Self-Regulatory Organizations; NYSE Arca, Inc.; Order Granting Approval of Proposed Rule Change, as Modified by Amendment Nos. 2 and 3 Thereto, To List and Trade Shares of Merk Hard Currency ETF Under NYSE Arca Equities Rule 8.600, 4788-4793 [2014-01661]
Download as PDF
4788
Federal Register / Vol. 79, No. 19 / Wednesday, January 29, 2014 / Notices
description of the Trust, including those
set forth above and in the Notice, as
modified by Amendment No. 1.
For the foregoing reasons, the
Commission believes the proposal to list
and trade the Shares is consistent with
the Exchange Act.
IV. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Exchange Act,40
that the proposed rule change (SR–
NYSEArca–2013–137), as modified by
Amendment No. 1, be, and it hereby is,
approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.41
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2014–01662 Filed 1–28–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–71373; File No. SR–FINRA–
2013–051]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Designation
of a Longer Period for Commission
Action on Proposed Rule Change To
Amend the Uniform Branch Office
Registration Form (Form BR)
Section 19(b)(2) of the Act 5 provides
that within 45 days of the publication of
notice of the filing of a proposed rule
change, or within such longer period up
to 90 days as the Commission may
designate if it finds such longer period
to be appropriate and publishes its
reasons for so finding or as to which the
self-regulatory organization consents,
the Commission shall either approve the
proposed rule change, disapprove the
proposed rule change, or institute
proceedings to determine whether the
proposed rule change should be
disapproved. The 45th day for this filing
is January 27, 2014. The Commission is
extending this 45-day time period.
The Commission finds it appropriate
to designate a longer period within
which to take action on the proposed
rule change, so that it has sufficient time
to consider this proposed rule change
and the Comment Letters that have been
submitted in connection with this
proposed rule change.
Accordingly, the Commission,
pursuant to Section 19(b)(2) of the Act,6
designates March 13, 2014, as the date
by which the Commission should either
approve or disapprove, or institute
proceedings to determine whether to
disapprove, the proposed rule change
(File No. SR–FINRA–2013–051).
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.7
Elizabeth M. Murphy,
Secretary.
January 23, 2014.
[FR Doc. 2014–01657 Filed 1–28–14; 8:45 am]
On November 25, 2013, Financial
Industry Regulatory Authority, Inc.
(‘‘FINRA’’) filed with the Securities and
Exchange Commission (‘‘Commission’’),
pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2 a
proposed rule change to amend the
Uniform Branch Office Registration
Form (Form BD). The proposed rule
change was published for comment in
the Federal Register on December 13,
2013.3 The Commission received three
comment letters on this proposal.4
BILLING CODE 8011–01–P
40 15
U.S.C. 78s(b)(2).
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See Securities Exchange Act Release No. 71027
(December 13, 2013), 78 FR 75954.
4 See letters to Elizabeth M. Murphy, Secretary,
Commission, from Jason Doss, President, Public
Investors Arbitration Bar Association, January 2,
2014; David T. Ballaire, Esq., Executive Vice
President and General Counsel, Financial Services
Institute, January 3, 2104; and Clifford Kirsch and
Eric A. Arnold, Sutherland, Asbill and Brennan
LLP, on behalf of the Committee of Annuity
Insurers, January 3, 2014 (collectively, the
‘‘Comment Letters’’).
tkelley on DSK3SPTVN1PROD with NOTICES
41 17
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–71377; File No. SR–
NYSEArca-2013–132]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Order Granting Approval of
Proposed Rule Change, as Modified by
Amendment Nos. 2 and 3 Thereto, To
List and Trade Shares of Merk Hard
Currency ETF Under NYSE Arca
Equities Rule 8.600
January 23, 2014.
I. Introduction
On November 22, 2013, NYSE Arca,
Inc. (‘‘Exchange’’ or ‘‘NYSE Arca’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
5 15
U.S.C. 78s(b)(2).
U.S.C. 78s(b)(2).
7 17 CFR 200.30–3(a)(31).
1 15 U.S.C. 78s(b)(1).
6 15
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19b–4 thereunder,2 a proposed rule
change to list and trade shares
(‘‘Shares’’) of the Merk Hard Currency
ETF (‘‘Fund’’) of the Forum ETF Trust
(‘‘Trust’’). The proposed rule change
was published for comment in the
Federal Register on December 11,
2013.3 On December 19, 2013, the
Exchange (1) submitted but
subsequently withdrew Amendment No.
1 to the proposed rule change, and (2)
submitted Amendment No. 2 to the
proposed rule change. On January 10,
2014, the Exchange submitted
Amendment No. 3 to the proposed rule
change.4 The Commission received no
comments on the proposal. This order
grants approval of the proposed rule
change, as modified by Amendment
Nos. 2 and 3 thereto.
II. Description of the Proposed Rule
Change
The Exchange proposes to list and
trade Shares of the Fund under NYSE
Arca Equities Rule 8.600, which governs
the listing and trading of Managed Fund
Shares. The Shares will be offered by
the Trust,5 a Delaware statutory trust
that is registered with the Commission
as an open-end management investment
company. Forum Investment Advisors,
LLC (‘‘Investment Manager’’) is the
investment manager of the Fund. Merk
Investments, LLC (‘‘Investment
Adviser’’) is the investment adviser of
the Fund.6 Foreside Fund Services LLC
2 17
CFR 240.19b–4.
Securities Exchange Act Release No. 70994
(Dec. 5, 2013), 78 FR 75423 (‘‘Notice’’).
4 In Amendment No. 2, the Exchange provided
further information regarding where pricing
information for certain Fund assets can be found
and corrected certain cross references. In
Amendment No. 3, the Exchange clarified: (1) that
the Fund will not invest in any non-U.S. equity
securities and that the Fund will not invest in
American Depositary Receipts, European
Depositary Receipts, Global Depositary Receipts
(collectively referred to as ‘‘depositary receipts’’),
New York Registered Shares, or American
Depositary Shares and removed all references
thereto; and (2) where pricing information for spot
currency transactions can be found. Because
Amendment Nos. 2 and 3 do not materially affect
the substance of the proposed rule change or raise
novel or unique issues, Amendment Nos. 2 and 3
did not require notice and comment.
5 The Trust is registered under the Investment
Company Act of 1940 (‘‘1940 Act’’). On April 12,
2013, the Trust filed with the Commission an
amendment to its registration statement on Form N–
1A under the Securities Act of 1933 (‘‘Securities
Act’’) and under the 1940 Act relating to the Fund
(File Nos. 333–180250 and 811–22679)
(‘‘Registration Statement’’). In addition, the
Exchange states that the Trust has obtained certain
exemptive relief under the 1940 Act. See
Investment Company Act Release No. 30549 (June
4, 2013) (File No. 812–13915–01) (‘‘Exemptive
Order’’).
6 The Investment Adviser will be responsible for
the day-to-day portfolio management of the Fund
and, as such, will make all investment decisions for
the Fund and is responsible for implementing the
3 See
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is the Fund’s principal underwriter and
distributer of the Fund’s Shares.
Atlantic Fund Administration, LLC, an
affiliate of the Investment Manager,
serves as the administrator for the Fund.
The Bank of New York Mellon
Corporation serves as custodian and
transfer agent for the Fund. The
Exchange represents that neither the
Investment Manager nor the Investment
Adviser is a broker-dealer or is affiliated
with a broker-dealer.7
The Exchange has made the following
representations and statements in
describing the Fund and its investment
strategies, including other permitted
portfolio holdings and investment
restrictions.8
tkelley on DSK3SPTVN1PROD with NOTICES
Description of the Fund
The Fund’s investment objective is to
seek to profit from a rise in hard
currencies relative to the U.S. dollar.
The Fund will be actively managed and
does not seek to replicate the
performance of a specified index. Under
normal market conditions,9 the Fund
will invest at least 80% of the value of
its net assets (plus borrowings for
investment purposes) in a basket of hard
currency-denominated investments
composed of high-quality, short-term 10
Fund’s investment strategy. The Investment
Manager will develop the overall investment
program for the Fund (which includes working with
the Investment Adviser to define principal
investment strategies) and will be responsible for
overseeing and reporting to the Board of the Trust
regarding the Investment Adviser.
7 See Commentary .06 to NYSE Arca Equities
Rule 8.600. The Exchange represents that, in the
event that (a) the Investment Manager or Investment
Adviser becomes a registered broker-dealer or
becomes newly affiliated with a broker-dealer, or (b)
any new investment adviser is or becomes affiliated
with a broker-dealer, it will implement a fire wall
with respect to its relevant personnel or its brokerdealer affiliate, as the case may be, regarding access
to information concerning the composition of, or
changes to, the portfolio and will be subject to
procedures designed to prevent the use and
dissemination of material, non-public information
regarding the portfolio.
8 The Commission notes that additional
information regarding the Trust, the Fund, and the
Shares, including investment strategies, risks, net
asset value (‘‘NAV’’) calculation, creation and
redemption procedures, fees, portfolio holdings,
disclosure policies, distributions, and taxes, among
other information, is included in the Notice and the
Registration Statement, as applicable. See Notice
and Registration Statement, supra notes 3 and 5,
respectively.
9 The term ‘‘under normal market conditions’’
includes, but is not limited to, the absence of
adverse market, economic, political or other
conditions including extreme volatility or trading
halts in the fixed income markets or the financial
markets generally; operational issues causing
dissemination of inaccurate market information; or
force majeure type events such as systems failure,
natural or man-made disaster, act of God, armed
conflict, act of terrorism, riot or labor disruption or
any similar intervening circumstance.
10 According to the Exchange, the Fund will
define ‘‘short-term’’ based upon an instrument’s
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debt instruments, physical gold, and
gold-related securities.11
The term ‘‘hard currencies’’ is used to
describe currencies of countries
pursuing what the Investment Adviser
believes to be ‘‘sound’’ monetary policy
and gold.12 Sound monetary policy is
defined by the Investment Adviser as a
monetary policy providing an
environment fostering long-term price
stability. The Investment Adviser
considers gold to be the only currency
with intrinsic value and, as such,
qualifies as a hard currency.
