Self-Regulatory Organizations; BATS Exchange, Inc.; Notice of Filing of a Proposed Rule Change to Rule 14.11(i), Managed Fund Shares, To List and Trade the Shares of the Elkhorn S&P GSCI Dynamic Roll Commodity ETF of Elkhorn ETF Trust, 120-129 [2015-32986]
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120
Federal Register / Vol. 81, No. 1 / Monday, January 4, 2016 / Notices
it accounts for the rate that BATS
Trading would be subject to for orders
it routes and are executed on EDGA,
BYX, and BZX. In addition, the proposal
allows the Exchange to pass-through to
its Members the rate for orders that are
routed to EDGA, BYX, and BZX using
the ALLB routing strategy. Furthermore,
the Exchange notes that routing through
BATS Trading is voluntary. Lastly, the
Exchange also believes that the
proposed amendment is nondiscriminatory because it applies
uniformly to all Members.
B. Self-Regulatory Organization’s
Statement on Burden on Competition
tkelley on DSK3SPTVN1PROD with NOTICES
This proposed rule change does not
impose any burden on competition that
is not necessary or appropriate in
furtherance of the purposes of the Act.
The Exchange does not believe that this
change represents a significant
departure from previous pricing offered
by the Exchange or pricing offered by
the Exchange’s competitors.
Additionally, Members may opt to
disfavor the Exchange’s pricing if they
believe that alternatives offer them
better value. Accordingly, the Exchange
does not believe that the proposed
changes will impair the ability of
Members or competing venues to
maintain their competitive standing in
the financial markets. The Exchange
believes that its proposal to pass
through the rates that BATS Trading
would be subject to for orders routing to
EDGA, BYX, and BZX using the ALLB
routing strategy to Members would
increase intermarket competition
because it offers customers an
alternative means to route orders to
those venues. In addition, the proposed
pricing would not provide any
advantage to Users when routing to
EDGA, BYX or BYX as compared to
other methods of routing or connectivity
available to Users by the Exchange
because the proposed rates are identical
to what the Member would be subject to
if it routed to those venues directly. The
Exchange believes that its proposal
would not burden intramarket
competition because the proposed rate
would apply uniformly to all Members.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants or Others
The Exchange has not solicited, and
does not intend to solicit, comments on
this proposed rule change. The
Exchange has not received any written
comments from members or other
interested parties.
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16:43 Dec 31, 2015
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III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change has become
effective pursuant to Section 19(b)(3)(A)
of the Act 14 and paragraph (f) of Rule
19b–4 thereunder.15 At any time within
60 days of the filing of the proposed rule
change, the Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is necessary or appropriate in the
public interest, for the protection of
investors, or otherwise in furtherance of
the purposes of the Act.
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 No. SR–
EDGX–2015–61 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 No.
SR–EDGX–2015–61. 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 such
filing will also 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
should refer to File No. SR–EDGX–
2015–61 and should be submitted on or
before January 25, 2016.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.16
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2015–32988 Filed 12–31–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–76776; File No. SR–BATS–
2015–105]
Self-Regulatory Organizations; BATS
Exchange, Inc.; Notice of Filing of a
Proposed Rule Change to Rule 14.11(i),
Managed Fund Shares, To List and
Trade the Shares of the Elkhorn S&P
GSCI Dynamic Roll Commodity ETF of
Elkhorn ETF Trust
December 28, 2015.
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 December
18, 2015, BATS Exchange, Inc. (the
‘‘Exchange’’ or ‘‘BATS’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I, II and III
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.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange is proposing a rule
change to list and trade the shares of the
Elkhorn S&P GSCI Dynamic Roll
Commodity ETF (the ‘‘Fund’’) of
Elkhorn ETF Trust (the ‘‘Trust’’) under
BATS Rule 14.11(i) (‘‘Managed Fund
Shares’’). The shares of the Fund are
collectively referred to herein as (the
‘‘Shares’’).
The text of the proposed rule change
is available at the Exchange’s Web site
at www.batstrading.com, at the
principal office of the Exchange, and at
16 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
14 15
U.S.C. 78s(b)(3)(A).
15 17 CFR 240.19b–4(f).
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Federal Register / Vol. 81, No. 1 / Monday, January 4, 2016 / Notices
the Commission’s Public Reference
Room.
of the Cayman Islands (referred to
herein as the ‘‘Subsidiary’’).
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
Description of the Shares and the Fund
Elkhorn Investments, LLC will be the
investment adviser (the ‘‘Adviser’’) to
the Fund and will monitor the Fund’s
investment portfolio. It is currently
anticipated that day-to-day portfolio
management for the Fund will be
provided by the Adviser. However, the
Fund and the Adviser may contract with
an investment sub-adviser (a ‘‘SubAdviser’’) to provide day-to-day
portfolio management for the Fund.
ALPS Distributors, Inc. (the
‘‘Distributor’’) will be the principal
underwriter and distributor of the
Fund’s Shares. The Fund will contract
with unaffiliated third parties to provide
administrative, custodial and transfer
agency services to the Fund.
Rule 14.11(i)(7) provides that, if the
investment adviser to the investment
company issuing Managed Fund Shares
is affiliated with a broker-dealer, such
investment adviser shall erect a ‘‘fire
wall’’ between the investment adviser
and the broker-dealer with respect to
access to information concerning the
composition and/or changes to such
investment company portfolio.6 In
addition, Rule 14.11(i)(7) further
requires that personnel who make
decisions on the investment company’s
portfolio composition must be subject to
procedures designed to prevent the use
and dissemination of material, nonpublic information regarding the
applicable investment company
portfolio. Rule 14.11(i)(7) is similar to
BATS Rule 14.11(b)(5)(A)(i), however,
Rule 14.11(i)(7) in connection with the
establishment of a ‘‘fire wall’’ between
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
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 parts of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
tkelley on DSK3SPTVN1PROD with NOTICES
The Exchange proposes to list and
trade the Shares under BATS Rule
14.11(i), which governs the listing and
trading of Managed Fund Shares on the
Exchange.3 The Fund will be an actively
managed fund. The Shares will be
offered by the Trust, which was
established as a Massachusetts business
trust on December 12, 2013.4 The Trust
is registered with the Commission as an
open-end investment company and has
filed a registration statement on behalf
of the Fund on Form N–1A
(‘‘Registration Statement’’) with the
Commission.5 The Fund will be a series
of the Trust. The Fund will invest in,
among other things, exchange-traded
commodity futures contracts and
exchange-traded commodity-linked
instruments held indirectly through a
wholly-owned subsidiary controlled by
the Fund and organized under the laws
3 The Commission approved BATS Rule 14.11(i)
in Securities Exchange Act Release No. 65225
(August 30, 2011), 76 FR 55148 (September 6, 2011)
(SR–BATS–2011–018).
4 The Trust has obtained from the Commission an
order granting certain exemptive relief to the Trust
under the 1940 Act (File No. 812–14262). In
compliance with BATS Rule 14.11(i)(2)(E), which
applies to Managed Fund Shares based on an
international or global portfolio, the Trust’s
application for exemptive relief under the 1940 Act
states that the Fund will comply with the federal
securities laws in accepting securities for deposits
and satisfying redemptions with redemption
securities, including that the securities accepted for
deposits and the securities used to satisfy
redemption requests are sold in transactions that
would be exempt from registration under the
Securities Act of 1933 (15 U.S.C. 77a).
5 See Registration Statement on Form N–1A for
the Trust, dated November 10, 2015 (File Nos. 333–
201473 and 811–22926). The descriptions of the
Fund and the Shares contained herein are based, in
part, on information in the Registration Statement.
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16:43 Dec 31, 2015
Jkt 238001
6 An investment adviser to an open-end fund is
required to be registered under the Investment
Advisers Act of 1940 (the ‘‘Advisers Act’’). As a
result, the Adviser and any 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 such
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.
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121
the investment adviser and the brokerdealer reflects the applicable open-end
fund’s portfolio, not an underlying
benchmark index, as is the case with
index-based funds. The Adviser is not a
broker-dealer, although it is affiliated
with a broker-dealer. The Adviser has
implemented a fire wall with respect to
its broker-dealer affiliate regarding
access to information concerning the
composition and/or changes to the
Fund’s portfolio. In addition, personnel
who make decisions regarding the
Fund’s portfolio composition will be
subject to procedures designed to
prevent the use and dissemination of
material non-public information
regarding the Fund’s portfolio. In the
event that (a) the Adviser or a SubAdviser becomes, or becomes newly
affiliated with, a broker-dealer or
registers as a broker-dealer, or (b) any
new adviser or sub-adviser is a
registered broker-dealer or becomes
affiliated with a broker-dealer, it will
implement a fire wall with respect to its
relevant personnel and/or such brokerdealer affiliate, as applicable, regarding
access to information concerning the
composition and/or changes to the
portfolio and will be subject to
procedures designed to prevent the use
and dissemination of material nonpublic information regarding such
portfolio.
Elkhorn S&P GSCI Dynamic Roll
Commodity ETF Portfolio
According to the Registration
Statement, the Fund’s investment
objective will be to provide total return
which exceeds that of the S&P GSCI
Dynamic Roll Index (the
‘‘Benchmark’’) 7 consistent with prudent
investment management. The Fund will
seek excess return above the Benchmark
through the active management of a
short duration portfolio of highly liquid,
high quality bonds.
The Fund will be an actively managed
fund that seeks to achieve its investment
objective by, under normal market
conditions,8 investing in exchangetraded commodity futures contracts,
centrally cleared and non-centrally
7 The Benchmark is developed, maintained and
sponsored by S&P Dow Jones Indices LLC (‘‘S&P
Indices’’).
8 The term ‘‘under normal market conditions’’
includes, but is not limited to, the absence of
extreme volatility or trading halts in the fixed
income markets, futures markets or the financial
markets generally; operational issues causing
dissemination of inaccurate market information; or
force majeure type events such as systems failure,
natural or man-made disaster, act of God, armed
conflict, act of terrorism, riot or labor disruption or
any similar intervening circumstance.
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tkelley on DSK3SPTVN1PROD with NOTICES
cleared swaps,9 exchange-traded
options on futures contracts and
exchange-traded commodity-linked
instruments 10 (collectively,
‘‘Commodities’’) through the Subsidiary,
thereby obtaining exposure to the
commodities markets, and directly
investing, as further described below, in
short-term investment grade fixed
income securities, money market
instruments, exchange-traded and nonexchange-traded investment companies,
certain bank instruments, and cash and
other cash equivalents.
The Fund’s Commodities
investments, in part, will be comprised
of exchange-traded futures contracts on
commodities that comprise the
Benchmark. Although the Fund,
through the Subsidiary, will generally
hold many of the futures contracts
included in the Benchmark, the Fund
and the Subsidiary will be actively
managed and will not be obligated to
invest in all of (or to limit investments
solely to) such futures contracts. In
addition, with respect to investments in
exchange-traded futures contracts, the
Fund and the Subsidiary will not be
obligated to invest in the same amount
or proportion as the Benchmark, or be
obligated to track the performance of the
Benchmark. There can be no assurance
that the Fund’s performance will exceed
the performance of the Benchmark at
any time. In addition to exchange-traded
futures contracts, the Fund’s
Commodities investments will also be
comprised of the following: Centrally
cleared and non-centrally-cleared swaps
on commodities, exchange-traded
options on futures contracts that
provide exposure to the investment
9 Investments in non-centrally cleared swaps
(through the Subsidiary) will not represent more
than 20% of the Fund’s net assets. When investing
in non-centrally cleared swaps, the Subsidiary 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 and/or a Sub-Adviser will evaluate the
creditworthiness of counterparties on an ongoing
basis. In addition to information provided by credit
agencies, the Adviser’s and/or a Sub-Adviser’s
analysis will evaluate each approved counterparty
using various methods of analysis and may consider
such factors as the counterparty’s liquidity, its
reputation, the Adviser’s and/or a Sub-Adviser’s
past experience with the counterparty, its known
disciplinary history and its share of market
participation.
10 Exchange-traded commodity-linked
instruments include only the following: (1) Funds
that provide exposure to commodities as would be
listed under Rules 14.11(b), (c), and (i); and (2)
pooled investment vehicles that invest primarily in
commodities and commodity-linked instruments as
would be listed under Rules 14.11(d) and
14.11(e)(2), (4), (6), (7), (8), (9) and (10). Such
pooled investment vehicles are commonly referred
to as ‘‘exchange-traded funds’’ but they are not
registered as investment companies because of the
nature of their underlying investments.
VerDate Sep<11>2014
16:43 Dec 31, 2015
Jkt 238001
returns of the commodities markets, and
exchange-traded commodity-linked
instruments, without investing directly
in physical commodities.
