Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Order Instituting Proceedings To Determine Whether To Approve or Disapprove Proposed Rule Change, as Modified by Amendment Nos. 1 and 2 Thereto, Relating to Listing and Trading of Shares of the NASDAQ-100 DIVS Index ETF Under Rule 5705, 45556-45560 [2014-18389]
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including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
MSRB–2014–06 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549.
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All submissions should refer to File
Number SR–MSRB–2014–06. This file
number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549 on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the MSRB. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–MSRB–
2014–06 and should be submitted on or
before August 26, 2014.
For the Commission, pursuant to delegated
authority.25
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–18381 Filed 8–4–14; 8:45 am]
BILLING CODE 8011–01–P
25 17
CFR § 200.30–3(a)(12).
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SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–72715; File No. SR–
NASDAQ–2014–038]
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Order
Instituting Proceedings To Determine
Whether To Approve or Disapprove
Proposed Rule Change, as Modified by
Amendment Nos. 1 and 2 Thereto,
Relating to Listing and Trading of
Shares of the NASDAQ–100 DIVS Index
ETF Under Rule 5705
July 29, 2014.
On April 10, 2014, The NASDAQ
Stock Market LLC (‘‘Exchange’’) 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 Reality Shares
NASDAQ–100 DIVS Index ETF
(‘‘Fund’’) (formerly, Reality Shares
NASDAQ–100 Isolated Dividend
Growth Index ETF) under NASDAQ
Rule 5705. The proposed rule change
was published for comment in the
Federal Register on April 30, 2014.3 On
May 6, 2014, the Exchange filed
Amendment No. 1 to the proposed rule
change, which amended and replaced
the proposed rule change in its
entirety.4 On June 4, 2014, the Exchange
filed Amendment No. 2 to the proposed
rule change.5 On June 13, 2014,
pursuant to Section 19(b)(2) of the Act,6
the Commission designated a longer
period within which to approve the
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 72014
(Apr. 24, 2014), 79 FR 24465 (‘‘Notice’’).
4 In Amendment No. 1, the Exchange confirmed
the hours of the three trading sessions on the
Exchange, clarified the valuation of investments for
purposes of calculating net asset value, clarified
what information would be available on the Fund’s
Web site, and provided additional information
relating to surveillance with respect to certain
assets held by the Fund. Amendment No. 1
provided clarification to the proposed rule change,
and because it does not materially affect the
substance of the proposed rule change or raise
novel or unique regulatory issues, Amendment No.
1 is not subject to notice and comment.
5 The Exchange filed Amendment No. 2 to the
proposal to reflect a name change to the Fund and
the underlying index. Specifically, the Exchange
replaced each reference to ‘‘Reality Shares
NASDAQ–100 Isolated Dividend Growth ETF’’ in
the proposal with ‘‘Reality Shares NASDAQ–100
DIVS Index ETF’’ and replaced each reference to
‘‘Reality Shares NASDAQ–100 Isolated Dividend
Growth Index’’ in the proposal with ‘‘Reality Shares
NASDAQ–100 DIVS Index.’’ Amendment No. 2 is
a technical amendment and is not subject to notice
and comment as it does not materially affect the
substance of the filing.
6 15 U.S.C. 78s(b)(2).
2 17
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proposed rule change, disapprove the
proposed rule change, or institute
proceedings to determine whether to
disapprove the proposed rule change.7
The Commission received no comment
letters on the proposed rule change.
This Order institutes proceedings under
Section 19(b)(2)(B) of the Act 8 to
determine whether to approve or
disapprove the proposed rule change, as
modified by Amendment Nos. 1 and 2
thereto.
I. Description of the Proposal
A. In General
The Exchange proposes to list and
trade Shares of the Fund under
NASDAQ Rule 5705(b), which governs
the listing and trading of Index Fund
Shares 9 on the Exchange. The Shares of
the Fund will be offered by the Reality
Shares ETF Trust (‘‘Trust’’). The Trust
will be registered with the Commission
as an open-end management investment
company.10 Reality Shares Advisors,
LLC will serve as the investment adviser
to the Fund (‘‘Adviser’’). ALPS
Distributors, Inc. will be the principal
underwriter and distributor of the
Fund’s Shares. The Bank of New York
Mellon will serve as administrator,
custodian, and transfer agent for the
Fund.
B. The Exchange’s Description of the
Fund
The Exchange has made the following
representations concerning the Fund.
7 See Securities Exchange Act Release No. 72384,
79 FR 35205 (June 19, 2014). The Commission
designated a longer period within which to take
action on the proposed rule change and designated
July 29, 2014, as the date by which it should
approve, disapprove, or institute proceedings to
determine whether to disapprove the proposed rule
change.
8 15 U.S.C. 78s(b)(2)(B).
9 Index Fund Shares that are issued by an openend investment company and listed and traded on
the Exchange under NASDAQ Rule 5705 seek to
provide investment results that correspond
generally to the price and yield performance of a
specific foreign or domestic stock index, fixed
income securities index, or combination thereof.
See Rule 5705(b)(1)(A).
10 According to the Exchange, the Trust will be
registered under the Investment Company Act of
1940 (‘‘1940 Act’’). On November 12, 2013, the
Trust filed a registration statement on Form N–1A
under the Securities Act of 1933 (‘‘1933 Act’’) and
under the 1940 Act relating to the Fund, as
amended by Pre-Effective Amendment Number 1,
filed with the Commission on February 6, 2014
(File Nos. 333–192288 and 811–22911) (the
‘‘Registration Statement’’). The description of the
operation of the Trust and the Fund herein is based,
in part, on the Registration Statement. In addition,
the Commission has issued an order granting
certain exemptive relief to the Trust under the 1940
Act. Investment Company Act Release No. 30678
(Aug. 27, 2013) (‘‘Exemptive Order’’). The Exchange
states that investments made by the Fund will
comply with the conditions set forth in the
Exemptive Order.
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The Fund will seek long-term capital
appreciation by tracking the
performance of the Reality Shares
NASDAQ–100 DIVS Index (‘‘Index’’).
The Index was developed and is
maintained by Reality Shares, Inc.
(‘‘Index Provider’’).11 The Adviser is a
wholly-owned subsidiary of the Index
Provider. The Index Provider is not
registered as a broker-dealer and is not
affiliated with any broker-dealer.12 The
Adviser is not registered as a brokerdealer and is not affiliated with any
broker-dealer.13
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1. Index Methodology
The Index will be calculated using a
proprietary, rules-based methodology
designed to track market expectations
for dividend growth conveyed in realtime using the mid-point of the bid-ask
spread on NASDAQ–100 Index options
and options on exchange-traded funds
(‘‘ETFs’’) designed to track the
NASDAQ–100 Index.14 All options
included in the Index will be listed and
traded on a U.S. national securities
exchange. The Index will consist of a
minimum of 20 components.15
The prices of index and ETF options
reflect the market trading prices of the
securities included in the applicable
underlying index or ETF, as well as
market expectations regarding the level
of dividends to be paid on those indexes
or ETFs during the term of the option.
