Self-Regulatory Organizations; NYSE Arca, Inc.; Order Granting Approval of Proposed Rule Change, as Modified by Amendment Nos. 1 and 3 Thereto, Relating to the Listing and Trading of Shares of the ALPS Enhanced Put Write Strategy ETF Under NYSE Arca Equities Rule 8.600, 36380-36385 [2015-15452]
Download as PDF
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conditions or for reasons that, in the
view of the Exchange, make trading in
the Shares inadvisable. Trading in the
Shares will be subject to NYSE Arca
Equities Rule 8.600(d)(2)(D), which sets
forth circumstances under which Shares
of the Fund may be halted. In addition,
as noted above, investors will have
ready access to information regarding
the Fund’s holdings, the IIV, the
Disclosed Portfolio, and quotation and
last sale information for the Shares.
The proposed rule change is designed
to perfect the mechanism of a free and
open market and, in general, to protect
investors and the public interest in that
it will facilitate the listing and trading
of an additional type of activelymanaged exchange-traded product that
will enhance competition among market
participants, to the benefit of investors
and the marketplace. As noted above,
the Exchange has in place surveillance
procedures relating to trading in the
Shares and may obtain information via
ISG from other exchanges that are
members of ISG or with which the
Exchange has entered into a
comprehensive surveillance sharing
agreement. In addition, as noted above,
investors will have ready access to
information regarding the Fund’s
holdings, the IIV, the Disclosed
Portfolio, and quotation and last sale
information for the Shares.
B. Self-Regulatory Organization’s
Statement on Burden on Competition
The Exchange does not believe that
the proposed rule change will impose
any burden on competition that is not
necessary or appropriate in furtherance
of the purpose of the Act. The Exchange
notes that the proposed rule change will
facilitate the listing and trading of an
additional type of actively-managed
exchange-traded product that will
enhance competition among market
participants, to the benefit of investors
and the marketplace.
tkelley on DSK3SPTVN1PROD with NOTICES
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
No written comments were solicited
or received with respect to the proposed
rule change.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of
publication of this notice in the Federal
Register or such longer period up to 90
days after publication (i) as the
Commission may designate if it finds
such longer period to be appropriate
and publishes its reasons for so finding
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or (ii) as to which the self-regulatory
organization consents, the Commission
will:
(A) by order approve or disapprove
the proposed rule change, or
(B) institute proceedings to determine
whether the proposed rule change
should be disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
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–
NYSEArca–2015–42 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Brent J. Fields, Secretary, Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
All submissions should refer to File
Number SR–NYSEArca–2015–42. 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 Section, 100 F Street, NE.,
Washington, DC 20549 on official
business days between 10:00 a.m. and
3:00 p.m. Copies of the filing will also
be available for inspection and copying
at the NYSE’s principal office and on its
Internet Web site at www.nyse.com. 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–NYSEArca–2015–42 and
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should be submitted on or before July
15, 2015.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.37
Brent J. Fields,
Secretary.
[FR Doc. 2015–15455 Filed 6–23–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–75244; File No. SR–
NYSEArca-2015–23]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Order Granting Approval of
Proposed Rule Change, as Modified by
Amendment Nos. 1 and 3 Thereto,
Relating to the Listing and Trading of
Shares of the ALPS Enhanced Put
Write Strategy ETF Under NYSE Arca
Equities Rule 8.600
June 18, 2015.
I. Introduction
On April 15, 2015, NYSE Arca, Inc.
(‘‘Exchange’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’), pursuant to section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Act’’ or ‘‘Exchange Act’’) 1 and
Rule 19b–4 thereunder,2 a proposed rule
change to list and trade shares
(‘‘Shares’’) of the ALPS Enhanced Put
Write Strategy ETF (‘‘Fund’’) under
NYSE Arca Equities Rule 8.600, which
governs the listing and trading of
Managed Fund Shares. The proposed
rule change was published for comment
in the Federal Register on May 5, 2015.3
On May 12, 2015, the Exchange filed
Amendment No. 1 to the proposed rule
change.4 On May 19, 2015, the
Exchange filed Amendment No. 2 to the
proposed rule change, but withdrew
that amendment on May 20, 2015.5 On
May 20, 2015, the Exchange filed
Amendment No. 3 to the proposed rule
change.6 The Commission received no
37 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See Securities Exchange Act Release No. 74839
(Apr. 29, 2015), 80 FR 25729 (‘‘Notice’’).
4 Amendment No. 1 to the proposed rule change
replaced and superseded the original filing in its
entirety.
5 The Exchange withdrew Amendment No. 2 to
the proposed rule change due to certain errors.
6 Amendment No. 3 to the proposed rule change
corrected typographical errors and clarified that any
futures and options on futures utilized by the Fund
will be U.S. exchange-traded futures contracts on
the S&P 500 Index and U.S. exchange-traded
options on futures contracts on the S&P 500 Index.
Amendment Nos. 1 and 3 are available at: https://
www.sec.gov/comments/sr-nysearca-2015–23/
nysearca201523.shtml.
1 15
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comments on the proposal, as modified
by Amendment Nos. 1 and 3 thereto.
This order grants approval of the
proposed rule change, as modified by
Amendment Nos. 1 and 3 thereto.
II. Description of the Proposal
tkelley on DSK3SPTVN1PROD with NOTICES
NYSE Arca 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 on the Exchange. The Shares will
be offered by ALPS ETF Trust (‘‘Trust’’),
which is registered with the
Commission as an investment
company.7 ALPS Advisors, Inc. is the
investment adviser (‘‘Adviser’’) to the
Fund.8 Rich Investment Solutions, LLC
is the investment sub-adviser (‘‘SubAdviser’’) to the Fund. ALPS Fund
Services, Inc. serves as the Trust’s
administrator, and The Bank of New
York Mellon serves as custodian
(‘‘Custodian’’) and transfer agent for the
Fund. ALPS Portfolio Solutions
Distributor, Inc. is the distributor of the
Fund’s Shares.
The Exchange has made the following
representations and statements in
describing the Fund and its investment
strategy, including the Fund’s portfolio
holdings and investment restrictions.9
7 The Trust is registered under the Investment
Company Act of 1940 (‘‘1940 Act’’). The Exchange
states that the Trust filed with the Commission a
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–
148826 and 811–22175) (‘‘Registration Statement’’)
on January 6, 2015. In addition, the Exchange
represents that the Trust has obtained certain
exemptive relief under the1940 Act. See Investment
Company Act Release No. 30553 (June 11, 2013)
(File No. 812–13884).
8 The Exchange represents that the Adviser is not
a registered broker-dealer, but is affiliated with a
broker-dealer and has implemented a ‘‘fire wall’’
with respect to that broker-dealer regarding access
to information concerning the composition of or
changes to the Fund’s portfolio. The Exchange
further represents that, in the event (a) the Adviser
or any sub-adviser becomes registered as a brokerdealer or newly affiliated with a broker-dealer, or
(b) any new adviser or sub-adviser is a registered
broker-dealer or becomes affiliated with a brokerdealer, the Adviser or any new adviser or subadviser, as the case may be, will implement a fire
wall with respect to its 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.
9 The Commission notes that additional
information regarding the Fund, the Trust, and the
Shares, including investment strategies, risks,
creation and redemption procedures, fees, portfolio
holdings disclosure policies, calculation of net asset
value (‘‘NAV’’), distributions, and taxes, among
other things, can be found in the Notice and the
Registration Statement, as applicable. See Notice
and Registration Statement, supra notes 3 and 7,
respectively.
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A. The Exchange’s Description of the
Fund’s Principal Investment Policies
According to the Exchange, the
investment objective of the Fund is to
seek total return, with an emphasis on
income as the source of that total return.