The Fund will invest in Commodities
through investments in the Subsidiary
and will not invest directly in physical
commodities. The Fund’s investment in
the Subsidiary may not exceed 25% of
the Fund’s total assets. In addition to
Commodities, the Fund’s assets will be
invested in: (1) Short-term investment
grade fixed income securities that
include only the following instruments:
U.S. government and agency
securities,11 corporate debt
obligations 12 and repurchase
agreements; 13 (2) money market
instruments; 14 (3) investment
companies (other than those that are
commodity-linked instruments),15
11 Such securities are securities that are issued or
guaranteed by the U.S. Treasury, by various
agencies of the U.S. government, or by various
instrumentalities, which have been established or
sponsored by the U.S. government. U.S. Treasury
obligations are backed by the ‘‘full faith and credit’’
of the U.S. government. Securities issued or
guaranteed by federal agencies and U.S.
government-sponsored instrumentalities may or
may not be backed by the full faith and credit of
the U.S. government.
12 At least 75% of corporate debt obligations will
have a minimum principal amount outstanding of
$100 million or more.
13 The Fund intends to enter into repurchase
agreements only with financial institutions and
dealers believed by the Adviser and/or a SubAdviser to present minimal credit risks in
accordance with criteria approved by the Trust’s
Board of Trustees (the ‘‘Board’’). The Adviser and/
or a Sub-Adviser will review and monitor the
creditworthiness of such institutions. The Adviser
and/or a Sub-Adviser will monitor the value of the
collateral at the time the transaction is entered into
and at all times during the term of the repurchase
agreement.
14 For the Fund’s purposes, money market
instruments will include only the following
instruments: short-term, high-quality securities
issued or guaranteed by non-U.S. governments,
agencies and instrumentalities; non-convertible
corporate debt securities with remaining maturities
of not more than 397 days that satisfy ratings
requirements under Rule 2a–7 under the 1940 Act;
money market mutual funds; and deposits and
other obligations of U.S. and non-U.S. banks and
financial institutions. In addition, the Fund may
invest in commercial paper, which are short-term
unsecured promissory notes. The Fund may
additionally invest in commercial paper only if it
has received the highest rating from at least one
nationally recognized statistical rating organization
or, if unrated, has been judged by the Adviser and/
or a Sub-Adviser to be of comparable quality.
15 The Fund may invest in the securities of certain
other investment companies in excess of the limits
imposed under the 1940 Act pursuant to an
exemptive order obtained by the Trust and the
Adviser from the Commission. See Investment
Company Act Release No. 31401 (December 29,
2014) (File No. 812–14264). The exchange-traded
investment companies in which the Fund may
invest include Index Fund Shares (as described in
Rule 14.11(c)), Portfolio Depository Receipts (as
described in Rule 14.11(b)), and Managed Fund
Shares (as described in Rule 14.11(i)). While the
Fund and the Subsidiary may invest in inverse
commodity-linked instruments, the Fund and the
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including both exchange-traded and
non-exchange-traded investment
companies, that provide exposure to
commodities, equity securities and fixed
income securities to the extent
permitted under the 1940 Act and any
applicable exemptive relief; 16 (4)
certain bank instruments 17; and (5) cash
and other cash equivalents (collectively,
‘‘Other Investments’’). The Fund will
use the Other Investments as
investments, to provide liquidity and to
collateralize the Subsidiary’s
commodity exposure on a day-to-day
basis.
The Fund’s investment in the
Subsidiary will be designed to help the
Fund achieve exposure to commodity
returns in a manner consistent with the
federal tax requirements applicable to
the Fund and other regulated
investment companies.
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.18
Subsidiary’s Investments
The Subsidiary will generally seek to
make investments in Commodities and
its portfolio will be managed by the
Adviser or a Sub-Adviser.19 The Adviser
or a Sub-Adviser will use its discretion
to determine the percentage of the
Fund’s assets allocated to the
Commodities held by the Subsidiary
that will be invested in exchange-traded
commodity futures contracts, centrally
cleared and non-centrally cleared
Subsidiary will not invest in leveraged or inverse
leveraged (e.g., 2X or -3X) commodity-linked
instruments.
16 The exchange-traded investment companies in
which the Fund invests will be listed and traded
in the U.S. on registered exchanges.
17 The term ‘‘certain bank instruments’’ includes
only the following instruments: certificates of
deposit issued against funds deposited in a bank or
savings and loan association; bankers’ acceptances,
which are short-term credit instruments used to
finance commercial transactions; and bank time
deposits, which are monies kept on deposit with
banks or savings and loan associations for a stated
period of time at a fixed rate of interest.
18 26 U.S.C. 851.
19 The Subsidiary will not be registered under the
1940 Act and will not be directly subject to its
investor protections, except as noted in the
Registration Statement. However, the Subsidiary
will be wholly-owned and controlled by the Fund.
Therefore, the Fund’s ownership and control of the
Subsidiary will prevent the Subsidiary from taking
action contrary to the interests of the Fund or its
shareholders. The Board will have oversight
responsibility for the investment activities of the
Fund, including its expected investment in the
Subsidiary, and the Fund’s role as the sole
shareholder of the Subsidiary. The Subsidiary will
also enter into separate contracts for the provision
of custody, transfer agency, and accounting agent
services with the same or with affiliates of the same
service providers that provide those services to the
Fund.
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swaps, exchange-traded options on
futures contracts and exchange-traded
commodity-linked instruments. In this
regard, under normal market conditions,
the Subsidiary is expected, as a general
matter, to invest in futures contracts in
proportional weights and allocations
that are similar to the Benchmark, as
well as in the other Commodities.
Additionally, the Subsidiary, like the
Fund, may invest in Other Investments
(e.g., as investments or to serve as
margin or collateral or otherwise
support the Subsidiary’s positions in
Commodities).
The Fund’s investment in the
Subsidiary is intended to provide the
Fund with exposure to commodity
markets within the limits of current
federal income tax laws applicable to
Commodity
Corn ............................
Cocoa .........................
WTI Crude Oil ............
Brent Crude Oil ..........
Cotton .........................
Feeder Cattle .............
Gold ............................
NY Harbor ULSD .......
Coffee ‘‘C’’ Arabica ....
HRW Wheat ...............
Aluminium primary .....
Live Cattle ..................
Lean Hogs ..................
Lead standard ............
Nickel primary ............
Copper grade A ..........
Zinc high grade ..........
Natural Gas ................
Gasoil .........................
Soybeans ...................
Sugar #11 ...................
Silver ..........................
SRW Wheat ...............
RBOB Gasoline ..........
investment companies such as the
Fund, which limit the ability of
investment companies to invest directly
in the derivative instruments. The
Subsidiary will have the same
investment objective as the Fund, but
unlike the Fund, it may invest without
limitation in Commodities. The
Subsidiary’s investments will provide
the Fund with exposure to domestic and
international markets.
The Benchmark is a version of the
S&P GSCI Index that aims to mitigate
the effects of ‘‘contango’’ (which means
that futures contracts with distant
delivery months are priced higher than
those with nearer delivery months) on
index performance. The S&P GSCI Index
is a broad-based, production-weighted
index that is designed to be
Exchange
code
CBT
NYB
NYM
ICE
NYB
CME
CMX
NYM
NYB
CBT
LME
CME
CME
LME
LME
LME
LME
NYM
ICE
CBT
NYB
CMX
CBT
NYM
123
representative of global commodity
market performance and to reflect
general levels of price movements and
inflation in the world economy. The
S&P GSCI Index consists of twenty-four
commodity futures on physical
commodities across five sectors: energy;
agriculture; livestock; industrial metals;
and precious metals. The following
table describes each of the commodities
underlying the futures contracts
included in the Benchmark as of
October 31, 2015. The table also
provides each instrument’s trading
hours, exchange and ticker symbol. The
table is subject to change (and the
Subsidiary will not in all cases invest in
the futures contracts included in the
Benchmark).
Exchange name 20
Trading hours electronic (E.T.)
Chicago Board of Trade .................................
ICE Futures US ..............................................
New York Mercantile Exchange .....................
ICE Futures Europe .......................................
ICE Futures US ..............................................
Chicago Mercantile Exchange .......................
COMEX ..........................................................
New York Mercantile Exchange .....................
ICE Futures US ..............................................
Chicago Board of Trade .................................
London Metal Exchange ................................
Chicago Mercantile Exchange .......................
Chicago Mercantile Exchange .......................
London Metal Exchange ................................
London Metal Exchange ................................
London Metal Exchange ................................
London Metal Exchange ................................
New York Mercantile Exchange .....................
ICE Futures Europe .......................................
Chicago Board of Trade .................................
ICE Futures US ..............................................
COMEX ..........................................................
Chicago Board of Trade .................................
New York Mercantile Exchange .....................
Sun-F 20:00–08:45 M–F 09:30–14:15 ...........
04:45–13:30 ...................................................
18:00–17:15 ...................................................
20:00–18:00 ...................................................
21:00–14:20 ...................................................
M 10:05–F 14:55 (Halts 17:00–18:00) ...........
18:00–17:15 ...................................................
18:00–17:15 ...................................................
04:15–13:30 ...................................................
Sun-F 20:00–08:45 M–F 9:30–14:15 .............
20:00–14:00 ...................................................
M 10:05–F 14:55 (Halts 17:00–18:00) ...........
M 10:05–F 14:55 (Halts 17:00–18:00) ...........
20:00–14:00 ...................................................
20:00–14:00 ...................................................
20:00–14:00 ...................................................
20:00–14:00 ...................................................
18:00–17:15 ...................................................
20:00–18:00 ...................................................
Sun-F 20:00–08:45 M–F 09:30–14:15 ...........
03:30–13:00 ...................................................
18:00–17:15 ...................................................
Sun-F 20:00–08:45 M–F 09:30–14:15 ...........
18:00–17:15 ...................................................
Contract
symbol(s)
C; ZC.
CC.
CL.
B.
CT.
FC; GF.
GC.
HO.
KC.
KW; KE.
AH.
LC; LE.
LH; HE.
PB.
NI.
CA.
ZS.
NG.
G.
S; ZS.
SB.
SI.
W; ZW.
RB.
tkelley on DSK3SPTVN1PROD with NOTICES
As the U.S. and foreign exchanges
noted above list additional contracts, as
currently listed contracts on those
exchanges gain sufficient liquidity, or as
other exchanges list sufficiently liquid
contracts, the Adviser and/or any SubAdviser will include those contracts in
the list of possible investments of the
Subsidiary. The list of commodities
futures and commodities markets
considered for investment can and will
change over time.
The Commodity Futures Trading
Commission (‘‘CFTC’’) has adopted
substantial amendments to CFTC Rule
4.5 relating to the permissible
exemptions and conditions for reliance
on exemptions from registration as a
commodity pool operator. As a result of
the instruments that will be indirectly
held by the Fund, the Adviser will
register as a commodity pool operator 21
and will also be a member of the
National Futures Association (‘‘NFA’’).
Any Sub-Adviser will register as a
commodity pool operator or commodity
trading adviser, as required by CFTC
regulations. The Fund and the
Subsidiary will be subject to regulation
by the CFTC and NFA and additional
20 All of the exchanges are Intermarket
Surveillance Group (‘‘ISG’’) members except for the
London Metal Exchange (‘‘LME’’), ICE Futures
Europe and Commodity Exchange, Inc. (‘‘COMEX’’).
The LME falls under the jurisdiction of the
Financial Conduct Authority (‘‘FCA’’). The FCA is
responsible for ensuring the financial stability of
the exchange members’ businesses, whereas the
LME is largely responsible for the oversight of dayto-day exchange activity, including conducting the
arbitration proceedings under the LME arbitration
regulations. With respect to the futures contracts in
which the Subsidiary invests, not more than 10%
of the weight (to be calculated as the value of the
contract divided by the total absolute notional value
of the Subsidiary’s futures contracts) of the futures
contracts held by the Subsidiary in the aggregate
shall consist of instruments whose principal trading
market is a market from which the Exchange may
not obtain information regarding trading in the
futures contracts by virtue of: (a) Its membership in
ISG; or (b) a comprehensive surveillance sharing
agreement. In addition, at least 90% of the Fund’s
net assets that are invested in exchange-traded
options on futures contracts and exchange-traded
commodity-linked instruments (in the aggregate)
will be invested in instruments that trade in
markets that are members of ISG or are parties to
a comprehensive surveillance sharing agreement
with the Exchange.
21 As defined in Section 1a(11) of the Commodity
Exchange Act.
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Commodities Regulation
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disclosure, reporting and recordkeeping
rules imposed upon commodity pools.
Investment Restrictions
tkelley on DSK3SPTVN1PROD with NOTICES
While the Fund will be permitted to
borrow as permitted under the 1940 Act,
the Fund’s investments will not be used
to seek performance that is the multiple
or inverse multiple (i.e., 2X and –3X) of
the Benchmark.
The Fund may not invest more than
25% of the value of its total assets in
securities of issuers in any one industry
or group of industries. This restriction
will not apply to obligations issued or
guaranteed by the U.S. government, its
agencies or instrumentalities, or
securities of other investment
companies.22
The Subsidiary’s shares will be
offered only to the Fund and the Fund
will not sell shares of the Subsidiary to
other investors. The Fund and the
Subsidiary will not invest in any nonU.S. equity securities (other than shares
of the Subsidiary). The Fund will not
purchase securities of open-end or
closed-end investment companies
except in compliance with the 1940 Act
or any applicable exemptive relief.23
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 securities
deemed illiquid by the Adviser.24 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.25
22 See Form N–1A, Item 9. The Commission has
taken the position that a fund is concentrated if it
invests more than 25% of the value of its total
assets in any one industry. See, e.g., Investment
Company Act Release No. 9011 (October 30, 1975),
40 FR 54241 (November 21, 1975).
23 See supra note 15.
24 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 trades (e.g., the time needed to dispose
of the security, the method of soliciting offers, and
the mechanics of transfer).