The term ‘‘high-quality’’ refers to debt
instruments rated in the top three
ratings by a U.S. nationally recognized
ratings service, or that the Investment
Adviser considers comparable in quality
to debt instruments rated in the top
three ratings.13
The Investment Adviser will
determine currency allocations based on
an analysis of monetary policies
pursued by central banks and economic
environments. The Investment Adviser
will search for currencies that, in the
Investment Adviser’s opinion, are
backed by sound monetary policy or
gold. Once this determination has been
made, money market or other debt
instruments will be selected to create a
liquid portfolio of short duration and
high credit quality.
remaining maturity period, not the initial maturity
period. For example, a twenty-year bond with three
months remaining until maturity will be considered
to be a short-term debt instrument.
11 ‘‘Gold-related securities’’ are exchange-traded
products (‘‘ETPs’’) that invest directly in gold
bullion. ETPs that hold gold, physically or
indirectly, are not regulated under the 1940 Act and
are not afforded the protections thereunder.
12 Provided that the Investment Adviser deems
the following currencies to be backed by sound
monetary policy, ‘‘hard currencies’’ include,
without limitation: Argentine Peso (ARS);
Australian Dollar (AUD); Brazilian Real (BRL);
British Pound (GBP); Canadian Dollar (CAD);
Chilean Peso (CLP); Chinese Renminbi (CNY);
Colombian Peso (COP); Czech Koruna (CZK);
Danish Krone (DKK); Euro (EUR); Hong Kong Dollar
(HKD); Hungarian Forint (HUF); Iceland Krona
(ISK); Indian Rupee (INR); Indonesian Rupiah (IDR);
Israeli Shekel (ILS); Japanese Yen (JPY); Malaysian
Ringgit (MYR); Mexican Peso (MXN); New Zealand
Dollar (NZD); Norwegian Krone (NOK); Pakistani
Rupee (PKR); Peruvian New Sol (PEN); Philippine
Peso (PHP); Polish Zloty (PLN); Russian Ruble
(RUB); Singapore Dollar (SGD); South African Rand
(ZAR); South Korean Won (KRW); Swedish Krona
(SEK); Swiss Franc (CHF); Taiwanese Dollar (TWD);
Thai Baht (THB); Thai Baht Onshore (THO);
Turkish Lira (TRY); U.S. Dollar (USD); and
successor currencies of the aforementioned
currencies, if any.
13 In determining which instruments are
comparable in quality to instruments rated in the
top three ratings, the Investment Adviser will
evaluate the relative creditworthiness of issuers and
the relative credit quality of debt issues.
Consideration may be given to an issuer’s financial
strength, capacity for timely payment and ability to
withstand adverse financial developments, as well
as any ratings assigned to other instruments issued
by that issuer.
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The Fund will specifically seek the
currency risk of select countries
pursuing what the Investment Adviser
believes are sound monetary policies.
As long-term price stability is unlikely
to be achieved by most currencies, if
any, the Investment Adviser will focus
on a country’s monetary policy that
fosters such stability. The Investment
Adviser will invest in a basket of hard
currency-denominated investments that
may include physical gold and goldrelated securities to reduce the Fund’s
exposure to the risks of any one
currency. The Investment Adviser may
adapt the currency allocations as its
analysis of monetary policies and
economic environments evolves.
The Investment Adviser may sacrifice
yield in return for high credit quality of
debt securities. The Investment Adviser
may limit or exclude currencies if, in
the Investment Adviser’s opinion, the
potential for appreciation is not backed
by sound monetary policy.
If the Investment Adviser deems a
currency crisis likely, it is possible that
the Fund will restrict its investments to
a few currencies that meet the
Investment Adviser’s investment criteria
for sound monetary policies and
practices.
Principal Investments
As noted above, under normal market
conditions,14 the Fund will invest at
least 80% of the value of its net assets
(plus borrowings for investment
purposes) in hard currencydenominated investments composed of
high-quality, short-term debt
instruments,15 physical gold, and goldrelated securities.
To try to reduce interest rate and
credit risk to its portfolio, the Fund will
seek to maintain a weighted average
portfolio maturity of less than eighteen
months, although the Fund may
maintain a weighted average portfolio
maturity of greater than eighteen
months at any given time. In addition,
the Fund will only buy money market
or other short-term debt instruments
that are rated in the top three ratings by
U.S. nationally recognized ratings
services or that the Investment Adviser
considers comparable in quality to
instruments rated in the top three
ratings.16
The high quality, short term debt
instruments in which the Fund will
primarily invest include: U.S. dollarand non-U.S. dollar-denominated
money market instruments and similar
securities; debt obligations issued by the
14 See
supra note 9.
supra note 10.
16 See supra note 13.
15 See
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tkelley on DSK3SPTVN1PROD with NOTICES
U.S. and foreign national, provincial,
state or municipal governments or their
political subdivisions or agencies,
central banks, sovereign entities,
supranational organizations or special
purpose entities organized or backed by
any of the foregoing entities (‘‘Special
Purpose Entities’’); debt instruments
issued by U.S. and foreign
corporations; 17 and debt obligations
issued by entities that the Investment
Adviser considers to be comparable to
entities in the categories enumerated
above.
Money market instruments in which
the Fund may invest include short-term
government securities, floating and
variable-rate notes, certificates of
deposit, time deposits, bankers’
acceptances, commercial paper, and
other short-term liquid instruments.
Securities issued by the U.S.
Government in which the Fund may
invest include short-term U.S. Treasury
obligations and short-term debt
obligations. The Fund may also
purchase certificates not issued by the
U.S. Department of the Treasury, which
evidence ownership of future interest,
principal, or interest and principal
payments on obligations issued by the
U.S. Department of the Treasury. The
Fund may invest in obligations issued
or guaranteed by U.S. Government
agencies.18 The Fund may also invest in
separated or divided U.S. government
securities.19 Foreign government
securities may include direct
obligations, as well as obligations
17 The Fund will typically invest only in debt
instruments that the Investment Adviser deems to
be sufficiently liquid at time of investment.
Generally, a debt instrument must have $100
million (or an equivalent value if denominated in
a currency other than U.S. dollars) or more par
amount outstanding and significant par value
traded to be considered sufficiently liquid at the
time of investment. The Fund may invest up to 25%
of its total assets in debt instrument having a lower
par amount outstanding to the extent the
Investment Advisor determines such an investment
to be appropriate. In any such determination, the
Investment Advisor will evaluate the relative
creditworthiness of issuers and the relative credit
quality of debt issues. Consideration may be given
to an issuer’s financial strength, capacity for timely
payment, and ability to withstand adverse financial
developments.
18 Obligations issued or guaranteed by U.S.
Government agencies include: (1) obligations issued
or guaranteed by U.S. Government agencies and
instrumentalities that are backed by the full faith
and credit of the U.S. Government; and (2)
securities that are guaranteed by agencies or
instrumentalities of the U.S. Government but are
not backed by the full faith and credit of the U.S.
Government.
19 These instruments represent a single interest or
principal payment on a U.S. government security
that has been separated from all the other interest
payments as well as the security itself. While the
components of such instruments are drawn from
U.S. government securities, separated or divided
securities may be formed by non-governmental
institutions.
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guaranteed by the foreign government
and obligations issued by Special
Purpose Entities.
The Fund may invest in U.S. and
foreign corporate debt obligations.
Corporate debt obligations include
corporate bonds, debentures, notes,
commercial paper, and other similar
corporate debt instruments. In addition,
the Fund also may invest in corporate
debt securities registered and sold in the
U.S. by foreign issuers (sometimes
called Yankee bonds) and those sold
outside the U.S. by foreign or U.S.
issuers (sometimes called Eurobonds).
The Fund may invest in investmentgrade debt securities and noninvestment-grade debt securities.
Investment-grade means rated in the top
four long-term rating categories, or
unrated and determined by the
Investment Adviser to be of comparable
quality. The Fund may invest up to 5%
of its total assets in non-investmentgrade debt securities, including
defaulted securities, however the Fund
does not expect to invest up to 5% in
defaulted securities.
The Fund may invest in physical gold
and gold-related securities. To the
extent that the Fund invests in gold, it
may do so by investing directly in
physical gold or indirectly by investing
through U.S.-listed ETPs 20 that invest in
gold bullion.
Other Investments
In addition to the principal
investments in hard currencydenominated investments described
above, the Fund may make certain other
investments. In addition to the U.S.listed ETPs that the Fund may use as an
indirect investment in gold, the Fund
may invest in other ETPs, including
exchange-traded funds (‘‘ETFs’’) 21 and
exchange traded notes (‘‘ETNs’’).22
The Fund may enter into repurchase
agreements. If the Fund enters into a
repurchase agreement, it will maintain
possession of the purchased securities
and any underlying collateral. The Fund
may also enter into reverse repurchase
20 Such ETPs may include the following
securities: Trust Issued Receipts (as described in
NYSE Arca Equities Rule 8.200) and CommodityBased Trust Shares (as described in NYSE Arca
Equities Rule 8.201). The Fund may invest in ETPs
which are not registered under the 1940 Act. The
Fund may invest in ETPs sponsored by the
Investment Adviser or its affiliates.
21 For purposes of this proposed rule change,
ETFs are securities that are registered pursuant to
the 1940 Act such as those listed and traded on the
Exchange pursuant to NYSE Arca Equities Rules
5.2(j)(3), 8.100, and 8.600.
22 For purposes of this proposed rule change,
ETNs are securities that are registered pursuant to
the Securities Act such as those listed and traded
on the Exchange pursuant to NYSE Arca Equities
Rule 5.2(j)(6).