11 The Index will be calculated by International
Data Corporation, which is not affiliated with the
Adviser, the Index Provider, or The NASDAQ OMX
Group and which is not a broker-dealer or fund
advisor. Rule 5705(b)(5)(A)(i) states that if an index
is maintained by a fund advisor or a broker-dealer,
the fund advisor or broker-dealer shall erect a ‘‘fire
wall’’ around the personnel who have access to
information concerning changes and adjustments to
the index.
12 The Adviser and the Index Provider have
represented that a fire wall exists around the
respective personnel who have access to
information concerning changes and adjustments to
the Index.
13 The Adviser and the Index Provider have
represented that a fire wall exists around the
respective personnel who have access to
information concerning changes and adjustments to
the Index. The Exchange notes that, in the event (a)
the Adviser, any sub-adviser, or the Index Provider
becomes registered as a broker-dealer or newly
affiliated with a broker-dealer, or (b) any new
adviser, sub-adviser, or Index Provider is a
registered broker-dealer or becomes affiliated with
a broker-dealer, that entity will implement a fire
wall with respect to their relevant personnel or
broker-dealer affiliate, as applicable, 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.
14 The Index will not directly measure or track
actual dividend payments or the actual growth in
dividend payments, but will instead track market
expectations of dividend growth as implied by the
prices of the options that make up the Index.
15 Rule 5705(b)(3).
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The Index constituents, and therefore
most of the Fund’s portfolio holdings,
will consist of multiple corresponding
near-term and long-term put and call
option combinations on the same
reference assets (i.e., options on the
NASDAQ–100 Index or the NASDAQ–
100 ETF) with the same strike price.
Because option prices reflect both stock
price and dividend expectations, they
can be used in combination to isolate
either price exposure or dividend
expectations. The use of near-term and
long-term put and call option
combinations on the same reference
asset with the same strike price, but
with different maturities, is designed to
gain exposure to the expected dividends
of the securities in the NASDAQ–100
Index while neutralizing the impact of
stock price movements. Over time, the
Index will increase or decrease in value
as the dividend spread between the
near-term and long-term option
combinations increases or decreases as
a result of changing market expectations
for dividend growth.
2. Principal Investments of the Fund
The Fund will seek long-term capital
appreciation and will seek investment
results that, before fees and expenses,
generally correspond to the performance
of the Index. At least 80% of the Fund’s
total assets (exclusive of collateral held
from securities lending, if any) will be
invested in the component securities of
the Index. The Fund will seek a
correlation of 0.95 or better between its
performance and the performance of its
Index. A figure of 1.00 would represent
perfect correlation. The Fund generally
will use a representative sampling
investment strategy.
The Fund will buy (i.e., hold a ‘‘long’’
position in) and sell (i.e., hold a ‘‘short’’
position in) put and call options. The
Fund will have a strategy of taking both
a long position in a security through its
ex-dividend date (the last date an
investor can own the security and
receive dividends paid on the security)
and a corresponding short position in
the same security immediately
thereafter. This is designed to allow the
Fund to isolate its exposure to the
growth of the level of dividends
expected to be paid on a security while
minimizing its exposure to changes in
the trading price of that security.
The Fund will buy and sell U.S.
exchange-listed options on the
NASDAQ–100 Index and U.S. exchangelisted options on ETFs designed to track
the NASDAQ–100 Index. A put option
gives the purchaser of the option the
right to sell, and the issuer of the option
the obligation to buy, the underlying
security or instrument on a specified
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45557
date or during a specified period of
time. A call option on a security gives
the purchaser of the option the right to
buy, and the writer of the option the
obligation to sell, the underlying
security or instrument on a specified
date or during a specified period of
time. The Fund will invest in a
combination of put and call options
designed to allow the Fund to isolate its
exposure to the growth of the level of
expected dividends reflected in options
on the NASDAQ–100 Index and options
on ETFs tracking the NASDAQ–100
Index, while minimizing the Fund’s
exposure to changes in the trading price
of such securities.
3. Other Investments of the Fund
While, as described above, at least
80% of the Fund’s total assets (exclusive
of collateral held from securities
lending, if any) will be invested in the
component securities of the Index, the
Fund may invest up to 20% of the
Fund’s total assets in other securities
and financial instruments, as described
below.
The Fund may invest in U.S.
exchange-listed futures contracts on the
NASDAQ–100 Index and ETFs designed
to track the NASDAQ–100 Index and
may invest in forward contracts on the
NASDAQ–100 Index and ETFs designed
to track the NASDAQ–100 Index. The
Fund’s use of exchange-listed futures
contracts and forward contracts is
designed to allow the Fund to isolate its
exposure to the growth of the level of
expected dividends reflected in options
on the NASDAQ–100 Index and options
on ETFs tracking the NASDAQ–100
Index, while minimizing the Fund’s
exposure to changes in the trading price
of such securities. The Fund may also
buy and sell OTC options on the
NASDAQ–100 Index and on ETFs
designed to track the NASDAQ–100
Index.
The Fund may enter into dividend
and total return swap transactions
(including equity swap transactions)
based on the NASDAQ–100 Index and
ETFs designed to track the NASDAQ–
100 Index.16 In a typical swap
transaction, one party agrees to make
periodic payments to another party
(‘‘counterparty’’) based on the change in
market value or level of a specified rate,
index, or asset. In return, the
counterparty agrees to make periodic
payments to the first party based on the
return of a different specified rate,
index, or asset. Swap transactions are
usually done on a net basis, with the
16 The Fund will transact only with swap dealers
that have in place an ISDA agreement with the
Fund.
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Fund receiving or paying only the net
amount of the two payments. In a
typical dividend swap transaction, the
Fund would pay the swap counterparty
a premium and would be entitled to
receive the value of the actual dividends
paid on the subject index during the
term of the swap contract. In a typical
total return swap transaction, the Fund
might exchange long or short exposures
to the return of the underlying securities
or index to isolate the value of the
dividends paid on the underlying
securities or index constituents. The
Fund also may engage in interest rate
swap transactions. In a typical interest
rate swap transaction, one stream of
future interest payments is exchanged
for another. Such transactions often take
the form of an exchange of a fixed
payment for a variable payment based
on a future interest rate. The Fund
intends to use interest rate swap
transactions to manage or hedge
exposure to interest rate fluctuations.