25 The Commission has stated that long-standing
Commission guidelines have required open-end
funds to hold no more than 15% of their net assets
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Net Asset Value
The Fund’s net asset value (‘‘NAV’’)
will be determined as of the close of
trading (normally 4:00 p.m., Eastern
Time (‘‘E.T.’’)) on each day the New
York Stock Exchange (‘‘NYSE’’) is open
for business. The NAV of the Fund will
be calculated by dividing the value of
the net assets of such Fund (i.e., the
value of its total assets, less total
liabilities) by the total number of
outstanding Shares, generally rounded
to the nearest cent.
The Fund’s and the Subsidiary’s
investments will be generally valued
using market valuations. A market
valuation generally means a valuation
(i) obtained from an exchange, a pricing
service, or a major market maker (or
dealer), (ii) based on a price quotation
or other equivalent indication of value
supplied by an exchange, a pricing
service, or a major market maker (or
dealer), or (iii) based on amortized cost.
The Fund and the Subsidiary may use
various pricing services or discontinue
the use of any pricing service. A price
obtained from a pricing service based on
such pricing service’s valuation matrix
may be considered a market valuation.
If available, debt securities and money
market instruments with maturities of
more than 60 days will typically be
priced based on valuations provided by
independent, third-party pricing agents.
Such values will generally reflect the
last reported sales price if the security
is actively traded. The third-party
pricing agents may also value debt
securities at an evaluated bid price by
employing methodologies that utilize
actual market transactions, brokersupplied valuations, or other
methodologies designed to identify the
market value for such securities. Debt
obligations with remaining maturities of
60 days or less may be valued on the
basis of amortized cost, which
approximates market value. If such
prices are not available, the security will
be valued based on values supplied by
in illiquid securities and other illiquid assets. See
Investment Company Act Release No. 28193 (March
11, 2008), 73 FR 14618 (March 18, 2008), footnote
34. See also Investment Company Act Release No.
5847 (October 21, 1969), 35 FR 19989 (December
31, 1970) (Statement Regarding ‘‘Restricted
Securities’’); Investment Company Act Release No.
18612 (March 12, 1992), 57 FR 9828 (March 20,
1992) (Revisions of Guidelines to Form N–1A). A
fund’s portfolio security is illiquid if it cannot be
disposed of in the ordinary course of business
within seven days at approximately the value
ascribed to it by the fund. See Investment Company
Act Release No. 14983 (March 12, 1986), 51 FR
9773 (March 21, 1986) (adopting amendments to
Rule 2a–7 under the 1940 Act); Investment
Company Act Release No. 17452 (April 23, 1990),
55 FR 17933 (April 30, 1990) (adopting Rule 144A
under the Securities Act of 1933).
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Frm 00064
Fmt 4703
Sfmt 4703
independent brokers or by fair value
pricing, as described below.
Futures contracts will be valued at the
settlement price established each day by
the board or exchange on which they are
traded.
Exchange-traded options will be
valued at the closing price in the market
where such contracts are principally
traded.
Swaps will be valued based on
valuations provided by independent,
third-party pricing agents.
Securities of non-exchange-traded
investment companies will be valued at
NAV. Equity securities listed on a
securities exchange (including
exchange-traded commodity-linked
instruments and exchange-traded
investment companies), market or
automated quotation system for which
quotations are readily available (except
for securities traded on The NASDAQ
Stock Market LLC (‘‘NASDAQ’’) and the
London Stock Exchange Alternative
Investment Market (‘‘LSE AIM’’)) will be
valued at the last reported sale price on
the primary exchange or market on
which they are traded on the valuation
date (or at approximately 4:00 p.m., E.T.
if a security’s primary exchange is
normally open at that time). For a
security that trades on multiple
exchanges, the primary exchange will
generally be considered to be the
exchange on which the security
generally has the highest volume of
trading activity. If it is not possible to
determine the last reported sale price on
the relevant exchange or market on the
valuation date, the value of the security
will be taken to be the most recent mean
between the bid and asked prices on
such exchange or market on the
valuation date. Absent both bid and
asked prices on such exchange, the bid
price may be used. For securities traded
on the NASDAQ or LSE AIM, the
official closing price will be used. If
such prices are not available, the
security will be valued based on values
supplied by independent brokers or by
fair value pricing, as described below.
The prices for foreign instruments
will be reported in local currency and
converted to U.S. dollars using currency
exchange rates. Exchange rates will be
provided daily by recognized
independent pricing agents.
In the event that current market
valuations are not readily available or
such valuations do not reflect current
market values, the affected investments
will be valued using fair value pricing
pursuant to the pricing policy and
procedures approved by the Board in
accordance with the 1940 Act. Fair
value pricing may require subjective
determinations about the value of an
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will apply until a new Creation Basket
is announced on the following business
day.
Creation and Redemption of Shares
The Fund will issue and redeem
Shares on a continuous basis at NAV26
only in large blocks of Shares (‘‘Creation
Units’’) in transactions with authorized
participants, generally including brokerdealers and large institutional investors
(‘‘Authorized Participants’’). Creation
Units are not expected to consist of less
than 25,000 Shares. The Fund will issue
and redeem Creation Units in exchange
for an in-kind portfolio of instruments
and/or cash in lieu of such instruments
(the ‘‘Creation Basket’’).27 In addition, if
there is a difference between the NAV
attributable to a Creation Unit and the
market value of the Creation Basket
exchanged for the Creation Unit, the
party conveying instruments with the
lower value will pay to the other an
amount in cash equal to the difference
(referred to as the ‘‘Cash Component’’).
Creations and redemptions must be
made by or through an Authorized
Participant that has executed an
agreement that has been agreed to by the
Distributor with respect to creations and
redemptions of Creation Units. All
standard orders to create Creation Units
must be received by the Distributor no
later than the closing time of the regular
trading session on the NYSE (ordinarily
4:00 p.m., E.T.) (the ‘‘Closing Time’’) in
each case on the date such order is
placed in order for the creation of
Creation Units to be effected based on
the NAV of Shares as next determined
on such date after receipt of the order
in proper form. Shares may be redeemed
only in Creation Units at their NAV next
determined after receipt not later than
the Closing Time of a redemption
request in proper form by the Fund
through the Distributor and only on a
business day.
On each business day, prior to the
opening of business of the Exchange, the
Fund will cause to be published through
the National Securities Clearing
Corporation the list of the names and
quantities of the instruments comprising
the Creation Basket, as well as the
estimated Cash Component (if any), for
that day. The published Creation Basket
tkelley on DSK3SPTVN1PROD with NOTICES
asset and may result in prices that differ
from the value that would be realized if
the asset was sold.
Availability of Information
The Fund’s Web site
(www.elkhorn.com), which will be
publicly available prior to the public
offering of Shares, will include a form
of the prospectus for the Fund that may
be downloaded. The Web site will
include the Shares’ ticker, CUSIP and
exchange information along with
additional quantitative information
updated on a daily basis, including, for
the Fund: (1) Daily trading volume, the
prior business day’s reported NAV and
closing price, mid-point of the bid/ask
spread at the time of calculation of such
NAV (the ‘‘Bid/Ask Price’’) 28 and a
calculation of the premium and
discount of the Bid/Ask Price against
the NAV; and (2) data in chart format
displaying the frequency distribution of
discounts and premiums of the daily
Bid/Ask Price against the NAV, within
appropriate ranges, for each of the four
previous calendar quarters. Daily
trading volume information for the
Fund will also be available in the
financial section of newspapers, through
subscription services such as
Bloomberg, Thomson Reuters, and
International Data Corporation, which
can be accessed by Authorized
Participants and other investors, as well
as through other electronic services,
including major public Web sites. On
each business day, before
commencement of trading in Shares
during Regular Trading Hours29 on the
Exchange, the Fund will disclose on its
Web site the identities and quantities of
the portfolio of securities, Commodities
and other assets (the ‘‘Disclosed
Portfolio’’ as defined in Rule
14.11(i)(3)(B)) held by the Fund and the
Subsidiary that will form the basis for
the Fund’s calculation of NAV at the
end of the business day.30 The Fund’s
disclosure of derivative positions in the
Disclosed Portfolio will include
information that market participants can
use to value these positions intraday.
On a daily basis, the Disclosed Portfolio
26 The NAV of the Fund’s Shares generally will
be calculated once daily Monday through Friday as
of the close of regular trading on the NYSE,
generally 4:00 p.m., E.T. (the ‘‘NAV Calculation
Time’’). NAV per Share will be calculated by
dividing the Fund’s net assets by the number of
Fund Shares outstanding.
27 The Adviser represents that, to the extent that
the Trust permits or requires a ‘‘cash in lieu’’
amount, such transactions will be effected in the
same or equitable manner for all Authorized
Participants.
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16:43 Dec 31, 2015
Jkt 238001
28 The Bid/Ask Price of the Fund will be
determined using the mid-point of the highest bid
and the lowest offer on the Exchange as of the time
of calculation of the Fund’s NAV. The records
relating to Bid/Ask Prices will be retained by the
Fund and its service providers.
29 Regular Trading Hours are 9:30 a.m. to 4:00
p.m. Eastern Time.
30 Under accounting procedures to be followed by
the Fund, trades made on the prior business day
(‘‘T’’) will be booked and reflected in NAV on the
current business day (‘‘T+1’’). Accordingly, the
Fund will be able to disclose at the beginning of the
business day the portfolio that will form the basis
for the NAV calculation at the end of the business
day.
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125
displayed 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 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 percentage weighting of
the holding in the Fund’s portfolio. The
Web site and information will be
publicly available at no charge.
In addition, for the Fund, an
estimated value, defined in BATS Rule
14.11(i)(3)(C) as the ‘‘Intraday Indicative
Value,’’ that reflects an estimated
intraday value of the Fund’s portfolio
(including the Subsidiary’s portfolio),
will be disseminated. Moreover, the
Intraday Indicative Value will be based
upon the current value for the
components of the Disclosed Portfolio
and will be updated and widely
disseminated by one or more major
market data vendors and broadly
displayed at least every 15 seconds
during the Exchange’s Regular Trading
Hours.31
The dissemination of the Intraday
Indicative Value, together with the
Disclosed Portfolio, will allow investors
to determine the value of the underlying
portfolio of the Fund on a daily basis
and will provide a close estimate of that
value throughout the trading day.
Intra-day executable price quotations
on the securities and other assets held
by the Fund and the Subsidiary will be
available from major broker-dealer firms
or on the exchange on which they are
traded, as applicable. Intra-day price
information on the securities and other
assets held by the Fund and the
Subsidiary will also be available
through subscription services, such as
Bloomberg and Thomson Reuters,
which can be accessed by Authorized
Participants and other investors. More
specifically, pricing information for
exchange-traded commodity futures
contracts, exchange-traded options on
futures contracts, exchange-traded
commodity-linked instruments,
securities of exchange-traded
investment companies other than
exchange-traded commodity-linked
31 Currently, it is the Exchange’s understanding
that several major market data vendors display and/
or make widely available Intraday Indicative Values
published via the Consolidated Tape Association
(‘‘CTA’’) or other data feeds.
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instruments will be available on the
exchanges on which they are traded and
through subscription services. Pricing
information for securities of nonexchange-traded investment companies
will be available through the applicable
fund’s Web site or major market data
vendors. Pricing information for swaps,
fixed income securities and money
market instruments will be available
through subscription services and/or
broker-dealer firms and/or pricing
services. Additionally, the Trade
Reporting and Compliance Engine
(‘‘TRACE’’) of the Financial Industry
Regulatory Authority (‘‘FINRA’’) will be
a source of price information for certain
fixed income securities held by the
Fund.
Investors will also be able to obtain
the Fund’s Statement of Additional
Information (‘‘SAI’’), the Fund’s annual
and semi-annual reports (together,
‘‘Shareholder Reports’’), and its Form
N–CSR and Form N–SAR, filed twice a
year. The Fund’s SAI and Shareholder
Reports will be available free upon
request from the Fund, and those
documents and the Form N–CSR and
Form N–SAR may be viewed on-screen
or downloaded from the Commission’s
Web site at www.sec.gov. Information
regarding market price and trading
volume of the Shares will be continually
available on a real-time basis throughout
the day on brokers’ computer screens
and other electronic services. The
previous day’s closing price and trading
volume information for the Shares will
be published daily in the financial
section of newspapers. Quotation and
last sale information for the Shares will
be available on the facilities of the CTA.