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agreements. A counterparty to a reverse
repurchase agreement must be a primary
dealer that reports to the Federal
Reserve Bank of New York or one of the
largest 100 commercial banks in the
United States.
While the Fund is permitted to invest
in exchange-listed common and
preferred stock and warrants, the
Exchange states that the Fund will not
generally invest in such assets. The
Fund will not invest in any non-U.S.
equity securities.
The Fund may invest in convertible
securities, which include debt
securities, preferred stock, or other
securities that may be converted into, or
exchanged for, a given amount of
common stock of the same or a different
issuer during a specified period and at
a specified price in the future.
The Fund may invest in variable
amount master demand notes. All
variable amount master demand notes
acquired by the Fund will be payable
within a prescribed notice period not to
exceed seven days.
The Fund may hold cash in bank
deposits in foreign currencies. The Fund
may conduct foreign currency exchange
transactions either on a spot (cash) basis
at the spot rate prevailing in the foreign
exchange market or by entering into a
forward foreign currency contract. The
Fund may enter into forward contracts
in order to ‘‘lock in’’ the exchange rate
between the currency it will deliver and
the currency it will receive for the
duration of the contract.
For the purpose of hedging, efficient
portfolio management, generating
income, or enhancement of returns, the
Fund may, from time to time, enter into
forward currency contracts,23 including
currency forwards and cross currency
forwards. The Fund may enter into
forward currency contracts to hedge
against risks arising from securities the
Fund owns or anticipates purchasing, or
the U.S. dollar value of interest and
dividends paid on those securities.24
The Fund may invest in a combination
of forward currency contracts and U.S.
dollar-denominated instruments in an
attempt to obtain an investment result
23 A forward currency contract is an obligation to
purchase or sell a specific currency at a future date,
which may be any fixed number of days from the
date of the contract agreed upon by the parties, at
a price set at the time of the contract.
24 To the extent the Fund retains various U.S.
fixed-income instruments to settle derivative
contracts, the Investment Adviser expects such
instruments to generate income for the Fund. The
value of such investments (to the extent used to
cover the Fund’s net exposure under the forward
foreign currency contracts and similar instruments)
and forward contracts and other instruments that
provide investment exposure to currencies will be
counted for purposes of the Fund’s 80% policy.
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that is substantially the same as a direct
investment in a foreign currencydenominated instrument. For hedging
purposes, the Fund may invest in
forward currency contracts to hedge
either specific transactions (transaction
hedging) or portfolio positions (position
hedging).25
In order to respond to adverse market,
economic, political, or other conditions,
the Fund may assume a temporary
defensive position that is inconsistent
with its principal investment strategies
and invest, without limitation, in cash
or cash equivalents (including
commercial paper, certificates of
deposit, banker’s acceptances, and time
deposits) which may be U.S. dollardenominated.
tkelley on DSK3SPTVN1PROD with NOTICES
Investment Restrictions
The Fund may hold up to an aggregate
amount of 15% of its net assets in
illiquid assets (calculated at the time of
investment), including Rule 144A
securities deemed illiquid by the
Investment Adviser consistent with
Commission guidance 26 and master
demand notes. The Fund will monitor
its portfolio liquidity on an ongoing
basis to determine whether, in light of
current circumstances, an adequate
level of liquidity is being maintained,
and will consider taking appropriate
steps in order to maintain adequate
liquidity if, through a change in values,
net assets, or other circumstances, more
than 15% of the Fund’s net assets are
held in illiquid assets. Illiquid assets
include securities subject to contractual
or other restrictions on resale and other
instruments that lack readily available
markets as determined in accordance
with Commission staff guidance.
The Fund may not purchase a security
if, as a result, more than 25% of its total
assets would be invested in securities of
issuers conducting their principal
business activities in the same industry.
For purposes of this limitation, there is
no limit on investments in U.S.
government securities and repurchase
agreements covering U.S. government
25 The Investment Adviser seeks to mitigate
counterparty risk associated with forward currency
contracts by employing multiple brokers to execute
trades and by monitoring the creditworthiness of
counterparties through analysis of credit ratings
available through U.S. nationally recognized ratings
services.
26 In reaching liquidity decisions, the Investment
Adviser may consider the following factors: the
frequency of trades and quotes for the security; the
number of dealers wishing to purchase or sell the
security and the number of other potential
purchasers; dealer undertakings to make a market
in the security; and the nature of the security and
the nature of the marketplace in which it trades
(e.g., the time needed to dispose of the security, the
method of soliciting offers, and the mechanics of
transfer).
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securities. With respect to foreign
government securities, the Fund treats
each foreign government or sovereign as
its own industry.
Although the Fund intends to invest
in a variety of securities and
instruments, the Fund will be
considered ‘‘non-diversified’ for the
purposes of the 1940 Act, which means
that it may invest more of its assets in
the securities of a smaller number of
issuers than if it were a diversified fund.
The Fund will use leveraged
investment techniques only when the
Investment Adviser believes that
leveraging and the returns available to
the Fund from investing the cash will
provide investors with a potentially
higher return. Such leveraged
investment techniques include
borrowing, repurchase agreements,
reverse repurchase agreements, and
securities lending. The Fund will not
invest in leveraged or inverse leveraged
ETPs. Such investments will not be
used to enhance the leverage of the
Fund as a whole and will otherwise be
consistent with the Fund’s investment
objective.
The Fund will not directly invest in
options contracts, futures contracts, or
swap agreements. The Fund intends, for
each taxable year, to qualify for
treatment as a ‘‘regulated investment
company’’ under Subchapter M of the
Internal Revenue Code of 1986, as
amended.27
III. Discussion and Commission’s
Findings
After careful review, the Commission
finds that the proposed rule change is
consistent with the requirements of
Section 6 of the Act 28 and the rules and
regulations thereunder applicable to a
national securities exchange.29 In
particular, the Commission finds that
the proposal is consistent with Section
6(b)(5) of the Act,30 which requires,
among other things, that the Exchange’s
rules be designed to promote just and
equitable principles of trade, to remove
impediments to, and perfect the
mechanism of, a free and open market
and a national market system, and, in
general, to protect investors and the
public interest. The Commission notes
that the Fund and the Shares must
comply with the initial and continued
listing criteria in NYSE Arca Equities
27 26
U.S.C. 851.
U.S.C. 78f.
29 In approving this proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
30 15 U.S.C. 78f(b)(5).
28 15
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4791
Rule 8.600 for the Shares to be listed
and traded on the Exchange.
The Commission finds that the
proposal to list and trade the Shares on
the Exchange is consistent with Section
11A(a)(1)(C)(iii) of the Act,31 which sets
forth Congress’ finding that it is in the
public interest and appropriate for the
protection of investors and the
maintenance of fair and orderly markets
to assure the availability to brokers,
dealers, and investors of information
with respect to quotations for, and
transactions in, securities. Quotation
and last-sale information for the Shares
and underlying U.S. exchange-traded
equities, including, without limitation,
ETPs (including ETFs and ETNs),
common and preferred stock, and
warrants, will be available via the
Consolidated Tape Association (‘‘CTA’’)
high-speed line. Quotation information
from brokers and dealers or pricing
services will be available for spot
currency transactions, forwards, fixed
income securities, other money market
instruments, and repurchase and reverse
repurchase agreements held by the
Fund. Price information for the Fund’s
portfolio securities and other
instruments is generally readily
available through major market data
vendors, automated quotation systems,
published or other public sources and,
for listed securities, the securities
exchange on which they are listed and
traded. Investors may obtain on a 24hour basis gold pricing information
based on the spot price for an ounce of
gold from various financial information
service providers, such as Reuters and
Bloomberg.32
On each business day, before
commencement of trading of Shares in
the Core Trading Session on the
Exchange, the Fund will disclose on its
Web site the identities and quantities of
the portfolio of securities and other
assets (‘‘Disclosed Portfolio’’) held by
the Fund and that will form the basis for
the Fund’s calculation of NAV at the
31 15
U.S.C. 78k–1(a)(1)(C)(iii).
to the Exchange, Reuters and
Bloomberg provide at no charge on their Web sites
delayed information regarding the spot price of
gold, as well as information about news and
developments in the gold market. Reuters and
Bloomberg also offer a professional service to
subscribers for a fee that provides information on
gold prices directly from market participants. ICAP
plc provides an electronic trading platform called
EBS for the trading of spot gold, as well as a feed
of live streaming prices to Reuters and Moneyline
Telerate subscribers. The Exchange also states that
there are a variety of other public Web sites
providing information on gold, ranging from those
specializing in precious metals to sites maintained
by major newspapers, such as The Wall Street
Journal. In addition, the daily London noon Fix is
publicly available at no charge at
www.thebulliondesk.com.
32 According
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end of the business day.33 In addition,
the Portfolio Indicative Value, as
defined in NYSE Arca Equities Rule
8.600(c)(3), that will be based upon the
current value for the components of the
Disclosed Portfolio, will be widely
disseminated at least every 15 seconds
during the Core Trading Session by one
or more major market data vendors.34
The Fund will calculate its NAV as of
the close of trading on the Exchange
(normally 4:00 p.m., Eastern Time) on
each weekday except on days when the
Exchange is closed.35 Information
regarding market price and trading
volume of the Shares will be continually
available on a real-time basis throughout
the day on brokers’ computer screens
and other electronic services.
Information regarding the previous
day’s closing price and trading volume
information for the Shares will be
published daily in the financial section
of newspapers. The Web site for the
Fund will include a form of the
33 On a daily basis, the Fund will disclose for
each portfolio security and other financial
instrument of the Fund the following information:
ticker symbol (if applicable), name or description of
security and financial instrument, number of shares
or dollar value of securities and financial
instruments held in the portfolio, and percentage
weighting of securities and financial instruments in
the portfolio. The Web site information will be
publicly available at no charge.
34 According to the Exchange, several major
market data vendors display or make widely
available Portfolio Indicative Values taken from
CTA or other data feeds.
