a
basis consistent with the valuation of the assets of the CIGNA Funds
and the normal valuation procedures of the PCM Funds.
13. Following the Substitution, the fees and expenses imposed by
Investors under the Account I Policies and the INA/Putnam Policies
would remain the same as currently in effect. In addition, the
Substitution would not impose any federal income tax liability on
owners of Account I Policies or INA/Putnam Policies.
14. Following the Substitution, Account I Policy owners would have
the right to transfer account values among the divisions of Account I
for which the four PCM Funds described above serve as the underlying
investment vehicle. INA/Putnam Policy owners would have the right to
transfer account values among the divisions of the INA/Putnam Account
for which three PCM funds (the PCM Money Market Fund, the PCM U.S.
Government High Quality Bond Fund, and the PCM Growth and Income Fund)
serve as the underlying investment vehicles. In addition, INA/Putnam
Policy owners who currently utilize one or more of the Putnam Funds as
their underlying investment vehicle(s) would be able to transfer such
values amongst the PCM Money Market Fund, the PCM U.S. Government and
High Quality Bond Fund, and the PCM Growth and Income Fund. The current
provisions of the INA/Putnam Policies which prevent a policyholder who
transfers values from the Putnam Funds to the CIGNA Funds from
subsequently transferring such values back to the Putnam Funds would
continue in effect, with the restriction applying to PCM Funds in place
of the CIGNA Funds.
15. Following the Substitution, Investors intends to redeem its
investment of seed money. However, the timing of such withdrawal has
not been established and will be at the discretion of Investors. By
making this withdrawal after the Substitution, Investors anticipates
that the brokerage and related expenses incurred by the underlying fund
would have a substantially reduced impact, if any, upon Policy owners,
as a result of the larger overall size of the applicable PCM Funds.
16. Investors has been advised by CII that, following the
Substitution and the redemption of CIGNA Funds shares by Investors, the
CIGNA Funds intends to file an application under Section 8(f) of the
1940 Act, requesting an order that it has ceased to be an investment
company. Following the issuance of such an order, the CIGNA Funds will
dissolve, pursuant to the applicable provisions of Massachusetts law.
17. If the Commission approves the Substitution, Policy holders
will receive notice of the intended substitution and will have the
opportunity to vote on the matter. The Account I Policies and the INA/
Putnam Policies provide that a substitution of the shares of one
registered investment company for those of another registered
investment company may be implemented with respect to a particular
division of the applicable separate account only if it (i.e., the
substitution) has been previously approved by a majority of the votes
to be cast be persons having a voting interest in the fund shares
allocated to the applicable separate account division.\6\
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\6\With respect to the INA/Putnam Policies, Investors will
request that the SEC staff confirm that the Substitution will not
affect adversely the no-action positions previously issued to
Investors and the INA/Putnam Account.
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18. The historical expense ratios for the CIGNA Funds generally
have been higher than the historical expense ratios for the PCM Funds.
The difference is attributable, in part, to the larger asset size of
the PCM Funds, as compared to the asset size of the CIGNA Funds.
Applicants' Legal Analysis
A. Request for Order Pursuant to Section 26(b) of the 1940 Act
1. Section 26(b) of the 1940 Act provides:
It shall be unlawful for any depositor or trustee of a registered
unit investment trust holding the security of a single issuer to
substitute another security for such security unless the Commission
shall have approved such substitution. The Commission shall issue an
order approving such substitution if the evidence establishes that it
is consistent with the protection of investors and the purposes fairly
intended by the policy and provisions of this title.\7\
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\7\The Applicants represent that the Commission has interpreted
Section 26(b) to apply to a ``substitution of securities in any sub-
account of a registered separate account.'' See Investment Company
Act Rel. No. 12678 (Sept. 21, 1982) at 13.
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2. The purpose of Section 26(b) is to protect the expectation of
investors in a unit investment trust that the unit investment trust
will accumulate the shares of a particular issuer, and to prevent
unscrutinized substitutions which might, in effect, force shareholders
dissatisfied with the substituted security to redeem their shares,
thereby incurring either a loss of the sales load deducted from initial
proceeds, an additional sales load upon reinvestment of the redemption
proceeds, or both. Section 26(b) affords this protection to investors
by preventing a depositor or trustee of a unit investment trust holding
the shares of one issuer from substituting the shares of another issuer
for those shares, unless the Commission approves the substitution.