The Fund will seek to achieve its
investment objective by selling listed
one-month put options on the SPDR®
S&P 500® ETF Trust (‘‘SPY’’). SPY is an
exchange-traded fund that seeks to
provide investment results that, before
expenses, correspond generally to the
price and yield performance of the S&P
500® Index (‘‘SPX’’ or ‘‘Index’’). SPY
holds a portfolio of the common stocks
that are included in the SPX, with the
weight of each stock in its portfolio
substantially corresponding to the
weight of that stock in the SPX. The
Fund may also sell listed one-month put
options directly on the SPX under
certain circumstances (such as if those
options have more liquidity and
narrower spreads than options on SPY).
SPY shares are listed on the Exchange
and traded on national securities
exchanges. SPX options are traded on
the Chicago Board Options Exchange,
and options on SPY are traded on
national securities exchanges.
Each listed put option sold by the
Fund will be an ‘‘American-style’’
option (i.e., an option that can be
exercised at the strike price at any time
prior to its expiration). As the seller of
a listed put option, the Fund will incur
an obligation to buy SPY underlying the
option from the purchaser of the option
at the option’s strike price, upon
exercise by the option purchaser. If a
listed put option sold by the Fund is
exercised prior to expiration, the Fund
will buy the SPY underlying the option
at the time of exercise and at the strike
price, and will hold SPY until the
market close on expiration.10
The option premiums and cash (in
respect of orders to create Shares in
large aggregations known as ‘‘Creation
Units,’’ as further described below)
received by the Fund will be invested in
an actively-managed portfolio of
investment grade debt securities
(‘‘Collateral Portfolio’’) at least equal in
value to the Fund’s maximum liability
under its written options (i.e., the strike
price of each option). Investment grade
debt securities are those rated ‘‘Baa’’
equivalent or higher by a nationally
10 The Fund may also sell put options on the SPX
directly under certain circumstances (such as if
such options have more liquidity and narrower
spreads than options on SPY) resulting in lower
transaction costs than options on SPY. The puts are
struck at-the-money (i.e., with a strike price that is
equal to the market price of the underlying SPY)
and are typically sold on a monthly basis, usually
on the third Friday of the month (the ‘‘roll date’’).
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36381
recognized statistical rating organization
(‘‘NRSROs’’), or are unrated securities
that the Sub-Adviser believes are of
comparable quality. These investment
grade debt securities will include
Treasury bills (short-term U.S.
government debt securities), corporate
bonds, commercial paper, mortgagebacked securities (‘‘MBS’’), asset-backed
securities (‘‘ABS’’), and notes issued or
guaranteed by federal agencies or U.S.
government sponsored
instrumentalities, such as the
Government National Mortgage
Administration, the Federal Housing
Administration, the Federal National
Mortgage Association, and the Federal
Home Loan Mortgage Corporation. It is
expected that the average duration of
these securities will not exceed six
months, and the maximum maturity of
any single security will not exceed one
year.
Under normal market conditions,11
substantially all of the Fund’s net assets
will be invested in options on SPY or
SPX and in the Collateral Portfolio.
The Fund may invest up to 20% of its
net assets in non-agency MBS and ABS
in the aggregate. The Fund may seek to
obtain exposure to U.S. agency mortgage
pass-through securities primarily
through the use of ‘‘to-be-announced’’ or
‘‘TBA transactions.’’ According to the
Exchange, ‘‘TBA’’ refers to a commonly
used mechanism for the forward
settlement of U.S. agency mortgage passthrough securities and not to a separate
type of mortgage-backed security. Most
transactions in mortgage pass-through
securities occur through the use of TBA
transactions. TBA transactions are
generally conducted in accordance with
widely-accepted guidelines that
establish commonly observed terms and
conditions for execution, settlement and
delivery. In a TBA transaction, the
buyer and seller decide on general trade
parameters, such as agency, settlement
date, par amount, and price. The actual
pools delivered are generally
determined two days prior to settlement
date. The Fund will enter into TBA
transactions only with established
counterparties (such as major brokerdealers) and the Sub-Adviser will
11 The term ‘‘under normal market conditions’’
includes, but is not limited to, the absence of
extreme volatility or trading halts in the equity,
options or fixed income markets or the financial
markets generally; events or circumstances causing
a disruption in market liquidity or orderly markets;
operational issues causing dissemination of
inaccurate market information; or force majeure
type events such as systems failure, natural or manmade disaster, act of God, armed conflict, act of
terrorism, riot or labor disruption, or any similar
intervening circumstance.
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tkelley on DSK3SPTVN1PROD with NOTICES
monitor the creditworthiness of such
counterparties.12
According to the Exchange, every
month, the options sold by the Fund
will be settled by delivery at expiration
or will expire with no value, and new
option positions will be established
while the Fund sells any units of SPY
it owns as a result of such settlements
or of the Fund’s prior option positions
having been exercised. 13 The Exchange
states that this monthly cycle likely will
cause the Fund to have frequent and
substantial turnover in its option
positions. If the Fund receives
additional inflows (and issues more
Shares in ‘‘Creation Unit’’ size during a
one-month period), the Fund will sell
additional listed put options, which will
be exercised or expire at the end of such
one-month period. Conversely, if the
Fund redeems Shares in Creation Unit
size during a monthly period, the Fund
will terminate the appropriate portion of
the options it has sold.
With respect to no more than 20% of
the Fund’s assets, the Fund may engage
in certain opportunistic ‘‘put spread’’
and ‘‘call spread’’ strategies.
Specifically, when the Sub-Adviser
believes the SPX (and thus SPY) will
rise or not decline in value, the Fund
may engage in ‘‘put spreads’’ whereby
the Fund will buy back certain of the
written put options that are out of the
money (i.e., the strike price of the put
option is lower than the market price of
the underlying SPY) prior to expiration
in order to sell new put options that are
less out of the money. Similarly, the
Fund may buy back certain of its written
put options prior to expiration in order
to sell new longer-dated options that
will remain open past the one-month
period of the original option.
Conversely, when the Sub-Adviser
believes the SPX will decline in value,
the Fund may engage in ‘‘call spreads’’
whereby the Fund will sell call options
that are in-the-money (i.e., the strike
price of the call option is lower than the
market price of the underlying SPY) and
buy back less in-the-money call options.
The Sub-Adviser may employ a variant
of this call spread strategy whereby the
Fund buys more calls than it sells (as
long as the Fund receives a net premium
on the transactions). This may enable
12 The Fund intends to invest cash pending
settlement of any TBA transactions in money
market instruments, repurchase agreements,
commercial paper (including asset-backed
commercial paper), or other high-quality, liquid
short-term instruments, which may include money
market funds affiliated with the Adviser or SubAdviser.
13 The Fund may hold U.S. exchange-listed equity
securities, generally shares of SPY, for temporary
periods upon settlement or exercise of the options
sold by the Fund.
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Jkt 235001
the Fund to perform better when the
SPX (and thus SPY) experiences gains
well above the strike price of the calls
bought by the Fund. However, even if
the Fund engages in such call spreads,
a declining SPX (and thus SPY) will
significantly detract from Fund
performance (given the Fund’s principal
strategy of selling put options on SPY).
B. The Exchange’s Description of the
Fund’s Non-Principal Investment
Policies
While, under normal market
conditions, substantially all of the
Fund’s net assets will be invested in
options on SPY or SPX and in the
Collateral Portfolio, the Fund may
invest its remaining assets in other
securities and financial instruments, as
described below. The Fund may invest
its remaining assets in any one or more
of the following instruments: money
market instruments (as described
below), in addition to those in which
the Fund invests as part of the Collateral
Portfolio, and including repurchase
agreements or other funds that invest
exclusively in money market
instruments; convertible securities;
structured notes (notes on which the
amount of principal repayment and
interest payments are based on the
movement of one or more specified
factors, such as the movement of a
particular stock or stock index); forward
foreign currency exchange contracts;
swaps; over-the-counter (‘‘OTC’’)
options on SPY or on the S&P 500
Index; and futures contracts and options
on futures contracts, as described
further below. Swaps, options, and
futures contracts may be used by the
Fund in seeking to achieve its
investment objective and in managing
cash flows. The Fund may also invest in
money market instruments or other
short-term fixed income instruments as
part of a temporary defensive strategy to
protect against temporary market
declines.