35 According to the Exchange, the Fund will value
securities for which market quotations are readily
available at current market value, except for money
market instruments with a maturity of sixty days or
less, which may be valued at amortized cost.
Securities for which market quotations are readily
available, such as exchange-listed common stock
and preferred stock and warrants, will be valued
using the last reported sales price provided by
independent pricing services as of the close of
trading on the Exchange. In the absence of sales,
such securities will be valued at the mean of the
last bid and ask prices. Non-exchange-traded
securities for which quotations are readily available
will be valued at the mean between the current bid
and ask prices. Debt securities, including master
demand notes and convertible securities, may be
valued at prices supplied by the Fund’s pricing
agents based on broker or dealer-supplied
valuations or matrix pricing, a method of valuing
securities by reference to the value of other
securities with similar characteristics such as
rating, interest rate, and maturity. Forward currency
contracts will be valued at the mean of bid and ask
prices for the time period interpolated from rates
reported by an independent pricing service for
proximate time periods. Spot currency transactions
will normally be valued on the basis of quotes
obtained from brokers and dealers or pricing
services using data reflecting the earlier closing of
the principal markets for those assets. Repurchase
agreements and reverse repurchase agreements will
generally be valued at par. Gold will generally be
valued at prices supplied by the Fund’s pricing
agents based on the spot price for an ounce of gold.
Investments in open-end registered investment
companies will be valued at their NAV, and
investments in other ETPs will be valued using
market prices.
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prospectus for the Fund and additional
data relating to NAV and other
applicable quantitative information.
The Commission further believes that
the proposal to list and trade the Shares
is reasonably designed to promote fair
disclosure of information that may be
necessary to price the Shares
appropriately and to prevent trading
when a reasonable degree of
transparency cannot be assured. The
Exchange will obtain a representation
from the issuer of the Shares that the
NAV per Share will be calculated daily
and that the NAV and the Disclosed
Portfolio will be made available to all
market participants at the same time.
Trading in Shares of the Fund will be
halted if the circuit breaker parameters
in NYSE Arca Equities Rule 7.12 have
been reached or because of market
conditions or for reasons that, in the
view of the Exchange, make trading in
the Shares inadvisable,36 and trading in
the Shares will be subject to NYSE Arca
Equities Rule 8.600(d)(2)(D), which sets
forth additional circumstances under
which Shares of the Fund may be
halted. The Exchange states that it has
a general policy prohibiting the
distribution of material, non-public
information by its employees.
Consistent with NYSE Arca Equities
Rule 8.600(d)(2)(B)(ii), the Reporting
Authority must implement and
maintain, or be subject to, procedures
designed to prevent the use and
dissemination of material, non-public
information regarding the actual
components of the Fund’s portfolio. In
addition, the Exchange states that
neither the Investment Manager nor the
Investment Adviser is a broker-dealer or
is affiliated with a broker-dealer.37 The
36 These reasons may include: (1) the extent to
which trading is not occurring in the securities or
the financial instruments composing the Disclosed
Portfolio of the Fund; or (2) whether other unusual
conditions or circumstances detrimental to the
maintenance of a fair and orderly market are
present. With respect to trading halts, the Exchange
may consider all relevant factors in exercising its
discretion to halt of suspend trading in the Shares
of the Fund.
37 See supra note 7 and accompanying text. The
Exchange states that an investment adviser to an
open-end fund is required to be registered under the
Investment Advisers Act of 1940 (‘‘Advisers Act’’).
As a result, the Investment Manager, the Investment
Adviser, and their related personnel are subject to
the provisions of Rule 204A–1 under the Advisers
Act relating to codes of ethics. This Rule requires
investment advisers to adopt a code of ethics that
reflects the fiduciary nature of the relationship to
clients as well as compliance with other applicable
securities laws. Accordingly, procedures designed
to prevent the communication and misuse of nonpublic information by an investment adviser must
be consistent with Rule 204A–1 under the Advisers
Act. In addition, Rule 206(4)–7 under the Advisers
Act makes it unlawful for an investment adviser to
provide investment advice to clients unless the
investment adviser has (i) adopted and
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Exchange represents that trading in the
Shares will be subject to the existing
trading surveillances, administered by
the Financial Industry Regulatory
Authority (‘‘FINRA’’) on behalf of the
Exchange, which are designed to detect
violations of Exchange rules and
applicable federal securities laws.38 The
Exchange further represents that these
procedures are adequate to properly
monitor Exchange trading of the Shares
in all trading sessions and to deter and
detect violations of Exchange rules and
applicable federal securities laws.
Moreover, prior to the commencement
of trading, the Exchange states that it
will inform its Equity Trading Permit
Holders in an Information Bulletin of
the special characteristics and risks
associated with trading the Shares.
The Exchange represents that the
Shares are deemed to be equity
securities, thus rendering trading in the
Shares subject to the Exchange’s
existing rules governing the trading of
equity securities. In support of this
proposal, the Exchange has made
representations, including the
following:
(1) The Shares will be subject to
NYSE Arca Equities Rule 8.600, which
sets forth the initial and continued
listing criteria applicable to Managed
Fund Shares.
(2) The Exchange has appropriate
rules to facilitate transactions in the
Shares during all trading sessions.
(3) The Exchange represents that its
surveillance procedures are adequate to
properly monitor Exchange trading of
the Shares in all trading sessions and to
deter and detect violations of Exchange
rules and applicable federal securities
laws
(4) FINRA, on behalf of the Exchange,
will communicate as needed regarding
trading in the Shares and underlying
equity securities (including, without
limitation, ETPs (including ETFs and
ETNs), common and preferred stock and
warrants, and any other exchangetraded products) with other markets and
other entities that are members of the
Intermarket Surveillance Group (‘‘ISG’’),
implemented written policies and procedures
reasonably designed to prevent violation, by the
investment adviser and its supervised persons, of
the Advisers Act and the Commission rules adopted
thereunder; (ii) implemented, at a minimum, an
annual review regarding the adequacy of the
policies and procedures established pursuant to
subparagraph (i) above and the effectiveness of their
implementation; and (iii) designated an individual
(who is a supervised person) responsible for
administering the policies and procedures adopted
under subparagraph (i) above.
38 The Exchange states that FINRA surveils
trading on the Exchange pursuant to a regulatory
services agreement and that the Exchange is
responsible for FINRA’s performance under this
regulatory services agreement.
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and FINRA, on behalf of the Exchange,
may obtain trading information
regarding trading in the Shares and
underlying equity securities (including,
without limitation, ETPs (including
ETFs and ETNs), common and preferred
stock and warrants, and any other
exchange-traded products) from such
markets and other entities. In addition,
the Exchange may obtain information
regarding trading in the Shares and
underlying equity securities (including,
without limitation, ETPs (including
ETFs and ETNs), common and preferred
stock and warrants, and any other
exchange-traded products) from markets
that are members of ISG or with which
the Exchange has in place a
comprehensive surveillance sharing
agreement. The ETPs (including ETFs
and ETNs), common and preferred
stock, and warrants in which the Fund
may invest all will be listed and traded
on an exchange which is a member of
ISG or with which the Exchange has in
place a comprehensive surveillance
sharing agreement. In addition, FINRA,
on behalf of the Exchange, is able to
access, as needed, trade information for
certain fixed income securities held by
the Fund reported to FINRA’s Trade
Reporting and Compliance Engine.
(5) Prior to the commencement of
trading, the Exchange will inform its
Equity Trading Permit Holders in an
Information Bulletin of the special
characteristics and risks associated with
trading the Shares. Specifically, the
Information Bulletin will discuss the
following: (a) The procedures for
purchases and redemptions of Shares in
creation unit aggregations (and that
Shares are not individually redeemable);
(b) NYSE Arca Equities Rule 9.2(a),
which imposes a duty of due diligence
on its Equity Trading Permit Holders to
learn the essential facts relating to every
customer prior to trading the Shares; (c)
the risks involved in trading the Shares
during the Opening and Late Trading
Sessions when an updated Portfolio
Indicative Value will not be calculated
or publicly disseminated; (d) how
information regarding the Portfolio
Indicative Value is disseminated; (e) the
requirement that Equity Trading Permit
Holders deliver a prospectus to
investors purchasing newly issued
Shares prior to or concurrently with the
confirmation of a transaction; and (f)
trading information.
(6) For initial and continued listing,
the Fund must be in compliance with
Rule 10A–3 under the Act,39 as
provided by NYSE Arca Equities Rule
5.3.
39 See
17 CFR 240.10A–3.
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(7) The Fund may hold up to an
aggregate amount of 15% of its net
assets in illiquid assets (calculated at
the time of investment), including Rule
144A securities deemed illiquid by the
Investment Adviser consistent with
Commission guidance, and master
demand notes.
(8) The Fund will only buy money
market or other short-term debt
instruments that are rated in the top
three ratings by U.S. nationally
recognized ratings services or that the
Investment Adviser considers
comparable in quality to instruments
rated in the top three ratings. The Fund
may only invest up to 5% of its total
assets in non-investment-grade debt
securities.
(9) If the Fund enters into a
repurchase agreement, it will maintain
possession of the purchased securities
and any underlying collateral. A
counterparty to a reverse repurchase
agreement must be a primary dealer that
reports to the Federal Reserve Bank of
New York or one of the largest 100
commercial banks in the United States.
(10) The Fund will not invest in: (a)
Any non-U.S. equity securities; (b)
options contracts, futures contracts, or
swap agreements; and (c) leveraged or
inverse leveraged ETPs.
(11) The Fund will typically invest
only in debt instruments that the
Investment Adviser deems to be
sufficiently liquid at time of investment.