3. The Applicants represent that, for the following reasons, the
purposes, terms, and conditions of the Substitution will not entail any
of the abuses that Section 26(b) is designed to prevent.
The Substitution is being proposed because the investment
adviser to CIGNA Funds has indicated that it would be unwilling to
serve as investment adviser to any of the CIGNA Funds on a long-term
basis. This decision, which is beyond the control of Investors, has
necessitated the proposal of an alternative funding vehicle for
variable annuity contracts offered by Investors.
The Substitution is for shares of PCM Funds with
investment objectives which are sufficiently similar to the objectives
of the corresponding portfolios of the CIGNA Funds to provide a means
for Policy holders to continue their current investment goals and risk
expectations.
The transactions effecting the Substitution, including the
redemption of the shares of the CIGNA Funds and the purchase of shares
of PCM Funds, will be effected at net asset value of the respective
shares, in conformity with Section 22(c) of the 1940 Act and Rule 22c-1
thereunder.
Utilization of ``in kind'' redemptions by the CIGNA Funds,
to the extent appropriate, followed by the use by Investors of the
shares received to purchase shares of PCM Funds, would reduce the
expenses and transaction costs involved in the Substitution.
The Substitution will not alter or affect the insurance
benefits provided by Investors to Policy holders under the terms of the
contracts.
The Substitution will not affect adversely the tax
benefits available to Policy holders. The Substitution will not give
rise to any current federal income tax to Policy holders.
The Substitution provides Policy holders with an
underlying investment vehicle with enhanced asset size.
4. The Account I Policies and the INA/Putnam Policies reserve to
Investors the right--subject to prior approval of affected Policy
holders, as well as approval by the SEC--to substitute shares of
another management investment company for shares of an investment
company held by a division of Account I or the INA/Putnam Account, or
to add or eliminate one or more such divisions.
5. Investors reserved this right of substitution in order to
protect itself and its Policy holders in several adverse situations.
This includes the present situation where the investment adviser to the
underlying investment vehicles has stated that it intends to withdraw
from the equity advisory business, with the related implication that a
dissolution of the CIGNA Funds would result in a forced liquidation of
Account I and that portion of the INA/Putnam Account for which the
CIGNA Funds serves as the underlying investment vehicle.
6. The Applicants submit that, under the circumstances, it is in
the best interests of Account I and INA/Putnam Policy owners to proceed
with the Substitution. The Applicants represent that the overall
investment objectives of the portfolio of PCM Funds which would be
substituted for the corresponding portfolio of the CIGNA Funds are
sufficiently similar for the Substitution to be appropriate. The
Applicants believe that the investment objectives are compatible.
7. The Applicants further represent that total fees and expenses,
as a percentage of net assets, for the portfolios of PCM Funds which
would be so substituted are not expected to increase as a result of the
Substitution. The Applicants acknowledge that, with the exception of
the PCM Money Market Fund, the advisory fee for each of the PCM Funds
is higher than the advisory fee for the corresponding CIGNA Fund.
However, the Applicants submit that since the PCM Funds are
substantially larger in asset size than the CIGNA Funds, the operating
expenses are spread over a larger base, thereby producing total expense
ratios for the PCM Funds which, on a historical basis, have been lower
than the ratios for the CIGNA Funds.
B. Request for Order Pursuant to Sections 6(c) and 17(b) of the 1940
Act
1. Under certain circumstances, Section 17(a)(1) of the 1940 Act
prohibits any affiliated person of a registered investment company, or
an affiliated person of an affiliated person, from selling any security
or other property to such registered investment company. Section
17(a)(2) of the 1940 Act prohibits any of the persons described above
from purchasing any security or other property from such registered
investment company.
2. The Applicants submit that because the Substitution may be
deemed to involve one or more purchases or sales of securities between
and among affiliated persons as a result of the purchase by Account I
and the INA/Putnam Account of shares of PCM Funds with proceeds
(including ``in kind'' distributions of securities in lieu of cash)
from the redemption of shares of the CIGNA Funds, the Substitution may
involve transactions prohibited by Section 17(a) of the 1940 Act. The
Applicants further submit that the Substitution would not be exempt
from Section 17 of the 1940 Act pursuant to Rule 17a-7 thereunder,
since the affiliations among the parties do not arise solely by reason
of having common investment advisers, common directors and/or common
officers.