Information relating to the
Benchmark, including its constituents,
weightings and changes to its
constituents, will be available on the
Web site of S&P Indices.
tkelley on DSK3SPTVN1PROD with NOTICES
Initial and Continued Listing
The Shares will be subject to BATS
Rule 14.11(i), which sets forth the initial
and continued listing criteria applicable
to Managed Fund Shares. The Exchange
represents that, for initial and/or
continued listing, the Fund and the
Subsidiary must be in compliance with
Rule 10A–3 under the Act.32 A
minimum of 100,000 Shares will be
outstanding at the commencement of
trading on the Exchange. 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
32 See
17 CFR 240.10A–3.
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Jkt 238001
will be made available to all market
participants at the same time.
Trading Halts
With respect to trading halts, the
Exchange may consider all relevant
factors in exercising its discretion to
halt or suspend trading in the Shares of
the Fund. The Exchange will halt
trading in the Shares under the
conditions specified in BATS Rule
11.18. Trading may be halted because of
market conditions or for reasons that, in
the view of the Exchange, make trading
in the Shares inadvisable. These may
include: (1) The extent to which trading
is not occurring in the securities,
Commodities and other assets
constituting the Disclosed Portfolio of
the Fund and the Subsidiary; or (2)
whether other unusual conditions or
circumstances detrimental to the
maintenance of a fair and orderly
market are present. Trading in the
Shares also will be subject to Rule
14.11(i)(4)(B)(iv), which sets forth
circumstances under which Shares of
the Fund may be halted.
Trading Rules
The Exchange 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. BATS will allow
trading in the Shares from 8:00 a.m.
until 5:00 p.m. Eastern Time. The
Exchange has appropriate rules to
facilitate transactions in the Shares
during all trading sessions. As provided
in BATS Rule 11.11(a), the minimum
price variation for quoting and entry of
orders in Managed Fund Shares traded
on the Exchange is $0.01, with the
exception of securities that are priced
less than $1.00, for which the minimum
price variation for order entry is
$0.0001.
Surveillance
The Exchange believes that its
surveillance procedures are adequate to
properly monitor the trading of the
Shares on the Exchange during all
trading sessions and to deter and detect
violations of Exchange rules and the
applicable federal securities laws.
Trading of the Shares through the
Exchange will be subject to the
Exchange’s surveillance procedures for
derivative products, including Managed
Fund Shares. The Exchange may obtain
information regarding trading in the
Shares and the underlying shares in
exchange traded investment companies,
futures, and options on futures via the
ISG, from other exchanges who are
members or affiliates of the ISG, or with
which the Exchange has entered into a
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Frm 00066
Fmt 4703
Sfmt 4703
comprehensive surveillance sharing
agreement. In addition, the Exchange is
able to access, as needed, trade
information for certain fixed income
instruments reported to TRACE. With
respect to the futures contracts in which
the Subsidiary invests, not more than
10% of the weight (to be calculated as
the value of the contract divided by the
total absolute notional value of the
Subsidiary’s futures contracts) of the
futures contracts held by the Subsidiary
in the aggregate shall consist of
instruments whose principal trading
market is a market from which the
Exchange may not obtain information
regarding trading in the futures
contracts by virtue of: (a) Its
membership in ISG; or (b) a
comprehensive surveillance sharing
agreement. In addition, at least 90% of
the Fund’s net assets that are invested
in exchange-traded options on futures
contracts and exchange-traded
commodity-linked instruments (in the
aggregate), will be invested in
instruments that trade in markets that
are members of ISG or are parties to a
comprehensive surveillance sharing
agreement with the Exchange.
Investments in non-centrally cleared
swaps (through the Subsidiary) will not
represent more than 20% of the Fund’s
net assets.
In addition, the Exchange prohibits
the distribution of material, non-public
information by its employees.
Information Circular
Prior to the commencement of
trading, the Exchange will inform its
members in an Information Circular of
the special characteristics and risks
associated with trading the Shares.
Specifically, the Information Circular
will discuss the following: (1) The
procedures for purchases and
redemptions of Shares in Creation Units
(and that Shares are not individually
redeemable); (2) BATS Rule 3.7, which
imposes suitability obligations on
Exchange members with respect to
recommending transactions in the
Shares to customers; (3) how
information regarding the Intraday
Indicative Value and the Disclosed
Portfolio is disseminated; (4) the risks
involved in trading the Shares during
the Pre-Opening33 and After Hours
Trading Sessions34 when an updated
Intraday Indicative Value will not be
calculated or publicly disseminated; (5)
the requirement that members deliver a
prospectus to investors purchasing
33 The Pre-Opening Session is from 8:00 a.m. to
9:30 a.m. Eastern Time.
34 The After Hours Trading Session is from 4:00
p.m. to 5:00 p.m. Eastern Time.
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tkelley on DSK3SPTVN1PROD with NOTICES
newly issued Shares prior to or
concurrently with the confirmation of a
transaction; and (6) trading information.
In addition, the Information Circular
will advise members, prior to the
commencement of trading, of the
prospectus delivery requirements
applicable to the Fund. Members
purchasing Shares from the Fund for
resale to investors will deliver a
prospectus to such investors. The
Information Circular will also discuss
any exemptive, no-action and
interpretive relief granted by the
Commission from any rules under the
Act.
Additionally, the Information Circular
will reference that the Fund is subject
to various fees and expenses described
in the Registration Statement. The
Information Circular will also disclose
the trading hours of the Shares of the
Fund and the applicable NAV
Calculation Time for the Shares. The
Information Circular will disclose that
information about the Shares of the
Fund will be publicly available on the
Fund’s Web site. In addition, the
Information Circular will reference that
the Trust is subject to various fees and
expenses described in the Fund’s
Registration Statement.
2. Statutory Basis
The Exchange believes that the
proposal is consistent with Section 6(b)
of the Act 35 in general and Section
6(b)(5) of the Act 36 in particular in that
it is designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade, to foster cooperation and
coordination with persons engaged in
facilitating transactions in securities, 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 Exchange believes that the
proposed rule change is designed to
prevent fraudulent and manipulative
acts and practices in that the Shares will
be listed and traded on the Exchange
pursuant to the initial and continued
listing criteria in BATS Rule 14.11(i).
The Exchange believes that its
surveillance procedures are adequate to
properly monitor the trading of the
Shares on the Exchange during all
trading sessions and to deter and detect
violations of Exchange rules and the
applicable federal securities laws. If the
investment adviser to the investment
company issuing Managed Fund Shares
is affiliated with a broker-dealer, such
35 15
36 15
U.S.C. 78f.
U.S.C. 78f(b)(5).
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investment adviser to the investment
company shall erect a ‘‘fire wall’’
between the investment adviser and the
broker-dealer with respect to access to
information concerning the composition
and/or changes to such investment
company portfolio. The Adviser is not
registered as a broker-dealer, although it
is affiliated with a broker-dealer, and is
therefore required to implement a ‘‘fire
wall’’ with respect to such broker-dealer
affiliate regarding access to information
concerning the composition and/or
changes to the Fund’s portfolio. In
addition, Rule 14.11(i)(7) further
requires that personnel who make
decisions on the open-end fund’s
portfolio composition must be subject to
procedures designed to prevent the use
and dissemination of material nonpublic information regarding the Fund’s
portfolio. The Exchange may obtain
information regarding trading in the
Shares and the underlying shares in
investment companies, futures, and
options on futures via the ISG, from
other exchanges who are members or
affiliates of the ISG, or with which the
Exchange has entered into a
comprehensive surveillance sharing
agreement. The Exchange represents
that trading in the Shares will be subject
to the existing trading surveillances
which are designed to detect violations
of Exchange rules and applicable federal
securities laws.
The Exchange will communicate as
needed regarding trading in the Shares
and in the exchange-traded
Commodities and exchange-traded
investment companies not included
within the definition of Commodities
(together, ‘‘Exchange-Traded
Instruments’’) held by the Fund and the
Subsidiary with other markets and other
entities that are members of the ISG and
may obtain trading information
regarding trading in the Shares and in
the Exchange-Traded Instruments held
by the Fund and the Subsidiary from
such markets and other entities. In
addition, the Exchange may obtain
information regarding trading in the
Shares and in the Exchange-Traded
Instruments held by the Fund and the
Subsidiary from markets and other
entities that are members of ISG, which
includes securities and futures
exchanges, or with which the Exchange
has in place a comprehensive
surveillance sharing agreement. The
Exchange will be able to access, as
needed, trade information for certain
fixed income securities held by the
Fund reported to FINRA’s TRACE.
With respect to the futures contracts
in which the Subsidiary invests, not
more than 10% of the weight (to be
calculated as the value of the contract
PO 00000
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127
divided by the total absolute notional
value of the Subsidiary’s futures
contracts) of the futures contracts held
by the Subsidiary in the aggregate shall
consist of instruments whose principal
trading market is a market from which
the Exchange may not obtain
information regarding trading in the
futures contracts by virtue of: (a) Its
membership in ISG; or (b) a
comprehensive surveillance sharing
agreement. In addition, at least 90% of
the Fund’s net assets that are invested
in exchange-traded options on futures
contracts and exchange-traded
commodity-linked instruments (in the
aggregate) will be invested in
instruments that trade in markets that
are members of ISG or are parties to a
comprehensive surveillance sharing
agreement with the Exchange.
Investments in non-centrally cleared
swaps (through the Subsidiary) will not
represent more than 20% of the Fund’s
net assets.
The Fund’s investment objective will
be to provide total return which exceeds
that of the Benchmark, consistent with
prudent investment management. The
Fund will invest in Commodities
through investments in the Subsidiary
and will not invest directly in physical
commodities. The Fund’s investment in
the Subsidiary may not exceed 25% of
the Fund’s total assets. While the Fund
will be permitted to borrow as permitted
under the 1940 Act, the Fund’s
investments will not be used to seek
performance that is the multiple or
inverse multiple (i.e., 2X and –3X) of the
Benchmark. 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
securities deemed illiquid by the
Adviser. The Fund and the Subsidiary
will not invest in any non-U.S. equity
securities (other than shares of the
Subsidiary).
The proposed rule change is designed
to promote just and equitable principles
of trade and to protect investors and the
public interest in that 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. In
addition, a large amount of information
will be publicly available regarding the
Fund and the Shares, thereby promoting
market transparency. Moreover, the
Intraday Indicative Value will be widely
disseminated by one or more major
market data vendors and broadly
displayed at least every 15 seconds
during Regular Trading Hours. On each
business day, before commencement of
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tkelley on DSK3SPTVN1PROD with NOTICES
128
Federal Register / Vol. 81, No. 1 / Monday, January 4, 2016 / Notices
trading in Shares during Regular
Trading Hours, the Fund will disclose
on its Web site the Disclosed Portfolio
of the Fund and the Subsidiary that will
form the basis for the Fund’s calculation
of NAV at the end of the business day.
Pricing information will be available on
the Fund’s Web site including: (1) The
prior business day’s reported NAV, the
Bid/Ask Price of the Fund, and a
calculation of the premium and
discount of the Bid/Ask Price against
the NAV; and (2) data in chart format
displaying the frequency distribution of
discounts and premiums of the daily
Bid/Ask Price against the NAV, within
appropriate ranges, for each of the four
previous calendar quarters.
Additionally, information regarding
market price and trading volume of the
Shares will be continually available on
a real-time basis throughout the day on
brokers’ computer screens and other
electronic services, and quotation and
last sale information for the Shares will
be available on the facilities of the CTA.
Intra-day executable price quotations
on the securities and other assets held
by the Fund and the Subsidiary will be
available from major broker-dealer firms
or on the exchange on which they are
traded, as applicable. Intra-day price
information on the securities and other
assets held by the Fund and the
Subsidiary will also be available
through subscription services, such as
Bloomberg and Thomson Reuters,
which can be accessed by Authorized
Participants and other investors. More
specifically, pricing information for
exchange-traded commodity futures
contracts, exchange-traded options on
futures contracts, exchange-traded
commodity-linked instruments, and
exchange-traded investment companies
other than exchange-traded commoditylinked instruments will be available on
the exchanges on which they are traded
and through subscription services.
Pricing information for non-exchangetraded investment companies will be
available through the applicable fund’s
Web site or major market data vendors.
Pricing information for swaps, fixed
income securities and money market
instruments will be available through
subscription services and/or brokerdealer firms and/or pricing services.
Additionally, FINRA’s TRACE will be a
source of price information for certain
fixed income securities held by the
Fund.
The Fund’s Web site will include a
form of the prospectus for the Fund and
additional data relating to NAV and
other applicable quantitative
information. Trading in Shares of the
Fund will be halted under the
conditions specified in BATS Rule
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16:43 Dec 31, 2015
Jkt 238001
11.18. Trading may also be halted
because of market conditions or for
reasons that, in the view of the
Exchange, make trading in the Shares
inadvisable. Finally, trading in the
Shares will be subject to BATS Rule
14.11(i)(4)(B)(iv), which sets forth
circumstances under which Shares of
the Fund may be halted. In addition, the
Exchange is able to access, as needed,
trade information for certain fixed
income instruments reported to FINRA’s
TRACE. As noted above, investors will
also have ready access to information
regarding the Fund’s holdings, the
Intraday Indicative Value, 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 in the Exchange-Traded
Instruments held by the Fund and the
Subsidiary with other markets and other
entities that are members of the ISG 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 Intraday Indicative Value,
the Disclosed Portfolio, and quotation
and last sale information for the Shares.