Generally a debt instrument must have
$100 million (or an equivalent value if
denominated in a currency other than
U.S. dollars) or more par amount
outstanding and significant par value
traded to be considered sufficiently
liquid at the time of investment. The
Fund may invest up to 25% of its total
assets in debt instruments having a
lower par amount outstanding to the
extent the Investment Advisor
determines such an investment to be
appropriate. In any such determination,
the Investment Advisor will evaluate
the relative creditworthiness of issuers
and the relative credit quality of debt
issues. Consideration may be given to an
issuer’s financial strength, capacity for
timely payment, and ability to
withstand adverse financial
developments.
(12) A minimum of 100,000 Shares of
the Fund will be outstanding at the
commencement of trading on the
Exchange.
This approval order is based on all of
the Exchange’s representations,
including those set forth above and in
the Notice, and the Exchange’s
description of the Funds.
For the foregoing reasons, the
Commission finds that the proposed
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4793
rule change is consistent with Section
6(b)(5) of the Act 40 and the rules and
regulations thereunder applicable to a
national securities exchange.
IV. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,41 that the
proposed rule change (SR–NYSEArca–
2013–132), as modified by Amendment
Nos. 2 and 3 thereto, be, and it hereby
is, approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.42
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2014–01661 Filed 1–28–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–71372; File No. SR–FINRA–
2014–003]
Self-Regulatory Organizations;
Financial Industry Regulatory
Authority, Inc.; Notice of Filing of a
Proposed Rule Change To Amend
FINRA’s Corporate Financing Rules To
Simplify and Refine the Scope of the
Rules
January 23, 2014.
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 January 9,
2014, Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’) 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 FINRA. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of the Substance
of the Proposed Rule Change
FINRA is proposing to amend
FINRA’s corporate financing rules to
simplify and refine the scope of the
rules.
The text of the proposed rule change
is available on FINRA’s Web site at
https://www.finra.org, at the principal
office of FINRA and at the
Commission’s Public Reference Room.
40 15
U.S.C. 78f(b)(5).
U.S.C. 78s(b)(2).
42 17 CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
41 15
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[Federal Register Volume 79, Number 19 (Wednesday, January 29, 2014)]
[Notices]
[Pages 4788-4793]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-01661]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-71377; File No. SR-NYSEArca-2013-132]
Self-Regulatory Organizations; NYSE Arca, Inc.; Order Granting
Approval of Proposed Rule Change, as Modified by Amendment Nos. 2 and 3
Thereto, To List and Trade Shares of Merk Hard Currency ETF Under NYSE
Arca Equities Rule 8.600
January 23, 2014.
I. Introduction
On November 22, 2013, NYSE Arca, Inc. (``Exchange'' or ``NYSE
Arca'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4 thereunder,\2\ a
proposed rule change to list and trade shares (``Shares'') of the Merk
Hard Currency ETF (``Fund'') of the Forum ETF Trust (``Trust''). The
proposed rule change was published for comment in the Federal Register
on December 11, 2013.\3\ On December 19, 2013, the Exchange (1)
submitted but subsequently withdrew Amendment No. 1 to the proposed
rule change, and (2) submitted Amendment No. 2 to the proposed rule
change. On January 10, 2014, the Exchange submitted Amendment No. 3 to
the proposed rule change.\4\ The Commission received no comments on the
proposal. This order grants approval of the proposed rule change, as
modified by Amendment Nos. 2 and 3 thereto.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 70994 (Dec. 5,
2013), 78 FR 75423 (``Notice'').
\4\ In Amendment No. 2, the Exchange provided further
information regarding where pricing information for certain Fund
assets can be found and corrected certain cross references. In
Amendment No. 3, the Exchange clarified: (1) that the Fund will not
invest in any non-U.S. equity securities and that the Fund will not
invest in American Depositary Receipts, European Depositary
Receipts, Global Depositary Receipts (collectively referred to as
``depositary receipts''), New York Registered Shares, or American
Depositary Shares and removed all references thereto; and (2) where
pricing information for spot currency transactions can be found.
Because Amendment Nos. 2 and 3 do not materially affect the
substance of the proposed rule change or raise novel or unique
issues, Amendment Nos. 2 and 3 did not require notice and comment.
---------------------------------------------------------------------------
II. Description of the Proposed Rule Change
The Exchange proposes to list and trade Shares of the Fund under
NYSE Arca Equities Rule 8.600, which governs the listing and trading of
Managed Fund Shares. The Shares will be offered by the Trust,\5\ a
Delaware statutory trust that is registered with the Commission as an
open-end management investment company. Forum Investment Advisors, LLC
(``Investment Manager'') is the investment manager of the Fund. Merk
Investments, LLC (``Investment Adviser'') is the investment adviser of
the Fund.\6\ Foreside Fund Services LLC
[[Page 4789]]
is the Fund's principal underwriter and distributer of the Fund's
Shares. Atlantic Fund Administration, LLC, an affiliate of the
Investment Manager, serves as the administrator for the Fund. The Bank
of New York Mellon Corporation serves as custodian and transfer agent
for the Fund. The Exchange represents that neither the Investment
Manager nor the Investment Adviser is a broker-dealer or is affiliated
with a broker-dealer.\7\
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\5\ The Trust is registered under the Investment Company Act of
1940 (``1940 Act''). On April 12, 2013, the Trust filed with the
Commission an amendment to its registration statement on Form N-1A
under the Securities Act of 1933 (``Securities Act'') and under the
1940 Act relating to the Fund (File Nos. 333-180250 and 811-22679)
(``Registration Statement''). In addition, the Exchange states that
the Trust has obtained certain exemptive relief under the 1940 Act.
See Investment Company Act Release No. 30549 (June 4, 2013) (File
No. 812-13915-01) (``Exemptive Order'').
\6\ The Investment Adviser will be responsible for the day-to-
day portfolio management of the Fund and, as such, will make all
investment decisions for the Fund and is responsible for
implementing the Fund's investment strategy. The Investment Manager
will develop the overall investment program for the Fund (which
includes working with the Investment Adviser to define principal
investment strategies) and will be responsible for overseeing and
reporting to the Board of the Trust regarding the Investment
Adviser.
\7\ See Commentary .06 to NYSE Arca Equities Rule 8.600. The
Exchange represents that, in the event that (a) the Investment
Manager or Investment Adviser becomes a registered broker-dealer or
becomes newly affiliated with a broker-dealer, or (b) any new
investment adviser is or becomes affiliated with a broker-dealer, it
will implement a fire wall with respect to its relevant personnel or
its broker-dealer affiliate, as the case may be, regarding access to
information concerning the composition of, or changes to, the
portfolio and will be subject to procedures designed to prevent the
use and dissemination of material, non-public information regarding
the portfolio.
---------------------------------------------------------------------------
The Exchange has made the following representations and statements
in describing the Fund and its investment strategies, including other
permitted portfolio holdings and investment restrictions.\8\
---------------------------------------------------------------------------
\8\ The Commission notes that additional information regarding
the Trust, the Fund, and the Shares, including investment
strategies, risks, net asset value (``NAV'') calculation, creation
and redemption procedures, fees, portfolio holdings, disclosure
policies, distributions, and taxes, among other information, is
included in the Notice and the Registration Statement, as
applicable. See Notice and Registration Statement, supra notes 3 and
5, respectively.
---------------------------------------------------------------------------
Description of the Fund
The Fund's investment objective is to seek to profit from a rise in
hard currencies relative to the U.S. dollar. The Fund will be actively
managed and does not seek to replicate the performance of a specified
index. Under normal market conditions,\9\ the Fund will invest at least
80% of the value of its net assets (plus borrowings for investment
purposes) in a basket of hard currency-denominated investments composed
of high-quality, short-term \10\ debt instruments, physical gold, and
gold-related securities.\11\
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\9\ The term ``under normal market conditions'' includes, but is
not limited to, the absence of adverse market, economic, political
or other conditions including extreme volatility or trading halts in
the fixed income markets or the financial markets generally;
operational issues causing dissemination of inaccurate market
information; or force majeure type events such as systems failure,
natural or man-made disaster, act of God, armed conflict, act of
terrorism, riot or labor disruption or any similar intervening
circumstance.
\10\ According to the Exchange, the Fund will define ``short-
term'' based upon an instrument's remaining maturity period, not the
initial maturity period. For example, a twenty-year bond with three
months remaining until maturity will be considered to be a short-
term debt instrument.
\11\ ``Gold-related securities'' are exchange-traded products
(``ETPs'') that invest directly in gold bullion. ETPs that hold
gold, physically or indirectly, are not regulated under the 1940 Act
and are not afforded the protections thereunder.
---------------------------------------------------------------------------
The term ``hard currencies'' is used to describe currencies of
countries pursuing what the Investment Adviser believes to be ``sound''
monetary policy and gold.\12\ Sound monetary policy is defined by the
Investment Adviser as a monetary policy providing an environment
fostering long-term price stability. The Investment Adviser considers
gold to be the only currency with intrinsic value and, as such,
qualifies as a hard currency.
---------------------------------------------------------------------------
\12\ Provided that the Investment Adviser deems the following
currencies to be backed by sound monetary policy, ``hard
currencies'' include, without limitation: Argentine Peso (ARS);
Australian Dollar (AUD); Brazilian Real (BRL); British Pound (GBP);
Canadian Dollar (CAD); Chilean Peso (CLP); Chinese Renminbi (CNY);
Colombian Peso (COP); Czech Koruna (CZK); Danish Krone (DKK); Euro
(EUR); Hong Kong Dollar (HKD); Hungarian Forint (HUF); Iceland Krona
(ISK); Indian Rupee (INR); Indonesian Rupiah (IDR); Israeli Shekel
(ILS); Japanese Yen (JPY); Malaysian Ringgit (MYR); Mexican Peso
(MXN); New Zealand Dollar (NZD); Norwegian Krone (NOK); Pakistani
Rupee (PKR); Peruvian New Sol (PEN); Philippine Peso (PHP); Polish
Zloty (PLN); Russian Ruble (RUB); Singapore Dollar (SGD); South
African Rand (ZAR); South Korean Won (KRW); Swedish Krona (SEK);
Swiss Franc (CHF); Taiwanese Dollar (TWD); Thai Baht (THB); Thai
Baht Onshore (THO); Turkish Lira (TRY); U.S. Dollar (USD); and
successor currencies of the aforementioned currencies, if any.