The Fund may invest up to 20% of its
assets (exclusive of collateral held from
securities lending, if any) in exchangelisted equity securities and derivative
instruments (specifically, futures
contracts, forward contracts, and swap
transactions) 17 relating to the Index and
its component securities that the
Adviser believes will help the Fund
track the Index. For example, the Fund
may buy and sell ETFs and, to a limited
extent, individual large-capitalization
equity securities listed and traded on a
U.S. national securities exchange.
The Fund may invest in the securities
of other investment companies
(including money market funds) to the
extent permitted under the 1940 Act.
The Fund’s short positions and its
investments in swaps, futures contracts,
forward contracts, and options based on
the NASDAQ–100 Index and ETFs
designed to track the NASDAQ–100
Index will be backed by investments in
cash, high-quality short-term debt
securities, and money-market
instruments in an amount equal to the
Fund’s maximum liability under the
applicable position or contract or will
otherwise be offset in accordance with
Section 18 of the 1940 Act. Short-term
debt securities and money market
instruments include shares of fixed
income or money market mutual funds,
commercial paper, certificates of
deposit, bankers’ acceptances, U.S.
17 Where practicable, the Fund intends to invest
in swaps cleared through a central clearing house
(‘‘Cleared Swaps’’). Currently, only certain of the
interest rate swaps in which the Fund intends to
invest are Cleared Swaps, while the dividend and
total return swaps (including equity swaps) in
which the Fund may invest are currently not
Cleared Swaps.
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Government Securities (including
securities issued or guaranteed by the
U.S. government or its authorities,
agencies, or instrumentalities),
repurchase agreements,18 and bonds
that are rated BBB or higher.
In addition to the investments
described above, and in a manner
consistent with its investment objective,
the Fund may invest a limited portion
of its net assets in high-quality, shortterm debt securities and money market
instruments for cash management
purposes.19
The Fund will attempt to limit
counterparty risk in non-cleared swap,
forward, and OTC option contracts by
entering into such contracts only with
counterparties the Adviser believes are
creditworthy and by limiting the Fund’s
exposure to each counterparty. The
Adviser will monitor the
creditworthiness of each counterparty
and the Fund’s exposure to each
counterparty on an ongoing basis.20
The Exchange represents that the
Fund’s investments in swaps, futures
contracts, forward contracts, and
options will be consistent with the
Fund’s investment objective and with
the requirements of the 1940 Act.21
18 The Fund may enter into repurchase
agreements with banks and broker-dealers. A
repurchase agreement is an agreement under which
securities are acquired by a fund from a securities
dealer or bank, subject to resale at an agreed-upon
price on a later date. The acquiring fund bears a risk
of loss in the event that the other party to a
repurchase agreement defaults on its obligations
and the fund is delayed or prevented from
exercising its rights to dispose of the collateral
securities.
19 The Fund may invest in shares of money
market mutual funds to the extent permitted by the
1940 Act.
20 The Fund will seek, where possible, to use
counterparties, as applicable, whose financial status
is such that the risk of default is reduced; however,
the risk of losses resulting from default is still
possible. The Adviser will evaluate the
creditworthiness of counterparties on an ongoing
basis. In addition to information provided by credit
agencies, the Adviser will evaluate each approved
counterparty using various methods of analysis,
such as, for example, the counterparty’s liquidity in
the event of default, the counterparty’s reputation,
the Adviser’s past experience with the
counterparty, and the counterparty’s share of
market participation.
21 To limit the potential risk associated with such
transactions, the Fund will segregate or ‘‘earmark’’
assets determined to be liquid by the Adviser in
accordance with procedures established by the
Trust’s Board of Trustees and in accordance with
the 1940 Act (or, as permitted by applicable
regulation, will enter into certain offsetting
positions) to cover its obligations arising from such
transactions. These procedures have been adopted
consistent with Section 18 of the 1940 Act and
related Commission guidance. In addition, the Fund
will include appropriate risk disclosure in its
offering documents, including leveraging risk.
Leveraging risk is the risk that certain transactions
of the Fund, including the Fund’s use of
derivatives, may give rise to leverage, causing the
Fund to be more volatile than if it had not been
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4. Investment Restrictions of the Fund
To the extent the Index concentrates
(i.e., holds 25% or more of its total
assets) in the securities of a particular
industry or group of industries, the
Fund will concentrate its investments to
approximately the same extent as the
Index.
The Fund may hold up to an aggregate
amount of 15% of its net assets in assets
(calculated at the time of investment)
deemed illiquid by the Adviser,
consistent with Commission guidance.22
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 make secured loans of
its portfolio securities; however,
securities loans will not be made if, as
a result, the aggregate amount of all
outstanding securities loans by the Fund
exceeds 33 1/3% of its total assets
(including the market value of collateral
received). To the extent the Fund
engages in securities lending, securities
loans will be made to broker-dealers
that the Adviser believes to be of
relatively high credit standing pursuant
to agreements requiring that the loans
continuously be collateralized by cash,
liquid securities, or shares of other
investment companies with a value at
least equal to the market value of the
loaned securities.
The Fund will be classified as a ‘‘nondiversified’’ investment company under
the 1940 Act and intends to qualify for,
and to elect treatment as, a separate
regulated investment company under
Subchapter M of the Internal Revenue
Code. The Exchange represents that the
Fund’s investments will be consistent
with its investment objective and will
leveraged. To mitigate leveraging risk, the Adviser
will segregate or ‘‘earmark’’ liquid assets or
otherwise cover the transactions that may give rise
to such risk.
22 In reaching liquidity decisions, the 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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not be used to provide multiple returns
of a benchmark or to produce leveraged
returns.
II. Proceedings to Determine Whether
To Approve or Disapprove SR–
NASDAQ–2014–038 and Grounds for
Disapproval Under Consideration
The Commission is instituting
proceedings pursuant to Section
19(b)(2)(B) of the Act 23 to determine
whether the proposed rule change
should be approved or disapproved.
Institution of such proceedings is
appropriate at this time in view of the
legal and policy issues raised by the
proposed rule change. Institution of
proceedings does not indicate that the
Commission has reached any
conclusions with respect to any of the
issues involved. Rather, as described
below, the Commission seeks and
encourages interested persons to
provide comments on the proposed rule
change.
Pursuant to Section 19(b)(2)(B) of the
Act,24 the Commission is providing
notice of the grounds for disapproval
under consideration. The Commission is
instituting proceedings to allow for
additional analysis of the proposed rule
change’s consistency with Section
6(b)(5) of the Act, which requires,
among other things, that the rules of a
national securities exchange be
‘‘designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade,’’ and ‘‘to protect investors and the
public interest.’’ 25
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III. Procedure: Request for Written
Comments
The Commission requests that
interested persons provide written
submissions of their views, data, and
arguments with respect to the issues
identified above, as well as any other
concerns they may have with the
proposal. In particular, the Commission
invites the written views of interested
persons concerning whether the
proposal is consistent with Section
6(b)(5) or any other provision of the Act,
or the rules and regulations thereunder.