For the above reasons, the Exchange
believes that the proposed rule change
is consistent with the requirements of
Section 6(b)(5) of the Act.
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 actively-managed exchangetraded product that will enhance
competition among market participants,
to the benefit of investors and the
marketplace.
PO 00000
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C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
The Exchange has neither solicited
nor received written comments on 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 within such longer period (i)
as the Commission may designate up to
90 days of such date if it finds such
longer period to be appropriate and
publishes its reasons for so finding or
(ii) as to which the Exchange consents,
the Commission will: (a) By order
approve or disapprove such 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–
BATS–2015–105 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
Number SR–BATS–2015–105. 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
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Federal Register / Vol. 81, No. 1 / Monday, January 4, 2016 / Notices
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 such
filing 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
should refer to File Number SR–BATS–
2015–105, and should be submitted on
or before January 25, 2016.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.37
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2015–32986 Filed 12–31–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
In the Matter of China Domestica BioTechnology Holdings, Inc., Order of
Suspension of Trading
tkelley on DSK3SPTVN1PROD with NOTICES
December 30, 2015.
It appears to the Securities and
Exchange Commission (‘‘Commission’’)
that there is a lack of current and
accurate information concerning the
securities of Changda International
Holdings, Inc. (‘‘CDBH 1’’) (CIK No.
1380706), a defaulted Nevada
corporation whose principal place of
business is listed as LungFung District,
Shenzhen, China because it is
delinquent in its periodic filings with
the Commission, having not filed any
periodic reports since it filed a Form
10–K for the period ended March 31,
2012. As of December 15, CDBH’s
common stock was quoted on OTC Link
(previously ‘‘Pink Sheets’’) operated by
OTC Markets Group Inc. On April 28,
2015, the Commission’s Division of
Corporation Finance sent a delinquency
letter to CDBH at the address shown in
its then-most recent filing in the
Commission’s EDGAR system
requesting compliance with its periodic
filing requirements. To date, CDBH has
failed to cure its delinquencies.
The Commission is of the opinion that
the public interest and the protection of
investors require a suspension of trading
CFR 200.30–3(a)(12).
short form of the issuer’s name is also its
ticker symbol.
1 The
VerDate Sep<11>2014
16:43 Dec 31, 2015
Jkt 238001
By the Commission.
Jill M. Peterson,
Assistant Secretary.
[FR Doc. 2015–33139 Filed 12–30–15; 4:15 pm]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–76777; File No. SR–EDGA–
2015–45]
Self-Regulatory Organizations; EDGA
Exchange, Inc.; Notice of Filing and
Immediate Effectiveness of a Proposed
Rule Change Related to Fees for Use
of EDGA Exchange, Inc.
December 28, 2015.
[File No. 500–1]
37 17
in the securities of the above-listed
company. Therefore, it is ordered,
pursuant to Section 12(k) of the
Securities Exchange Act of 1934, that
trading in the securities of the abovelisted company is suspended for the
period from 9:30 a.m. EST on December
30, 2015, through 11:59 p.m. EST on
January 13, 2016.
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 December
15, 2015, EDGA Exchange, Inc. (the
‘‘Exchange’’ or ‘‘EDGA’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III below, which Items have been
prepared by the Exchange. The
Exchange has designated the proposed
rule change as one establishing or
changing a member due, fee, or other
charge imposed by the Exchange under
Section 19(b)(3)(A)(ii) of the Act 3 and
Rule 19b–4(f)(2) thereunder,4 which
renders the proposed rule change
effective upon filing with the
Commission. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange filed a proposal to
amend the fee schedule applicable to
Members 5 and non-members of the
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 15 U.S.C. 78s(b)(3)(A)(ii).
4 17 CFR 240.19b–4(f)(2).
5 The term ‘‘Member’’ is defined as ‘‘any
registered broker or dealer, or any person associated
with a registered broker or dealer, that has been
admitted to membership in the Exchange. A
Member will have the status of a ‘‘member’’ of the
Exchange as that term is defined in Section 3(a)(3)
of the Act.’’ See Exchange Rule 1.5(n).
2 17
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129
Exchange pursuant to EDGA Rules
15.1(a) and (c) (‘‘Fee Schedule’’) to
adopt fees for the recently adopted
ALLB routing strategy.
The text of the proposed rule change
is available at the Exchange’s Web site
at www.batstrading.com, at the
principal office of the Exchange, 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
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 parts 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 adopt fees
for the ALLB routing strategy. In sum,
ALLB is a routing option under which
the order checks the System 6 for
available shares and is then sent to the
BATS Exchange, Inc. (‘‘BZX’’), BATS YExchange, Inc. (‘‘BYX’’), and the EDGX
Exchange, Inc. (‘‘EDGX’’ collectively
with the Exchange, BZX, and BYX, the
‘‘BGM Affiliated Exchanges’’).7
Specifically, an order subject to the
ALLB routing option would execute first
against liquidity on the EDGA Book.8
Any remainder would then be routed to
BZX, BYX, and/or EDGX in accordance
with the System routing table.9
The Exchange now proposes to adopt
three new fee codes, AX, AY, and AZ
and related fees for the ALLB routing
strategy. These fee codes would enable
6 The term ‘‘System’’ is defined as ‘‘the electronic
communications and trading facility designated by
the Board through which securities orders of Users
are consolidated for ranking, execution and, when
applicable, routing away.’’ See Exchange Rule
1.5(cc).
7 See Exchange Rule 11.11(g)(7). See also
Securities Exchange Act Release No. 76455
(November 17, 2015), 80 FR 73009 (November 23,
2015) (SR–EDGA–2015–42).
8 The term ‘‘EDGA Book’’ is defined as ‘‘the
System’s electronic file of orders.’’ See Exchange
Rule 1.5(d).
9 The term ‘‘System routing table’’ refers to the
proprietary process for determining the specific
trading venues to which the System routes orders
and the order in which it routes them. See
Exchange Rule 11.11(g).
E:\FR\FM\04JAN1.SGM
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Agencies
[Federal Register Volume 81, Number 1 (Monday, January 4, 2016)]
[Notices]
[Pages 120-129]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-32986]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-76776; File No. SR-BATS-2015-105]
Self-Regulatory Organizations; BATS Exchange, Inc.; Notice of
Filing of a Proposed Rule Change to Rule 14.11(i), Managed Fund Shares,
To List and Trade the Shares of the Elkhorn S&P GSCI Dynamic Roll
Commodity ETF of Elkhorn ETF Trust
December 28, 2015.
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 December 18, 2015, BATS Exchange, Inc. (the ``Exchange'' or
``BATS'') filed with the Securities and Exchange Commission
(``Commission'') the proposed rule change as described in Items I, II
and III 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.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------
I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
The Exchange is proposing a rule change to list and trade the
shares of the Elkhorn S&P GSCI Dynamic Roll Commodity ETF (the
``Fund'') of Elkhorn ETF Trust (the ``Trust'') under BATS Rule 14.11(i)
(``Managed Fund Shares''). The shares of the Fund are collectively
referred to herein as (the ``Shares'').
The text of the proposed rule change is available at the Exchange's
Web site at www.batstrading.com, at the principal office of the
Exchange, and at
[[Page 121]]
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 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 parts 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 list and trade the Shares under BATS Rule
14.11(i), which governs the listing and trading of Managed Fund Shares
on the Exchange.\3\ The Fund will be an actively managed fund. The
Shares will be offered by the Trust, which was established as a
Massachusetts business trust on December 12, 2013.\4\ The Trust is
registered with the Commission as an open-end investment company and
has filed a registration statement on behalf of the Fund on Form N-1A
(``Registration Statement'') with the Commission.\5\ The Fund will be a
series of the Trust. The Fund will invest in, among other things,
exchange-traded commodity futures contracts and exchange-traded
commodity-linked instruments held indirectly through a wholly-owned
subsidiary controlled by the Fund and organized under the laws of the
Cayman Islands (referred to herein as the ``Subsidiary'').
---------------------------------------------------------------------------
\3\ The Commission approved BATS Rule 14.11(i) in Securities
Exchange Act Release No. 65225 (August 30, 2011), 76 FR 55148
(September 6, 2011) (SR-BATS-2011-018).
\4\ The Trust has obtained from the Commission an order granting
certain exemptive relief to the Trust under the 1940 Act (File No.
812-14262). In compliance with BATS Rule 14.11(i)(2)(E), which
applies to Managed Fund Shares based on an international or global
portfolio, the Trust's application for exemptive relief under the
1940 Act states that the Fund will comply with the federal
securities laws in accepting securities for deposits and satisfying
redemptions with redemption securities, including that the
securities accepted for deposits and the securities used to satisfy
redemption requests are sold in transactions that would be exempt
from registration under the Securities Act of 1933 (15 U.S.C. 77a).
\5\ See Registration Statement on Form N-1A for the Trust, dated
November 10, 2015 (File Nos. 333-201473 and 811-22926). The
descriptions of the Fund and the Shares contained herein are based,
in part, on information in the Registration Statement.
---------------------------------------------------------------------------
Description of the Shares and the Fund
Elkhorn Investments, LLC will be the investment adviser (the
``Adviser'') to the Fund and will monitor the Fund's investment
portfolio. It is currently anticipated that day-to-day portfolio
management for the Fund will be provided by the Adviser. However, the
Fund and the Adviser may contract with an investment sub-adviser (a
``Sub-Adviser'') to provide day-to-day portfolio management for the
Fund. ALPS Distributors, Inc. (the ``Distributor'') will be the
principal underwriter and distributor of the Fund's Shares. The Fund
will contract with unaffiliated third parties to provide
administrative, custodial and transfer agency services to the Fund.
Rule 14.11(i)(7) provides that, if the investment adviser to the
investment company issuing Managed Fund Shares is affiliated with a
broker-dealer, such investment adviser shall erect a ``fire wall''
between the investment adviser and the broker-dealer with respect to
access to information concerning the composition and/or changes to such
investment company portfolio.\6\ In addition, Rule 14.11(i)(7) further
requires that personnel who make decisions on the investment company's
portfolio composition must be subject to procedures designed to prevent
the use and dissemination of material, non-public information regarding
the applicable investment company portfolio. Rule 14.11(i)(7) is
similar to BATS Rule 14.11(b)(5)(A)(i), however, Rule 14.11(i)(7) in
connection with the establishment of a ``fire wall'' between the
investment adviser and the broker-dealer reflects the applicable open-
end fund's portfolio, not an underlying benchmark index, as is the case
with index-based funds. The Adviser is not a broker-dealer, although it
is affiliated with a broker-dealer. The Adviser has implemented a fire
wall with respect to its broker-dealer affiliate regarding access to
information concerning the composition and/or changes to the Fund's
portfolio. In addition, personnel who make decisions regarding the
Fund's portfolio composition will be subject to procedures designed to
prevent the use and dissemination of material non-public information
regarding the Fund's portfolio. In the event that (a) the Adviser or a
Sub-Adviser becomes, or becomes newly affiliated with, a broker-dealer
or registers as a broker-dealer, or (b) any new adviser or sub-adviser
is a registered broker-dealer or becomes affiliated with a broker-
dealer, it will implement a fire wall with respect to its relevant
personnel and/or such broker-dealer affiliate, as applicable, regarding
access to information concerning the composition and/or changes to the
portfolio and will be subject to procedures designed to prevent the use
and dissemination of material non-public information regarding such
portfolio.
---------------------------------------------------------------------------
\6\ An investment adviser to an open-end fund is required to be
registered under the Investment Advisers Act of 1940 (the ``Advisers
Act''). As a result, the Adviser and any 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 such 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.
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Elkhorn S&P GSCI Dynamic Roll Commodity ETF Portfolio
According to the Registration Statement, the Fund's investment
objective will be to provide total return which exceeds that of the S&P
GSCI Dynamic Roll Index (the ``Benchmark'') \7\ consistent with prudent
investment management. The Fund will seek excess return above the
Benchmark through the active management of a short duration portfolio
of highly liquid, high quality bonds.
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\7\ The Benchmark is developed, maintained and sponsored by S&P
Dow Jones Indices LLC (``S&P Indices'').
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The Fund will be an actively managed fund that seeks to achieve its
investment objective by, under normal market conditions,\8\ investing
in exchange-traded commodity futures contracts, centrally cleared and
non-centrally
[[Page 122]]
cleared swaps,\9\ exchange-traded options on futures contracts and
exchange-traded commodity-linked instruments \10\ (collectively,
``Commodities'') through the Subsidiary, thereby obtaining exposure to
the commodities markets, and directly investing, as further described
below, in short-term investment grade fixed income securities, money
market instruments, exchange-traded and non-exchange-traded investment
companies, certain bank instruments, and cash and other cash
equivalents.
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\8\ The term ``under normal market conditions'' includes, but is
not limited to, the absence of extreme volatility or trading halts
in the fixed income markets, futures markets or the financial
markets generally; operational issues causing dissemination of
inaccurate market information; or force majeure type events such as
systems failure, natural or man-made disaster, act of God, armed
conflict, act of terrorism, riot or labor disruption or any similar
intervening circumstance.