The Fund may invest in high-quality
money market instruments on an
ongoing basis to provide liquidity. The
instruments in which the Fund may
invest include: (i) Short-term obligations
issued by the U.S. Government; 14 (ii)
negotiable certificates of deposit
(‘‘CDs’’), fixed time deposits, and
bankers’ acceptances of U.S. and foreign
14 Obligations issued or guaranteed by the U.S.
Government, its agencies and instrumentalities
include bills, notes, and bonds issued by the U.S.
Treasury, as well as ‘‘stripped’’ or ‘‘zero coupon’’
U.S. Treasury obligations representing future
interest or principal payments on U.S. Treasury
notes or bonds.
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banks and similar institutions; 15 (iii)
commercial paper rated at the date of
purchase ‘‘Prime-1’’ by Moody’s
Investors Service, Inc. or ‘‘A–1+’’ or ‘‘A–
1’’ by Standard & Poor’s or, if unrated,
of comparable quality as determined by
the Adviser; (iv) repurchase
agreements; 16 and (v) money market
mutual funds.
The Fund may enter into reverse
repurchase agreements, which involve
the sale of securities with an agreement
to repurchase the securities at an
agreed-upon price, date, and interest
payment and have the characteristics of
borrowing. The securities purchased
with the funds obtained from the
agreement and securities collateralizing
the agreement will have maturity dates
no later than the repayment date.
The Fund may invest in the securities
of other investment companies
(including money market funds), subject
to applicable restrictions under the 1940
Act.
To the extent the Fund utilizes futures
and options on futures, the Fund will
utilize U.S. exchange-traded futures
contracts on the S&P 500 Index and U.S.
exchange-traded options on futures
contracts on the S&P 500 Index. The
Fund may utilize such options on
futures contracts as a hedge against
changes in value of its portfolio
securities, or in anticipation of the
purchase of securities, and may enter
into closing transactions with respect to
such options to terminate existing
positions.
To the extent the Fund enters into
swap agreements, the Fund will enter
into swap agreements based on the S&P
500 Index.
The Fund may invest in investment
grade debt obligations traded in the U.S.
Such debt obligations include, among
others, bonds, notes, debentures, and
variable rate demand notes. In choosing
corporate debt securities on behalf of
the Fund, the Sub-Adviser may consider
(i) general economic and financial
conditions; and (ii) the specific issuer’s
(a) business and management, (b) cash
flow, (c) earnings coverage of interest
and dividends, (d) ability to operate
15 CDs are short-term negotiable obligations of
commercial banks. Time deposits are nonnegotiable deposits maintained in banking
institutions for specified periods of time at stated
interest rates. Banker’s acceptances are time drafts
drawn on commercial banks by borrowers, usually
in connection with international transactions.
16 Repurchase agreements may be characterized
as loans secured by the underlying securities. The
Fund may enter into repurchase agreements with (i)
member banks of the Federal Reserve System
having total assets in excess of $500 million and (ii)
securities dealers (‘‘Qualified Institutions’’). The
Adviser will monitor the continued
creditworthiness of Qualified Institutions.
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under adverse economic conditions, (e)
fair market value of assets, and (f) other
considerations deemed appropriate.
The Fund, in the absence of normal
market conditions, may invest up to
100% of its total assets in debt securities
that are rated investment grade by an
NRSRO or are unrated securities that the
Sub-Adviser believes are of comparable
quality.
The Fund may invest in securities
that have variable or floating interest
rates which are readjusted on set dates
(such as the last day of the month or
calendar quarter) in the case of variable
rates or whenever a specified interest
rate change occurs in the case of a
floating rate instrument.
The Fund may use delayed delivery
transactions as an investment technique.
Delayed delivery transactions, also
referred to as forward commitments,
involve commitments by the Fund to
dealers or issuers to acquire or sell
securities at a specified future date
beyond the customary settlement for
such securities. These commitments
may fix the payment price and interest
rate to be received or paid on the
investment. The Fund may purchase
securities on a delayed delivery basis to
the extent that it can anticipate having
available cash on the settlement date.
Delayed delivery agreements will not be
used as a speculative or leverage
technique. The Fund also may purchase
when-issued securities.
In addition, the Fund may invest in
zero-coupon or pay-in-kind securities.
These securities are debt securities that
do not make regular cash interest
payments. Zero-coupon securities are
sold at a deep discount to their face
value. Pay-in-kind securities pay
interest through the issuance of
additional securities.
tkelley on DSK3SPTVN1PROD with NOTICES
C. The Exchange’s Description of the
Fund’s Investment Restrictions
The Fund may hold up to an aggregate
of 15% of its net assets in illiquid assets
(calculated at the time of investment),
including Rule 144A securities deemed
illiquid by the Adviser or SubAdviser.17 The Fund will monitor its
17 Rule 144A securities are securities that, while
privately placed, are eligible for purchase and resale
pursuant to Rule 144A under the Securities Act.
This rule permits certain qualified institutional
buyers, such as the Fund, to trade in privately
placed securities even though such securities are
not registered under the Securities Act. The SubAdviser, under supervision of the Board, will
consider whether securities purchased under Rule
144A are illiquid and thus subject to the Fund’s
restriction on illiquid assets. Determination of
whether a Rule 144A security is liquid or not is a
question of fact. In making this determination, the
Sub-Adviser will consider the trading markets for
the specific security taking into account the
unregistered nature of a Rule 144A security. In
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Jkt 235001
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 intends to qualify for and
to elect to be treated as a separate
regulated investment company under
subchapter M of the Internal Revenue
Code. The Exchange further represents
that the Fund’s investments will be
consistent with the Fund’s investment
objective and will not be used to
enhance leverage.18
III. Discussion and Commission
Findings
After careful review, the Commission
finds that the Exchange’s proposal to list
and trade the Shares is consistent with
the Exchange Act and the rules and
regulations thereunder applicable to a
national securities exchange.19 In
particular, the Commission finds that
the proposed rule change, as modified
addition, the Sub-Adviser could consider the (i)
frequency of trades and quotes; (ii) number of
dealers and potential purchasers; (iii) dealer
undertakings to make a market; and (iv) nature of
the security and of market place trades (for
example, the time needed to dispose of the security,
the method of soliciting offers and the mechanics
of transfer). The Sub-Adviser will also monitor the
liquidity of Rule 144A securities, and if, as a result
of changed conditions, the Sub-Adviser determines
that a Rule 144A security is no longer liquid, the
Sub-Adviser will review the Fund’s holdings of
illiquid securities to determine what, if any, action
is required to assure that the Fund complies with
its restriction on investment of illiquid securities.
18 Investments in derivative instruments by the
Fund will be made in accordance with the 1940 Act
and consistent with the Fund’s investment objective
and policies. To limit the potential risk associated
with transactions in derivatives, the Fund will
segregate or ‘‘earmark’’ assets determined to be
liquid by the Adviser in accordance with
procedures that will established by the Trust’s
Board of Trustees (‘‘Board’’) and in accordance with
the 1940 Act (or, as permitted by applicable
regulation, enter into certain offsetting positions) to
cover its obligations under derivative instruments.
These procedures will be 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’s Shares to be
more volatile than if they had not been leveraged.
19 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).