---------------------------------------------------------------------------
The term ``high-quality'' refers to debt instruments rated in the
top three ratings by a U.S. nationally recognized ratings service, or
that the Investment Adviser considers comparable in quality to debt
instruments rated in the top three ratings.\13\
---------------------------------------------------------------------------
\13\ In determining which instruments are comparable in quality
to instruments rated in the top three ratings, the Investment
Adviser will evaluate the relative creditworthiness of issuers and
the relative credit quality of debt issues. Consideration may be
given to an issuer's financial strength, capacity for timely payment
and ability to withstand adverse financial developments, as well as
any ratings assigned to other instruments issued by that issuer.
---------------------------------------------------------------------------
The Investment Adviser will determine currency allocations based on
an analysis of monetary policies pursued by central banks and economic
environments. The Investment Adviser will search for currencies that,
in the Investment Adviser's opinion, are backed by sound monetary
policy or gold. Once this determination has been made, money market or
other debt instruments will be selected to create a liquid portfolio of
short duration and high credit quality.
The Fund will specifically seek the currency risk of select
countries pursuing what the Investment Adviser believes are sound
monetary policies. As long-term price stability is unlikely to be
achieved by most currencies, if any, the Investment Adviser will focus
on a country's monetary policy that fosters such stability. The
Investment Adviser will invest in a basket of hard currency-denominated
investments that may include physical gold and gold-related securities
to reduce the Fund's exposure to the risks of any one currency. The
Investment Adviser may adapt the currency allocations as its analysis
of monetary policies and economic environments evolves.
The Investment Adviser may sacrifice yield in return for high
credit quality of debt securities. The Investment Adviser may limit or
exclude currencies if, in the Investment Adviser's opinion, the
potential for appreciation is not backed by sound monetary policy.
If the Investment Adviser deems a currency crisis likely, it is
possible that the Fund will restrict its investments to a few
currencies that meet the Investment Adviser's investment criteria for
sound monetary policies and practices.
Principal Investments
As noted above, under normal market conditions,\14\ the Fund will
invest at least 80% of the value of its net assets (plus borrowings for
investment purposes) in hard currency-denominated investments composed
of high-quality, short-term debt instruments,\15\ physical gold, and
gold-related securities.
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\14\ See supra note 9.
\15\ See supra note 10.
---------------------------------------------------------------------------
To try to reduce interest rate and credit risk to its portfolio,
the Fund will seek to maintain a weighted average portfolio maturity of
less than eighteen months, although the Fund may maintain a weighted
average portfolio maturity of greater than eighteen months at any given
time. In addition, the Fund will only buy money market or other short-
term debt instruments that are rated in the top three ratings by U.S.
nationally recognized ratings services or that the Investment Adviser
considers comparable in quality to instruments rated in the top three
ratings.\16\
---------------------------------------------------------------------------
\16\ See supra note 13.
---------------------------------------------------------------------------
The high quality, short term debt instruments in which the Fund
will primarily invest include: U.S. dollar- and non-U.S. dollar-
denominated money market instruments and similar securities; debt
obligations issued by the
[[Page 4790]]
U.S. and foreign national, provincial, state or municipal governments
or their political subdivisions or agencies, central banks, sovereign
entities, supranational organizations or special purpose entities
organized or backed by any of the foregoing entities (``Special Purpose
Entities''); debt instruments issued by U.S. and foreign corporations;
\17\ and debt obligations issued by entities that the Investment
Adviser considers to be comparable to entities in the categories
enumerated above.
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\17\ The Fund will typically invest only in debt instruments
that the Investment Adviser deems to be sufficiently liquid at time
of investment. Generally, a debt instrument must have $100 million
(or an equivalent value if denominated in a currency other than U.S.
dollars) or more par amount outstanding and significant par value
traded to be considered sufficiently liquid at the time of
investment. The Fund may invest up to 25% of its total assets in
debt instrument having a lower par amount outstanding to the extent
the Investment Advisor determines such an investment to be
appropriate. In any such determination, the Investment Advisor will
evaluate the relative creditworthiness of issuers and the relative
credit quality of debt issues. Consideration may be given to an
issuer's financial strength, capacity for timely payment, and
ability to withstand adverse financial developments.
---------------------------------------------------------------------------
Money market instruments in which the Fund may invest include
short-term government securities, floating and variable-rate notes,
certificates of deposit, time deposits, bankers' acceptances,
commercial paper, and other short-term liquid instruments.
Securities issued by the U.S. Government in which the Fund may
invest include short-term U.S. Treasury obligations and short-term debt
obligations. The Fund may also purchase certificates not issued by the
U.S. Department of the Treasury, which evidence ownership of future
interest, principal, or interest and principal payments on obligations
issued by the U.S. Department of the Treasury. The Fund may invest in
obligations issued or guaranteed by U.S. Government agencies.\18\ The
Fund may also invest in separated or divided U.S. government
securities.\19\ Foreign government securities may include direct
obligations, as well as obligations guaranteed by the foreign
government and obligations issued by Special Purpose Entities.
---------------------------------------------------------------------------
\18\ Obligations issued or guaranteed by U.S. Government
agencies include: (1) obligations issued or guaranteed by U.S.
Government agencies and instrumentalities that are backed by the
full faith and credit of the U.S. Government; and (2) securities
that are guaranteed by agencies or instrumentalities of the U.S.
Government but are not backed by the full faith and credit of the
U.S. Government.
\19\ These instruments represent a single interest or principal
payment on a U.S. government security that has been separated from
all the other interest payments as well as the security itself.
While the components of such instruments are drawn from U.S.
government securities, separated or divided securities may be formed
by non-governmental institutions.
---------------------------------------------------------------------------
The Fund may invest in U.S. and foreign corporate debt obligations.
Corporate debt obligations include corporate bonds, debentures, notes,
commercial paper, and other similar corporate debt instruments. In
addition, the Fund also may invest in corporate debt securities
registered and sold in the U.S. by foreign issuers (sometimes called
Yankee bonds) and those sold outside the U.S. by foreign or U.S.
issuers (sometimes called Eurobonds).
The Fund may invest in investment-grade debt securities and non-
investment-grade debt securities. Investment-grade means rated in the
top four long-term rating categories, or unrated and determined by the
Investment Adviser to be of comparable quality. The Fund may invest up
to 5% of its total assets in non-investment-grade debt securities,
including defaulted securities, however the Fund does not expect to
invest up to 5% in defaulted securities.
The Fund may invest in physical gold and gold-related securities.
To the extent that the Fund invests in gold, it may do so by investing
directly in physical gold or indirectly by investing through U.S.-
listed ETPs \20\ that invest in gold bullion.
---------------------------------------------------------------------------
\20\ Such ETPs may include the following securities: Trust
Issued Receipts (as described in NYSE Arca Equities Rule 8.200) and
Commodity-Based Trust Shares (as described in NYSE Arca Equities
Rule 8.201). The Fund may invest in ETPs which are not registered
under the 1940 Act. The Fund may invest in ETPs sponsored by the
Investment Adviser or its affiliates.
---------------------------------------------------------------------------
Other Investments
In addition to the principal investments in hard currency-
denominated investments described above, the Fund may make certain
other investments. In addition to the U.S.-listed ETPs that the Fund
may use as an indirect investment in gold, the Fund may invest in other
ETPs, including exchange-traded funds (``ETFs'') \21\ and exchange
traded notes (``ETNs'').\22\
---------------------------------------------------------------------------
\21\ For purposes of this proposed rule change, ETFs are
securities that are registered pursuant to the 1940 Act such as
those listed and traded on the Exchange pursuant to NYSE Arca
Equities Rules 5.2(j)(3), 8.100, and 8.600.
\22\ For purposes of this proposed rule change, ETNs are
securities that are registered pursuant to the Securities Act such
as those listed and traded on the Exchange pursuant to NYSE Arca
Equities Rule 5.2(j)(6).
---------------------------------------------------------------------------
The Fund may enter into repurchase agreements. If the Fund enters
into a repurchase agreement, it will maintain possession of the
purchased securities and any underlying collateral. The Fund may also
enter into reverse repurchase agreements. A counterparty to a reverse
repurchase agreement must be a primary dealer that reports to the
Federal Reserve Bank of New York or one of the largest 100 commercial
banks in the United States.
While the Fund is permitted to invest in exchange-listed common and
preferred stock and warrants, the Exchange states that the Fund will
not generally invest in such assets. The Fund will not invest in any
non-U.S. equity securities.
The Fund may invest in convertible securities, which include debt
securities, preferred stock, or other securities that may be converted
into, or exchanged for, a given amount of common stock of the same or a
different issuer during a specified period and at a specified price in
the future.
The Fund may invest in variable amount master demand notes. All
variable amount master demand notes acquired by the Fund will be
payable within a prescribed notice period not to exceed seven days.
The Fund may hold cash in bank deposits in foreign currencies. The
Fund may conduct foreign currency exchange transactions either on a
spot (cash) basis at the spot rate prevailing in the foreign exchange
market or by entering into a forward foreign currency contract. The
Fund may enter into forward contracts in order to ``lock in'' the
exchange rate between the currency it will deliver and the currency it
will receive for the duration of the contract.