\9\ Investments in non-centrally cleared swaps (through the
Subsidiary) will not represent more than 20% of the Fund's net
assets. When investing in non-centrally cleared swaps, the
Subsidiary 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 and/or a Sub-Adviser will evaluate the
creditworthiness of counterparties on an ongoing basis. In addition
to information provided by credit agencies, the Adviser's and/or a
Sub-Adviser's analysis will evaluate each approved counterparty
using various methods of analysis and may consider such factors as
the counterparty's liquidity, its reputation, the Adviser's and/or a
Sub-Adviser's past experience with the counterparty, its known
disciplinary history and its share of market participation.
\10\ Exchange-traded commodity-linked instruments include only
the following: (1) Funds that provide exposure to commodities as
would be listed under Rules 14.11(b), (c), and (i); and (2) pooled
investment vehicles that invest primarily in commodities and
commodity-linked instruments as would be listed under Rules 14.11(d)
and 14.11(e)(2), (4), (6), (7), (8), (9) and (10). Such pooled
investment vehicles are commonly referred to as ``exchange-traded
funds'' but they are not registered as investment companies because
of the nature of their underlying investments.
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The Fund's Commodities investments, in part, will be comprised of
exchange-traded futures contracts on commodities that comprise the
Benchmark. Although the Fund, through the Subsidiary, will generally
hold many of the futures contracts included in the Benchmark, the Fund
and the Subsidiary will be actively managed and will not be obligated
to invest in all of (or to limit investments solely to) such futures
contracts. In addition, with respect to investments in exchange-traded
futures contracts, the Fund and the Subsidiary will not be obligated to
invest in the same amount or proportion as the Benchmark, or be
obligated to track the performance of the Benchmark. There can be no
assurance that the Fund's performance will exceed the performance of
the Benchmark at any time. In addition to exchange-traded futures
contracts, the Fund's Commodities investments will also be comprised of
the following: Centrally cleared and non-centrally-cleared swaps on
commodities, exchange-traded options on futures contracts that provide
exposure to the investment returns of the commodities markets, and
exchange-traded commodity-linked instruments, without investing
directly in physical commodities.
The Fund will invest in Commodities through investments in the
Subsidiary and will not invest directly in physical commodities. The
Fund's investment in the Subsidiary may not exceed 25% of the Fund's
total assets. In addition to Commodities, the Fund's assets will be
invested in: (1) Short-term investment grade fixed income securities
that include only the following instruments: U.S. government and agency
securities,\11\ corporate debt obligations \12\ and repurchase
agreements; \13\ (2) money market instruments; \14\ (3) investment
companies (other than those that are commodity-linked instruments),\15\
including both exchange-traded and non-exchange-traded investment
companies, that provide exposure to commodities, equity securities and
fixed income securities to the extent permitted under the 1940 Act and
any applicable exemptive relief; \16\ (4) certain bank instruments
\17\; and (5) cash and other cash equivalents (collectively, ``Other
Investments''). The Fund will use the Other Investments as investments,
to provide liquidity and to collateralize the Subsidiary's commodity
exposure on a day-to-day basis.
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\11\ Such securities are securities that are issued or
guaranteed by the U.S. Treasury, by various agencies of the U.S.
government, or by various instrumentalities, which have been
established or sponsored by the U.S. government. U.S. Treasury
obligations are backed by the ``full faith and credit'' of the U.S.
government. Securities issued or guaranteed by federal agencies and
U.S. government-sponsored instrumentalities may or may not be backed
by the full faith and credit of the U.S. government.
\12\ At least 75% of corporate debt obligations will have a
minimum principal amount outstanding of $100 million or more.
\13\ The Fund intends to enter into repurchase agreements only
with financial institutions and dealers believed by the Adviser and/
or a Sub-Adviser to present minimal credit risks in accordance with
criteria approved by the Trust's Board of Trustees (the ``Board'').
The Adviser and/or a Sub-Adviser will review and monitor the
creditworthiness of such institutions. The Adviser and/or a Sub-
Adviser will monitor the value of the collateral at the time the
transaction is entered into and at all times during the term of the
repurchase agreement.
\14\ For the Fund's purposes, money market instruments will
include only the following instruments: short-term, high-quality
securities issued or guaranteed by non-U.S. governments, agencies
and instrumentalities; non-convertible corporate debt securities
with remaining maturities of not more than 397 days that satisfy
ratings requirements under Rule 2a-7 under the 1940 Act; money
market mutual funds; and deposits and other obligations of U.S. and
non-U.S. banks and financial institutions. In addition, the Fund may
invest in commercial paper, which are short-term unsecured
promissory notes. The Fund may additionally invest in commercial
paper only if it has received the highest rating from at least one
nationally recognized statistical rating organization or, if
unrated, has been judged by the Adviser and/or a Sub-Adviser to be
of comparable quality.
\15\ The Fund may invest in the securities of certain other
investment companies in excess of the limits imposed under the 1940
Act pursuant to an exemptive order obtained by the Trust and the
Adviser from the Commission. See Investment Company Act Release No.
31401 (December 29, 2014) (File No. 812-14264). The exchange-traded
investment companies in which the Fund may invest include Index Fund
Shares (as described in Rule 14.11(c)), Portfolio Depository
Receipts (as described in Rule 14.11(b)), and Managed Fund Shares
(as described in Rule 14.11(i)). While the Fund and the Subsidiary
may invest in inverse commodity-linked instruments, the Fund and the
Subsidiary will not invest in leveraged or inverse leveraged (e.g.,
2X or -3X) commodity-linked instruments.
\16\ The exchange-traded investment companies in which the Fund
invests will be listed and traded in the U.S. on registered
exchanges.
\17\ The term ``certain bank instruments'' includes only the
following instruments: certificates of deposit issued against funds
deposited in a bank or savings and loan association; bankers'
acceptances, which are short-term credit instruments used to finance
commercial transactions; and bank time deposits, which are monies
kept on deposit with banks or savings and loan associations for a
stated period of time at a fixed rate of interest.
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The Fund's investment in the Subsidiary will be designed to help
the Fund achieve exposure to commodity returns in a manner consistent
with the federal tax requirements applicable to the Fund and other
regulated investment companies.
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.\18\
---------------------------------------------------------------------------
\18\ 26 U.S.C. 851.
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Subsidiary's Investments
The Subsidiary will generally seek to make investments in
Commodities and its portfolio will be managed by the Adviser or a Sub-
Adviser.\19\ The Adviser or a Sub-Adviser will use its discretion to
determine the percentage of the Fund's assets allocated to the
Commodities held by the Subsidiary that will be invested in exchange-
traded commodity futures contracts, centrally cleared and non-centrally
cleared
[[Page 123]]
swaps, exchange-traded options on futures contracts and exchange-traded
commodity-linked instruments. In this regard, under normal market
conditions, the Subsidiary is expected, as a general matter, to invest
in futures contracts in proportional weights and allocations that are
similar to the Benchmark, as well as in the other Commodities.
Additionally, the Subsidiary, like the Fund, may invest in Other
Investments (e.g., as investments or to serve as margin or collateral
or otherwise support the Subsidiary's positions in Commodities).
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\19\ The Subsidiary will not be registered under the 1940 Act
and will not be directly subject to its investor protections, except
as noted in the Registration Statement. However, the Subsidiary will
be wholly-owned and controlled by the Fund. Therefore, the Fund's
ownership and control of the Subsidiary will prevent the Subsidiary
from taking action contrary to the interests of the Fund or its
shareholders. The Board will have oversight responsibility for the
investment activities of the Fund, including its expected investment
in the Subsidiary, and the Fund's role as the sole shareholder of
the Subsidiary. The Subsidiary will also enter into separate
contracts for the provision of custody, transfer agency, and
accounting agent services with the same or with affiliates of the
same service providers that provide those services to the Fund.
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The Fund's investment in the Subsidiary is intended to provide the
Fund with exposure to commodity markets within the limits of current
federal income tax laws applicable to investment companies such as the
Fund, which limit the ability of investment companies to invest
directly in the derivative instruments. The Subsidiary will have the
same investment objective as the Fund, but unlike the Fund, it may
invest without limitation in Commodities. The Subsidiary's investments
will provide the Fund with exposure to domestic and international
markets.
The Benchmark is a version of the S&P GSCI Index that aims to
mitigate the effects of ``contango'' (which means that futures
contracts with distant delivery months are priced higher than those
with nearer delivery months) on index performance. The S&P GSCI Index
is a broad-based, production-weighted index that is designed to be
representative of global commodity market performance and to reflect
general levels of price movements and inflation in the world economy.
The S&P GSCI Index consists of twenty-four commodity futures on
physical commodities across five sectors: energy; agriculture;
livestock; industrial metals; and precious metals. The following table
describes each of the commodities underlying the futures contracts
included in the Benchmark as of October 31, 2015. The table also
provides each instrument's trading hours, exchange and ticker symbol.
The table is subject to change (and the Subsidiary will not in all
cases invest in the futures contracts included in the Benchmark).
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\20\ All of the exchanges are Intermarket Surveillance Group
(``ISG'') members except for the London Metal Exchange (``LME''),
ICE Futures Europe and Commodity Exchange, Inc. (``COMEX''). The LME
falls under the jurisdiction of the Financial Conduct Authority
(``FCA''). The FCA is responsible for ensuring the financial
stability of the exchange members' businesses, whereas the LME is
largely responsible for the oversight of day-to-day exchange
activity, including conducting the arbitration proceedings under the
LME arbitration regulations. With respect to the futures contracts
in which the Subsidiary invests, not more than 10% of the weight (to
be calculated as the value of the contract divided by the total
absolute notional value of the Subsidiary's futures contracts) of
the futures contracts held by the Subsidiary in the aggregate shall
consist of instruments whose principal trading market is a market
from which the Exchange may not obtain information regarding trading
in the futures contracts by virtue of: (a) Its membership in ISG; or
(b) a comprehensive surveillance sharing agreement. In addition, at
least 90% of the Fund's net assets that are invested in exchange-
traded options on futures contracts and exchange-traded commodity-
linked instruments (in the aggregate) will be invested in
instruments that trade in markets that are members of ISG or are
parties to a comprehensive surveillance sharing agreement with the
Exchange.
----------------------------------------------------------------------------------------------------------------
Trading hours Contract
Commodity Exchange code Exchange name \20\ electronic (E.T.) symbol(s)
----------------------------------------------------------------------------------------------------------------
Corn.......................... CBT Chicago Board of Trade Sun-F 20:00-08:45 M-F C; ZC.
09:30-14:15.
Cocoa......................... NYB ICE Futures US........ 04:45-13:30........... CC.
WTI Crude Oil................. NYM New York Mercantile 18:00-17:15........... CL.
Exchange.
Brent Crude Oil............... ICE ICE Futures Europe.... 20:00-18:00........... B.
Cotton........................ NYB ICE Futures US........ 21:00-14:20........... CT.
Feeder Cattle................. CME Chicago Mercantile M 10:05-F 14:55 (Halts FC; GF.
Exchange. 17:00-18:00).
Gold.......................... CMX COMEX................. 18:00-17:15........... GC.
NY Harbor ULSD................ NYM New York Mercantile 18:00-17:15........... HO.
Exchange.
Coffee ``C'' Arabica.......... NYB ICE Futures US........ 04:15-13:30........... KC.
HRW Wheat..................... CBT Chicago Board of Trade Sun-F 20:00-08:45 M-F KW; KE.
9:30-14:15.
Aluminium primary............. LME London Metal Exchange. 20:00-14:00........... AH.
Live Cattle................... CME Chicago Mercantile M 10:05-F 14:55 (Halts LC; LE.
Exchange. 17:00-18:00).
Lean Hogs..................... CME Chicago Mercantile M 10:05-F 14:55 (Halts LH; HE.
Exchange. 17:00-18:00).
Lead standard................. LME London Metal Exchange. 20:00-14:00........... PB.
Nickel primary................ LME London Metal Exchange. 20:00-14:00........... NI.
Copper grade A................ LME London Metal Exchange. 20:00-14:00........... CA.
Zinc high grade............... LME London Metal Exchange. 20:00-14:00........... ZS.
Natural Gas................... NYM New York Mercantile 18:00-17:15........... NG.
Exchange.
Gasoil........................ ICE ICE Futures Europe.... 20:00-18:00........... G.
Soybeans...................... CBT Chicago Board of Trade Sun-F 20:00-08:45 M-F S; ZS.
09:30-14:15.
Sugar #11..................... NYB ICE Futures US........ 03:30-13:00........... SB.
Silver........................ CMX COMEX................. 18:00-17:15........... SI.
SRW Wheat..................... CBT Chicago Board of Trade Sun-F 20:00-08:45 M-F W; ZW.
09:30-14:15.
RBOB Gasoline................. NYM New York Mercantile 18:00-17:15........... RB.
Exchange.
----------------------------------------------------------------------------------------------------------------
As the U.S. and foreign exchanges noted above list additional
contracts, as currently listed contracts on those exchanges gain
sufficient liquidity, or as other exchanges list sufficiently liquid
contracts, the Adviser and/or any Sub-Adviser will include those
contracts in the list of possible investments of the Subsidiary. The
list of commodities futures and commodities markets considered for
investment can and will change over time.