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36383
by Amendment Nos. 1 and 3 thereto, is
consistent with section 6(b)(5) of the
Exchange Act,20 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 also
finds that the proposal to list and trade
the Shares on the Exchange is consistent
with section 11A(a)(1)(C)(iii) of the
Exchange Act,21 which sets forth the
finding of Congress 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 will be available via the
Consolidated Tape Association highspeed line and from the Exchange. The
approximate value of the Fund’s
investments on a per-Share basis, the
Indicative Intra-Day Value (‘‘IIV’’),
which is the Portfolio Indicative Value
as defined in NYSE Arca Equities Rule
8.600(c)(3), will be disseminated by one
or more major market data vendors
every 15 seconds during the Exchange’s
Core Trading Session.22 On each
business day, before commencement of
trading in the Shares in the Core Session
on the Exchange, the Fund will disclose
on its Web site the portfolio that will
form the basis for the Fund’s calculation
of NAV at the end of the business day.23
The NAV per Share will be calculated
by the Custodian and determined as of
the close of the regular trading session
on the New York Stock Exchange
(ordinarily 4:00 p.m., Eastern time)
(‘‘NYSE Close’’) on each day that such
exchange is open. Information regarding
market price and trading volume of the
20 15
U.S.C. 78f(b)(5).
U.S.C. 78k–1(a)(1)(C)(iii).
22 According to the Exchange, several major
market data vendors display or make widely
available IIVs taken from CTA or other data feeds.
23 The Fund will disclose on the Fund’s Web site
the following information regarding each portfolio
holding, as applicable to the type of holding: ticker
symbol, CUSIP number or other identifier, if any;
a description of the holding (including the type of
holding, such as the type of swap); the identity of
the security, commodity, index, or other asset or
instrument underlying the holding, if any; for
options, the option strike price; quantity held (as
measured by, for example, par value, notional
value, or number of shares, contracts or units);
maturity date, if any; coupon rate, if any; effective
date, if any; market value of the holding; and the
percentage weighting of the holding in the Fund’s
portfolio. The Web site information will be publicly
available at no charge.
21 15
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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.
Intra-day and closing price information
regarding exchange-traded options
(including options on futures) and
futures will be available from the
exchange on which such instruments
are traded. Intra-day and closing price
information regarding debt securities,
money market instruments, convertible
securities, structured notes, forward
foreign currency exchange contracts,
swaps, repurchase agreements, reverse
repurchase agreements, US government
securities, MBS and ABS, mortgage
pass-throughs, variable or floating
interest rate securities, when-issued
securities, delayed delivery securities,
zero-coupon securities, and pay-in-kind
securities also will be available from
major market data vendors. Price
information for non-exchange-traded
investment company securities will be
available from major market data
vendors and from the Web site of the
applicable investment company. In
addition, quotation and last-sale
information for exchange-listed options
cleared via the Options Clearing
Corporation will be available via the
Options Price Reporting Authority. The
S&P 500 Index value is available from
major market data vendors.
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. Trading also may be
halted because of market conditions or
for reasons that, in the view of the
Exchange, make trading in the Shares
inadvisable.24 Trading in the Shares also
will be subject to NYSE Arca Equities
24 These may include: (1) the extent to which
trading is not occurring in the securities or the
financial instruments constituting 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.
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16:43 Jun 23, 2015
Jkt 235001
Rule 8.600(d)(2)(D), which sets forth
circumstances under which Shares of
the Fund may be halted. The Exchange
represents that it has a general policy
prohibiting the distribution of material,
non-public information by its
employees. The Adviser is not a
registered broker-dealer, but is affiliated
with a broker-dealer, and has
implemented a ‘‘fire wall’’ with respect
to that broker-dealer regarding access to
information concerning the composition
or changes to the Fund’s portfolio.25
Prior to the commencement of trading,
the Exchange will inform its Equity
Trading Permit Holders (‘‘ETP Holders’’)
in an Information Bulletin (‘‘Bulletin’’)
of the special characteristics and risks
associated with trading the Shares. 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.26
The Exchange represents that it deems
the Shares 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 also made the
following representations:
(1) The Shares will conform to the
initial and continued listing criteria
under NYSE Arca Equities Rule 8.600.
25 See supra note 8. The Exchange represents 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 Adviser, Sub-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 that
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.
26 The Exchange states that FINRA surveils
trading on the Exchange pursuant to a regulatory
services agreement. The Exchange is responsible for
FINRA’s performance under this regulatory services
agreement.
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(2) The Exchange has appropriate
rules to facilitate transactions in the
Shares during all trading sessions.
(3) Trading in the Shares will be
subject to the existing trading
surveillances, administered by FINRA
on behalf of the Exchange, which are
designed to detect violations of
Exchange rules and applicable federal
securities laws, and 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 federal
securities laws applicable to trading on
the Exchange.
(4) FINRA, on behalf of the Exchange,
will communicate as needed regarding
trading in the Shares, other exchangetraded equity securities, exchangetraded investment company securities,
futures contracts, and exchange-traded
options contracts with other market and
other entities that are members of the
Intermarket Surveillance Group (‘‘ISG’’),
and FINRA, on behalf of the Exchange,
may obtain trading information in the
Shares, other exchange-traded equity
securities, exchange-traded investment
company securities, futures contracts,
and exchange-traded options contracts
from those markets and other entities. In
addition, the Exchange may obtain
information regarding trading in the
Shares, other exchange-traded equity
securities, exchange-traded investment
company securities, futures contracts,
and exchange-traded options contracts
from markets and other entities that are
members of ISG or with which the
Exchange has in place a comprehensive
surveillance sharing agreement.27 The
Exchange states that 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 of Shares in the Fund, the
Exchange will inform its ETP Holders in
a Bulletin of the special characteristics
and risks associated with trading the
Shares. Specifically, the Bulletin will
discuss the following: (i) The
procedures for purchases and
redemptions of Shares in Creation Unit
aggregations (and that Shares are not
individually redeemable); (ii) NYSE
Arca Equities Rule 9.2(a), which
imposes a duty of due diligence on its
ETP Holders to learn the essential facts
relating to every customer prior to
27 For a list of the current members of ISG, see
www.isgportal.org. The Exchange notes that not all
components of the Disclosed Portfolio for the Fund
may trade on markets that are members of ISG or
with which the Exchange has in place a
comprehensive surveillance sharing agreement.
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Federal Register / Vol. 80, No. 121 / Wednesday, June 24, 2015 / Notices
trading the Shares; (iii) the risks
involved in trading the Shares during
the Opening and Late Trading Sessions
when an updated IIV or Index value will
not be calculated or publicly
disseminated; (iv) how information
regarding the IIV, the Disclosed
Portfolio, and the Index value will be
disseminated; (v) the requirement that
ETP Holders deliver a prospectus to
investors purchasing newly issued
Shares prior to or concurrently with the
confirmation of a transaction; and (vi)
trading information.
(6) For initial and continued listing,
the Fund will be in compliance with
Rule 10A–3 under the Act,28 as
provided by NYSE Arca Equities Rule
5.3.
(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 restricted securities deemed
illiquid by the Adviser or Sub-Adviser,
consistent with Commission guidance.
(8) The Fund’s investments will be
consistent with its investment objective
and will not be used to enhance
leverage.
(9) To the extent the Fund utilizes
futures and options on futures, the Fund
will utilize U.S. exchange-traded futures
contracts on the S&P 500 Index and U.S.
exchange-traded options on futures
contracts on the S&P 500 Index. To the
extent the Fund enters into swap
agreements, the Fund will enter into
swap agreements based on the S&P 500
Index.
(10) Not more than 20% of the net
assets of the Fund will be invested in
MBS and ABS in the aggregate.
(11) A minimum of 100,000 Shares for
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 Amendment Nos. 1 and
3 to the proposed rule change. The
Commission notes that the Fund and the
Shares must comply with the
requirements of NYSE Arca Equities
Rule 8.600 to be initially and
continuously listed and traded on the
Exchange.