Although there do not appear to be any
issues relevant to approval or
disapproval that would be facilitated by
an oral presentation of views, data, and
arguments, the Commission will
consider, pursuant to Rule 19b–4, any
request for an opportunity to make an
oral presentation.26
23 15
U.S.C. 78s(b)(2)(B).
24 Id.
25 15
U.S.C. 78f(b)(5).
19(b)(2) of the Act, as amended by the
Securities Act Amendments of 1975, Public Law
26 Section
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18:16 Aug 04, 2014
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Interested persons are invited to
submit written data, views, and
arguments regarding whether the
proposal should be approved or
disapproved by August 26, 2014. Any
person who wishes to file a rebuttal to
any other person’s submission must file
that rebuttal by September 9, 2014.
The Commission asks that
commenters address the sufficiency of
the Exchange’s statements in support of
the proposal, which are set forth in the
Notice,27 as modified by Amendment
Nos. 1 and 2 to the proposed rule
change, in addition to any other
comments they may wish to submit
about the proposed rule change. In
particular, the Commission seeks
comment on the following:
1. Because the Index is designed to
reflect changes in market expectations
of future dividend growth, rather than to
track actual dividend growth, is the
Fund’s investment strategy
fundamentally based on an assumption
that the options markets systemically
underprice dividend growth? What are
commenters’ views regarding whether
investors would be able to understand
the strategy, risks, potential rewards,
assumptions, and expected performance
of the Fund’s strategy?
2. With respect to the trading of the
Shares on the Exchange, do commenters
believe that the Exchange’s rules
governing sales practices are adequately
designed to ensure the suitability of
recommendations regarding the Shares?
Why or why not? If not, should the
Exchange’s rules governing sales
practices be enhanced? If so, in what
ways?
3. How closely do commenters think
the market price of the Shares will track
the Fund’s intraday indicative value
(‘‘IIV’’) or the intraday value of the
Index? Are certain of these values likely
to be more volatile than others? If so,
how would this affect trading in the
Shares? Are the Shares likely to trade
with a significant premium or discount
to IIV? What are commenters’ views of
how effectively the IIV of the Fund
would represent the Fund’s portfolio?
What are commenters’ views of how the
Shares’ market price, the Fund’s IIV,
and the intraday value of the Index will
relate to one another during times of
market stress?
94–29 (June 4, 1975), grants the Commission
flexibility to determine what type of proceeding—
either oral or notice and opportunity for written
comments—is appropriate for consideration of a
particular proposal by a self-regulatory
organization. See Securities Act Amendments of
1975, Senate Comm. on Banking, Housing & Urban
Affairs, S. Rep. No. 75, 94th Cong., 1st Sess. 30
(1975).
27 See supra note 3.
PO 00000
Frm 00138
Fmt 4703
Sfmt 4703
45559
4. Does the liquidity of the long-dated
options in which the Fund will invest
differ materially from that of the shortdated options in which the Fund will
invest? If so, how would that affect the
ability of market makers to engage in
arbitrage or to hedge their positions
while making a market in the Shares?
Would the liquidity characteristics of
the Index components or of the options
in the Fund’s portfolio affect the
calculation of the Index value, the
calculation of the Fund’s IIV, the
calculation of the Fund’s NAV, or the
ability of market makers or other market
participants to value the Shares? If so,
how?
Comments may be submitted by any
of the following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
NASDAQ–2014–038 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
All submissions should refer to File
Numbers SR–NASDAQ–2014–038. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of these
filings also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
E:\FR\FM\05AUN1.SGM
05AUN1
45560
Federal Register / Vol. 79, No. 150 / Tuesday, August 5, 2014 / Notices
should refer to File Number SR–
NASDAQ–2014–038 and should be
submitted on or before August 26, 2014.
Rebuttal comments should be submitted
by September 9, 2014.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.28
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–18389 Filed 8–4–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–72704; File No. SR–CBOE–
2014–060
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Notice of Filing of a
Proposed Rule Change To Amend Rule
24.19
July 29, 2014.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on July 25,
2014, Chicago Board Options Exchange,
Incorporated (the ‘‘Exchange’’ or
‘‘CBOE’’) filed with the Securities and
Exchange Commission (the
‘‘Commission’’) the proposed rule
change as described in Items I and II
below, which Items have been prepared
by the Exchange. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
mstockstill on DSK4VPTVN1PROD with NOTICES
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend its
rule related to Multi-Class Broad-Based
Index Option Spread Orders. The text of
the proposed rule change is available on
the Exchange’s Web site (https://
www.cboe.com/AboutCBOE/
CBOELegalRegulatoryHome.aspx), at
the Exchange’s Office of the Secretary,
and at the Commission’s Public
Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
28 17
CFR 200.30–3(a)(57).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
VerDate Mar<15>2010
18:16 Aug 04, 2014
Jkt 232001
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in sections A, B, and C below, of
the most significant aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to amend
Rule 24.19. This Rule allows Trading
Permit Holders (‘‘TPHs’’) to execute
Multi-Class Broad-Based Index Option
Spread Orders (‘‘Multi-Class Spread
Orders’’) that meet certain qualifying
criteria. Currently, not all Multi-Class
Spread Orders may be entered
electronically due to systems
constraints. The Exchange is in the
process of modifying its electronic
order-entry systems to provide for the
electronic entry and validation of all
Multi-Class Spread Orders to the floor of
the Exchange. This will provide for an
enhanced audit trail that will better
allow regulatory oversight in connection
with the provisions of Rule 24.19. For
the Exchange’s systems to determine
that two separate legs are part of the
same Multi-Class Spread Order
(allowing for treatment as a Multi-Class
Spread Order), both legs must be
entered together on a single order ticket.
As such, the Exchange proposes to
amend Rule 24.19 to state that ‘‘MultiClass Spread Orders must be entered on
a single order ticket at time of
systemization to be eligible for the
procedures and relief set out in this
Rule.’’ 3 The Multi-Class Spread Order
type will enforce the permitted
combinations of options covered by
Rule 24.19. The Exchange will not
accept Multi-Class Spread Orders with
invalid combinations. While the
proposed rule change allows for all
Multi-Class Spread Orders to be entered
electronically, all Multi-Class Spread
Orders will still be executed in open
outcry on the Exchange’s trading floor.