For the purpose of hedging, efficient portfolio management,
generating income, or enhancement of returns, the Fund may, from time
to time, enter into forward currency contracts,\23\ including currency
forwards and cross currency forwards. The Fund may enter into forward
currency contracts to hedge against risks arising from securities the
Fund owns or anticipates purchasing, or the U.S. dollar value of
interest and dividends paid on those securities.\24\ The Fund may
invest in a combination of forward currency contracts and U.S. dollar-
denominated instruments in an attempt to obtain an investment result
[[Page 4791]]
that is substantially the same as a direct investment in a foreign
currency-denominated instrument. For hedging purposes, the Fund may
invest in forward currency contracts to hedge either specific
transactions (transaction hedging) or portfolio positions (position
hedging).\25\
---------------------------------------------------------------------------
\23\ A forward currency contract is an obligation to purchase or
sell a specific currency at a future date, which may be any fixed
number of days from the date of the contract agreed upon by the
parties, at a price set at the time of the contract.
\24\ To the extent the Fund retains various U.S. fixed-income
instruments to settle derivative contracts, the Investment Adviser
expects such instruments to generate income for the Fund. The value
of such investments (to the extent used to cover the Fund's net
exposure under the forward foreign currency contracts and similar
instruments) and forward contracts and other instruments that
provide investment exposure to currencies will be counted for
purposes of the Fund's 80% policy.
\25\ The Investment Adviser seeks to mitigate counterparty risk
associated with forward currency contracts by employing multiple
brokers to execute trades and by monitoring the creditworthiness of
counterparties through analysis of credit ratings available through
U.S. nationally recognized ratings services.
---------------------------------------------------------------------------
In order to respond to adverse market, economic, political, or
other conditions, the Fund may assume a temporary defensive position
that is inconsistent with its principal investment strategies and
invest, without limitation, in cash or cash equivalents (including
commercial paper, certificates of deposit, banker's acceptances, and
time deposits) which may be U.S. dollar-denominated.
Investment Restrictions
The Fund may hold up to an aggregate amount of 15% of its net
assets in illiquid assets (calculated at the time of investment),
including Rule 144A securities deemed illiquid by the Investment
Adviser consistent with Commission guidance \26\ and master demand
notes. The Fund will monitor its portfolio liquidity on an ongoing
basis to determine whether, in light of current circumstances, an
adequate level of liquidity is being maintained, and will consider
taking appropriate steps in order to maintain adequate liquidity if,
through a change in values, net assets, or other circumstances, more
than 15% of the Fund's net assets are held in illiquid assets. Illiquid
assets include securities subject to contractual or other restrictions
on resale and other instruments that lack readily available markets as
determined in accordance with Commission staff guidance.
---------------------------------------------------------------------------
\26\ In reaching liquidity decisions, the Investment Adviser may
consider the following factors: the frequency of trades and quotes
for the security; the number of dealers wishing to purchase or sell
the security and the number of other potential purchasers; dealer
undertakings to make a market in the security; and the nature of the
security and the nature of the marketplace in which it trades (e.g.,
the time needed to dispose of the security, the method of soliciting
offers, and the mechanics of transfer).
---------------------------------------------------------------------------
The Fund may not purchase a security if, as a result, more than 25%
of its total assets would be invested in securities of issuers
conducting their principal business activities in the same industry.
For purposes of this limitation, there is no limit on investments in
U.S. government securities and repurchase agreements covering U.S.
government securities. With respect to foreign government securities,
the Fund treats each foreign government or sovereign as its own
industry.
Although the Fund intends to invest in a variety of securities and
instruments, the Fund will be considered ``non-diversified' for the
purposes of the 1940 Act, which means that it may invest more of its
assets in the securities of a smaller number of issuers than if it were
a diversified fund.
The Fund will use leveraged investment techniques only when the
Investment Adviser believes that leveraging and the returns available
to the Fund from investing the cash will provide investors with a
potentially higher return. Such leveraged investment techniques include
borrowing, repurchase agreements, reverse repurchase agreements, and
securities lending. The Fund will not invest in leveraged or inverse
leveraged ETPs. Such investments will not be used to enhance the
leverage of the Fund as a whole and will otherwise be consistent with
the Fund's investment objective.
The Fund will not directly invest in options contracts, futures
contracts, or swap agreements. The Fund intends, for each taxable year,
to qualify for treatment as a ``regulated investment company'' under
Subchapter M of the Internal Revenue Code of 1986, as amended.\27\
---------------------------------------------------------------------------
\27\ 26 U.S.C. 851.
---------------------------------------------------------------------------
III. Discussion and Commission's Findings
After careful review, the Commission finds that the proposed rule
change is consistent with the requirements of Section 6 of the Act \28\
and the rules and regulations thereunder applicable to a national
securities exchange.\29\ In particular, the Commission finds that the
proposal is consistent with Section 6(b)(5) of the Act,\30\ which
requires, among other things, that the Exchange's rules be designed to
promote just and equitable principles of trade, to remove impediments
to, and perfect the mechanism of, a free and open market and a national
market system, and, in general, to protect investors and the public
interest. The Commission notes that the Fund and the Shares must comply
with the initial and continued listing criteria in NYSE Arca Equities
Rule 8.600 for the Shares to be listed and traded on the Exchange.
---------------------------------------------------------------------------
\28\ 15 U.S.C. 78f.
\29\ In approving this proposed rule change, the Commission has
considered the proposed rule's impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
\30\ 15 U.S.C. 78f(b)(5).
---------------------------------------------------------------------------
The Commission finds that the proposal to list and trade the Shares
on the Exchange is consistent with Section 11A(a)(1)(C)(iii) of the
Act,\31\ which sets forth Congress' finding that it is in the public
interest and appropriate for the protection of investors and the
maintenance of fair and orderly markets to assure the availability to
brokers, dealers, and investors of information with respect to
quotations for, and transactions in, securities. Quotation and last-
sale information for the Shares and underlying U.S. exchange-traded
equities, including, without limitation, ETPs (including ETFs and
ETNs), common and preferred stock, and warrants, will be available via
the Consolidated Tape Association (``CTA'') high-speed line. Quotation
information from brokers and dealers or pricing services will be
available for spot currency transactions, forwards, fixed income
securities, other money market instruments, and repurchase and reverse
repurchase agreements held by the Fund. Price information for the
Fund's portfolio securities and other instruments is generally readily
available through major market data vendors, automated quotation
systems, published or other public sources and, for listed securities,
the securities exchange on which they are listed and traded. Investors
may obtain on a 24-hour basis gold pricing information based on the
spot price for an ounce of gold from various financial information
service providers, such as Reuters and Bloomberg.\32\
---------------------------------------------------------------------------
\31\ 15 U.S.C. 78k-1(a)(1)(C)(iii).
\32\ According to the Exchange, Reuters and Bloomberg provide at
no charge on their Web sites delayed information regarding the spot
price of gold, as well as information about news and developments in
the gold market. Reuters and Bloomberg also offer a professional
service to subscribers for a fee that provides information on gold
prices directly from market participants. ICAP plc provides an
electronic trading platform called EBS for the trading of spot gold,
as well as a feed of live streaming prices to Reuters and Moneyline
Telerate subscribers. The Exchange also states that there are a
variety of other public Web sites providing information on gold,
ranging from those specializing in precious metals to sites
maintained by major newspapers, such as The Wall Street Journal. In
addition, the daily London noon Fix is publicly available at no
charge at www.thebulliondesk.com.
---------------------------------------------------------------------------
On each business day, before commencement of trading of Shares in
the Core Trading Session on the Exchange, the Fund will disclose on its
Web site the identities and quantities of the portfolio of securities
and other assets (``Disclosed Portfolio'') held by the Fund and that
will form the basis for the Fund's calculation of NAV at the
[[Page 4792]]
end of the business day.\33\ In addition, the Portfolio Indicative
Value, as defined in NYSE Arca Equities Rule 8.600(c)(3), that will be
based upon the current value for the components of the Disclosed
Portfolio, will be widely disseminated at least every 15 seconds during
the Core Trading Session by one or more major market data vendors.\34\
The Fund will calculate its NAV as of the close of trading on the
Exchange (normally 4:00 p.m., Eastern Time) on each weekday except on
days when the Exchange is closed.\35\ Information regarding market
price and trading volume of the Shares will be continually available on
a real-time basis throughout the day on brokers' computer screens and
other electronic services. Information regarding the previous day's
closing price and trading volume information for the Shares will be
published daily in the financial section of newspapers. The Web site
for the Fund will include a form of the prospectus for the Fund and
additional data relating to NAV and other applicable quantitative
information.
---------------------------------------------------------------------------
\33\ On a daily basis, the Fund will disclose for each portfolio
security and other financial instrument of the Fund the following
information: ticker symbol (if applicable), name or description of
security and financial instrument, number of shares or dollar value
of securities and financial instruments held in the portfolio, and
percentage weighting of securities and financial instruments in the
portfolio. The Web site information will be publicly available at no
charge.
\34\ According to the Exchange, several major market data
vendors display or make widely available Portfolio Indicative Values
taken from CTA or other data feeds.
\35\ According to the Exchange, the Fund will value securities
for which market quotations are readily available at current market
value, except for money market instruments with a maturity of sixty
days or less, which may be valued at amortized cost. Securities for
which market quotations are readily available, such as exchange-
listed common stock and preferred stock and warrants, will be valued
using the last reported sales price provided by independent pricing
services as of the close of trading on the Exchange. In the absence
of sales, such securities will be valued at the mean of the last bid
and ask prices. Non-exchange-traded securities for which quotations
are readily available will be valued at the mean between the current
bid and ask prices. Debt securities, including master demand notes
and convertible securities, may be valued at prices supplied by the
Fund's pricing agents based on broker or dealer-supplied valuations
or matrix pricing, a method of valuing securities by reference to
the value of other securities with similar characteristics such as
rating, interest rate, and maturity. Forward currency contracts will
be valued at the mean of bid and ask prices for the time period
interpolated from rates reported by an independent pricing service
for proximate time periods. Spot currency transactions will normally
be valued on the basis of quotes obtained from brokers and dealers
or pricing services using data reflecting the earlier closing of the
principal markets for those assets. Repurchase agreements and
reverse repurchase agreements will generally be valued at par. Gold
will generally be valued at prices supplied by the Fund's pricing
agents based on the spot price for an ounce of gold. Investments in
open-end registered investment companies will be valued at their
NAV, and investments in other ETPs will be valued using market
prices.