For the foregoing reasons, the
Commission finds that the proposed
rule change, as modified by Amendment
Nos. 1 and 3 thereto, is consistent with
section 6(b)(5) of the Act 29 and the rules
and regulations thereunder applicable to
a national securities exchange.
28 17
29 15
CFR 240.10A–3.
U.S.C. 78f(b)(5).
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IV. Conclusion
It is therefore ordered, pursuant to
section 19(b)(2) of the Exchange Act,30
that the proposed rule change (SR–
NYSEArca–2015–23), as modified by
Amendment Nos. 1 and 3 thereto, be,
and it hereby is, approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.31
Brent J. Fields,
Secretary.
[FR Doc. 2015–15452 Filed 6–23–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–75248; File No. SR–NYSE–
2015–02]
Self-Regulatory Organizations; New
York Stock Exchange LLC; Notice of
Designation of a Longer Period for
Commission Action on Proposed Rule
Change Amending Sections 312.03(b)
and 312.04 of the NYSE Listed
Company Manual To Exempt Early
Stage Companies From Having To
Obtain Shareholder Approval Before
Issuing Shares for Cash to Related
Parties, Affiliates of Related Parties or
Entities In Which a Related Party has
a Substantial Interest
June 18, 2015.
On April 16, 2015, New York Stock
Exchange (‘‘NYSE’’) 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 sections 312.03(b) and 312.04 of
the NYSE Listed Company Manual
(‘‘Manual’’) to exempt early stage
companies 3 from having to obtain
shareholder approval before issuing
shares for cash to related parties,
affiliates of related parties or entities in
which a related party has a substantial
interest. A related party is defined
under section 312.04 of the Manual as
a director, officer or substantial security
holder of a company. The proposed rule
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 The Exchange proposes to define the term
‘‘Early Stage Company’’ to mean ‘‘a company that
has not reported revenues greater than $20 million
in any two consecutive fiscal years since its
incorporation and any Early Stage Company will
lose that designation at any time after listing on the
Exchange that it files an annual report with the SEC
in which it reports two consecutive fiscal years in
which it has revenues greater than $20 million in
each year.’’
36385
change was published for comment in
the Federal Register on May 6, 2015.4
The Commission received no comment
letters on the proposal.
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 June 20, 2015.
The Commission is extending the 45day time period for Commission action
on the proposed rule change. The
Commission finds that it is appropriate
to designate a longer period within
which to take action on the proposed
rule change so that it has sufficient time
to consider the Exchange’s proposal, as
described above.
Accordingly, pursuant to section
19(b)(2) of the Act,6 the Commission
designates August 4, 2015, 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–NYSE–2015–02).
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.7
Brent J. Fields,
Secretary.
[FR Doc. 2015–15456 Filed 6–23–15; 8:45 am]
BILLING CODE 8011–01–P
30 15
31 17
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4 See Securities Exchange Act Release No. 74849
(April 30, 2015), 80 FR 26118.
5 15 U.S.C. 78s(b)(2).
6 15 U.S.C. 78s(b)(2).
7 17 CFR 200.30–3(a)(31).
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Agencies
[Federal Register Volume 80, Number 121 (Wednesday, June 24, 2015)]
[Notices]
[Pages 36380-36385]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-15452]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-75244; File No. SR-NYSEArca-2015-23]
Self-Regulatory Organizations; NYSE Arca, Inc.; Order Granting
Approval of Proposed Rule Change, as Modified by Amendment Nos. 1 and 3
Thereto, Relating to the Listing and Trading of Shares of the ALPS
Enhanced Put Write Strategy ETF Under NYSE Arca Equities Rule 8.600
June 18, 2015.
I. Introduction
On April 15, 2015, NYSE Arca, Inc. (``Exchange'') filed with the
Securities and Exchange Commission (``Commission''), pursuant to
section 19(b)(1) of the Securities Exchange Act of 1934 (``Act'' or
``Exchange Act'') \1\ and Rule 19b-4 thereunder,\2\ a proposed rule
change to list and trade shares (``Shares'') of the ALPS Enhanced Put
Write Strategy ETF (``Fund'') under NYSE Arca Equities Rule 8.600,
which governs the listing and trading of Managed Fund Shares. The
proposed rule change was published for comment in the Federal Register
on May 5, 2015.\3\ On May 12, 2015, the Exchange filed Amendment No. 1
to the proposed rule change.\4\ On May 19, 2015, the Exchange filed
Amendment No. 2 to the proposed rule change, but withdrew that
amendment on May 20, 2015.\5\ On May 20, 2015, the Exchange filed
Amendment No. 3 to the proposed rule change.\6\ The Commission received
no
[[Page 36381]]
comments on the proposal, as modified by Amendment Nos. 1 and 3
thereto. This order grants approval of the proposed rule change, as
modified by Amendment Nos. 1 and 3 thereto.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 74839 (Apr. 29,
2015), 80 FR 25729 (``Notice'').
\4\ Amendment No. 1 to the proposed rule change replaced and
superseded the original filing in its entirety.
\5\ The Exchange withdrew Amendment No. 2 to the proposed rule
change due to certain errors.
\6\ Amendment No. 3 to the proposed rule change corrected
typographical errors and clarified that any futures and options on
futures utilized by the Fund will be U.S. exchange-traded futures
contracts on the S&P 500 Index and U.S. exchange-traded options on
futures contracts on the S&P 500 Index. Amendment Nos. 1 and 3 are
available at: https://www.sec.gov/comments/sr-nysearca-2015-23/nysearca201523.shtml.
---------------------------------------------------------------------------
II. Description of the Proposal
NYSE Arca 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 on the Exchange. The Shares will be offered by ALPS
ETF Trust (``Trust''), which is registered with the Commission as an
investment company.\7\ ALPS Advisors, Inc. is the investment adviser
(``Adviser'') to the Fund.\8\ Rich Investment Solutions, LLC is the
investment sub-adviser (``Sub-Adviser'') to the Fund. ALPS Fund
Services, Inc. serves as the Trust's administrator, and The Bank of New
York Mellon serves as custodian (``Custodian'') and transfer agent for
the Fund. ALPS Portfolio Solutions Distributor, Inc. is the distributor
of the Fund's Shares.
---------------------------------------------------------------------------
\7\ The Trust is registered under the Investment Company Act of
1940 (``1940 Act''). The Exchange states that the Trust filed with
the Commission a 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. 333-148826 and 811-22175)
(``Registration Statement'') on January 6, 2015. In addition, the
Exchange represents that the Trust has obtained certain exemptive
relief under the1940 Act. See Investment Company Act Release No.
30553 (June 11, 2013) (File No. 812-13884).
\8\ The Exchange represents that the Adviser is not a registered
broker-dealer, but is affiliated with a broker-dealer and has
implemented a ``fire wall'' with respect to that broker-dealer
regarding access to information concerning the composition of or
changes to the Fund's portfolio. The Exchange further represents
that, in the event (a) the Adviser or any sub-adviser becomes
registered as a broker-dealer or newly affiliated with a broker-
dealer, or (b) any new adviser or sub-adviser is a registered
broker-dealer or becomes affiliated with a broker-dealer, the
Adviser or any new adviser or sub-adviser, as the case may be, will
implement a fire wall with respect to its 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.
---------------------------------------------------------------------------
The Exchange has made the following representations and statements
in describing the Fund and its investment strategy, including the
Fund's portfolio holdings and investment restrictions.\9\
---------------------------------------------------------------------------
\9\ The Commission notes that additional information regarding
the Fund, the Trust, and the Shares, including investment
strategies, risks, creation and redemption procedures, fees,
portfolio holdings disclosure policies, calculation of net asset
value (``NAV''), distributions, and taxes, among other things, can
be found in the Notice and the Registration Statement, as
applicable. See Notice and Registration Statement, supra notes 3 and
7, respectively.