Commodities Regulation
The Commodity Futures Trading Commission (``CFTC'') has adopted
substantial amendments to CFTC Rule 4.5 relating to the permissible
exemptions and conditions for reliance on exemptions from registration
as a commodity pool operator. As a result of the instruments that will
be indirectly held by the Fund, the Adviser will register as a
commodity pool operator \21\ and will also be a member of the National
Futures Association (``NFA''). Any Sub-Adviser will register as a
commodity pool operator or commodity trading adviser, as required by
CFTC regulations. The Fund and the Subsidiary will be subject to
regulation by the CFTC and NFA and additional
[[Page 124]]
disclosure, reporting and recordkeeping rules imposed upon commodity
pools.
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\21\ As defined in Section 1a(11) of the Commodity Exchange Act.
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Investment Restrictions
While the Fund will be permitted to borrow as permitted under the
1940 Act, the Fund's investments will not be used to seek performance
that is the multiple or inverse multiple (i.e., 2X and -3X) of the
Benchmark.
The Fund may not invest more than 25% of the value of its total
assets in securities of issuers in any one industry or group of
industries. This restriction will not apply to obligations issued or
guaranteed by the U.S. government, its agencies or instrumentalities,
or securities of other investment companies.\22\
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\22\ See Form N-1A, Item 9. The Commission has taken the
position that a fund is concentrated if it invests more than 25% of
the value of its total assets in any one industry. See, e.g.,
Investment Company Act Release No. 9011 (October 30, 1975), 40 FR
54241 (November 21, 1975).
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The Subsidiary's shares will be offered only to the Fund and the
Fund will not sell shares of the Subsidiary to other investors. The
Fund and the Subsidiary will not invest in any non-U.S. equity
securities (other than shares of the Subsidiary). The Fund will not
purchase securities of open-end or closed-end investment companies
except in compliance with the 1940 Act or any applicable exemptive
relief.\23\
---------------------------------------------------------------------------
\23\ See supra note 15.
---------------------------------------------------------------------------
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 securities deemed illiquid by the Adviser.\24\ 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.\25\
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\24\ 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 trades (e.g., the time
needed to dispose of the security, the method of soliciting offers,
and the mechanics of transfer).
\25\ The Commission has stated that long-standing Commission
guidelines have required open-end funds to hold no more than 15% of
their net assets in illiquid securities and other illiquid assets.
See Investment Company Act Release No. 28193 (March 11, 2008), 73 FR
14618 (March 18, 2008), footnote 34. See also Investment Company Act
Release No. 5847 (October 21, 1969), 35 FR 19989 (December 31, 1970)
(Statement Regarding ``Restricted Securities''); Investment Company
Act Release No. 18612 (March 12, 1992), 57 FR 9828 (March 20, 1992)
(Revisions of Guidelines to Form N-1A). A fund's portfolio security
is illiquid if it cannot be disposed of in the ordinary course of
business within seven days at approximately the value ascribed to it
by the fund. See Investment Company Act Release No. 14983 (March 12,
1986), 51 FR 9773 (March 21, 1986) (adopting amendments to Rule 2a-7
under the 1940 Act); Investment Company Act Release No. 17452 (April
23, 1990), 55 FR 17933 (April 30, 1990) (adopting Rule 144A under
the Securities Act of 1933).
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Net Asset Value
The Fund's net asset value (``NAV'') will be determined as of the
close of trading (normally 4:00 p.m., Eastern Time (``E.T.'')) on each
day the New York Stock Exchange (``NYSE'') is open for business. The
NAV of the Fund will be calculated by dividing the value of the net
assets of such Fund (i.e., the value of its total assets, less total
liabilities) by the total number of outstanding Shares, generally
rounded to the nearest cent.
The Fund's and the Subsidiary's investments will be generally
valued using market valuations. A market valuation generally means a
valuation (i) obtained from an exchange, a pricing service, or a major
market maker (or dealer), (ii) based on a price quotation or other
equivalent indication of value supplied by an exchange, a pricing
service, or a major market maker (or dealer), or (iii) based on
amortized cost. The Fund and the Subsidiary may use various pricing
services or discontinue the use of any pricing service. A price
obtained from a pricing service based on such pricing service's
valuation matrix may be considered a market valuation.
If available, debt securities and money market instruments with
maturities of more than 60 days will typically be priced based on
valuations provided by independent, third-party pricing agents. Such
values will generally reflect the last reported sales price if the
security is actively traded. The third-party pricing agents may also
value debt securities at an evaluated bid price by employing
methodologies that utilize actual market transactions, broker-supplied
valuations, or other methodologies designed to identify the market
value for such securities. Debt obligations with remaining maturities
of 60 days or less may be valued on the basis of amortized cost, which
approximates market value. If such prices are not available, the
security will be valued based on values supplied by independent brokers
or by fair value pricing, as described below.
Futures contracts will be valued at the settlement price
established each day by the board or exchange on which they are traded.
Exchange-traded options will be valued at the closing price in the
market where such contracts are principally traded.
Swaps will be valued based on valuations provided by independent,
third-party pricing agents.
Securities of non-exchange-traded investment companies will be
valued at NAV. Equity securities listed on a securities exchange
(including exchange-traded commodity-linked instruments and exchange-
traded investment companies), market or automated quotation system for
which quotations are readily available (except for securities traded on
The NASDAQ Stock Market LLC (``NASDAQ'') and the London Stock Exchange
Alternative Investment Market (``LSE AIM'')) will be valued at the last
reported sale price on the primary exchange or market on which they are
traded on the valuation date (or at approximately 4:00 p.m., E.T. if a
security's primary exchange is normally open at that time). For a
security that trades on multiple exchanges, the primary exchange will
generally be considered to be the exchange on which the security
generally has the highest volume of trading activity. If it is not
possible to determine the last reported sale price on the relevant
exchange or market on the valuation date, the value of the security
will be taken to be the most recent mean between the bid and asked
prices on such exchange or market on the valuation date. Absent both
bid and asked prices on such exchange, the bid price may be used. For
securities traded on the NASDAQ or LSE AIM, the official closing price
will be used. If such prices are not available, the security will be
valued based on values supplied by independent brokers or by fair value
pricing, as described below.
The prices for foreign instruments will be reported in local
currency and converted to U.S. dollars using currency exchange rates.
Exchange rates will be provided daily by recognized independent pricing
agents.
In the event that current market valuations are not readily
available or such valuations do not reflect current market values, the
affected investments will be valued using fair value pricing pursuant
to the pricing policy and procedures approved by the Board in
accordance with the 1940 Act. Fair value pricing may require subjective
determinations about the value of an
[[Page 125]]
asset and may result in prices that differ from the value that would be
realized if the asset was sold.
Creation and Redemption of Shares
The Fund will issue and redeem Shares on a continuous basis at
NAV\26\ only in large blocks of Shares (``Creation Units'') in
transactions with authorized participants, generally including broker-
dealers and large institutional investors (``Authorized
Participants''). Creation Units are not expected to consist of less
than 25,000 Shares. The Fund will issue and redeem Creation Units in
exchange for an in-kind portfolio of instruments and/or cash in lieu of
such instruments (the ``Creation Basket'').\27\ In addition, if there
is a difference between the NAV attributable to a Creation Unit and the
market value of the Creation Basket exchanged for the Creation Unit,
the party conveying instruments with the lower value will pay to the
other an amount in cash equal to the difference (referred to as the
``Cash Component'').
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\26\ The NAV of the Fund's Shares generally will be calculated
once daily Monday through Friday as of the close of regular trading
on the NYSE, generally 4:00 p.m., E.T. (the ``NAV Calculation
Time''). NAV per Share will be calculated by dividing the Fund's net
assets by the number of Fund Shares outstanding.
\27\ The Adviser represents that, to the extent that the Trust
permits or requires a ``cash in lieu'' amount, such transactions
will be effected in the same or equitable manner for all Authorized
Participants.
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Creations and redemptions must be made by or through an Authorized
Participant that has executed an agreement that has been agreed to by
the Distributor with respect to creations and redemptions of Creation
Units. All standard orders to create Creation Units must be received by
the Distributor no later than the closing time of the regular trading
session on the NYSE (ordinarily 4:00 p.m., E.T.) (the ``Closing Time'')
in each case on the date such order is placed in order for the creation
of Creation Units to be effected based on the NAV of Shares as next
determined on such date after receipt of the order in proper form.
Shares may be redeemed only in Creation Units at their NAV next
determined after receipt not later than the Closing Time of a
redemption request in proper form by the Fund through the Distributor
and only on a business day.
On each business day, prior to the opening of business of the
Exchange, the Fund will cause to be published through the National
Securities Clearing Corporation the list of the names and quantities of
the instruments comprising the Creation Basket, as well as the
estimated Cash Component (if any), for that day. The published Creation
Basket will apply until a new Creation Basket is announced on the
following business day.
Availability of Information
The Fund's Web site (www.elkhorn.com), which will be publicly
available prior to the public offering of Shares, will include a form
of the prospectus for the Fund that may be downloaded. The Web site
will include the Shares' ticker, CUSIP and exchange information along
with additional quantitative information updated on a daily basis,
including, for the Fund: (1) Daily trading volume, the prior business
day's reported NAV and closing price, mid-point of the bid/ask spread
at the time of calculation of such NAV (the ``Bid/Ask Price'') \28\ and
a calculation of the premium and discount of the Bid/Ask Price against
the NAV; and (2) data in chart format displaying the frequency
distribution of discounts and premiums of the daily Bid/Ask Price
against the NAV, within appropriate ranges, for each of the four
previous calendar quarters. Daily trading volume information for the
Fund will also be available in the financial section of newspapers,
through subscription services such as Bloomberg, Thomson Reuters, and
International Data Corporation, which can be accessed by Authorized
Participants and other investors, as well as through other electronic
services, including major public Web sites. On each business day,
before commencement of trading in Shares during Regular Trading
Hours\29\ on the Exchange, the Fund will disclose on its Web site the
identities and quantities of the portfolio of securities, Commodities
and other assets (the ``Disclosed Portfolio'' as defined in Rule
14.11(i)(3)(B)) held by the Fund and the Subsidiary that will form the
basis for the Fund's calculation of NAV at the end of the business
day.\30\ The Fund's disclosure of derivative positions in the Disclosed
Portfolio will include information that market participants can use to
value these positions intraday. On a daily basis, the Disclosed
Portfolio displayed 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 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 percentage weighting of the holding in the Fund's
portfolio. The Web site and information will be publicly available at
no charge.
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\28\ The Bid/Ask Price of the Fund will be determined using the
mid-point of the highest bid and the lowest offer on the Exchange as
of the time of calculation of the Fund's NAV. The records relating
to Bid/Ask Prices will be retained by the Fund and its service
providers.
\29\ Regular Trading Hours are 9:30 a.m. to 4:00 p.m. Eastern
Time.
\30\ Under accounting procedures to be followed by the Fund,
trades made on the prior business day (``T'') will be booked and
reflected in NAV on the current business day (``T+1''). Accordingly,
the Fund will be able to disclose at the beginning of the business
day the portfolio that will form the basis for the NAV calculation
at the end of the business day.
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In addition, for the Fund, an estimated value, defined in BATS Rule
14.11(i)(3)(C) as the ``Intraday Indicative Value,'' that reflects an
estimated intraday value of the Fund's portfolio (including the
Subsidiary's portfolio), will be disseminated. Moreover, the Intraday
Indicative Value will be based upon the current value for the
components of the Disclosed Portfolio and will be updated and widely
disseminated by one or more major market data vendors and broadly
displayed at least every 15 seconds during the Exchange's Regular
Trading Hours.\31\
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\31\ Currently, it is the Exchange's understanding that several
major market data vendors display and/or make widely available
Intraday Indicative Values published via the Consolidated Tape
Association (``CTA'') or other data feeds.
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The dissemination of the Intraday Indicative Value, together with
the Disclosed Portfolio, will allow investors to determine the value of
the underlying portfolio of the Fund on a daily basis and will provide
a close estimate of that value throughout the trading day.
Intra-day executable price quotations on the securities and other
assets held by the Fund and the Subsidiary will be available from major
broker-dealer firms or on the exchange on which they are traded, as
applicable. Intra-day price information on the securities and other
assets held by the Fund and the Subsidiary will also be available
through subscription services, such as Bloomberg and Thomson Reuters,
which can be accessed by Authorized Participants and other investors.
More specifically, pricing information for exchange-traded commodity
futures contracts, exchange-traded options on futures contracts,
exchange-traded commodity-linked instruments, securities of exchange-
traded investment companies other than exchange-traded commodity-linked
[[Page 126]]
instruments will be available on the exchanges on which they are traded
and through subscription services. Pricing information for securities
of non-exchange-traded investment companies will be available through
the applicable fund's Web site or major market data vendors. Pricing
information for swaps, fixed income securities and money market
instruments will be available through subscription services and/or
broker-dealer firms and/or pricing services. Additionally, the Trade
Reporting and Compliance Engine (``TRACE'') of the Financial Industry
Regulatory Authority (``FINRA'') will be a source of price information
for certain fixed income securities held by the Fund.