3. Section 17(b) of the 1940 Act provides that:
Notwithstanding subsection (a), any person may file with the
Commission an application for an order exempting a proposed transaction
of the applicant from one or more provisions of that subsection. The
Commission shall grant such application and issue such order of
exemption if evidence establishes that--
(1) The terms of the proposed transaction, including the
consideration to be paid or received, are reasonable and fair and do
not involve overreaching on the part of any person concerned;
(2) The proposed transaction is consistent with the policy of
each registered investment company concerned, as recited in its
registration statement and reports filed under this title; and
(3) The proposed transaction is consistent with the general
purposes of this title.
4. The Applicants seek an exemption from Section 17(a) under both
Sections 17(b) and 6(c) of the 1940 Act, because Section 17(b) refers
to a single ``proposed transaction'' while, under Section 6(c), the
Commission may exempt a series of transactions.
5. The Applicants represent that the terms of the Substitution meet
all of the requirements of Section 17(b). The Applicants submit that,
for the reasons set forth in their request for exemptive relief under
Section 26(b) of the 1940 Act--particularly those set forth below, the
terms of the Substitution are reasonable and fair and do not involve
overreaching on the part of any person concerned.
The Substitution will be effected pursuant to the
established net asset values of CIGNA Funds and PCM Funds as of the
effective date of the Substitution, in conformity with Section 22(c) of
the 1940 Act and Rule 22c-1 thereunder.
The Substitution is intended to provide owners of Account
I Policies and INA/Putnam Policies with underlying investment vehicles
which correspond to the options currently available under the CIGNA
Funds.
The Substitution is intended to provide owners of Account
I Policies and INA/Putnam Policies with continuity, given the announced
intention of CII to withdraw as investment adviser to the CIGNA Funds.
The Substitution is expected to result in lower expense
ratios.
The Substitution is not expected to have federal income
tax consequences for Policy holders.
6. The Applicants further submit that, with respect to the ``in
kind'' aspects of the Substitution: (a) Investors has been advised by
CIGNA Funds and PCM Funds that only those securities which Putnam
otherwise would select for the applicable portfolios of PCM Funds will
be included in the ``in kind'' transfer to Investors; (b) Investors has
been assured by CII and Putnam that the securities to be included in
the ``in kind'' transfer will be valued at independent current market
prices on the effective date of the Substitution; and (c) CII and
Putnam have assured Investors that no brokerage commissions, fees or
other remuneration would be paid or charged in connection with the in
kind transfers.
7. The Applicants represent that because the ``in kind'' transfer
would occur only once--i.e., on the effective date of the Substitution,
Account I and INA/Putnam Account have not adopted the written
procedures described in paragraph (e)(1) of Rule 17a-7. Investors
submits that the purposes intended to be served by such written
procedures are not applicable to the current situation. Investors
submits that the proposed transactions involved in the Substitution
fall within the intent of Rule 17a-7 securities redeemed in kind and
that, consequently, there will be no overreaching because all
securities redeemed in kind and used to purchase shares of the PCM
Funds will be consistently valued for all purposes. Nonetheless,
Investors, Account I and INA/Putnam Account will comply with paragraphs
(b), (c) and (d) of Rule 17a-7.
8. The Applicants submit that the Substitution is consistent with
the general purposes of the 1940 Act and does not present any of the
investor protection concerns that Section 26(b) is designed to address.
The Applicants note that Policy holder will be informed fully of the
terms of the Substitution and will have an opportunity to vote on the
Substitution following the approval of this application by the
Commission. The variable annuity contracts issued by Account I and the
INA/Putnam Account provide that, in the event of a substitution of
underlying fund shares, ``prior approval by the vote of a majority of
the votes to be cast by persons having their contract values determined
by the affected [separate account] [d]ivision will be obtained.''
Applicants' Conclusion
For the reasons discussed above, the Applicants submit that the
requested order under Section 26(b) meets the standards of that
section, and that the requested exemption from Section 17(a) meets the
standards of Sections 6(c) and 17(b).
For the Commission by the Division of Investment Management
pursuant to delegated authority.
Jonathan G. Katz,
Secretary.
[FR Doc. 94-29419 Filed 11-29-94; 8:45 am]
BILLING CODE 8010-01-M