---------------------------------------------------------------------------
A. The Exchange's Description of the Fund's Principal Investment
Policies
According to the Exchange, the investment objective of the Fund is
to seek total return, with an emphasis on income as the source of that
total return. The Fund will seek to achieve its investment objective by
selling listed one-month put options on the SPDR[supreg] S&P
500[supreg] ETF Trust (``SPY''). SPY is an exchange-traded fund that
seeks to provide investment results that, before expenses, correspond
generally to the price and yield performance of the S&P 500[supreg]
Index (``SPX'' or ``Index''). SPY holds a portfolio of the common
stocks that are included in the SPX, with the weight of each stock in
its portfolio substantially corresponding to the weight of that stock
in the SPX. The Fund may also sell listed one-month put options
directly on the SPX under certain circumstances (such as if those
options have more liquidity and narrower spreads than options on SPY).
SPY shares are listed on the Exchange and traded on national securities
exchanges. SPX options are traded on the Chicago Board Options
Exchange, and options on SPY are traded on national securities
exchanges.
Each listed put option sold by the Fund will be an ``American-
style'' option (i.e., an option that can be exercised at the strike
price at any time prior to its expiration). As the seller of a listed
put option, the Fund will incur an obligation to buy SPY underlying the
option from the purchaser of the option at the option's strike price,
upon exercise by the option purchaser. If a listed put option sold by
the Fund is exercised prior to expiration, the Fund will buy the SPY
underlying the option at the time of exercise and at the strike price,
and will hold SPY until the market close on expiration.\10\
---------------------------------------------------------------------------
\10\ The Fund may also sell put options on the SPX directly
under certain circumstances (such as if such options have more
liquidity and narrower spreads than options on SPY) resulting in
lower transaction costs than options on SPY. The puts are struck at-
the-money (i.e., with a strike price that is equal to the market
price of the underlying SPY) and are typically sold on a monthly
basis, usually on the third Friday of the month (the ``roll date'').
---------------------------------------------------------------------------
The option premiums and cash (in respect of orders to create Shares
in large aggregations known as ``Creation Units,'' as further described
below) received by the Fund will be invested in an actively-managed
portfolio of investment grade debt securities (``Collateral
Portfolio'') at least equal in value to the Fund's maximum liability
under its written options (i.e., the strike price of each option).
Investment grade debt securities are those rated ``Baa'' equivalent or
higher by a nationally recognized statistical rating organization
(``NRSROs''), or are unrated securities that the Sub-Adviser believes
are of comparable quality. These investment grade debt securities will
include Treasury bills (short-term U.S. government debt securities),
corporate bonds, commercial paper, mortgage-backed securities
(``MBS''), asset-backed securities (``ABS''), and notes issued or
guaranteed by federal agencies or U.S. government sponsored
instrumentalities, such as the Government National Mortgage
Administration, the Federal Housing Administration, the Federal
National Mortgage Association, and the Federal Home Loan Mortgage
Corporation. It is expected that the average duration of these
securities will not exceed six months, and the maximum maturity of any
single security will not exceed one year.
Under normal market conditions,\11\ substantially all of the Fund's
net assets will be invested in options on SPY or SPX and in the
Collateral Portfolio.
---------------------------------------------------------------------------
\11\ The term ``under normal market conditions'' includes, but
is not limited to, the absence of extreme volatility or trading
halts in the equity, options or fixed income markets or the
financial markets generally; events or circumstances causing a
disruption in market liquidity or orderly markets; 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.
---------------------------------------------------------------------------
The Fund may invest up to 20% of its net assets in non-agency MBS
and ABS in the aggregate. The Fund may seek to obtain exposure to U.S.
agency mortgage pass-through securities primarily through the use of
``to-be-announced'' or ``TBA transactions.'' According to the Exchange,
``TBA'' refers to a commonly used mechanism for the forward settlement
of U.S. agency mortgage pass-through securities and not to a separate
type of mortgage-backed security. Most transactions in mortgage pass-
through securities occur through the use of TBA transactions. TBA
transactions are generally conducted in accordance with widely-accepted
guidelines that establish commonly observed terms and conditions for
execution, settlement and delivery. In a TBA transaction, the buyer and
seller decide on general trade parameters, such as agency, settlement
date, par amount, and price. The actual pools delivered are generally
determined two days prior to settlement date. The Fund will enter into
TBA transactions only with established counterparties (such as major
broker-dealers) and the Sub-Adviser will
[[Page 36382]]
monitor the creditworthiness of such counterparties.\12\
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\12\ The Fund intends to invest cash pending settlement of any
TBA transactions in money market instruments, repurchase agreements,
commercial paper (including asset-backed commercial paper), or other
high-quality, liquid short-term instruments, which may include money
market funds affiliated with the Adviser or Sub-Adviser.
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According to the Exchange, every month, the options sold by the
Fund will be settled by delivery at expiration or will expire with no
value, and new option positions will be established while the Fund
sells any units of SPY it owns as a result of such settlements or of
the Fund's prior option positions having been exercised. \13\ The
Exchange states that this monthly cycle likely will cause the Fund to
have frequent and substantial turnover in its option positions. If the
Fund receives additional inflows (and issues more Shares in ``Creation
Unit'' size during a one-month period), the Fund will sell additional
listed put options, which will be exercised or expire at the end of
such one-month period. Conversely, if the Fund redeems Shares in
Creation Unit size during a monthly period, the Fund will terminate the
appropriate portion of the options it has sold.
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\13\ The Fund may hold U.S. exchange-listed equity securities,
generally shares of SPY, for temporary periods upon settlement or
exercise of the options sold by the Fund.
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With respect to no more than 20% of the Fund's assets, the Fund may
engage in certain opportunistic ``put spread'' and ``call spread''
strategies. Specifically, when the Sub-Adviser believes the SPX (and
thus SPY) will rise or not decline in value, the Fund may engage in
``put spreads'' whereby the Fund will buy back certain of the written
put options that are out of the money (i.e., the strike price of the
put option is lower than the market price of the underlying SPY) prior
to expiration in order to sell new put options that are less out of the
money. Similarly, the Fund may buy back certain of its written put
options prior to expiration in order to sell new longer-dated options
that will remain open past the one-month period of the original option.
Conversely, when the Sub-Adviser believes the SPX will decline in
value, the Fund may engage in ``call spreads'' whereby the Fund will
sell call options that are in-the-money (i.e., the strike price of the
call option is lower than the market price of the underlying SPY) and
buy back less in-the-money call options. The Sub-Adviser may employ a
variant of this call spread strategy whereby the Fund buys more calls
than it sells (as long as the Fund receives a net premium on the
transactions). This may enable the Fund to perform better when the SPX
(and thus SPY) experiences gains well above the strike price of the
calls bought by the Fund. However, even if the Fund engages in such
call spreads, a declining SPX (and thus SPY) will significantly detract
from Fund performance (given the Fund's principal strategy of selling
put options on SPY).
B. The Exchange's Description of the Fund's Non-Principal Investment
Policies
While, under normal market conditions, substantially all of the
Fund's net assets will be invested in options on SPY or SPX and in the
Collateral Portfolio, the Fund may invest its remaining assets in other
securities and financial instruments, as described below. The Fund may
invest its remaining assets in any one or more of the following
instruments: money market instruments (as described below), in addition
to those in which the Fund invests as part of the Collateral Portfolio,
and including repurchase agreements or other funds that invest
exclusively in money market instruments; convertible securities;
structured notes (notes on which the amount of principal repayment and
interest payments are based on the movement of one or more specified
factors, such as the movement of a particular stock or stock index);
forward foreign currency exchange contracts; swaps; over-the-counter
(``OTC'') options on SPY or on the S&P 500 Index; and futures contracts
and options on futures contracts, as described further below. Swaps,
options, and futures contracts may be used by the Fund in seeking to
achieve its investment objective and in managing cash flows. The Fund
may also invest in money market instruments or other short-term fixed
income instruments as part of a temporary defensive strategy to protect
against temporary market declines.