Because the current method for
representing and executing Multi-Class
Spread Orders is manual and must
occur only in open outcry, the current
3 The Exchange notes that the substance of this
proposal was published in a prior proposal which
was published for the entire 21 day comment
period, and no comments were received. That prior
proposal provided for several changes to Rule
24.19; however, this proposal specifically relates to
the electronic entry and validation of Multi-Class
Spread Orders and can be considered and approved
without reference to the other proposed changes in
the prior proposal. See Securities Exchange Act
Release No. 71872 (April 4, 2014), 79 FR 19940
(April 10, 2014) (SR–CBOE–2014–026).
PO 00000
Frm 00139
Fmt 4703
Sfmt 4703
language states that a Multi-Class
Spread Order may be represented at the
trading station of either Broad-Based
Option comprising the order, and also
requires that the TPH initiating the
order in the trading crowd to contact an
Order Book Official (‘‘OBO’’),
Designated Primary Market-Maker
(‘‘DPM’’), or appropriate Exchange staff,
as applicable, at the other trading
station to have a notice of such order
disseminated to the other trading crowd.
The proposed rule change will require
that a Multi-Class Spread Order be
represented at the primary trading
station, and states that the TPH
representing the order must contact the
DPM or Exchange staff 4 (as applicable)
at the other trading station in order to
provide notice of such order for
dissemination to the other trading
crowd. Each Broad-Based Index Option
has a trading station. The primary
trading station is the first trading station
at which the Multi-Class Spread Order
is represented. The floor broker
representing the Multi-Class Spread
Order may determine which trading
station should be the primary trading
station. The current rule states that
notice of a Multi-Class Spread order
‘‘shall be disseminated by the Recipient
who shall verbalize the terms of the
order to the other trading crowd.’’
However, the Exchange proposes to
replace the word ‘‘verbalize’’ with the
word ‘‘announce’’, as the Exchange is
currently contemplating changes that
will allow such notice to be posted on
screens electronically to the other
trading crowd (which could be a more
efficient method of posting such order
information). This ensures that all
market participants at both physical
trading locations are aware of the terms
of the order being processed.
The proposed rule change will
enhance and improve the process of
sending Multi-Class Spread Orders to
the floor of the Exchange, as well as
enhance the Exchange’s audit trail with
respect to such orders. No later than 90
days following the effective date of the
proposed rule change, the Exchange will
announce to TPHs via Regulatory
Circular the implementation date by
which TPHs must be in compliance
with the changes described herein. The
implementation date will be no later
than 180 days following the effective
date of the proposed rule change, and
will be at least 30 days following the
release of the abovementioned
Regulatory Circular (in order to give
TPHs ample time to come into
4 The Exchange proposes to remove the reference
to contacting an OBO, as the Exchange no longer
has OBOs.
E:\FR\FM\05AUN1.SGM
05AUN1
Agencies
[Federal Register Volume 79, Number 150 (Tuesday, August 5, 2014)]
[Notices]
[Pages 45556-45560]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-18389]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-72715; File No. SR-NASDAQ-2014-038]
Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Order
Instituting Proceedings To Determine Whether To Approve or Disapprove
Proposed Rule Change, as Modified by Amendment Nos. 1 and 2 Thereto,
Relating to Listing and Trading of Shares of the NASDAQ-100 DIVS Index
ETF Under Rule 5705
July 29, 2014.
On April 10, 2014, The NASDAQ Stock Market LLC (``Exchange'') 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 Reality Shares NASDAQ-100 DIVS Index
ETF (``Fund'') (formerly, Reality Shares NASDAQ-100 Isolated Dividend
Growth Index ETF) under NASDAQ Rule 5705. The proposed rule change was
published for comment in the Federal Register on April 30, 2014.\3\ On
May 6, 2014, the Exchange filed Amendment No. 1 to the proposed rule
change, which amended and replaced the proposed rule change in its
entirety.\4\ On June 4, 2014, the Exchange filed Amendment No. 2 to the
proposed rule change.\5\ On June 13, 2014, pursuant to Section 19(b)(2)
of the Act,\6\ the Commission designated a longer period within which
to approve the proposed rule change, disapprove the proposed rule
change, or institute proceedings to determine whether to disapprove the
proposed rule change.\7\ The Commission received no comment letters on
the proposed rule change. This Order institutes proceedings under
Section 19(b)(2)(B) of the Act \8\ to determine whether to approve or
disapprove the proposed rule change, as modified by Amendment Nos. 1
and 2 thereto.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 72014 (Apr. 24,
2014), 79 FR 24465 (``Notice'').
\4\ In Amendment No. 1, the Exchange confirmed the hours of the
three trading sessions on the Exchange, clarified the valuation of
investments for purposes of calculating net asset value, clarified
what information would be available on the Fund's Web site, and
provided additional information relating to surveillance with
respect to certain assets held by the Fund. Amendment No. 1 provided
clarification to the proposed rule change, and because it does not
materially affect the substance of the proposed rule change or raise
novel or unique regulatory issues, Amendment No. 1 is not subject to
notice and comment.
\5\ The Exchange filed Amendment No. 2 to the proposal to
reflect a name change to the Fund and the underlying index.
Specifically, the Exchange replaced each reference to ``Reality
Shares NASDAQ-100 Isolated Dividend Growth ETF'' in the proposal
with ``Reality Shares NASDAQ-100 DIVS Index ETF'' and replaced each
reference to ``Reality Shares NASDAQ-100 Isolated Dividend Growth
Index'' in the proposal with ``Reality Shares NASDAQ-100 DIVS
Index.'' Amendment No. 2 is a technical amendment and is not subject
to notice and comment as it does not materially affect the substance
of the filing.
\6\ 15 U.S.C. 78s(b)(2).
\7\ See Securities Exchange Act Release No. 72384, 79 FR 35205
(June 19, 2014). The Commission designated a longer period within
which to take action on the proposed rule change and designated July
29, 2014, as the date by which it should approve, disapprove, or
institute proceedings to determine whether to disapprove the
proposed rule change.
\8\ 15 U.S.C. 78s(b)(2)(B).
---------------------------------------------------------------------------
I. Description of the Proposal
A. In General
The Exchange proposes to list and trade Shares of the Fund under
NASDAQ Rule 5705(b), which governs the listing and trading of Index
Fund Shares \9\ on the Exchange. The Shares of the Fund will be offered
by the Reality Shares ETF Trust (``Trust''). The Trust will be
registered with the Commission as an open-end management investment
company.\10\ Reality Shares Advisors, LLC will serve as the investment
adviser to the Fund (``Adviser''). ALPS Distributors, Inc. will be the
principal underwriter and distributor of the Fund's Shares. The Bank of
New York Mellon will serve as administrator, custodian, and transfer
agent for the Fund.
---------------------------------------------------------------------------
\9\ Index Fund Shares that are issued by an open-end investment
company and listed and traded on the Exchange under NASDAQ Rule 5705
seek to provide investment results that correspond generally to the
price and yield performance of a specific foreign or domestic stock
index, fixed income securities index, or combination thereof. See
Rule 5705(b)(1)(A).