Investors will also be able to obtain the Fund's Statement of
Additional Information (``SAI''), the Fund's annual and semi-annual
reports (together, ``Shareholder Reports''), and its Form N-CSR and
Form N-SAR, filed twice a year. The Fund's SAI and Shareholder Reports
will be available free upon request from the Fund, and those documents
and the Form N-CSR and Form N-SAR may be viewed on-screen or downloaded
from the Commission's Web site at www.sec.gov. Information regarding
market price and trading volume of the Shares will be continually
available on a real-time basis throughout the day on brokers' computer
screens and other electronic services. The previous day's closing price
and trading volume information for the Shares will be published daily
in the financial section of newspapers. Quotation and last sale
information for the Shares will be available on the facilities of the
CTA.
Information relating to the Benchmark, including its constituents,
weightings and changes to its constituents, will be available on the
Web site of S&P Indices.
Initial and Continued Listing
The Shares will be subject to BATS Rule 14.11(i), which sets forth
the initial and continued listing criteria applicable to Managed Fund
Shares. The Exchange represents that, for initial and/or continued
listing, the Fund and the Subsidiary must be in compliance with Rule
10A-3 under the Act.\32\ A minimum of 100,000 Shares will be
outstanding at the commencement of trading on the Exchange. 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.
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\32\ See 17 CFR 240.10A-3.
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Trading Halts
With respect to trading halts, the Exchange may consider all
relevant factors in exercising its discretion to halt or suspend
trading in the Shares of the Fund. The Exchange will halt trading in
the Shares under the conditions specified in BATS Rule 11.18. Trading
may be halted because of market conditions or for reasons that, in the
view of the Exchange, make trading in the Shares inadvisable. These may
include: (1) The extent to which trading is not occurring in the
securities, Commodities and other assets constituting the Disclosed
Portfolio of the Fund and the Subsidiary; or (2) whether other unusual
conditions or circumstances detrimental to the maintenance of a fair
and orderly market are present. Trading in the Shares also will be
subject to Rule 14.11(i)(4)(B)(iv), which sets forth circumstances
under which Shares of the Fund may be halted.
Trading Rules
The Exchange 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. BATS will allow
trading in the Shares from 8:00 a.m. until 5:00 p.m. Eastern Time. The
Exchange has appropriate rules to facilitate transactions in the Shares
during all trading sessions. As provided in BATS Rule 11.11(a), the
minimum price variation for quoting and entry of orders in Managed Fund
Shares traded on the Exchange is $0.01, with the exception of
securities that are priced less than $1.00, for which the minimum price
variation for order entry is $0.0001.
Surveillance
The Exchange believes that its surveillance procedures are adequate
to properly monitor the trading of the Shares on the Exchange during
all trading sessions and to deter and detect violations of Exchange
rules and the applicable federal securities laws. Trading of the Shares
through the Exchange will be subject to the Exchange's surveillance
procedures for derivative products, including Managed Fund Shares. The
Exchange may obtain information regarding trading in the Shares and the
underlying shares in exchange traded investment companies, futures, and
options on futures via the ISG, from other exchanges who are members or
affiliates of the ISG, or with which the Exchange has entered into a
comprehensive surveillance sharing agreement. In addition, the Exchange
is able to access, as needed, trade information for certain fixed
income instruments reported to TRACE. With respect to the futures
contracts in which the Subsidiary invests, not more than 10% of the
weight (to be calculated as the value of the contract divided by the
total absolute notional value of the Subsidiary's futures contracts) of
the futures contracts held by the Subsidiary in the aggregate shall
consist of instruments whose principal trading market is a market from
which the Exchange may not obtain information regarding trading in the
futures contracts by virtue of: (a) Its membership in ISG; or (b) a
comprehensive surveillance sharing agreement. In addition, at least 90%
of the Fund's net assets that are invested in exchange-traded options
on futures contracts and exchange-traded commodity-linked instruments
(in the aggregate), will be invested in instruments that trade in
markets that are members of ISG or are parties to a comprehensive
surveillance sharing agreement with the Exchange. Investments in non-
centrally cleared swaps (through the Subsidiary) will not represent
more than 20% of the Fund's net assets.
In addition, the Exchange prohibits the distribution of material,
non-public information by its employees.
Information Circular
Prior to the commencement of trading, the Exchange will inform its
members in an Information Circular of the special characteristics and
risks associated with trading the Shares. Specifically, the Information
Circular will discuss the following: (1) The procedures for purchases
and redemptions of Shares in Creation Units (and that Shares are not
individually redeemable); (2) BATS Rule 3.7, which imposes suitability
obligations on Exchange members with respect to recommending
transactions in the Shares to customers; (3) how information regarding
the Intraday Indicative Value and the Disclosed Portfolio is
disseminated; (4) the risks involved in trading the Shares during the
Pre-Opening\33\ and After Hours Trading Sessions\34\ when an updated
Intraday Indicative Value will not be calculated or publicly
disseminated; (5) the requirement that members deliver a prospectus to
investors purchasing
[[Page 127]]
newly issued Shares prior to or concurrently with the confirmation of a
transaction; and (6) trading information.
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\33\ The Pre-Opening Session is from 8:00 a.m. to 9:30 a.m.
Eastern Time.
\34\ The After Hours Trading Session is from 4:00 p.m. to 5:00
p.m. Eastern Time.
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In addition, the Information Circular will advise members, prior to
the commencement of trading, of the prospectus delivery requirements
applicable to the Fund. Members purchasing Shares from the Fund for
resale to investors will deliver a prospectus to such investors. The
Information Circular will also discuss any exemptive, no-action and
interpretive relief granted by the Commission from any rules under the
Act.
Additionally, the Information Circular will reference that the Fund
is subject to various fees and expenses described in the Registration
Statement. The Information Circular will also disclose the trading
hours of the Shares of the Fund and the applicable NAV Calculation Time
for the Shares. The Information Circular will disclose that information
about the Shares of the Fund will be publicly available on the Fund's
Web site. In addition, the Information Circular will reference that the
Trust is subject to various fees and expenses described in the Fund's
Registration Statement.
2. Statutory Basis
The Exchange believes that the proposal is consistent with Section
6(b) of the Act \35\ in general and Section 6(b)(5) of the Act \36\ in
particular in that it is designed to prevent fraudulent and
manipulative acts and practices, to promote just and equitable
principles of trade, to foster cooperation and coordination with
persons engaged in facilitating transactions in securities, 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.
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\35\ 15 U.S.C. 78f.
\36\ 15 U.S.C. 78f(b)(5).
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The Exchange believes that the proposed rule change is designed to
prevent fraudulent and manipulative acts and practices in that the
Shares will be listed and traded on the Exchange pursuant to the
initial and continued listing criteria in BATS Rule 14.11(i). The
Exchange believes that its surveillance procedures are adequate to
properly monitor the trading of the Shares on the Exchange during all
trading sessions and to deter and detect violations of Exchange rules
and the applicable federal securities laws. If the investment adviser
to the investment company issuing Managed Fund Shares is affiliated
with a broker-dealer, such investment adviser to the investment company
shall erect a ``fire wall'' between the investment adviser and the
broker-dealer with respect to access to information concerning the
composition and/or changes to such investment company portfolio. The
Adviser is not registered as a broker-dealer, although it is affiliated
with a broker-dealer, and is therefore required to implement a ``fire
wall'' with respect to such broker-dealer affiliate regarding access to
information concerning the composition and/or changes to the Fund's
portfolio. In addition, Rule 14.11(i)(7) further requires that
personnel who make decisions on the open-end fund's portfolio
composition must be subject to procedures designed to prevent the use
and dissemination of material non-public information regarding the
Fund's portfolio. The Exchange may obtain information regarding trading
in the Shares and the underlying shares in investment companies,
futures, and options on futures via the ISG, from other exchanges who
are members or affiliates of the ISG, or with which the Exchange has
entered into a comprehensive surveillance sharing agreement. The
Exchange represents that trading in the Shares will be subject to the
existing trading surveillances which are designed to detect violations
of Exchange rules and applicable federal securities laws.
The Exchange will communicate as needed regarding trading in the
Shares and in the exchange-traded Commodities and exchange-traded
investment companies not included within the definition of Commodities
(together, ``Exchange-Traded Instruments'') held by the Fund and the
Subsidiary with other markets and other entities that are members of
the ISG and may obtain trading information regarding trading in the
Shares and in the Exchange-Traded Instruments held by the Fund and the
Subsidiary from such markets and other entities. In addition, the
Exchange may obtain information regarding trading in the Shares and in
the Exchange-Traded Instruments held by the Fund and the Subsidiary
from markets and other entities that are members of ISG, which includes
securities and futures exchanges, or with which the Exchange has in
place a comprehensive surveillance sharing agreement. The Exchange will
be able to access, as needed, trade information for certain fixed
income securities held by the Fund reported to FINRA's TRACE.
With respect to the futures contracts in which the Subsidiary
invests, not more than 10% of the weight (to be calculated as the value
of the contract divided by the total absolute notional value of the
Subsidiary's futures contracts) of the futures contracts held by the
Subsidiary in the aggregate shall consist of instruments whose
principal trading market is a market from which the Exchange may not
obtain information regarding trading in the futures contracts by virtue
of: (a) Its membership in ISG; or (b) a comprehensive surveillance
sharing agreement. In addition, at least 90% of the Fund's net assets
that are invested in exchange-traded options on futures contracts and
exchange-traded commodity-linked instruments (in the aggregate) will be
invested in instruments that trade in markets that are members of ISG
or are parties to a comprehensive surveillance sharing agreement with
the Exchange. Investments in non-centrally cleared swaps (through the
Subsidiary) will not represent more than 20% of the Fund's net assets.
The Fund's investment objective will be to provide total return
which exceeds that of the Benchmark, consistent with prudent investment
management. The Fund will invest in Commodities through investments in
the Subsidiary and will not invest directly in physical commodities.
The Fund's investment in the Subsidiary may not exceed 25% of the
Fund's total assets. While the Fund will be permitted to borrow as
permitted under the 1940 Act, the Fund's investments will not be used
to seek performance that is the multiple or inverse multiple (i.e., 2X
and -3X) of the Benchmark. 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 securities deemed illiquid by the Adviser. The
Fund and the Subsidiary will not invest in any non-U.S. equity
securities (other than shares of the Subsidiary).
The proposed rule change is designed to promote just and equitable
principles of trade and to protect investors and the public interest in
that 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. In addition, a large amount of
information will be publicly available regarding the Fund and the
Shares, thereby promoting market transparency. Moreover, the Intraday
Indicative Value will be widely disseminated by one or more major
market data vendors and broadly displayed at least every 15 seconds
during Regular Trading Hours. On each business day, before commencement
of
[[Page 128]]
trading in Shares during Regular Trading Hours, the Fund will disclose
on its Web site the Disclosed Portfolio of the Fund and the Subsidiary
that will form the basis for the Fund's calculation of NAV at the end
of the business day. Pricing information will be available on the
Fund's Web site including: (1) The prior business day's reported NAV,
the Bid/Ask Price of the Fund, and a calculation of the premium and
discount of the Bid/Ask Price against the NAV; and (2) data in chart
format displaying the frequency distribution of discounts and premiums
of the daily Bid/Ask Price against the NAV, within appropriate ranges,
for each of the four previous calendar quarters. Additionally,
information regarding market price and trading volume of the Shares
will be continually available on a real-time basis throughout the day
on brokers' computer screens and other electronic services, and
quotation and last sale information for the Shares will be available on
the facilities of the CTA.
Intra-day executable price quotations on the securities and other
assets held by the Fund and the Subsidiary will be available from major
broker-dealer firms or on the exchange on which they are traded, as
applicable. Intra-day price information on the securities and other
assets held by the Fund and the Subsidiary will also be available
through subscription services, such as Bloomberg and Thomson Reuters,
which can be accessed by Authorized Participants and other investors.
More specifically, pricing information for exchange-traded commodity
futures contracts, exchange-traded options on futures contracts,
exchange-traded commodity-linked instruments, and exchange-traded
investment companies other than exchange-traded commodity-linked
instruments will be available on the exchanges on which they are traded
and through subscription services. Pricing information for non-
exchange-traded investment companies will be available through the
applicable fund's Web site or major market data vendors. Pricing
information for swaps, fixed income securities and money market
instruments will be available through subscription services and/or
broker-dealer firms and/or pricing services. Additionally, FINRA's
TRACE will be a source of price information for certain fixed income
securities held by the Fund.
The Fund's Web site will include a form of the prospectus for the
Fund and additional data relating to NAV and other applicable
quantitative information. Trading in Shares of the Fund will be halted
under the conditions specified in BATS Rule 11.18. Trading may also be
halted because of market conditions or for reasons that, in the view of
the Exchange, make trading in the Shares inadvisable. Finally, trading
in the Shares will be subject to BATS Rule 14.11(i)(4)(B)(iv), which
sets forth circumstances under which Shares of the Fund may be halted.
In addition, the Exchange is able to acc