The Fund may invest in high-quality money market instruments on an
ongoing basis to provide liquidity. The instruments in which the Fund
may invest include: (i) Short-term obligations issued by the U.S.
Government; \14\ (ii) negotiable certificates of deposit (``CDs''),
fixed time deposits, and bankers' acceptances of U.S. and foreign banks
and similar institutions; \15\ (iii) commercial paper rated at the date
of purchase ``Prime-1'' by Moody's Investors Service, Inc. or ``A-1+''
or ``A-1'' by Standard & Poor's or, if unrated, of comparable quality
as determined by the Adviser; (iv) repurchase agreements; \16\ and (v)
money market mutual funds.
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\14\ Obligations issued or guaranteed by the U.S. Government,
its agencies and instrumentalities include bills, notes, and bonds
issued by the U.S. Treasury, as well as ``stripped'' or ``zero
coupon'' U.S. Treasury obligations representing future interest or
principal payments on U.S. Treasury notes or bonds.
\15\ CDs are short-term negotiable obligations of commercial
banks. Time deposits are non-negotiable deposits maintained in
banking institutions for specified periods of time at stated
interest rates. Banker's acceptances are time drafts drawn on
commercial banks by borrowers, usually in connection with
international transactions.
\16\ Repurchase agreements may be characterized as loans secured
by the underlying securities. The Fund may enter into repurchase
agreements with (i) member banks of the Federal Reserve System
having total assets in excess of $500 million and (ii) securities
dealers (``Qualified Institutions''). The Adviser will monitor the
continued creditworthiness of Qualified Institutions.
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The Fund may enter into reverse repurchase agreements, which
involve the sale of securities with an agreement to repurchase the
securities at an agreed-upon price, date, and interest payment and have
the characteristics of borrowing. The securities purchased with the
funds obtained from the agreement and securities collateralizing the
agreement will have maturity dates no later than the repayment date.
The Fund may invest in the securities of other investment companies
(including money market funds), subject to applicable restrictions
under the 1940 Act.
To the extent the Fund utilizes futures and options on futures, the
Fund will utilize U.S. exchange-traded futures contracts on the S&P 500
Index and U.S. exchange-traded options on futures contracts on the S&P
500 Index. The Fund may utilize such options on futures contracts as a
hedge against changes in value of its portfolio securities, or in
anticipation of the purchase of securities, and may enter into closing
transactions with respect to such options to terminate existing
positions.
To the extent the Fund enters into swap agreements, the Fund will
enter into swap agreements based on the S&P 500 Index.
The Fund may invest in investment grade debt obligations traded in
the U.S. Such debt obligations include, among others, bonds, notes,
debentures, and variable rate demand notes. In choosing corporate debt
securities on behalf of the Fund, the Sub-Adviser may consider (i)
general economic and financial conditions; and (ii) the specific
issuer's (a) business and management, (b) cash flow, (c) earnings
coverage of interest and dividends, (d) ability to operate
[[Page 36383]]
under adverse economic conditions, (e) fair market value of assets, and
(f) other considerations deemed appropriate.
The Fund, in the absence of normal market conditions, may invest up
to 100% of its total assets in debt securities that are rated
investment grade by an NRSRO or are unrated securities that the Sub-
Adviser believes are of comparable quality.
The Fund may invest in securities that have variable or floating
interest rates which are readjusted on set dates (such as the last day
of the month or calendar quarter) in the case of variable rates or
whenever a specified interest rate change occurs in the case of a
floating rate instrument.
The Fund may use delayed delivery transactions as an investment
technique. Delayed delivery transactions, also referred to as forward
commitments, involve commitments by the Fund to dealers or issuers to
acquire or sell securities at a specified future date beyond the
customary settlement for such securities. These commitments may fix the
payment price and interest rate to be received or paid on the
investment. The Fund may purchase securities on a delayed delivery
basis to the extent that it can anticipate having available cash on the
settlement date. Delayed delivery agreements will not be used as a
speculative or leverage technique. The Fund also may purchase when-
issued securities.
In addition, the Fund may invest in zero-coupon or pay-in-kind
securities. These securities are debt securities that do not make
regular cash interest payments. Zero-coupon securities are sold at a
deep discount to their face value. Pay-in-kind securities pay interest
through the issuance of additional securities.
C. The Exchange's Description of the Fund's Investment Restrictions
The Fund may hold up to an aggregate of 15% of its net assets in
illiquid assets (calculated at the time of investment), including Rule
144A securities deemed illiquid by the Adviser or Sub-Adviser.\17\ 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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\17\ Rule 144A securities are securities that, while privately
placed, are eligible for purchase and resale pursuant to Rule 144A
under the Securities Act. This rule permits certain qualified
institutional buyers, such as the Fund, to trade in privately placed
securities even though such securities are not registered under the
Securities Act. The Sub-Adviser, under supervision of the Board,
will consider whether securities purchased under Rule 144A are
illiquid and thus subject to the Fund's restriction on illiquid
assets. Determination of whether a Rule 144A security is liquid or
not is a question of fact. In making this determination, the Sub-
Adviser will consider the trading markets for the specific security
taking into account the unregistered nature of a Rule 144A security.
In addition, the Sub-Adviser could consider the (i) frequency of
trades and quotes; (ii) number of dealers and potential purchasers;
(iii) dealer undertakings to make a market; and (iv) nature of the
security and of market place trades (for example, the time needed to
dispose of the security, the method of soliciting offers and the
mechanics of transfer). The Sub-Adviser will also monitor the
liquidity of Rule 144A securities, and if, as a result of changed
conditions, the Sub-Adviser determines that a Rule 144A security is
no longer liquid, the Sub-Adviser will review the Fund's holdings of
illiquid securities to determine what, if any, action is required to
assure that the Fund complies with its restriction on investment of
illiquid securities.
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The Fund intends to qualify for and to elect to be treated as a
separate regulated investment company under subchapter M of the
Internal Revenue Code. The Exchange further represents that the Fund's
investments will be consistent with the Fund's investment objective and
will not be used to enhance leverage.\18\
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\18\ Investments in derivative instruments by the Fund will be
made in accordance with the 1940 Act and consistent with the Fund's
investment objective and policies. To limit the potential risk
associated with transactions in derivatives, the Fund will segregate
or ``earmark'' assets determined to be liquid by the Adviser in
accordance with procedures that will established by the Trust's
Board of Trustees (``Board'') and in accordance with the 1940 Act
(or, as permitted by applicable regulation, enter into certain
offsetting positions) to cover its obligations under derivative
instruments. These procedures will be 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's
Shares to be more volatile than if they had not been leveraged.
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III. Discussion and Commission Findings
After careful review, the Commission finds that the Exchange's
proposal to list and trade the Shares is consistent with the Exchange
Act and the rules and regulations thereunder applicable to a national
securities exchange.\19\ In particular, the Commission finds that the
proposed rule change, as modified by Amendment Nos. 1 and 3 thereto, is
consistent with section 6(b)(5) of the Exchange Act,\20\ 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 also finds that the proposal to list and trade
the Shares on the Exchange is consistent with section 11A(a)(1)(C)(iii)
of the Exchange Act,\21\ which sets forth the finding of Congress 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.
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\19\ 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).
\20\ 15 U.S.C. 78f(b)(5).
\21\ 15 U.S.C. 78k-1(a)(1)(C)(iii).