\10\ According to the Exchange, the Trust will be registered
under the Investment Company Act of 1940 (``1940 Act''). On November
12, 2013, the Trust filed a registration statement on Form N-1A
under the Securities Act of 1933 (``1933 Act'') and under the 1940
Act relating to the Fund, as amended by Pre-Effective Amendment
Number 1, filed with the Commission on February 6, 2014 (File Nos.
333-192288 and 811-22911) (the ``Registration Statement''). The
description of the operation of the Trust and the Fund herein is
based, in part, on the Registration Statement. In addition, the
Commission has issued an order granting certain exemptive relief to
the Trust under the 1940 Act. Investment Company Act Release No.
30678 (Aug. 27, 2013) (``Exemptive Order''). The Exchange states
that investments made by the Fund will comply with the conditions
set forth in the Exemptive Order.
---------------------------------------------------------------------------
B. The Exchange's Description of the Fund
The Exchange has made the following representations concerning the
Fund.
[[Page 45557]]
The Fund will seek long-term capital appreciation by tracking the
performance of the Reality Shares NASDAQ-100 DIVS Index (``Index'').
The Index was developed and is maintained by Reality Shares, Inc.
(``Index Provider'').\11\ The Adviser is a wholly-owned subsidiary of
the Index Provider. The Index Provider is not registered as a broker-
dealer and is not affiliated with any broker-dealer.\12\ The Adviser is
not registered as a broker-dealer and is not affiliated with any
broker-dealer.\13\
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\11\ The Index will be calculated by International Data
Corporation, which is not affiliated with the Adviser, the Index
Provider, or The NASDAQ OMX Group and which is not a broker-dealer
or fund advisor. Rule 5705(b)(5)(A)(i) states that if an index is
maintained by a fund advisor or a broker-dealer, the fund advisor or
broker-dealer shall erect a ``fire wall'' around the personnel who
have access to information concerning changes and adjustments to the
index.
\12\ The Adviser and the Index Provider have represented that a
fire wall exists around the respective personnel who have access to
information concerning changes and adjustments to the Index.
\13\ The Adviser and the Index Provider have represented that a
fire wall exists around the respective personnel who have access to
information concerning changes and adjustments to the Index. The
Exchange notes that, in the event (a) the Adviser, any sub-adviser,
or the Index Provider becomes registered as a broker-dealer or newly
affiliated with a broker-dealer, or (b) any new adviser, sub-
adviser, or Index Provider is a registered broker-dealer or becomes
affiliated with a broker-dealer, that entity will implement a fire
wall with respect to their relevant personnel or broker-dealer
affiliate, as applicable, 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.
---------------------------------------------------------------------------
1. Index Methodology
The Index will be calculated using a proprietary, rules-based
methodology designed to track market expectations for dividend growth
conveyed in real-time using the mid-point of the bid-ask spread on
NASDAQ-100 Index options and options on exchange-traded funds
(``ETFs'') designed to track the NASDAQ-100 Index.\14\ All options
included in the Index will be listed and traded on a U.S. national
securities exchange. The Index will consist of a minimum of 20
components.\15\
---------------------------------------------------------------------------
\14\ The Index will not directly measure or track actual
dividend payments or the actual growth in dividend payments, but
will instead track market expectations of dividend growth as implied
by the prices of the options that make up the Index.
\15\ Rule 5705(b)(3).
---------------------------------------------------------------------------
The prices of index and ETF options reflect the market trading
prices of the securities included in the applicable underlying index or
ETF, as well as market expectations regarding the level of dividends to
be paid on those indexes or ETFs during the term of the option. The
Index constituents, and therefore most of the Fund's portfolio
holdings, will consist of multiple corresponding near-term and long-
term put and call option combinations on the same reference assets
(i.e., options on the NASDAQ-100 Index or the NASDAQ-100 ETF) with the
same strike price. Because option prices reflect both stock price and
dividend expectations, they can be used in combination to isolate
either price exposure or dividend expectations. The use of near-term
and long-term put and call option combinations on the same reference
asset with the same strike price, but with different maturities, is
designed to gain exposure to the expected dividends of the securities
in the NASDAQ-100 Index while neutralizing the impact of stock price
movements. Over time, the Index will increase or decrease in value as
the dividend spread between the near-term and long-term option
combinations increases or decreases as a result of changing market
expectations for dividend growth.
2. Principal Investments of the Fund
The Fund will seek long-term capital appreciation and will seek
investment results that, before fees and expenses, generally correspond
to the performance of the Index. At least 80% of the Fund's total
assets (exclusive of collateral held from securities lending, if any)
will be invested in the component securities of the Index. The Fund
will seek a correlation of 0.95 or better between its performance and
the performance of its Index. A figure of 1.00 would represent perfect
correlation. The Fund generally will use a representative sampling
investment strategy.
The Fund will buy (i.e., hold a ``long'' position in) and sell
(i.e., hold a ``short'' position in) put and call options. The Fund
will have a strategy of taking both a long position in a security
through its ex-dividend date (the last date an investor can own the
security and receive dividends paid on the security) and a
corresponding short position in the same security immediately
thereafter. This is designed to allow the Fund to isolate its exposure
to the growth of the level of dividends expected to be paid on a
security while minimizing its exposure to changes in the trading price
of that security.
The Fund will buy and sell U.S. exchange-listed options on the
NASDAQ-100 Index and U.S. exchange-listed options on ETFs designed to
track the NASDAQ-100 Index. A put option gives the purchaser of the
option the right to sell, and the issuer of the option the obligation
to buy, the underlying security or instrument on a specified date or
during a specified period of time. A call option on a security gives
the purchaser of the option the right to buy, and the writer of the
option the obligation to sell, the underlying security or instrument on
a specified date or during a specified period of time. The Fund will
invest in a combination of put and call options designed to allow the
Fund to isolate its exposure to the growth of the level of expected
dividends reflected in options on the NASDAQ-100 Index and options on
ETFs tracking the NASDAQ-100 Index, while minimizing the Fund's
exposure to changes in the trading price of such securities.
3. Other Investments of the Fund
While, as described above, at least 80% of the Fund's total assets
(exclusive of collateral held from securities lending, if any) will be
invested in the component securities of the Index, the Fund may invest
up to 20% of the Fund's total assets in other securities and financial
instruments, as described below.
The Fund may invest in U.S. exchange-listed futures contracts on
the NASDAQ-100 Index and ETFs designed to track the NASDAQ-100 Index
and may invest in forward contracts on the NASDAQ-100 Index and ETFs
designed to track the NASDAQ-100 Index. The Fund's use of exchange-
listed futures contracts and forward contracts is designed to allow the
Fund to isolate its exposure to the growth of the level of expected
dividends reflected in options on the NASDAQ-100 Index and options on
ETFs tracking the NASDAQ-100 Index, while minimizing the Fund's
exposure to changes in the trading price of such securities. The Fund
may also buy and sell OTC options on the NASDAQ-100 Index and on ETFs
designed to track the NASDAQ-100 Index.