---------------------------------------------------------------------------
The Commission further believes that the proposal to list and trade
the Shares is reasonably designed to promote fair disclosure of
information that may be necessary to price the Shares appropriately and
to prevent trading when a reasonable degree of transparency cannot be
assured. The Exchange will obtain a representation from the issuer of
the Shares that the NAV per Share will be calculated daily and that the
NAV and the Disclosed Portfolio will be made available to all market
participants at the same time. Trading in Shares of the Fund will be
halted if the circuit breaker parameters in NYSE Arca Equities Rule
7.12 have been reached or because of market conditions or for reasons
that, in the view of the Exchange, make trading in the Shares
inadvisable,\36\ and trading in the Shares will be subject to NYSE Arca
Equities Rule 8.600(d)(2)(D), which sets forth additional circumstances
under which Shares of the Fund may be halted. The Exchange states that
it has a general policy prohibiting the distribution of material, non-
public information by its employees. Consistent with NYSE Arca Equities
Rule 8.600(d)(2)(B)(ii), the Reporting Authority must implement and
maintain, or be subject to, procedures designed to prevent the use and
dissemination of material, non-public information regarding the actual
components of the Fund's portfolio. In addition, the Exchange states
that neither the Investment Manager nor the Investment Adviser is a
broker-dealer or is affiliated with a broker-dealer.\37\ The Exchange
represents that trading in the Shares will be subject to the existing
trading surveillances, administered by the Financial Industry
Regulatory Authority (``FINRA'') on behalf of the Exchange, which are
designed to detect violations of Exchange rules and applicable federal
securities laws.\38\ The Exchange further represents that these
procedures are adequate to properly monitor Exchange trading of the
Shares in all trading sessions and to deter and detect violations of
Exchange rules and applicable federal securities laws. Moreover, prior
to the commencement of trading, the Exchange states that it will inform
its Equity Trading Permit Holders in an Information Bulletin of the
special characteristics and risks associated with trading the Shares.
---------------------------------------------------------------------------
\36\ These reasons may include: (1) the extent to which trading
is not occurring in the securities or the financial instruments
composing the Disclosed Portfolio of the Fund; or (2) whether other
unusual conditions or circumstances detrimental to the maintenance
of a fair and orderly market are present. With respect to trading
halts, the Exchange may consider all relevant factors in exercising
its discretion to halt of suspend trading in the Shares of the Fund.
\37\ See supra note 7 and accompanying text. The Exchange states
that an investment adviser to an open-end fund is required to be
registered under the Investment Advisers Act of 1940 (``Advisers
Act''). As a result, the Investment Manager, the Investment Adviser,
and their related personnel are subject to the provisions of Rule
204A-1 under the Advisers Act relating to codes of ethics. This Rule
requires investment advisers to adopt a code of ethics that reflects
the fiduciary nature of the relationship to clients as well as
compliance with other applicable securities laws. Accordingly,
procedures designed to prevent the communication and misuse of non-
public information by an investment adviser must be consistent with
Rule 204A-1 under the Advisers Act. In addition, Rule 206(4)-7 under
the Advisers Act makes it unlawful for an investment adviser to
provide investment advice to clients unless the investment adviser
has (i) adopted and implemented written policies and procedures
reasonably designed to prevent violation, by the investment adviser
and its supervised persons, of the Advisers Act and the Commission
rules adopted thereunder; (ii) implemented, at a minimum, an annual
review regarding the adequacy of the policies and procedures
established pursuant to subparagraph (i) above and the effectiveness
of their implementation; and (iii) designated an individual (who is
a supervised person) responsible for administering the policies and
procedures adopted under subparagraph (i) above.
\38\ The Exchange states that FINRA surveils trading on the
Exchange pursuant to a regulatory services agreement and that the
Exchange is responsible for FINRA's performance under this
regulatory services agreement.
---------------------------------------------------------------------------
The Exchange represents that the Shares are deemed to be equity
securities, thus rendering trading in the Shares subject to the
Exchange's existing rules governing the trading of equity securities.
In support of this proposal, the Exchange has made representations,
including the following:
(1) The Shares will be subject to NYSE Arca Equities Rule 8.600,
which sets forth the initial and continued listing criteria applicable
to Managed Fund Shares.
(2) The Exchange has appropriate rules to facilitate transactions
in the Shares during all trading sessions.
(3) The Exchange represents that its surveillance procedures are
adequate to properly monitor Exchange trading of the Shares in all
trading sessions and to deter and detect violations of Exchange rules
and applicable federal securities laws
(4) FINRA, on behalf of the Exchange, will communicate as needed
regarding trading in the Shares and underlying equity securities
(including, without limitation, ETPs (including ETFs and ETNs), common
and preferred stock and warrants, and any other exchange-traded
products) with other markets and other entities that are members of the
Intermarket Surveillance Group (``ISG''),
[[Page 4793]]
and FINRA, on behalf of the Exchange, may obtain trading information
regarding trading in the Shares and underlying equity securities
(including, without limitation, ETPs (including ETFs and ETNs), common
and preferred stock and warrants, and any other exchange-traded
products) from such markets and other entities. In addition, the
Exchange may obtain information regarding trading in the Shares and
underlying equity securities (including, without limitation, ETPs
(including ETFs and ETNs), common and preferred stock and warrants, and
any other exchange-traded products) from markets that are members of
ISG or with which the Exchange has in place a comprehensive
surveillance sharing agreement. The ETPs (including ETFs and ETNs),
common and preferred stock, and warrants in which the Fund may invest
all will be listed and traded on an exchange which is a member of ISG
or with which the Exchange has in place a comprehensive surveillance
sharing agreement. In addition, FINRA, on behalf of the Exchange, is
able to access, as needed, trade information for certain fixed income
securities held by the Fund reported to FINRA's Trade Reporting and
Compliance Engine.
(5) Prior to the commencement of trading, the Exchange will inform
its Equity Trading Permit Holders in an Information Bulletin of the
special characteristics and risks associated with trading the Shares.
Specifically, the Information Bulletin will discuss the following: (a)
The procedures for purchases and redemptions of Shares in creation unit
aggregations (and that Shares are not individually redeemable); (b)
NYSE Arca Equities Rule 9.2(a), which imposes a duty of due diligence
on its Equity Trading Permit Holders to learn the essential facts
relating to every customer prior to trading the Shares; (c) the risks
involved in trading the Shares during the Opening and Late Trading
Sessions when an updated Portfolio Indicative Value will not be
calculated or publicly disseminated; (d) how information regarding the
Portfolio Indicative Value is disseminated; (e) the requirement that
Equity Trading Permit Holders deliver a prospectus to investors
purchasing newly issued Shares prior to or concurrently with the
confirmation of a transaction; and (f) trading information.
(6) For initial and continued listing, the Fund must be in
compliance with Rule 10A-3 under the Act,\39\ as provided by NYSE Arca
Equities Rule 5.3.
---------------------------------------------------------------------------
\39\ See 17 CFR 240.10A-3.
---------------------------------------------------------------------------
(7) The Fund may hold up to an aggregate amount of 15% of its net
assets in illiquid assets (calculated at the time of investment),
including Rule 144A securities deemed illiquid by the Investment
Adviser consistent with Commission guidance, and master demand notes.
(8) The Fund will only buy money market or other short-term debt
instruments that are rated in the top three ratings by U.S. nationally
recognized ratings services or that the Investment Adviser considers
comparable in quality to instruments rated in the top three ratings.
The Fund may only invest up to 5% of its total assets in non-
investment-grade debt securities.
(9) If the Fund enters into a repurchase agreement, it will
maintain possession of the purchased securities and any underlying
collateral. A counterparty to a reverse repurchase agreement must be a
primary dealer that reports to the Federal Reserve Bank of New York or
one of the largest 100 commercial banks in the United States.
(10) The Fund will not invest in: (a) Any non-U.S. equity
securities; (b) options contracts, futures contracts, or swap
agreements; and (c) leveraged or inverse leveraged ETPs.
(11) The Fund will typically invest only in debt instruments that
the Investment Adviser deems to be sufficiently liquid at time of
investment. Generally a debt instrument must have $100 million (or an
equivalent value if denominated in a currency other than U.S. dollars)
or more par amount outstanding and significant par value traded to be
considered sufficiently liquid at the time of investment. The Fund may
invest up to 25% of its total assets in debt instruments having a lower
par amount outstanding to the extent the Investment Advisor determines
such an investment to be appropriate. In any such determination, the
Investment Advisor will evaluate the relative creditworthiness of
issuers and the relative credit quality of debt issues. Consideration
may be given to an issuer's financial strength, capacity for timely
payment, and ability to withstand adverse financial developments.
(12) A minimum of 100,000 Shares of the Fund will be outstanding at
the commencement of trading on the Exchange.
This approval order is based on all of the Exchange's
representations, including those set forth above and in the Notice, and
the Exchange's description of the Funds.
For the foregoing reasons, the Commission finds that the proposed
rule change is consistent with Section 6(b)(5) of the Act \40\ and the
rules and regulations thereunder applicable to a national securities
exchange.
---------------------------------------------------------------------------
\40\ 15 U.S.C. 78f(b)(5).
---------------------------------------------------------------------------
IV. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\41\ that the proposed rule change (SR-NYSEArca-2013-132), as
modified by Amendment Nos. 2 and 3 thereto, be, and it hereby is,
approved.
---------------------------------------------------------------------------
\41\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\42\
---------------------------------------------------------------------------
\42\ 17 CFR 200.30-3(a)(12).
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Elizabeth M. Murphy,
Secretary.
[FR Doc. 2014-01661 Filed 1-28-14; 8:45 am]
BILLING CODE 8011-01-P