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Quotation and last-sale information for the Shares will be
available via the Consolidated Tape Association high-speed line and
from the Exchange. The approximate value of the Fund's investments on a
per-Share basis, the Indicative Intra-Day Value (``IIV''), which is the
Portfolio Indicative Value as defined in NYSE Arca Equities Rule
8.600(c)(3), will be disseminated by one or more major market data
vendors every 15 seconds during the Exchange's Core Trading
Session.\22\ On each business day, before commencement of trading in
the Shares in the Core Session on the Exchange, the Fund will disclose
on its Web site the portfolio that will form the basis for the Fund's
calculation of NAV at the end of the business day.\23\
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\22\ According to the Exchange, several major market data
vendors display or make widely available IIVs taken from CTA or
other data feeds.
\23\ The Fund will disclose on the Fund's Web site the following
information regarding each portfolio holding, as applicable to the
type of holding: ticker symbol, CUSIP number or other identifier, if
any; a description of the holding (including the type of holding,
such as the type of swap); the identity of the security, commodity,
index, or other asset or instrument underlying the holding, if any;
for options, the option strike price; quantity held (as measured by,
for example, par value, notional value, or number of shares,
contracts or units); maturity date, if any; coupon rate, if any;
effective date, if any; market value of the holding; and the
percentage weighting of the holding in the Fund's portfolio. The Web
site information will be publicly available at no charge.
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The NAV per Share will be calculated by the Custodian and
determined as of the close of the regular trading session on the New
York Stock Exchange (ordinarily 4:00 p.m., Eastern time) (``NYSE
Close'') on each day that such exchange is open. Information regarding
market price and trading volume of the
[[Page 36384]]
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. Intra-day and closing price
information regarding exchange-traded options (including options on
futures) and futures will be available from the exchange on which such
instruments are traded. Intra-day and closing price information
regarding debt securities, money market instruments, convertible
securities, structured notes, forward foreign currency exchange
contracts, swaps, repurchase agreements, reverse repurchase agreements,
US government securities, MBS and ABS, mortgage pass-throughs, variable
or floating interest rate securities, when-issued securities, delayed
delivery securities, zero-coupon securities, and pay-in-kind securities
also will be available from major market data vendors. Price
information for non-exchange-traded investment company securities will
be available from major market data vendors and from the Web site of
the applicable investment company. In addition, quotation and last-sale
information for exchange-listed options cleared via the Options
Clearing Corporation will be available via the Options Price Reporting
Authority. The S&P 500 Index value is available from major market data
vendors.
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. Trading also may be halted because of market
conditions or for reasons that, in the view of the Exchange, make
trading in the Shares inadvisable.\24\ Trading in the Shares also will
be subject to NYSE Arca Equities Rule 8.600(d)(2)(D), which sets forth
circumstances under which Shares of the Fund may be halted. The
Exchange represents that it has a general policy prohibiting the
distribution of material, non-public information by its employees. The
Adviser is not a registered broker-dealer, but is affiliated with a
broker-dealer, and has implemented a ``fire wall'' with respect to that
broker-dealer regarding access to information concerning the
composition or changes to the Fund's portfolio.\25\ Prior to the
commencement of trading, the Exchange will inform its Equity Trading
Permit Holders (``ETP Holders'') in an Information Bulletin
(``Bulletin'') of the special characteristics and risks associated with
trading the Shares. 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.\26\
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\24\ These may include: (1) the extent to which trading is not
occurring in the securities or the financial instruments
constituting 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.
\25\ See supra note 8. The Exchange represents 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 Adviser, Sub-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 that 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.
\26\ The Exchange states that FINRA surveils trading on the
Exchange pursuant to a regulatory services agreement. The Exchange
is responsible for FINRA's performance under this regulatory
services agreement.
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The Exchange represents that it deems the Shares 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 also made the following
representations:
(1) The Shares will conform to the initial and continued listing
criteria under NYSE Arca Equities Rule 8.600.
(2) The Exchange has appropriate rules to facilitate transactions
in the Shares during all trading sessions.
(3) Trading in the Shares will be subject to the existing trading
surveillances, administered by FINRA on behalf of the Exchange, which
are designed to detect violations of Exchange rules and applicable
federal securities laws, and 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 federal securities
laws applicable to trading on the Exchange.
(4) FINRA, on behalf of the Exchange, will communicate as needed
regarding trading in the Shares, other exchange-traded equity
securities, exchange-traded investment company securities, futures
contracts, and exchange-traded options contracts with other market and
other entities that are members of the Intermarket Surveillance Group
(``ISG''), and FINRA, on behalf of the Exchange, may obtain trading
information in the Shares, other exchange-traded equity securities,
exchange-traded investment company securities, futures contracts, and
exchange-traded options contracts from those markets and other
entities. In addition, the Exchange may obtain information regarding
trading in the Shares, other exchange-traded equity securities,
exchange-traded investment company securities, futures contracts, and
exchange-traded options contracts from markets and other entities that
are members of ISG or with which the Exchange has in place a
comprehensive surveillance sharing agreement.\27\ The Exchange states
that 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.
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\27\ For a list of the current members of ISG, see
www.isgportal.org. The Exchange notes that not all components of the
Disclosed Portfolio for the Fund may trade on markets that are
members of ISG or with which the Exchange has in place a
comprehensive surveillance sharing agreement.
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(5) Prior to the commencement of trading of Shares in the Fund, the
Exchange will inform its ETP Holders in a Bulletin of the special
characteristics and risks associated with trading the Shares.
Specifically, the Bulletin will discuss the following: (i) The
procedures for purchases and redemptions of Shares in Creation Unit
aggregations (and that Shares are not individually redeemable); (ii)
NYSE Arca Equities Rule 9.2(a), which imposes a duty of due diligence
on its ETP Holders to learn the essential facts relating to every
customer prior to
[[Page 36385]]
trading the Shares; (iii) the risks involved in trading the Shares
during the Opening and Late Trading Sessions when an updated IIV or
Index value will not be calculated or publicly disseminated; (iv) how
information regarding the IIV, the Disclosed Portfolio, and the Index
value will be disseminated; (v) the requirement that ETP Holders
deliver a prospectus to investors purchasing newly issued Shares prior
to or concurrently with the confirmation of a transaction; and (vi)
trading information.
(6) For initial and continued listing, the Fund will be in
compliance with Rule 10A-3 under the Act,\28\ as provided by NYSE Arca
Equities Rule 5.3.
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\28\ 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 restricted securities deemed illiquid by the
Adviser or Sub-Adviser, consistent with Commission guidance.
(8) The Fund's investments will be consistent with its investment
objective and will not be used to enhance leverage.
(9) To the extent the Fund utilizes futures and options on futures,
the Fund will utilize U.S. exchange-traded futures contracts on the S&P
500 Index and U.S. exchange-traded options on futures contracts on the
S&P 500 Index. To the extent the Fund enters into swap agreements, the
Fund will enter into swap agreements based on the S&P 500 Index.
(10) Not more than 20% of the net assets of the Fund will be
invested in MBS and ABS in the aggregate.
(11) A minimum of 100,000 Shares for 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
Amendment Nos. 1 and 3 to the proposed rule change. The Commission
notes that the Fund and the Shares must comply with the requirements of
NYSE Arca Equities Rule 8.600 to be initially and continuously listed
and traded on the Exchange.
For the foregoing reasons, the Commission finds that the proposed
rule change, as modified by Amendment Nos. 1 and 3 thereto, is
consistent with section 6(b)(5) of the Act \29\ and the rules and
regulations thereunder applicable to a national securities exchange.
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\29\ 15 U.S.C. 78f(b)(5).
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IV. Conclusion
It is therefore ordered, pursuant to section 19(b)(2) of the
Exchange Act,\30\ that the proposed rule change (SR-NYSEArca-2015-23),
as modified by Amendment Nos. 1 and 3 thereto, be, and it hereby is,
approved.
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\30\ 15 U.S.C. 78s(b)(2).
\31\ 17 CFR 200.30-3(a)(12).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\31\
Brent J. Fields,
Secretary.
[FR Doc. 2015-15452 Filed 6-23-15; 8:45 am]
BILLING CODE 8011-01-P