The Fund may enter into dividend and total return swap transactions
(including equity swap transactions) based on the NASDAQ-100 Index and
ETFs designed to track the NASDAQ-100 Index.\16\ In a typical swap
transaction, one party agrees to make periodic payments to another
party (``counterparty'') based on the change in market value or level
of a specified rate, index, or asset. In return, the counterparty
agrees to make periodic payments to the first party based on the return
of a different specified rate, index, or asset. Swap transactions are
usually done on a net basis, with the
[[Page 45558]]
Fund receiving or paying only the net amount of the two payments. In a
typical dividend swap transaction, the Fund would pay the swap
counterparty a premium and would be entitled to receive the value of
the actual dividends paid on the subject index during the term of the
swap contract. In a typical total return swap transaction, the Fund
might exchange long or short exposures to the return of the underlying
securities or index to isolate the value of the dividends paid on the
underlying securities or index constituents. The Fund also may engage
in interest rate swap transactions. In a typical interest rate swap
transaction, one stream of future interest payments is exchanged for
another. Such transactions often take the form of an exchange of a
fixed payment for a variable payment based on a future interest rate.
The Fund intends to use interest rate swap transactions to manage or
hedge exposure to interest rate fluctuations.
---------------------------------------------------------------------------
\16\ The Fund will transact only with swap dealers that have in
place an ISDA agreement with the Fund.
---------------------------------------------------------------------------
The Fund may invest up to 20% of its assets (exclusive of
collateral held from securities lending, if any) in exchange-listed
equity securities and derivative instruments (specifically, futures
contracts, forward contracts, and swap transactions) \17\ relating to
the Index and its component securities that the Adviser believes will
help the Fund track the Index. For example, the Fund may buy and sell
ETFs and, to a limited extent, individual large-capitalization equity
securities listed and traded on a U.S. national securities exchange.
---------------------------------------------------------------------------
\17\ Where practicable, the Fund intends to invest in swaps
cleared through a central clearing house (``Cleared Swaps'').
Currently, only certain of the interest rate swaps in which the Fund
intends to invest are Cleared Swaps, while the dividend and total
return swaps (including equity swaps) in which the Fund may invest
are currently not Cleared Swaps.
---------------------------------------------------------------------------
The Fund may invest in the securities of other investment companies
(including money market funds) to the extent permitted under the 1940
Act.
The Fund's short positions and its investments in swaps, futures
contracts, forward contracts, and options based on the NASDAQ-100 Index
and ETFs designed to track the NASDAQ-100 Index will be backed by
investments in cash, high-quality short-term debt securities, and
money-market instruments in an amount equal to the Fund's maximum
liability under the applicable position or contract or will otherwise
be offset in accordance with Section 18 of the 1940 Act. Short-term
debt securities and money market instruments include shares of fixed
income or money market mutual funds, commercial paper, certificates of
deposit, bankers' acceptances, U.S. Government Securities (including
securities issued or guaranteed by the U.S. government or its
authorities, agencies, or instrumentalities), repurchase
agreements,\18\ and bonds that are rated BBB or higher.
---------------------------------------------------------------------------
\18\ The Fund may enter into repurchase agreements with banks
and broker-dealers. A repurchase agreement is an agreement under
which securities are acquired by a fund from a securities dealer or
bank, subject to resale at an agreed-upon price on a later date. The
acquiring fund bears a risk of loss in the event that the other
party to a repurchase agreement defaults on its obligations and the
fund is delayed or prevented from exercising its rights to dispose
of the collateral securities.
---------------------------------------------------------------------------
In addition to the investments described above, and in a manner
consistent with its investment objective, the Fund may invest a limited
portion of its net assets in high-quality, short-term debt securities
and money market instruments for cash management purposes.\19\
---------------------------------------------------------------------------
\19\ The Fund may invest in shares of money market mutual funds
to the extent permitted by the 1940 Act.
---------------------------------------------------------------------------
The Fund will attempt to limit counterparty risk in non-cleared
swap, forward, and OTC option contracts by entering into such contracts
only with counterparties the Adviser believes are creditworthy and by
limiting the Fund's exposure to each counterparty. The Adviser will
monitor the creditworthiness of each counterparty and the Fund's
exposure to each counterparty on an ongoing basis.\20\
---------------------------------------------------------------------------
\20\ The Fund will seek, where possible, to use counterparties,
as applicable, whose financial status is such that the risk of
default is reduced; however, the risk of losses resulting from
default is still possible. The Adviser will evaluate the
creditworthiness of counterparties on an ongoing basis. In addition
to information provided by credit agencies, the Adviser will
evaluate each approved counterparty using various methods of
analysis, such as, for example, the counterparty's liquidity in the
event of default, the counterparty's reputation, the Adviser's past
experience with the counterparty, and the counterparty's share of
market participation.
---------------------------------------------------------------------------
The Exchange represents that the Fund's investments in swaps,
futures contracts, forward contracts, and options will be consistent
with the Fund's investment objective and with the requirements of the
1940 Act.\21\
---------------------------------------------------------------------------
\21\ To limit the potential risk associated with such
transactions, the Fund will segregate or ``earmark'' assets
determined to be liquid by the Adviser in accordance with procedures
established by the Trust's Board of Trustees and in accordance with
the 1940 Act (or, as permitted by applicable regulation, will enter
into certain offsetting positions) to cover its obligations arising
from such transactions. These procedures have been adopted
consistent with Section 18 of the 1940 Act and related Commission
guidance. In addition, the Fund will include appropriate risk
disclosure in its offering documents, including leveraging risk.
Leveraging risk is the risk that certain transactions of the Fund,
including the Fund's use of derivatives, may give rise to leverage,
causing the Fund to be more volatile than if it had not been
leveraged. To mitigate leveraging risk, the Adviser will segregate
or ``earmark'' liquid assets or otherwise cover the transactions
that may give rise to such risk.
---------------------------------------------------------------------------
4. Investment Restrictions of the Fund
To the extent the Index concentrates (i.e., holds 25% or more of
its total assets) in the securities of a particular industry or group
of industries, the Fund will concentrate its investments to
approximately the same extent as the Index.
The Fund may hold up to an aggregate amount of 15% of its net
assets in assets (calculated at the time of investment) deemed illiquid
by the Adviser, consistent with Commission guidance.\22\ 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.
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\22\ In reaching liquidity decisions, the 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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The Fund may make secured loans of its portfolio securities;
however, securities loans will not be made if, as a result, the
aggregate amount of all outstanding securities loans by the Fund
exceeds 33 1/3% of its total assets (including the market value of
collateral received). To the extent the Fund engages in securities
lending, securities loans will be made to broker-dealers that the
Adviser believes to be of relatively high credit standing pursuant to
agreements requiring that the loans continuously be collateralized by
cash, liquid securities, or shares of other investment companies with a
value at least equal to the market value of the loaned securities.
The Fund will be classified as a ``non-diversified'' investment
company under the 1940 Act and intends to qualify for, and to elect
treatment as, a separate regulated investment company under Subchapter
M of the Internal Revenue Code. The Exchange represents that the Fund's
investments will be consistent with its investment objective and will
[[Page 45559]]
not be used to provide multiple returns of a benchmark or to produce
leveraged returns.
II. Proceedings to Determine Whether To Approve or Disapprove SR-
NASDAQ-2014-038 and Grounds for Disapproval Under Consideration
The Commission is instituting proceedings pursuant to Section
19(b)(2)(B) of the Act \23\ to determine whether the proposed rule
change should be approved or disapproved. Institution of such
proceedings is appropriate at this time in view of the legal and policy
issues raised by the proposed rule change. Institution of proceedings
does not indicate that the Commission has reached any conclusions with
respect to any of the issues involved. Rather, as described below, the
Commission seeks and encourages interested persons to provide comments
on the proposed rule change.
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\23\ 15 U.S.C. 78s(b)(2)(B).
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Pursuant to Section 19(b)(2)(B) of the Act,\24\ the Commission is
providing notice of the grounds for disapproval under consideration.
The Commission is instituting proceedings to allow for additional
analysis of the proposed rule change's consistency with Section 6(b)(5)
of the Act, which requires, among other things, that the rules of a
national securities exchange be ``designed to prevent fraudulent and
manipulative acts and practices, to promote just and equitable
principles of trade,'' and ``to protect investors and the public
interest.'' \25\
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\24\ Id.
\25\ 15 U.S.C. 78f(b)(5).
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III. Procedure: Request for Written Comments
The Commission requests that interested persons provide written
submissions of their views, data, and arguments with respect to the
issues identified above, as well as any other concerns they may have
with the proposal. In particular, the Commission invites the written
views of interested persons concerning whether the proposal is
consistent with Section 6(b)(5) or any other provision of the Act, or
the rules and regulations thereunder. Although there do not appear to
be any issues relevant to approval or disapproval that would be
facilitated by an oral presentation of views, data, and arguments, the
Commission will consider, pursuant to Rule 19b-4, any request for an
opportunity to make an oral presentation.\26\
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\26\ Section 19(b)(2) of the Act, as amended by the Securities
Act Amendments of 1975, Public Law 94-29 (June 4, 1975), grants the
Commission flexibility to determine what type of proceeding--either
oral or notice and opportunity for written comments--is appropriate
for consideration of a particular proposal by a self-regulatory
organization. See Securities Act Amendments of 1975, Senate Comm. on
Banking, Housing & Urban Affairs, S. Rep. No. 75, 94th Cong., 1st
Sess. 30 (1975).
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Interested persons are invited to submit written data, views, and
arguments regarding whether the proposal should be approved or
disapproved by August 26, 2014. Any person who wishes to file a
rebuttal to any other person's submission must file that rebuttal by
September 9, 2014.
The Commission asks that commenters address the sufficiency of the
Exchange's statements in support of the proposal, which are set forth
in the Notice,\27\ as modified by Amendment Nos. 1 and 2 to the
proposed rule change, in addition to any other comments they may wish
to submit about the proposed rule change. In particular, the Commission
seeks comment on the following:
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\27\ See supra note 3.
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1. Because the Index is designed to reflect changes in market
expectations of future dividend growth, rather than to track actual
dividend growth, is the Fund's investment strategy fundamentally based
on an assumption that the options markets systemically underprice
dividend growth? What are commenters' views regarding whether investors
would be able to understand the strategy, risks, potential rewards,
assumptions, and expected performance of the Fund's strategy?
2. With respect to the trading of the Shares on the Exchange, do
commenters believe that the Exchange's rules governing sales practices
are adequately designed to ensure the suitability of recommendations
regarding the Shares? Why or why not? If not, should the Exchange's
rules governing sales practices be enhanced? If so, in what ways?
3. How closely do commenters think the market price of the Shares
will track the Fund's intraday indicative value (``IIV'') or the
intraday value of the Index? Are certain of these values likely to be
more volatile than others? If so, how would this affect trading in the
Shares? Are the Shares likely to trade with a significant premium or
discount to IIV? What are commenters' views of how effectively the IIV
of the Fund would represent the Fund's portfolio? What are commenters'
views of how the Shares' market price, the Fund's IIV, and the intraday
value of the Index will relate to one another during times of market
stress?
4. Does the liquidity of the long-dated options in which the Fund
will invest differ materially from that of the short-dated options in
which the Fund will invest? If so, how would that affect the ability of
market makers to engage in arbitrage or to hedge their positions while
making a market in the Shares? Would the liquidity characteristics of
the Index components or of the options in the Fund's portfolio affect
the calculation of the Index value, the calculation of the Fund's IIV,
the calculation of the Fund's NAV, or the ability of market makers or
other market participants to value the Shares? If so, how?
Comments may be submitted by any of the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an email to rule-comments@sec.gov. Please include
File Number SR-NASDAQ-2014-038 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE., Washington, DC 20549-1090.
All submissions should refer to File Numbers SR-NASDAQ-2014-038.
This file number should be included on the subject line if email is
used. To help the Commission process and review your comments more
efficiently, please use only one method. The Commission will post all
comments on the Commission's Internet Web site (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments,
all written statements with respect to the proposed rule change that
are filed with the Commission, and all written communications relating
to the proposed rule change between the Commission and any person,
other than those that may be withheld from the public in accordance
with the provisions of 5 U.S.C. 552, will be available for Web site
viewing and printing in the Commission's Public Reference Room, 100 F
Street NE., Washington, DC 20549, on official business days between the
hours of 10:00 a.m. and 3:00 p.m. Copies of these filings also will be
available for inspection and copying at the principal office of the
Exchange. All comments received will be posted without change; the
Commission does not edit personal identifying information from
submissions. You should submit only information that you wish to make
available publicly. All submissions
[[Page 45560]]
should refer to File Number SR-NASDAQ-2014-038 and should be submitted
on or before August 26, 2014. Rebuttal comments should be submitted by
September 9, 2014.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\28\
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\28\ 17 CFR 200.30-3(a)(57).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-18389 Filed 8-4-14; 8:45 am]
BILLING CODE 8011-01-P